Do you have a strategy for your I-9 Program???
If not, this could be your story someday…
You have recently been audited and some deficiencies were flagged that resulted in $50k in ICE fines. Your executive team wants to know how you, the HR leader, is going to address this to avoid future fines. You need to pull your team together and problem-solve quickly!! You have some things to juggle – nailing down a perfect and efficient process, and effectively demonstrating your company’s commitment to I-9 compliance. The proposed strategy you share not only will ensure legal compliance but also contributes to operational efficiency and potential cost savings. Easy, right??! (sigh…. 😊)
Get ahead of this event so it never happens to your organization.
Here is an outline of the next steps you can take and present like the HR compliance pro that you are!!
Presentation Objective: Ensure Compliance with I-9 and E-Verify Regulations for your Company
I. Introduction
– Brief Overview of I-9 and E-Verify
– Importance of Compliance for Legal and Reputation Reasons
II. Proposed Program Strategy and Current Status Assessment
– Define your goal: What is the ultimate position you want the program to achieve
– Review Current I-9 Processes and E-Verify Implementation
– Identify any Compliance Gaps or Weaknesses (to accomplish that goal you shared previously)
– Update your program policy(ies) related to I-9 and the on-boarding approach, re-Verification, document retention.
III. Leverage Technology as Part of the Solution
Step 1: Technology Integration and Automation – If you are doing paper I-9s this is a no brainer! Get digital!!
– Leverage Technology to Streamline I-9 Process
– Implement Automation for Data Validation and Alerts
– Benefits for Efficiency and Accuracy
– Showcase Potential Cost Savings
Step 2: Plan, Schedule and Deliver Comprehensive Training and Education to all touching I-9s
– Develop Training Modules for HR and Employees
– Regularly Update Training Material to Reflect Current Regulations
– Promote Awareness and Understanding of I-9 Compliance
– Define accountability expectations!!! (can’t stress this enough)
Step 3: Ongoing Monitoring and Auditing
– Regular Internal Audits to Ensure Compliance
– Establish a Compliance Review Schedule
– Implement Corrective Actions for Non-Compliance Instances
– Highlight the Proactive Approach to Compliance
– Identify accountability requirements and consequences
Step 4: Vendor Collaboration (if applicable)*
– Evaluate Electronic I-9 Service Providers
– Ensure Seamless Integration with HR Systems
– Establish Clear Communication Channels for Support
Step 5: Continuous Improvement
– Establish Feedback Loops from HR and Employees
– Stay Informed about Regulatory Changes and Adapt Accordingly (you can leverage your I-9 service provider for regular updates!!)
– Foster a Culture of Compliance and Accountability
IV. Key Performance Indicators (KPIs)
– Define Metrics for Success (e.g., Compliance Rate, Audit Results)
– Set Targets and Milestones for Improvement
V. Cost-Benefit Analysis
– Estimate Initial Investment (Technology, Training, Auditing)
– Compare with Projected Savings and Risk Mitigation
VI. Risk Mitigation and Legal Safeguards
– Highlight How the Strategy Minimizes Legal Risks
– Provide Assurance of Preparedness for Audits and Inspections
VII. Timeline and Implementation Plan
– Detail the Phased Rollout of the I-9 Program
– Assign Responsibilities and Deadlines
– Provide regular updates (Quarterly is recommended or twice a year to keep everyone aligned)
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