Back to Top skip to main content
GandS U.S. Immigration Logo
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 Many companies which think they have everything in order find that the policies and procedures are out-of-date and that mistakes have creeped into the onboarding process.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

Related Team

D Spaulding Team Page

David Spaulding

(215) 395-8959

(215) 395-8959

email David

Philadelphia (US Headquarters)

Full Biography

David Spaulding

Related Services:

Recent Blogs

Jan 27, 2021

Update – All In-Bound Travelers to United States Must Have Negative COVID-19 Test

As of January 26, 2021, all passengers on international flights to the United States must show a negative viral test for COVID-19. Requirement applies to all passengers, even U.S. Citizens, and as of right now proof of vaccination is not a substitute. Viral test must be taken within 72 hours of travel. Post-arrival self-quarantine also suggested. No testing requirements required at this time for travelers entering the United States at land crossings or by sea.

Jan 26, 2021

Proclamation on the Suspension of Entry as Immigrants and Non-Immigrants of Certain Additional Persons Who Pose a Risk of Transmitting Coronavirus Disease

On January 25, 2020, the Biden Administration extended the travel restrictions for Ireland, the United Kingdom, the Schengen Area, and Brazil and added travel restrictions for South Africa. Travel restrictions for South Africa go into effect on January 30, 2021 and the others are an extension of existing travel restrictions. The travel restrictions do not apply to a number of categories of Noncitizens and provide a waiver for the national interest. The policy does not contain procedures necessary to request national interest exceptions, likely leaving in place the procedures presently employed.

Jan 22, 2021

Biden Administration Changes to International Travel Policy Leaves People Wondering If the Travel Restrictions Will Remain

U.S. travel restrictions will be lifted unless the Biden Administration steps in. The White House says it will not lift the travel restrictions. COVID-19 testing and quarantine / isolation are not required for international travel. Learn more in this blog.