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Apr 29, 2020

A New Form I-9 Employer Handbook (M-274) is Available and Now Is an Excellent Time to Proactively Access Compliance

David Spaulding

Come May 1, 2020, employers are required to use the newest edition of the Form I-9, Employment Eligibility Verification and United States Citizenship and Immigration Services (USCIS) has now updated the Form M-274, Handbook for Employers.  Among the updates are List B and List C document clarifications, additional information about “authorized representatives” in Section 2, and document expiration dates and extensions. 

Form I-9, Employment Eligibility Verification (Form I-9) is required for every employee in the United States and federal authorities are particular about how we complete the forms, verify worker identity and work authorization, and how we store and present the forms. Form I-9s and onboarding issues are often overlooked and fines and penalties in this area of law are substantial.  More costly still is the business disruption of having to abruptly terminate unauthorized workers following a government inspection. 

The federal government’s inspection program has been ramping up for a decade and will likely top 10,000 inspections this year. Many companies which think they have everything in order find that the policies and procedures are out-of-date and that mistakes have creeped into the onboarding process. The result may be that unauthorized workers have been working for the company for years, flying under the radar of antiquated hiring protocols. Managers rightly note that being proactive reduces liability and that is as true for onboarding as it is in financial matters.

Government inspections often result in fines and penalties. That is a tough pill to swallow for companies with established onboarding policies and procedures but it is far more troubling to discover that significant numbers of critical workers are not authorized to work in the United States. Government inspections often find that employees in crucial roles don’t have permission to work here or that a whole team is out of status. Just as companies self-audit to avoid adverse OSHA findings, effective employee management should include onboarding assessments.

My firm is well suited to help with these matters. We work with management and human resources teams to confidentially and effectively tweak company policies and procedures, orienting them to the best long-term onboarding approaches. Many clients are able to achieve full compliance with simple changes to existing policies and procedures and a proactive posture allows businesses to address challenges on their own terms.

Green and Spiegel’s Compliance and Regulatory Practice is working remotely during the pandemic, but we are available to support employers in Form I-9 and E-Verify issues. Please contact us if we can be of any assistance (Compliance and Regulatory Enforcement Practice Director David Spaulding can be reached at 484-645-4194 or

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