Eligibility To Work: Form I-9

Overview

Columbia University is required to comply with federal laws and regulations concerning verification of identity and employment eligibility and associated recordkeeping for employees hired to work in the United States. This policy applies to all new hires and rehires. To this end, certain members of Columbia staff have been designated to assist the University in such compliance.

Columbia uses an online system, I-9 Management (provided by Equifax), to collect and process the required documentation from new hires to comply with these laws. There are I-9 Service Centers on the Morningside campus, Manhattanville, the Columbia University Medical Center, and at Lamont-Doherty Earth Observatory.

 

CU I-9 Service Centers

Morningside Campus

205 Kent Hall (Morningside Campus)

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Studebaker (in Manhattanville)
622 West 132nd Street - 4th Floor

Lamont-Doherty Earth Observatory

 
Lamont-Doherty Earth Observatory
61 Route 9W
Administration Building, Room 208
Palisades, NY 10964
 

Medical Center

CUMC Human Resources - Black Building, Room 101

Medicine - PH 8 West Room 862

Mailman School of Public Health - 600 W. 168th, 7th Floor

Pediatrics - Children's Hospital CHC Room 104

Surgery - PH 14, Room 105

Psychiatry - 1051 Riverside Drive, Unit 5

OB/GYN - PH 16021

College of Dental Medicine - P&S 7th Floor

Neurology - 710 W. 168th, 9th Floor room 100

 

All employees must complete a Form I-9 within three business days of the first day of employment. The first day of employment is the day the individual starts working, regardless of the appointment or hiring date. 

Requirements & Process

New Hires

  • 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 three (3) business days of employment. The law applies to both foreign nationals and United States citizens.
  • The address on the I-9 does not necessarily need to match the address on the tax forms (W-4, W2, etc.).  The employee should indicate the address of where s/he is staying at that point in time when completing the 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.

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.

New Form I-9s are required for all rehires if any one of the following is true:

  1. The employee completed his or her original Form I-9 more than three years ago.
  2. The employee completed the original Form I-9 less than three years ago but is no longer eligible to work under the original documents presented.
  3. The employee completed his or her original Form I-9 on paper.
  4. Before determining that a new I-9 is not required, the original I-9 should be reviewed to confirm that the work eligibility has not expired for the individual.
  5. All rehires, regardless of whether or not they require a completely new I-9, must go to one of the I-9 Service Centers to complete Section 3 of the Form I-9—reverification—in order to update their hire date.

Process

For all Faculty & Staff:

  1. Direct the new hire to complete Section 1 of the online I-9 Form and sign 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. Please note: expired documents are not acceptable by order of the Department of Homeland Security.

    • Note: For Nonimmigrant Personnel, the International Students and Scholars Office (ISSO) assists schools/departments of the University that wish to bring nonimmigrant personnel to Columbia in positions of academic teaching and research. Please see the ISSO Handbook for Departmental Managers for more information.

  2. Ensure that the employee goes to one of the I-9 Service Centers and completes section 2 with a Columbia University representative within three business days of the first day of employment. The Columbia University representative refers the 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.

  3. 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.

  4. 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.

  5. Columbia University representative electronically signs, dates and completes Section 2 "Employer Certification" including the date of employment.

On the very rare occasion when a paper I-9 must be completed, please ensure that you are using the most current version of the form.  If you require a paper I-9, you can print a copy of the Form I-9 directly from the Department of Homeland Security website.

Fines

The University is subject to periodic audits by the US Federal Government and is subject to fines for incorrect I-9s. Fines could be 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).