Headlines of raids by the Immigration and Customs Enforcement Agency (ICE) signal employers that immigration compliance must be a priority. Develop a complete immigration compliance plan with these6secrets to prove you mean business when it comes to immigration rules.
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Secret #1 - Put it in writing.
Develop an easy to follow written immigration policy including the basics of Form I-9 preparation, the I-9 storage and retention rules and a summary of both the federal and state immigration rules. Include procedures to investigate any claims of unauthorized employment or fraudulent documents submitted during the I-9 process.
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Secret #2- Train, train, train!
While a well written training manual is a great roadmap, you must take it for a test drive to know whether it will lead you to successful compliance. All employees responsible for hiring or completing the I-9 forms should be trained and re-trained at least once a year.
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Secret # 3- Audit: Check and double check!
Employers must periodically verify their I-9 forms are in proper order and personnel are complying with the I-9 requirements. A systemized audit is the best way to do this. An internal self audit of the I-9 forms by experienced HR managers on monthly, quarterly or bi-annual basis is recommended. Also, hire an immigration attorney to conduct an I-9 audit annually. The attorney will know how to identify, edit and correct I-9 form errors and recommend improvements for I-9 compliance and training.
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Secret #4 - Enforce the rules.
Your company is not protected by a compliance policy that is not followed. Require individuals with I-9 oversight to strictly compliance with your policy and hold them accountable if they don’t.
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Secret #5 - Investigate reports of violations.
Employers must develop and implement a nondiscriminatory, consistent, and effective process to investigate credible reports from individuals who allege unauthorized employment, document fraud or identity theft. Considering that ICE audits are often triggered by “tips” from concerned citizens, a prudent Employer must take seriously any tips it receives.
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