It is Northwestern’s responsibility to ensure that all its US employees are authorized to work in the United States. If a new employee’s Form I-9 is not complete by the deadline, Northwestern is out of compliance with federal law and is subject to fines and/or loss of federal contracts.
Each School/Unit has a designated I-9 Compliance Officer who is responsible for monitoring Form I-9 compliance for its employees in adherence to Northwestern’s Form I-9 Policy. Compliance Officers will maintain a current list of trained Section 2 Processors, ensure clear communication on the Form I-9 requirement for new employees, and provide assistance to employees and Section 2 Processors regarding their School/Unit’s compliance procedures.
When Form I-9 is not completed by the deadline, the I-9 Compliance Officer of the employee’s school or unit is notified that Northwestern University is out of compliance. The Compliance Officer, the employee’s supervisor, or the employee must submit verification of Form I-9 completion to HR to remove non-compliance and/or rehire the employee. See Compliance and Notification timeline below.
Section 2 Processors can be department administrators, program assistants, hiring managers, or anyone else that assists in the onboarding process for new employees. Section 2 Processors can search for employees in Northwestern's I-9 Service Center to determine whether the employee has completed their Form I-9, meet with new employees for document verification and completion of Section 2, and complete Section 3 for rehires as needed. Section 2 Processors must submit HR Systems General Access Form, (select I-9 Section 2 Authorizer role in section 4) and successfully complete Form I-9 Training in myHR Learn. Only Section 2 Processors who completed the Remote Meeting supplemental training or have taken myHR Learn training course December 2024 or later are permitted to meet remotely with employees for Section 2.
The following targeted communications will be sent from HR if Form I-9 Section 2 is not complete.