I-9 Employee Eligibility Verification

All U.S. employers are required by law to verify the identity and work eligibility of their employees, whether U.S. citizens or not, by filing an Employment Eligibility Verification Form I-9. The University uses the online version of Form I-9 and E-Verify.

It is important for the University to be in full compliance with the law by verifying the eligibility of every faculty or staff member as well as student workers. For the purposes of the I-9 process, an employee is any person who holds a job at the University of Minnesota for pay, even if the faculty, staff, or student worker requests their pay be waived, paid to another entity, or paid in a lump sum for their work.

At the University of Minnesota, faculty, staff, or student workers must have a completed their Form I-9—both Sections 1 and 2—on or before their first day of work for pay.

Go to: 

Quick Links to I-9 Express

Use employer code 13636.

Overview of I-9 Process and Responsibilities by Role

Managing Your Unit's I-9 Process

Every employee must have a valid I-9 to work at the University of Minnesota. The chart below outlines the communication and responsibilities related to the required I-9 process. Supervisors, employees, and I-9 administrators all play a critical role in this process.

ResponsibilitySupervisorsFaculty, Staff, and Student WorkersI-9 Administrators
Communication

Direct new employees to complete the I-9 on or before the first day of work for pay.

Offer letter must include template language on I-9 requirements.

Provide faculty, staff, or student worker with contact information for I-9 questions.

Meet with the I-9 administrator to submit documentation for Section 2 of the I-9.

Communicate the following:

  • Required documents for Section 2 of I-9
  • I-9 results from E-Verify
I-9 CompletionAllows the faculty, staff, or student worker to go home to retrieve documents needed for Section 2 on the first day of work for pay.Completes both Section 1 of the I-9 online and Section 2 with the employer, on or before the first day of work for pay.Uses online I-9 Express Management system to complete Section 2 of the I-9 online during appointment with the faculty or staff member or student worker.
ComplianceFaculty, staff, or student workers must not be allowed to work without a valid I-9.I-9 completion on or before first day of work for pay.Correct documents must be verified and indicated on Section 2.
Follow-up Faculty, staff, or student workers must complete any steps required by SSN or DHS as indicated in any documentation provided by the I-9 administrator.

Monitor status of open E-Verify cases in I-9 Express using the I-9 Management dashboard and reports.

Identify hires that must be terminated due to failure to submit required I-9 documentation.

Termination of Faculty, Staff, or Student Worker With Incomplete I-9   

Terminate the new hire in PeopleSoft if the I-9 is lacking required documentation.

Update Section 2 of I-9 by selecting "Employee terminated before completing I-9."

For more detailed instructions, see:

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I-9 Process for Remote Hires

When hiring a person to work in a remote location, the employer can designate an agent to carry out the employer's I-9 responsibilities. See these instructions for more information on how the remote hire should complete the online I-9, or contact the Office of Human Resources at 4-UOHR (612-624-8647 or 800-756-2363).

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I-9 Process for Foreign National Faculty, Staff, or Student Workers

International student and nonstudent employees can complete their I-9 and tax documents with their HR department. For more information, see our I-9 Process for Foreign National Employees page.

If international faculty, staff, or student workers don't already have a Social Security number, they are not required to apply for a Social Security number before they complete their I-9. However, they should be strongly encouraged to apply for their SSN within 10 days of their employment start date. A Social Security number is required for employment, and foreign nationals will not be able to claim tax treaty benefits until they have received and reported their SSN. They will also need their SSN for many personal transactions such as opening a bank account and filing a tax return.

See Social Security Number Requirements for more information about applying for a Social Security number.

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I-9 Process for Rehires

If the employee is rehired within 3 years of the date that Form I-9, Employment Eligibility Verification, was originally completed, you may complete a Supplement B Rehire as an alternative to completing a new I-9. 

Review the original Form I-9 to determine if the employee is still authorized to work, including whether employment authorization documentation presented in Section 2 (List A or List C) or a previous reverification has since expired (or has been extended). 

If the employee is still authorized to work and their employment authorization documentation is still unexpired, enter the date of the rehire in the space provided in Supplement B. 

If your employee is no longer authorized to work or the employment authorization documentation has expired and requires reverification, request that the employee present an unexpired List A or List C document. Do not reverify an employee’s List B (identity) document. 

Enter the document information and the date of rehire in the spaces provided in Supplement B. If the version of the previously completed Form I-9 has expired, you must complete Supplement B on the current version.

If the employee's most recent hire date is more than three years before the original I-9 completion date, a new I-9 form is required. Due to the University of Minnesota’s University Timeliness Standard, Section 1 and 2 must be completed on or before their rehire date, and they must again present original documentation to be reviewed by the I-9 administrator.

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I-9 New Hire Scenarios

The University of Minnesota Form I-9 processing standard requires that:

  • Faculty, staff, and student workers complete Section 1 and present required I-9 documents on or before the first day of work for pay
  • The I-9 administrator completes Section 2 by the end of first day of work for pay
If the following scenario happens:The correct action is:Resulting I-9 compliance status based on University standard

SCENARIO 1

The faculty, staff or student worker is able to complete Section 1

AND

is able to present the I-9 required documents on or before the first day of work for pay

AND

the I-9 Administrator is able to complete Section 2 by the end of the first day of work for pay.

