OSC Seeks Employer Input for I-9 Self Audit Best Practices
Our loyal readers may finally be getting what they’ve long been wanting; a best practice guide from the government (in this case, the Office of Special Counsel). But wait, OSC would first like you to provide valuable input regarding employer-conducted self-audits of I-9 records. (You’ll recall we wrote about the Dangers of the Self I-9 Audit back in April and our Guest Attorney Blogger Chuck Kuck back in early January 2011.)
A few weeks ago (September 13, 2012), OSC held its first Input Session to elicit feedback from the public (employers and their representatives included) about concerns regarding I-9 self-audits. The OSC has in fact been leading many educational and interactive-public efforts to help educate both employers and U.S. workers on immigration-related unfair employment practices. Ultimately, the goal is to provide the public (specifically employers) with best practices on how companies can conduct self-audits in a non-discriminatory fashion. In this regard, OSC is seeking public comment and feedback regarding the following:
- What are some of the greatest challenges that you (employer, attorney, HR representative or other representative) face when conducting self-audits? Alternatively, what are some of the issues that employees or their employee advocates have faced when an employer conducts a self-audit of their I-9 documents?
- Describe some of your procedures or processes when asking employees for their identity documents in order to remediate deficient I-9 records during a self-audit? How do you notify the employees of the need for remediation?
- During an I-9 self-audit, do you provide employees with opportunities to correct deficiencies discovered in the I-9 records? If so, what type of procedures have you implemented? What is the time period for the remediation?
- How do you notate the deficiencies found in your I-9 records during a self-audit?
- What other ways of conducting I-9 self-audits that were offered by other government agencies have you found to be helpful?
- What additional questions do you have which you would like OSC to provide guidance (as they relate to self-audits)?
Input received on this session will be reserved for internal use by OSC. Please send any feedback you may have regarding the above to [email protected] before November 9, 2012. Stay updated on I-9 and E-Verify news by subscribing to our free newsletter.