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Form I-9 audit

Follow These 5 Steps for an Effective Internal I-9 Audit

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Increased scrutiny from U.S. Immigrations and Customs Enforcement (ICE) on whether your employees are authorized to work in this country means that employers need to be fully aware of the state of their I-9 compliance. No business expects to be audited. But when fines for errors on I-9 forms can range from $216 to $2,156 per worker, knowing that those documents are error-free can give you peace of mind.

An internal I-9 audit – or I-9 self-audit – can help you accomplish that. It gives you time to correct errors or find missing information without the pressure of an official audit.

Additionally, when consistent self-audits are a standard business practice for your organization, it becomes easier to defend against claims of retaliation or discrimination. If your organization ever does undergo an official audit, robust, documented internal I-9 audits can prevent you from being hit with fines, and gives your HR department experience in conducting an efficient, accurate audit of I-9 forms.

Here’s what you need to know in order to conduct an internal I-9 audit in your organization.

Before conducting an internal I-9 audit

Ensure your internal audit strategy doesn’t violate discrimination laws. While ICE’s priority is to ensure all workers in the U.S. are authorized to work here, the priority of the Office of Special Council for Immigration Related Unfair Practices (OSC) in this context is to ensure that individuals are not discriminated against based on citizenship status or national origin.

Fortunately, the way your organization conducts its internal I-9 audit can help it comply with both ICE’s and OSC’s priorities. Here are ways you can ensure you aren’t swinging the balance in the other direction when conducting your internal audit and becoming vulnerable to accusations of discrimination:

  • If you use E-Verify, you must run cases for all your employees. You can submit an E-Verify case past the three-day deadline if an internal audit reveals that a new-hire case was not completed. You will have to select this as the reason for submitting late verification. However, do not go back and run E-Verify cases for employees who were hired when your company was not enrolled in the E-Verify service.
  • During your audit, if you conduct a selective I-9 audit (rather than auditing all employees’ I-9 forms), be careful to ensure truly random selection. We’ll talk more about how to do that in step 1.
  • If you need additional or updated employment authorization documents, you must allow the employee to choose his or her own forms of I-9 acceptable documents. However, if a document he or she originally provided is insufficient for employment authorization, you may request that same type of documentation is not submitted again. Not every expired document can be updated, so consult the U.S. Citizenship and Immigration Services’ M-274, Handbook for Employers, if you are uncertain.
  • Have translators/preparers available for employees who don’t speak English, if applicable.

5 Steps for conducting an internal I-9 audit:

Step 1. Decide whether you will audit a random selection – or all – employee I-9 forms.

If auditing a selection of I-9 forms, make sure you’re able to verify the selection was in fact random – for example, using Excel’s “RAND” and “RANK” functions and documenting your selection process can help.

Auditing a selection of forms will help you assess your onboarding procedures, but may not be as effective as a full audit in correcting form errors. An internal audit of all I-9 forms also minimizes liability for claims of discrimination or retaliation, so that’s the process we’ll focus on here.

Step 2. Gather employee data.

You’ll need a list of all employees hired after Nov. 6, 1986, as well as a list of all employees terminated within the last three years. Collect paper or electronic forms for both lists.

If your company uses paper I-9 forms, make sure you have forms from all locations, or ensure that your regional HR offices also are conducting an internal I-9 audit according to best practices.

To do that, identify which locations store paper I-9 forms: company headquarters, regional or field offices, or even different departments. If some locations have paper forms, while others have electronic I-9s, you may be able to improve the accuracy of your internal I-9 audit by getting your forms into the same format, either by printing online forms (which can be risky) or by uploading paper I-9s to a secure electronic storage location.

The latter is the safer option, in the event of theft or weather damage.

At this point, you can collect paper or electronic forms and conduct the audit in a centralized location, or you can guide the audits of other locations. You may wish to designate someone in HR headquarters to call weekly and track progress to ensure consistent I-9 compliance across locations.

Step 3. Compare I-9 forms to the lists of current and terminated employees.

