Near the end of every fiscal year, the Auditor of Public Accounts (APA) performs a payroll and compliance audit on the University of Virginia. Because UVA is partially funded by the state, we must maintain appropriate records and provide information to APA when requested. For the last two cycles, UVA has been issued an audit finding related to I-9 compliance issues. After review of the findings, it was determined that the root cause of the compliance issues can primarily be tied to student workers.
The U.S. Citizenship and Immigration Services agency established the Form I-9 in 1986. The form is used to verify identity and employment authorization of individuals hired for employment in the United States. The University of Virginia, because of federal funding, is also mandated to participate in the E-Verify program (managed by the Department of Homeland Security). E-Verify is used to confirm, through the Social Security Administration and Department of Homeland Security, that a new employee has used appropriate documentation for the completion of the I-9 form.
The I-9 form is two parts:
- Section 1: Completed by the new employee and per USCIS must be completed by the end of Day 1 of employment. For UVA employees, this is done directly in Workday as part of onboarding.
- Section 2: Completed by the employer (UVA HR) and requires presentation of appropriate documents by the employee within 3 business days of employment commencing. Section 2 is finalized in Workday through an integration process with E-Verify.