  • The faculty, staff, or student worker is paid for time worked.
  • The PeopleSoft hire date reflects the first day of work for pay.
I-9 is not late

SCENARIO 2

The faculty, staff, or student worker does not show up to work.

  • The faculty, staff or student worker is not paid.
  • In PeopleSoft, the hire record must be terminated using the action of "Termination" and the reason "End of Appointment." This should occur on the same effective date as the hire date by adding an additional sequence number to the record.
  • In I-9 Express, if the faculty, staff, or student worker completed Section 1 of the I-9 form, select "Employee terminated before completing I-9" on Section 2 of the form.
I-9 is not late

SCENARIO 3

The faculty, staff, or student worker is able to complete Section 1

BUT

is not able to present the required I-9 documents on or before the first day of work for pay.

  • The faculty, staff or student worker must not be allowed to start work or remain in the
            workplace until they present the required documents.
  • In PeopleSoft, the hire date must be changed to the actual day the faculty, staff, or student worker presents their I-9 documents.
  • Submit a data correction form to OHR Operations to reflect the updated hire date*.
  • In I-9 Express, the hire date must be changed to the actual day the faculty, staff, or student worker presents the required I-9 documents.
I-9 is not late

SCENARIO 4

The faculty, staff or student worker is not able to complete Section 1

AND

does not present the I-9 required documents on or before the first day of work for pay.

  • The faculty, staff or student worker must not be allowed to start work or remain in the workplace until they present the required documents.
  • In PeopleSoft, the hire date must be changed to the actual day the faculty, staff, or student worker has Section 1 complete and presents the required I-9 documents.
  • Submit a data correction form to OHR Operations to reflect the updated hire date*.
  • In I-9 Express, the hire date must be changed to the actual day the faculty, staff, or student worker has Section 1 complete and presents their I-9 documents.
  • This does not require a new offer/appointment letter.
I-9 is not late

SCENARIO 5

The faculty, staff, or student worker is able to complete Section 1

AND

is able to present the I-9 required documents on or before the first day of work for pay

BUT

the I-9 administrator does notcomplete Section 2 by the end of the first day of work for pay.

  • The faculty, staff, or student worker must be paid for time worked.
  • The PeopleSoft and I-9 Express hire dates should reflect the date the employee began work for pay and presented their I-9 documents.
  • The I-9 administrator must complete Section 2 immediately after the situation is discovered.
  • This does not require a new offer/appointment letter.
I-9 is late

SCENARIO 6 

The faculty, staff, or student worker continues to work for pay beyond the first day, but did not complete Section 1 or did not present the required I-9 documents

AND

is able to complete Section 1 and is able to provide the required documents immediately after the situation is discovered.

  • The faculty, staff, or student worker must be paid for time worked.
  • The PeopleSoft and I-9 Express hire dates should continue to reflect the date the employee began work for pay.
  • The I-9 administrator must complete Section 2 immediately after the situation is discovered.
  • This does not require a new offer/appointment letter.
I-9 is late 

SCENARIO 7

The faculty, staff, or student worker continues to work for pay beyond the first day but did not complete Section 1 or did not present the required I-9 documents

AND

the employee is not able to complete Section 1 or provide required I-9 documents immediately after the situation is discovered.

  • The faculty, staff, or student worker must be paid for time worked.
  • In PeopleSoft, terminate the employee's record using the action of "Termination" and the reason of "Employment I-9 Ineligibility."
  • In I-9 Express, if the faculty, staff, or student worker completed Section 1 of the I-9 form and is not rehired, select "Employee terminated before completing I-9" on Section 2 of the form.
  • If Section 1 was not completed in I-9 Express, no action needed in I-9 Express.
  • This faculty, staff, or student worker may be rehired when they can complete Section 1 and present the required I-9 documents.
  • A new offer/appointment letter is required.
I-9 is late

*Note: Changes to a hire date may impact the faculty, staff or student workers' eligibility for benefits. Examples include health, dental, life, retirement, disability and tuition benefits.

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Retaining the I-9 Form

Although I-9 regulations allow employers to make copies of the documents presented to show I-9 compliance, the University of Minnesota does not require copies of I-9 documentation for the online I-9 process.

The University retains a copy only when the employee presents a document used as part of Photo Matching, which includes:

  • U.S. passport and passport card
  • Permanent Resident card (Form I-551)
  • Employment Authorization Document (Form I-766)

In these cases, you should scan a copy and upload it to I-9 Express.

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I-9 Resources

Online I-9 System

  • Use I-9 Express to enter, verify, and document employment eligibility for new hires.

Training and User Guides

I-9 Administrators :

Employees:

General:

Contact

  • For I-9 questions or more information, email or call the OHR Contact Center (ohr@umn.edu, 4-UOHR, 612-624-8647 or 800-756-2363).

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