Note which forms have errors, missing sections or missing documents. Keep track of any employees who never completed I-9 forms at all (as long as they were hired after Nov. 6, 1986). It may be helpful to create an audit log with three sections to help you keep track: employee’s name, errors found and the actions taken to correct the errors.

Step 4. Make note of changes that need to be made.

Keep these notes with the corresponding I-9 form either with a sticky note or a note on the electronic document. Avoid writing directly on a paper I-9 form.

If reviewing paper I-9 forms, determine a contingency plan if the sticky notes falls off or if water damage occurs. How will you prove the noted changes were made? An electronic backup of the notes (in the form of an audit log or something else) can help you guard against the unforeseeable.

Paycom clients: You easily can collect all employee I-9 forms from the Employment Authorization Dashboard in our Document and Task Management tool. You also can make dated, secure changes with just a couple of clicks through I-9 correction tasks or by uploading a signed and dated note to an employee’s file. That’ll save you a lot of time when it comes to collecting and correcting I-9 forms.

Step 5. Correct omissions or discrepancies.

When making corrections, be careful to avoid making misleading changes; – it should be exceedingly clear when the original form was completed and when the correction was made. Following correct compliance procedures means that both dates should be obvious to anyone reading the document, regardless of his or her level of familiarity with your company.

If minimal omissions or inaccurate information exist in Section 1:

  • The employee (or a translator/preparer if necessary) must make the change.
  • The employee should draw one line through the inaccurate information, enter or write the correct information, and initial and date the correct information.
  • If the employee needs assistance, the translator/preparer should draw one line through the incorrect info, and enter or write the correct information. Then the employee should initial and date the correct information, and the translator/preparer should initial and date the correction next to the employee’s initials.

If there are minimal omissions or inaccurate information in Section 2 or 3:

  • The employer must make the change.
  • The employer should draw a line through the incorrect information, enter or write the correct or omitted information, and initial and date the changes made.

If the form was never completed, is missing or has substantial errors:

  • Complete the current version of the I-9 form as soon as possible. Do not backdate the form.
  • Note the actual date employment began and attach a signed and dated explanation of the action taken, to show good-faith compliance effort.

If an employee’s employment authorization or employment authorization document has expired, or if an employee has changed names:

  • Complete Section 3 on the current version of the I-9 form for re-verification.
  • Keep the completed Section 3 with the original Form I-9.
  • Keep in mind that U.S. citizens and noncitizen nationals (lawful permanent residents who presented a Form I-551 for Section 2), List B documents should not be re-verified, even if now expired. If the document was expired when completing the original Form I-9, correct Section 2 instead.

If an E-Verify error is found, the necessary action depends on when the employee was hired:

  • If the employee was hired while your organization was participating in E-Verify, create an E-Verify case for him or her immediately.
  • If  the employee was hired before your organization was enrolled E-Verify, do not create an E-Verify case for him or her.

After completing your internal I-9 audit

Once your HR department has completed an audit of your organization’s I-9 forms, you may want to consider a postmortem meeting with the HR team to identify areas for improvement. Regardless, you should ensure safe, secure storage of your I-9 forms and any corresponding employment authorization documents.

In the postmortem meeting, identify issues or patterns that arose during the audit that need to be addressed. Are there certain elements or stages where your organization consistently struggles (such as consistently late or incomplete forms)? Do certain locations or departments have significant numbers of delayed or poorly completed forms? What can your HR department learn from the internal I-9 audit to improve your practices and policies?

Summarize the postmortem meeting in an email to any key stakeholders, like the HR professionals involved in the audit. It’s helpful to collect the lessons learned in writing to refer to during next year’s internal audit, and it can help you prove a good-faith effort to improve your I-9 compliance if you were to undergo an official audit.

Before moving on to the next initiative, it’s crucial to ensure safe, secure storage of your I-9 forms and any corresponding employment authorization documents.

Paper is the less secure way to store these documents, but if your I-9 documents are physical, make sure they’re stored in a location that’s safe from potential water and weather damage, and  accessible only to those who should have access. Create and document a contingency plan for natural disasters that might affect your copies, like a flood, hurricane or tornado.

