The University of Missouri is required by state law to participate in the federal E-Verify program for all new hires. Give the I-9 Form to the employee on or before the first day of employment, but not before the job offer has been accepted.

Within three business days of the first day of employment, the employee must provide original documentation establishing the employee’s identity and demonstrating that he or she is authorized to work in the United States. The employer has up to three business days from the employment begin date to complete Section 2. Non-compliance may result in fines assessed directly to the department in which the error occurred. Contact Human Resources for more information.


Section 1 – Employee Information and Attestation

After the job offer has been accepted, the employee is responsible for completing Section 1 of Form I-9 before or on the first day of employment. The employee must have access to all instruction pages and the list of acceptable documents. The employer should not complete any portion of this section. Any changes or corrections to this section should be made by the employee, then initialed and dated.

The employer is responsible for reviewing to ensure all information in Section 1 is fully and properly completed. Common errors include missing or incomplete information and signature date after first day of employment.


Section 2 – Employer or Authorized Representative Review and Verification

The employee is required to present original document(s) that establish identity and employment eligibility within three business days of the first day of employment. Lists of acceptable documents are available in the Form I-9. The employer may not require or state which documents the employee presents, nor ask for evidence of continuing employment authorization.

The employer is responsible for physically examining the original document(s) and completing Section 2 for each document presented. The employee should not complete any portion of this section. Common errors include missing or incomplete information, invalid documents per the Form I-9 lists, documents verified after first three days of employment, attached documents do not match documents listed on form, acceptable document indicated under wrong list (e.g., List C document indicated as List A document on Form I-9).

No documents presented may be expired. Refer to Form I-9 (PDF) for lists of acceptable documents.


List A documents

  • Visas: A visa is not a valid List A document. An unexpired foreign passport is an acceptable List A document.
  • Form I-94/passport combination: The Form I-94 Arrival/Departure Record often does not state an employment eligibility date but indicates the employee’s status (e.g., F-1 nonimmigrant student) and duration of status (D/S). In these instances, the employer should explain that the combination of unexpired passport with Form I-94 is not acceptable without additional documentation indicating the employee’s employment authorization date. Some examples of additional documentation include:
    • Form I-20: Given to foreign students with F-1 nonimmigrant student status, authorized by the Dept. of Homeland Security and issued by the International Center.
    • Form DS-2019: Formerly IAP-66, given to some exchange visitors in J-1 nonimmigrant status, authorized by the U.S. Dept. of State and issued by the International Center.

List B documents

  • Photographs: Because the university participates in the E-Verify program, all List B documents must contain a photograph.
  • Minors under 18/individuals with special needs: Minors under the age of 18 or individuals with special needs who are unable to produce one of the identity documents listed above are exempt from producing one of the enumerated identity documents if:
    • Parent and/or legal guardian completes Form I-9 Section 1 “Employee Information and Attestation” and in the space for the signature, the parent or legal guardian writes the words, “Individual under age 18” (minors) or “Special Placement” (special needs).
    • Parent or legal guardian completes Form I-9 the “Preparer/Translator Certification.”
    • Employer writes “Individual under age 18” (minors) or “Special Placement” (special needs) in the Document Title for Section 2’s “Employer or Authorized Representative Review and Verification” under List B.

List C documents

  • Receipt in lieu: An employer must accept a receipt in lieu of the required document unless the individual is employed less than three business days. An application for initial work authorization or an extension of expiring work authorization is not acceptable. A receipt for application for a replacement document is acceptable if:
    • Required document was lost, damaged, or stolen.
    • Individual presents a receipt for the application for replacement document within three business days of the first day of employment.
    • Individual presents replacement document within 90 days of hire or, in the case of reverification, the date the employment authorization expires.
    • If the employee presents a receipt for replacement Social Security card for List C, a case cannot be created in E-Verify until the replacement card is received and the E-Verify exception process (PDF) must be followed.

Corrections or changes to Form I-9 must be handled in a way that is compliant for audit purposes, following two key guidelines. When making changes or corrections:

  1. Corrections should be made by the person who completed the section of the form originally.
    • Instructions for when this individual is unavailable are provided below.
  2. Change the form such that the original error is still visible in addition to the correction.
  • Draw a thin line through the error.
  • Initial and date each correction.
  • Do not use white out or otherwise mark out the error completely.

When the Employee is Unavailable to Make Corrections

If the employee has terminated their employment with the university or no longer employed by the department, attach a memo on official department letterhead documenting the employee is no longer employed.

