COVID-19: Flagging and Reporting on Remote Inspection I-9s
How to identify I-9s that require physical document inspection
This section explains how employers can identify Form I-9 records that require follow-up in-person physical document inspection after documents were initially inspected remotely under the DHS COVID-19 flexibilities. It also outlines recommended practices for documenting remote inspection and tracking impacted I-9 records in the Tracker I-9 system.
Background and DHS Guidance
Initially, DHS instructed employers to enter “COVID-19” in the Additional Information text box in Section 2 of Form I-9 when documents were inspected remotely.
In a revised FAQ, USCIS clarified that employers may indicate that remote inspection was completed and when in the Section 2 Additional Information field. DHS provided an example format such as:
Remote inspection completed on xx/xx/xxxx
Entering “COVID-19” or “Remote inspection completed on xx/xx/xxxx” is not a strict DHS requirement. Employers are not required to be consistent, and DHS has stated that employers should not be penalized or required to retroactively edit Forms I-9 if different language was used.
However, entering some form of notation in the Additional Information field is the primary method used to identify Form I-9 records that require follow-up in-person physical document inspection. This information enables reporting and tracking of impacted records.
TIP: Keep track of the first and last day your organization inspected documents remotely because of COVID-19 so you can run a report to capture these I-9 records within the date range.
Completing Section 3 when Documents are Inspected Remotely
When you initially complete Section 3 and the documents are inspected remotely, in addition to saving a copy of the image file in Section 3, we strongly recommend that you enter “COVID-19 Section 3” in the Additional Information textbox in Section 2 since there isn’t an Additional Information textbox on Section 3. Adding “Section 3” to the textbox will help you distinguish between Section 2 and Section 3 in-person document inspection follow-up.
Tracking Remotely Inspected Document I-9s:
Customers want to keep track of impacted I-9s to ensure that the steps above are followed and the in-person document inspection follow-up tasks are managed. To identify these records, employers should create a Custom Report that returns all Form I-9s for which documents were inspected remotely.
Step 1: Navigate to the I-9 Custom Reports page under "Reports" tab.
Step 2: Select the filter criteria that best meet your reporting needs. The following criteria are recommended:
- Select all impacted worksites
- Date Type: Create Date
- “From” date: The first day you started inspecting document remotely
- “To” date: Leave this date field empty until you stop inspecting documents remotely, then enter the last day you inspected documents remotely
- Select all Citizen Status options
- Select all Next Action options
- Optionally, any additional Fields that will help you with your process.
Step 3: Select the fields to include in the report by drag-dropping fields from the list of available fields into the Selected Fields column. The following fields are recommended:
- Employee Profile Worksite
- Employee Profile Name
- Section 2 Additional Information
- Created On
- Start Date
- Next Action
- Optionally, any additional Fields that will help you with your process.
Step 4: Once the report criteria and selected fields are defined, click Run Report to generate the results.
In the example shown, the report results include one Form I-9 record containing “COVID-19” in the results, indicating that documents were inspected remotely.
TIP: Report results can be exported to Excel for additional data manipulation as needed. The Edit Report option can be used to modify report criteria or selected fields.
Once the report configuration meets organizational requirements:
- Click Save As New Report
- Save the report to "My Reports" or "Shared Reports" for later use
- To run a saved report, select the report name from the Saved Reports dropdown on the main Custom Report page.
To run the saved report, simply select the Report’s Name from the saved report dropdown on the main Custom Report page.
Tracking Completed/Incomplete In-Person Inspection
Using the COVID-19 Custom Report described above, employers can track:
- Form I-9 records that require in-person document inspection, and
- Form I-9 records for which in-person document inspection has been fully completed.
This report enables employers to monitor inspection status and manage required follow-up actions.
TIP: To be successful, employers should be diligent about entering and updating the text in the Additional Information text box. Failure to do so will make it extremely difficult identifying these I-9s and the required follow-up, in-person inspection.
Click here to learn more about the Scheduled Custom Report feature.