Electronic storage is the more secure way to store I-9 forms and any corresponding employment authorization documents – and your due diligence can help ensure their safety. Ask your IT department or service provider about how securely electronic I-9 documents are saved. Are they stored on your company’s server? In the cloud? On a secure third-party server? How frequently are backups performed?

No matter how your documentation is stored, make sure it is easily accessible. In an official audit, you may have as little as a three-day turnaround to send I-9 documents to the government, so it’s important you can access these items quickly.

Enjoy post-audit peace of mind

An internal I-9 audit gives you time to correct form errors without the pressure of an official audit. You can rest assured that your forms are completed accurately and that your HR department will know how to quickly and accurately conduct an official audit, in case your organization is ever required to do so.

If you have access to Paycom’s Employment Authorization Dashboard, you can collect what you need to make corrections efficiently and securely. To request a meeting and see a demo, click here.

To read about more ways that moving away from manual, paper processes can give you peace of mind, download our executive summary on the topic, Discover the Hidden Cost of Manual Processes.

DISCLAIMER: The information provided in this blog is for general informational purposes only. Accordingly, Paycom and the writer of the above content do not warrant the completeness or accuracy of the above information. It does not constitute the provision of legal advice, tax advice, accounting services, or professional consulting. The information provided herein should not be used as a substitute for consultation with professional tax, accounting, legal or other professional services.


by Lauren Rogers

Author Bio: As a communications specialist at Paycom, Lauren Rogers keeps employees abreast of company news and events, and provides insight to industry leaders regarding issues affecting human capital management. With experience in marketing and communications, Lauren has written blogs and other materials for a variety of businesses and nonprofits. Outside the office, she enjoys gardening, testing new recipes and sipping something caffeinated with her nose in a book.

Anonymous Sexual Harassment Reports

Building Employee Trust with Anonymous Sexual Harassment Reports

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Employee trust is one of the most important factors in handling sexual harassment complaints. Employees need to trust HR will listen to their concerns and will respond appropriately to reports of sexual harassment. Yet the EEOC notes only about 30% of employees who experienced harassment reported the harassment internally within their company.

One way HR can help build trust with employees is with a robust system of reporting and investigation that allows anonymous complaints and communications.

If clear procedures are communicated to employees and consistently followed, an anonymous complaint process can help build trust that HR is prepared and committed to investigating harassment complaints in a fair and thorough manner.

Make a plan and stick to it

 As with all company policies, developing your procedure ahead of time, and following it when issues arise, are key to workplace fairness. Following the steps of a robust and outlined policy can also help limit company liability after an incident occurs by demonstrating the company seriously investigated the complaint and took appropriate action in accordance with its policy.

Providing the means for employees to make anonymous complaints can help employees trust their complaints will be handled discretely and appropriately, and can help lessen employee concerns about retaliation.

Some employers contract with an outside vendor to provide a third-party anonymous reporting system that will pass on complaints only to a specific person or group who needs to know of the complaint in order to investigate. The vendor can also allow the person making the report to specify individuals who may be involved in the behavior, so those people will not receive access to the anonymous report.

Follow up

 Take anonymous reports as seriously as any other type of report, including face-to-face complaints. Recognize the reasons an individual may wish to remain anonymous and be sensitive in your response.

Think of anonymous reporting as simply another pathway to allow your employees to share their concerns, in addition to the other methods available to them, like discussions with HR personnel or meetings with supervisors. Thoroughly investigate any complaint made, regardless of whether the person who filed a report chooses to remain anonymous or not.

Don’t promise more than you can deliver

 Communicate to employees that they can make a report of sexual harassment completely anonymously. However, if they choose to identify themselves in a complaint, don’t promise you will be able to keep their identity secret. Make clear you have a duty to investigate all complaints, and this may involve interviews with the person or people accused of taking part in inappropriate or harassing behavior.

Emphasize the company will follow its internal procedures. Do not imply or promise what may result from an investigation after an employee complaint is made. An anonymous complaint is the first step of a workplace investigation, and must be investigated in accordance with policy, just like any other type of report.