Month Day, 20YY

Employee [Firstname Lastname], EMPLID [12345678], is no longer employed with the [Department name] as of [Month Day, 20YY] and therefore not available to make corrections to the Form I-9.

[Signer firstname lastname]

[Signer title]
[Department name]


When the Employer’s Representative is Unavailable to Make Corrections

If the employer’s representative who completed Section 2 of the Form I-9 is not available to make corrections (e.g., terminated employment with the university; transferred to another department), do not correct/change the Form I-9 and attach a memo on official department letterhead documenting the reason the person is not available.

Month Day, 20YY

Employee: [Firstname Lastname], EMPLID [12345678],

[Firstname Lastname] is no longer employed with the [Department name], therefore corrections to Section 2 of the Form I-9 cannot be completed.

[Signer firstname lastname]

[Signer title]
[Department name]

When an employee’s employment authorization expires, the employer must reverify his or her employment eligibility. The reverification should occur no later than the date the employee’s work authorization expires.

Human Resources sends a monthly report to Divisional Fiscal Officers (DFO) and CAPS Center leads informing the division of employees who have a future expiring work authorization date with more than four months advance notice of the expiration. This report should be distributed to the department level as necessary so that the information reaches the employee. Human Resources also contacts the employee directly regarding reverification of their authorization to work.


Work Authorization Process Timeline

The timeline for the work authorization process is as follows:

  • Four months before work authorization expiration date
    • Employee first appears on expiring work authorization report. Report sent to division fiscal officer.
    • Individual email sent to employee (first notice)
  • Three months before work authorization expiration date
    • Employee continues to appear on expiring work authorization report. Report sent to division fiscal officer.
    • No note sent to employee.
  • Two months before work authorization expiration date
    • Employee continues to appear on expiring work authorization report. Report sent to division fiscal officer.
    • No note sent to employee.
  • One months before work authorization expiration date
    • Employee continues to appear on expiring work authorization report. Report sent to division fiscal officer.
    • Final notice sent to employee. Division fiscal officer and supervisor copied on email.
  • Day following work authorization expiration date
    • Employee may not work and HR places employee on unpaid leave of absence (no PAF required).
    • Email sent to employee notifying of leave of absence. Division fiscal officer and supervisor copied on email (sent on work authorization date).
  • Two months after work authorization expiration date
    • HR terminates employment (no PAF required).
    • Email sent to employee notifying of termination. Division fiscal officer and supervisor copied on email.

Q: Are I-9s required for courtesy appointments at the University?
A:
I-9s are not required for courtesy appointments. If an individual has a courtesy appointment and either transfers to paid status or continues in the courtesy appointment while also taking a paid job, then a Form I-9 should be completed.

Q: What is “remuneration”?
A:
Remuneration is anything of value that is given in exchange for labor or services, i.e., compensation. Therefore, any individual who receives compensation should complete a Form I-9. For courtesy appointments, it is not necessary to complete the form.

Q: What are the differences between the List A, B, and C documents?
A:
The purpose of the Form I-9 is to document verification of the identity and employment eligibility of each new employee. List A documents establish both identity and eligibility for employment. List B documents establish identity only and List C documents establish employment eligibility. Therefore one document from each list is necessary when presenting List B and List C documents.

Q: Can I specify which documents I will accept for use on an employee’s Form I-9?
A:
No. It is viewed as discriminatory to specify which documents to provide for the form. However, the University is a participant in E-Verify (as required by State Law); therefore all List B documents must contain a photograph. If the employee presents a List B document without a photograph, you must request one with a photograph.

Q: Is it necessary to complete a new Form I-9 when an employee is promoted or transfers within the University?
A:
No. New Form I-9s are only required for new hires, rehires, and certain changes in citizenship status.

Q: Do I need to make copies of the documents presented to complete Section 2?
A:
Yes. It is University policy to do so and the federal law permits the employer to make copies of the document(s) and attach it to the Form I-9.

Q: What if the employee is unable to provide the required documents at the time of hire?
A:
If an employee is unable to present the required document(s) within 3 business days of the first day of employment, the employee must produce a receipt showing that he/she applied for a replacement document. See the "Special Circumstances Relating to Acceptable Documents" section for additional information. In the event that the employee has the documents but has merely forgotten to bring them in to complete the form in a timely manner, the department should attach a note to the Form I-9 explaining the reason for the delay in completing the Form I-9 within 3 business days.

Q: What if the person is unable to provide any of the required documents or receipts for replacement documents within 3 business days?
A:
The employee should be terminated immediately.

