I-9 Employment Eligibility Verification Policy

This I-9 Employment Eligibility Verification Policy (Policy) applies to all new hires and rehires returning to the University of Cincinnati (University).

This Policy sets forth the University’s process for complying with the Immigration Reform and Control Act of 1986 (IRCA).  IRCA requires employers to verify the identity and employment authorization of new employees using the U.S. Citizenship and Immigration Services (USCIS) Form I-9, Employment Eligibility Verification (Form I-9) to verify the identity and employment authorization of individuals hired for employment in the United States.

For purposes of completing Form I-9, the University will use the definitions set forth in the USCIS Instructions for Form I-9, Employment Eligibility Verification document.

For purposes of completing E-Verify, the University will use the definitions set forth in the USCIS E-Verify User Manual.

The Department of Human Resources is responsible for managing the employment verification process for all U.S. Citizens and all lawful permanent residents to ensure eligibility for employment in the United States. UC International Services is responsible for managing the employment verification process for all foreign nationals authorized to work in the United States.   

All newly hired employees and all rehired employees must complete the Form I-9 and present original document(s) that establish their identity and employment authorization within three business days of their first day of employment.

Failure to complete the Form I-9 and/or provide the required document(s), or a receipt for replacement document(s) that were lost, stolen or destroyed, within three (3) business days may result in termination of employment.   

Verifications for New Hires and Rehires

1. Employees will receive an email notification prompting them to complete the online new employee paperwork and Section 1 of the Form I-9, which must be completed by the end of business on their first day of work.
2. After completing the new employee paperwork, the employee will receive an additional email notice with instructions for completing I-9 document verification.
   1. In person and hybrid Immigrant & Law Permanent Resident Employees must present original document(s) for work-authorization to a University Authorized Representative no later than the end of business on the third business day following their first day of work. 
   2. Employees with an approved fully remote, out of the tri-state exception form on file must present original document(s) for work-authorization and Section 2 of the Form I-9 in person to an Authorized Representative or schedule a virtual verification meeting with a University Authorized Representative. If using an Authorized Representative outside of the University, the representative will be required to verify the documents and complete Section 2 of the Form I-9. Once complete, the employee must provide the Department of Human Resources a legible copy of the original document(s) and Section 2 of the Form I-9 by the end of business on the third business day following their first day of work.
   3. Foreign National Hires must submit the appropriate Employment Eligibility Verification or Check-In e-form in the UC International system to be onboarded. Foreign National Hires are required to bring their original documents to the UC International Services office for review. 
3. Authorized Representatives at the University will verify the provided documents and complete employment eligibility through E-Verify no later than the 3^rd business day following the employees start date. All collected documents will be uploaded and stored securely by the University. These documents are accessible only by authorized University personnel and are used only for purposes of verification of work authorization.

Reverifications

When a reverification is required, it must be completed by the earlier of the employment authorization expiration date stated in Section 1 of the I-9 Form (if any), or the expiration date of the List A or List C employment authorization documentation recorded in Section 2 of the I-9 Form. Subsequent reverifications, if required, must be done by the expiration date of the I-9 Form List A or List C documentation entered during the employee's most recent reverification.

Reverification is only done for certain categories of employees.  Refer to the USCIS Instructions for Form I-9, Employment Eligibility Verification and the Handbook for Employers M-274 document for current information on what employees are subject to reverification.

Complaints alleging a faculty member violated this Policy should be submitted to the Office of the Provost via EthicsPoint under “Academic Affairs.”  Complaints against represented faculty members will be processed in accordance with the disciplinary procedures set forth in the Collective Bargaining Agreement between the University of Cincinnati and the American Association of University Professors.  Complaints against unrepresented faculty members will be processed by the Office of the Provost in accordance with the procedures similar to those established herein for unrepresented staff members.

1. Employees who are subject to reverification will receive notification from the applicant tracking system when their employment authorization is due to expire within 180 days.
2. UC International Services will collect the supporting documents and complete Supplement B, Reverification and Rehire of Form I-9 for Foreign National Hires.
3. Once the reverification is complete all files are stored securely by the University in a location that is accessible only to authorized University personnel.

Related links

Phone Contacts

Human Resources: 513-556-6381

UC International Services: 513-556-4278