It’s important to take your company’s responsibilities seriously when you respond to sexual harassment complaints. A robust policy that allows anonymous reports and responds with an impartial and thorough investigation to each anonymous complaint can be an effective part of an overall anti-harassment strategy, and can help build and maintain employee trust in HR personnel and anti-harassment efforts.

 Disclaimer: This blog includes general information about legal issues and developments in the law. Such materials are for informational purposes only and may not reflect the most current legal developments. These informational materials are not intended, and must not be taken, as legal advice on any particular set of facts or circumstances. You need to contact a lawyer licensed in your jurisdiction for advice on specific legal problems.

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Posted in Blog, Compliance, Featured

Erin Maxwell

by Erin Maxwell

Author Bio: As a compliance attorney for Paycom, Erin Maxwell monitors legal and regulatory changes at the state and federal level, focusing on health and employee benefits laws, to ensure the Paycom system is updated accordingly. She previously served as assistant general counsel at Asset Servicing Group in Oklahoma City. She holds a bachelor’s degree from the University of Central Oklahoma and a J.D. from the University of Oklahoma. Outside of work, Maxwell enjoys politics, historical mysteries and spending time with her family.


Levels and Landscapes: Equipping Tomorrow’s Leaders

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Leaders are “the primary factor behind employee productivity, commitment and bottom-line profitability,” according to research from leadership consultant expert researchers Zenger Folkman.

The stakes are high, which doesn’t make it any easier to ensure the leaders in your organization are reaching their full potential, or that your next crop of leaders will be up to the task. In fact, research shows that one of the five largest challenges HR faces in 2018 is developing leaders. To make sure your organization’s current and future leaders are in good shape, help develop them through the five levels of leadership with an eye on your specific organization’s landscape.

John Maxwell’s levels of leadership

 In the fast-paced global economy, strong leadership is key to helping employers innovate and adapt on a dime. But before delving into the vast array of advice, employers must first assess their own leadership. According leadership guru John Maxwell, there are five different levels of leadership a leader may progress through.

Maxwell’s levels are:

  1. Position
  2. Permission
  3. Production
  4. People development
  5. Pinnacle


As leaders grow, they should progress through the levels of leadership, which build on top of each other. For example, when a leader reaches the third level, Production, their priority is to produce results. Maxwell writes, “[t]he Production level is where leaders can become change agents. Work gets done, morale improves, profits go up, turnover goes down, and goals are achieved. The more you produce, the more you’re able to tackle tough problems and face thorny issues.”

When a leader reaches the final level – Pinnacle –  they reproduce other leaders who are willing and able to develop still more leaders. Their organizations thrive, and they develop a personal legacy of leadership.

Leaders in all areas of an organization can identify where they can grow to move toward Pinnacle – which benefits them, their companies and everyone they work with.

Knowing your business landscape

 The way a leader carries out Maxwell’s five levels may look somewhat different depending on your business and industry. According to a recent study in the Harvard Business Review, different kind of enterprises thrive under different types of leadership. Businesses should take stock of their products, makeup, competition and the types of people who rise and fall in the ranks to understand which leaders are best suited for their future endeavors.

According to the study, “[l]eadership styles, or brands if you prefer the term, are always contextual. Different kinds of leaders are minted in different organizations.”

This gives your organization an opportunity. Determine how the best, most effective leaders in your company lead. How do they make decisions? What are their priorities, and how do they communicate those to their employees? What are the commonalities your top leaders share? Then, seek those common elements in your rising leaders to build a strong bench of future leaders.

In an upcoming webinar presented by John Maxwell on HR.com, gain insight on how leaders can develop themselves and others. Don’t miss this opportunity to learn how you can grow leaders and elevate the rest of your organization while you do it.

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Posted in Blog

Author Bio: Jason Bodin has been the communications pulse for a number of organizations, including Paycom, where he serves as director of public relations and corporate communications. He helped launch Paycom’s blog, webinar platform and social media channels. He aided in the development of Paycom’s tool to assist organizations in complying with the Affordable Care Act, one of the largest changes in health care the country has seen. A graduate of the University of Oklahoma, Bodin previously worked for ESPN and FoxSports. In his free time, he enjoys adventuring with his family, reading and strengthen his business acumen.

