Three Must-Haves for I-9 Change Management
As organizations and HR departments continue to centralize and digitize the recruitment, retention and management of employees, many use these initiatives to conduct ground-up process improvements. This is particularly true when it comes to the transformation of the I-9 process. Many HR professionals would agree that proper completion of the Form I-9, is that little dark cloud hanging over the onboarding process for new hires working in the United States.
Organizations are wise to re-evaluate their I-9 program when moving from a paper to electronic environment. This technology leap provides the perfect impetus to train and educate personnel on the I-9 process.
The following three rules should be considered in order to pack a one-two punch for efficiency and compliance gains.
Early and Informed Communication
Don’t underestimate the impact of introducing change to the hiring process. There may be many types of personnel responsible for I-9 activities within an organization, from dedicated onboarding recruiters or HR staff, to hiring managers or ad hoc company representatives. Take the opportunity to educate the entire organization on the transformation project. This should start early, possibly even before an electronic I-9 system is chosen. The frequency and globalization of the messaging re-emphasizes the importance of the I-9 process and helps foster adoption.
Once the project is underway, prepare the responsible parties for the changes in store. Call out how the process is changing, and more importantly how that change positively impacts the individual and why change is being made. Organizations with union employees will need to pay careful attention to this point (and consult with labor counsel) so that there is a clear understanding about the intent (and potential ramifications) of the initiative. The most effective rollouts result when top leadership is a sponsor or co-sponsor of the initiative. Similarly, deploying a cross-functional team consisting of members from HR, IT, and Compliance provides just the right blend to execute and legitimize the change (including the necessary elements of who, how, and why). Themes such as “increased compliance”, “improved experience”, and “easier management” should emerge.
Express the expected and desired outcomes. Often when compliance (and financial liability) is on the line, having organizational alignment related to shared responsibility and ownership is important. Ingraining a culture of accountability into the initiative solidifies its importance. When it comes to the Form I-9 this could be regular measurements and standards related to the timeliness of completion.
Assess the landscape to determine overlapping or competing initiatives so that the project takes this information into account. Be sensitive to the temperament and constraints of the organization, e.g. avoiding times of increased activity to implement the ultimate roll out. Similarly, plan for the unexpected by padding the project timeline to account for unknowns. Gather a team of advocates who can help shape the message, provide feedback related to program participants’ needs, and evangelize the change.
While I-9 verifiers will need to understand how the electronic process works, you must also balance training efforts with a combination of I-9 compliance requirements and system usage. Take the opportunity to work with inside or outside legal counsel to create (or enhance) an I-9 training program. A good training program includes background on the form so that the audience has a foundation with which to understand how and why it’s used. Other topics to cover include timing requirements, roles and responsibilities, document abuse, and proper procedures when reviewing documents and working with foreign nationals.
Whether conducted in-person or online, maintaining on demand training materials is essential to a successful roll out as well as ongoing compliance efforts (especially in light of frequent turnover of those responsible for I-9 verification). Both video (e.g., narrated presentation) and print materials are recommended. Organizations with a dedicated learning management system (LMS) often include I-9 compliance in its own category. Lastly, a concise job aid is useful to pro-actively address typical questions related to the process (both compliance and procedural), and is a mainstay for organizations in which the verifier infrequently completes the I-9 process.
It’s important to not just plan for the product or project, but for the people. Carefully message the change as well as the ultimate outcomes and artifacts resulting from the initiative. Know your audience-both specific and broad. Take the opportunity to be introspective and map out the onboarding process across the organization as there may be more than one workflow in the wild.