Policy

Columbia University is required to comply with federal laws and regulations concerning verification of employment eligibility and associated record keeping for employees hired to work in the United States. To this end, certain members of Columbia staff have been designated to assist the University in such compliance. There are I-9 Processing Centers on the Morningside Campus, at the Columbia University Medical Center, and at Lamont-Doherty Earth Observatory. For a list of specific locations, click here.

Requirements

Employee fully completes Section 1 of the I-9 and signs the form electronically, on or prior to the first day of employment. The first day of employment is the day the individual starts working, regardless of the appointment or hiring date.
Verification of employment eligibility by an authorized representative of Columbia University must be made within seventy-two (72) hours of employment. The law applies to both foreign nationals and United States citizens.

Addresses

The address on the I-9 does not necessarily need to match the address on the tax forms (W-4, W2, etc.).

Because we can verify employment prior to the actual start date the employee would indicate the address of where s/he is staying at that given point in time when completing that I-9.
Therefore, it can be a hotel address, the address of a friend’s house, etc. However, the address on the I-9 should never be the place of employment.

Fines

The University is subject to periodic audits by the US Federal Government and is subject to fines for incorrect I-9s. Fines range from $1,000–$10,000 and are incurred for mistakes like information omissions, completing an I-9 after the date of hire as well as more egregious offenses like not having an I-9 on file for an employee or hiring an illegal immigrant to work (meaning having constructive knowledge of a violation).

Re-Hires

An employee who leaves the University and is subsequently rehired, regardless of the length of separation, must complete a new Form I-9, unless the employee is being rehired within 3 years of the date the I-9 was originally completed and is still authorized to work pursuant to the same documentation. The “I-9 date of hire” in Section 2 of the I-9 Form must reflect the date of rehire as opposed to the employee's original hire date.

When an employee receives an adjusted date of hire to bridge his/her dates of service, payroll or personnel records must record the actual date of rehire.

Note: Because of the way the current University Payroll and Human Resources systems operate, part-time faculty, officers of research, and student officers are marked as “terminated” at the end of their current appointment even though they will be reappointed for the following academic year. As a matter of Columbia's policy, if such an officer is “terminated” at the end of one semester only to be rehired within the next academic year, this will not be considered a “termination” requiring a new I-9, as the individual's employment was not terminated for I-9 purposes.

I-9 Employment Eligibility & Verification Policy and Procedure Manual

For more information regarding I-9 processing, please refer to the I-9 Employment Eligibility & Verification Policy and Procedure Manual.

Process

For all University Officers, Support Staff, and Casual Employees:

The link to the online I-9 Form is available in the Forms/Useful Links box above. Employee fully completes Section 1 of Form I-9, and signs the form electronically, on or prior to the first day of employment. The first day of employment is the day the individual starts working, regardless of the appointment or hiring date.

The employee should review the list of acceptable documents for Section 2; the list is provided upon completion of Section 1 online.
Columbia University representative refers employee to the list of acceptable documents for Section 2 and advises him or her to present either one original document from List A OR one original document from List B and one original document from List C. In carrying out this step, the Columbia University representative does not tell the employee which documents to present or which documents are preferable.
Columbia University representative examines the original documents provided by the employee to verify that they are on the list of acceptable documents, that they appear genuine and relate to the employee, and that they evidence the employee's unexpired employment eligibility. Employee must be physically present when Section 2 is being completed. The Columbia University representative reviews Section 1 for accuracy and completeness and completes Section 2.
Columbia University representative fully completes Section 2 “Employer Review and Verification" with the pertinent information from the employee's documents, including document numbers, issuing authority and expiration dates, if any.
Columbia University representative electronically signs, dates and completes Section 2 "Employer Certification" including the date of employment.
Columbia University representative prints a copy of the complete I-9 for the employee's record.
Columbia University Human Resources reviews electronic I-9s and enters the employment eligibility dates in tickler system.

Required Steps & Field Descriptions

Step 1 – Employee Information and Verification

Name

Address

Date of Birth

Social Security Number

[Citizenship Status]

Employee Signature

Translator Certification (if applicable)*

* Note: Translator Certification is only required when appropriate (i.e., when the employee required a translator).

Step 2 – Employer Review and Verification

[List A Documents] OR

[List B Documents] AND [List C Documents]

Certification

Signature of Employer or Authorized Representative

Business or Organization Name

Step 3 – Updating and Verification

New Name

Date of rehire

[Documentation for] current employment eligibility

Signature of Employer or Authorized Representative