Physical Wellness

Practical Tactics to Improve Your Workforce’s Physical Wellness

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By now, most of us are well aware physical wellness should be a priority for employees and employers. Being physically active helps employees perform at a high level and brings a host of work-related benefits, including increased mental stamina, better concentration and memory, and the ability to learn more quickly. Studies have shown working out for as little as 30 minutes can drastically reduce stress levels. Plus, on days when employees exercise, they tend to be more productive and have improved moods, which benefits the entire company.

Although many employers are aware of this correlation, it can seem difficult to encourage physical wellness in the workplace without expensive perks like exercise equipment or onsite personal trainers. But, the good news is you can encourage physical wellness in your workforce by implementing practical tactics in three key areas: culture, environment and ergonomics.


It’s difficult for any wellness initiative to succeed without support and buy-in from top-level leadership. Ideally, through words and actions, leaders should communicate employee physical health is important.

This could happen in several ways, including:

  • encouraging participation in sports
  • facilitating company teams or leagues
  • holding walking meetings
  • offering full or partial reimbursements for local race entry fees
  • partnering with local fitness centers to offer employee discounts

After encouraging employee engagement in company offerings, leadership might choose to cement their support by participating in that big community run or taking part in an office-wide volleyball game. A physical wellness program will thrive in a culture that recognizes its importance at all levels.


You also can help employees get the most out of your organization’s wellness program by creating visual cues throughout the workplace reminding employees to make healthy choices. It’s certainly difficult for employees to overlook the on-campus gym or track they walk past each day, but choosing a healthy snack from the vending machine might increase with some signage indicating 100-calorie or less options. Post signs in stairwells to remind employees how many calories they can burn by choosing to walk instead of using the elevator.  An environment with myriad positive visual cues will encourage employees to take the next step toward a healthier lifestyle.

For businesses with smaller office spaces, take stock of the number of windows present and position desks near them when possible to help improve office visuals. If it’s an option, bring some plants into an all-beige office space – they can improve employee productivity in addition to providing visual interest.

It turns out that acting on those visual cues matters, too. According to Harvard Business Review, Leeds Metropolitan University researched more than 200 employees at a variety of companies and had them report their work performance on days they exercised during work hours and days they did not. On the days they did, the employees reported markedly better productivity and time management, as well as improved interactions with others.


According to the United States Department of Labor, ergonomics (the science concerned with people’s efficiency in work environments) can help increase productivity, decrease muscle fatigue and lessen the incidence of work-related injuries like carpal tunnel syndrome, tendonitis and rotator cuff injuries.

For the many employees who work in an office, implementing a few simple ergonomic best practices can make a big difference. Businesses could enact the 20/20/20 rule for vision breaks, which suggests individuals take a 20-second break every 20 minutes to focus their eyes on an object 20 feet away. Doing so can prevent harmful eye strain that occurs more frequently in jobs with high levels of screen time. Additionally, accommodations like additional lumbar support, standing desk options and adjustable chairs for comfort can be beneficial for desk dwellers, as can suggesting a two-minute break to stretch each hour.

There are many ways to encourage physical wellness in the workplace – start with what makes sense within your organization’s current wellness initiatives. Whether your company has a spiffy new gym in mind or strives to embrace a culture where walking meetings are the norm, prioritizing physical wellness can improve productivity and morale in your workforce and directly contribute to continued success!

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Posted in Blog, Featured

Tiffany Gamblin

by Tiffany Gamblin

Author Bio: Tiffany Gamblin is an HR manager at Paycom. Since joining the company in early 2016, she has implemented innovative benefit communications, as well as developed and delivered an immersive “HR Leadership for Management” training program across the organization. A certified professional of the Society for Human Resource Management, Gamblin obtained her bachelor’s degree in 2013 from the University of Central Oklahoma and has more than eight years of HR experience in a generalist capacity, with a focus on benefits administration and HR training.


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