Q: If someone accepts a job but will not start immediately, can the Form I-9 be processed when the employee accepts the job?
A:
Yes. The Form I-9 can be processed prior to the employee’s actual start date, but not prior to offer acceptance.

Q: Can I accept a photocopy, scanned image through email or facsimile of a document presented by an employee?
A:
No. The person completing Section 2 is responsible for examining the original documents to determine if they reasonably appear genuine and relate to the employee presenting them. There is only one exception where a copy is allowed and that is a certified copy of a birth certificate, bearing an official seal.

Q: Are there social security cards that are not acceptable for List C?
A:
Yes. If the social security card has one of the following restrictions, it cannot be used for I-9 documentation of employment eligibility, regardless of citizenship status:

  • Not Valid For Employment
  • Valid For Work Only With INS Authorization
  • Valid For Work Only With DHS Authorization

Q: May I accept a social security card that has been laminated?
A:
According to the Handbook for Employers, M-274 (Rev 03/08/13) page 43, a laminated social security card can be accepted as long as the card reasonably appears to be genuine and to relate to the person presenting it. However, if you have any reason to believe that the laminated document being presented is not genuine you can refuse the document and request a different List C document. Metal replicas or plastic reproductions of the social security card are not acceptable for Form I-9 purposes.

Q: May I accept an expired document?
A:
No. As of March 2, 2009 expired documents are no longer acceptable.

Q: Why is the Native American Tribal Document listed in both List B and List C?
A:
This document is evidence of both identity and employment eligibility. It is not found in List A because List A documents are limited to those designated by Congress in the law. If the employee presents a Native American Tribal Document, record the appropriate information in both List B and C.

Q: Are a passport and visa the same thing?
A:
No. The unexpired foreign passport is a List A document but the visa is not an acceptable document for the Form I-9. The visa and the passport serve two distinct purposes. The visa is a document that shows permission for entry into the United States. There are 22 different nonimmigrant visa categories, not all of which would make the employee eligible for employment. The passport is a formal document issued by an authorized official of a country to one of its citizens to allow for exit from and reentry into the country.

Q: Are both unexpired and expired passports acceptable List A documents?
A:
No. As of March 2, 2009, expired documents are no longer acceptable.

Q: If someone indicates a limited duration work authorization at the time of hire and upon reverification the individual produces a social security card as proof of employment eligibility, should I ask for a DHS work authorization document?
A:
No. You must accept any document from List A or List C, including a social security card, as evidence as long as it doesn’t indicate a restriction such as “valid for work only with DHS authorization”.

Q: May I accept a receipt for application of a replacement document?
A:
Yes, with clarification. The most common receipt presented is for a replacement social security card. This may be accepted for purposes of completing the Form I-9 and then within 90 days from the receipt date, the employee should present the actual document for review. If the employee is hired for less than 3 days, a receipt may not be accepted.

Q: May I create the case in E-Verify if a receipt for a replacement document is presented?
A:
It depends. If the document is being used to prove identity (e.g. a temporary driver’s license with a photo), then you may create the case in E-Verify. If the document is being used for employment eligibility (e.g. receipt for a replacement social security card), you must wait until the actual card is presented to create the case in E-Verify. Regardless of whether the case can be created or not in E-Verify, the actual document is required to be submitted to the employer once received.

Q: What constitutes “document abuse”?
A:
Document abuse occurs when an individual is asked to present more documents than necessary or different documents than those presented during the completion process. One example is copying all documents presented rather than just those used to complete the Form I-9. You may only ask for additional documents for the Form I-9 if the documents presented aren’t acceptable.

Q: If I choose not to present my social security card for the I-9, why am I still required to provide a copy of the card with my hire paperwork?
A:
It is University policy to maintain a copy of the social security card to ensure accurate data entry of the social security number and name for W-2 purposes

Q: What do I do if the employee presents me with documents from all 3 lists (A, B & C)?
A:
If the employee presents you with documents from all 3 lists (e.g. US passport, Driver License, and Social Security Card), you will need to show them the list of acceptable documents and ask them which document(s) they choose to use for their I-9. Only copy the document(s) that the employee chooses.

Q: What issuing authority should I list for the social security card?
A:
You will need to review the front and back of the social security card to determine the issuing authority. Typically there is a round seal on the front of the card that will have the issuing authority printed around the seal. Examples of issuing authorities you will see are; Social Security Administration, Department of Health and Human Services, or Department of Health, Education and Welfare. The issuing authority can be abbreviated on the I-9 as follows; Social Security Administration is abbreviated SSA, Department of Health and Human Services is abbreviated DHHS, and Department of Health, Education and Welfare is abbreviated DHEW.