COVID-19: Flagging and Reporting on Remote Inspection I-9s
How to identify I-9s that require physical document inspection
Initially, DHS instructed employers to enter “COVID-19” in the Additional Information textbox in Section 2 as shown below. In their revised FAQ, the USCIS notes that employers “may indicate that remote inspection was completed and when” in the Section 2 Additional Information box. As illustrated in the mockup below, the DHS suggests writing “Remote inspection completed on xx/xx/xxxx”. Entering COVID-19 or Remote inspection completed on xx/xx/xxxx is not a strict DHS requirement, so don’t worry if you weren’t consistent. Employers should not be penalized or required to go back and edit I-9s if you used different language. However, entering something in the Additional Information textbox will serve as the way to report on these I-9s that require the follow-up in person document inspection (more on this below).
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 will 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 do this, build a Custom Report to return all I-9s where documents were inspected remotely.
Step 1: Navigate to the I-9 Custom Report page
Select the filter criteria that best fits your reporting needs. We suggested the following:
- 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
Next, select the Report Fields to include in the report by drag-dropping a field from the list of available fields to the right-hand Selected Fields column. We suggest the following
- Employee Profile Worksite
- Employee Profile Name
- Additional Information (maps to the Section 2 “Additional Information” text box)
- Created On
- Start Date
- Next Action
- Optionally, any additional Fields that will help you with your process
Once you have the criteria and fields defined, click “Run Report” to generate the results. In the example below the report results include one I-9 with the “COVID-19” in the results.
TIP: You can export the results to Excel and manipulate the data as necessary. You can also click Edit Report to change the criteria or fields.
Once you are happy with the report’s criteria, save the report to My Reports (or Shared Reports) for later use, by clicking the “Save As New Report” button and filling out the saved report fields.
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, you can now track which I-9s require in-person document inspection, and which I-9s are fully complete.
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.