Overview
Create employer-side Form I-9 internal audit packages for proactive compliance reviews, E-Verify reconciliation, remediation campaigns, and ICE Notice of Inspection readiness.
What It Covers
- Audit checklist for Section 1, Section 2, Supplement B, document lists, timing, remote examination, and anti-discrimination controls.
- Deficiency and anomaly log with severity tiers, authority citations, recommended actions, owners, and due dates.
- Per-employee remediation memo templates that preserve original records and avoid whiteout or backdating.
- Written I-9 policy covering completion, retention, reverification, E-Verify, remote hires, authorized representatives, and training.
- E-Verify reconciliation report, retention/destruction schedule, and ICE inspection-readiness binder.
Example Conversation
You: We have 420 employees in Florida and Georgia, an I-9 scan folder, and an E-Verify export. Counsel wants a self-audit package before enforcement activity increases. Can you build the audit checklist, deficiency log, policy, retention schedule, and ICE readiness binder?
Agent: Yes. I’ll first map the audit scope, identify whether Florida or Georgia E-Verify overlays require current-law confirmation, and create a data request list for any missing roster, termination, or case-closure fields. Then I’ll draft the checklist, deficiency log, remediation memo template, written I-9 policy, E-Verify reconciliation, retention schedule, and ICE readiness binder.
You: Some older corrections used whiteout, and a few remote hires used authorized representatives.
Agent: I’ll flag the whiteout corrections for counsel review, preserve original records in the remediation memos, and add no-whiteout/no-backdating correction instructions. For remote hires, I’ll review whether the employer used physical inspection, an authorized representative, or a DHS alternative procedure, and whether document-copy retention and E-Verify conditions were handled consistently.
Sample Output Excerpt
Below is an excerpt from the type of package the skill drafts.
Form I-9 Self-Audit & ICE-Readiness Package — Acme Manufacturing
Executive Summary
Acme Manufacturing conducted a counsel-directed Form I-9 self-audit covering active employees and terminated employees still inside the federal retention period. The review covered Section 1 timing, Section 2 completion, Supplement B/reverification, remote examination, E-Verify case closure, anti-discrimination controls, and retention/destruction rules.
Deficiency and Anomaly Log
| Employee identifier | Record area | Finding | Severity | Authority | Recommended action |
|---|---|---|---|---|---|
| E-0142 | Section 2 | Employer certification was signed late | Substantive | 8 CFR §274a.2(b)(1)(ii); USCIS M-274 | Annotate record, document audit finding, and add hiring-manager training |
| E-0198 | Correction | Prior correction obscured original entry with whiteout | Substantive / counsel review | USCIS M-274 correction guidance | Preserve record, attach remediation memo, do not recreate or backdate |
| E-0211 | E-Verify | Case appears unclosed in export | E-Verify process risk | E-Verify MOU/user manual | Confirm case status, close if appropriate, document explanation |
Retention Rule
For terminated employees, retain each Form I-9 until the later of three years after hire or one year after termination. Suspend destruction for any legal hold, ICE Notice of Inspection, subpoena, agency charge, or counsel-directed hold.
Extension Tools
validate_i9_audit_package checks a drafted package or binder index for the expected deliverables and safeguards. It looks for the audit checklist, deficiency log, per-employee remediation memos, written I-9 policy, E-Verify reconciliation, retention/destruction schedule, and ICE inspection-readiness binder.
The tool also checks for compliance safeguards such as no whiteout, no backdating, initialed-and-dated corrections, IER anti-discrimination language, the later-of retention rule, the three-business-day Notice of Inspection timeline, current Form I-9 edition review, and document-copy retention consistency.
Getting Started
Upload the employee roster, I-9 inventory or scans, E-Verify case export, current I-9 policy, remote inspection procedure, and any ICE or agency correspondence. Tell the agent whether the audit is proactive, counsel-directed, post-NOI, or focused on a particular location or employee population.
Before relying on the package for an ICE response or employee remediation campaign, have qualified immigration or employment counsel review the final output.