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Policy No: 2173
Responsible Office: Human Resources
Last Review Date: 11/10/2026
Next Required Review: 11/10/2031
Policy No: 2173
Responsible Office: Human Resources
Last Review Date: 11/10/2026
Next Required Review: 11/10/2031

Employment Eligibility Verification (Form I-9)


1. Purpose

Enforced by the U.S. Department of Homeland Security (DHS) and administered by U.S. Citizenship and Immigration Services (USCIS), the Immigration Reform and Control Act of 1986 (the "federal act") requires all employers to verify the identity and employment authorization of each new hire employee, in compliance with federal deadlines. Allowing an employee to work who is not authorized to work in the U.S., could result in civil and federal penalties. 
 
In addition, the University of South Alabama participates in E-Verify, which electronically verifies information provided on the Form I-9.

2. Applicability

Applies to all employees (regular, temporary, faculty, staff, administrators and students) of the University of South Alabama and all of its entities, to include USA HealthCare Management, LLC and University of South Alabama Health Care Authority, hired after November 6, 1986.

3. Definitions

Form I-9: A federal form that is used for the purpose of verifying the identity and employment authorization of individuals hired for employment in the United States.
 
E-Verify: A web-based system that allows employers and other participants to confirm the eligibility of their newly hired employees to work in the U.S. by electronically matching information on the employee’s Form I-9, Employment Eligibility Verification, against records available to the Social Security Administration (SSA) and the DHS.
 
First day of employment: The first day that the employee begins work for pay or other remuneration. This is the employee’s hire date, based on payroll records.

4. Policy Guidelines

Any new hire or employee with a one-day or more break in service must complete a new I-9.
 
In compliance with the federal act, all University of South Alabama employees must complete Section 1 of Form I-9 on or before the first day of employment (date of hire) and must provide acceptable documentation within three business days following the date of hire as required to complete Section 2 of Form I-9. Employees who have not completed Section 1 by their hire date should not begin work.
 
Completion of Section 2 is required within three business days following the date of hire to continue employment. In order for Human Resources to complete Section 2, the employee must provide Form I-9 Acceptable Documents, as mandated, to their respective Human Resources department. Sections 1 and 2 may be completed any time prior to the hire date, following an acceptance of an offer of employment.
 
Employees who fail to provide the required ID documentation by the federal deadline are not allowed to continue employment beyond the deadline and are required to be terminated effective immediately.

5. Procedures

Immediately upon an accepted offer of employment, before employment begins, Human Resources must be notified of the new hire and the date employment begins, if they are not already aware.  Human Resources will provide the employee with instructions for completing Section 1 of the Form I-9 electronically on or before their date of hire.  The employee must present, in person, acceptable ID documentation required for Section 2 of the Form I-9 to Human Resources within three business days following their date of hire.
 
If the employee is unable to be present at their respective Human Resources location within the first three business days following their hire date, reach out to Human Resources for additional instructions.
 
Human Resources will notify hiring managers/designees of any employees who fail to comply within three business days and advise the department that the employee is to be terminated immediately. The employee cannot report to work for a fourth work day without adherence to the federal act.
 
Student Employees: The hiring department is responsible for instructing new student employees, or students being reappointed, to report to Human Resources on or before their date of hire for paid employment, regardless of whether they have a current student job or not. If HR determines that a student employee is new or will experience a break in service, they will be required to complete a Form I-9.

6. Enforcement

Per federal policy, new or rehired employees who fail to comply with I-9 completion requirements are not allowed to continue employment and require immediate termination. The University of South Alabama is subject to penalty fines due to any noncompliance or violations of the federal act. Noncompliance by hiring managers is subject to disciplinary action by the University of South Alabama.

7. Related Documents

7.1  United States Citizenship and Immigration Services: https://USCIS.gov