Form I-9 Administrators
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.
I-9 Compliance Officers
Each school or unit has a designated I-9 Compliance Officer who establishes the business process for their school or unit that adheres to Northwestern’s Form I-9 Policy and ensures that employees are Form I-9 compliant. The I-9 Compliance Officer serves as Human Resources’ communication point regarding Form I-9 compliance for all employees (Faculty, staff, temp, and graduate and undergraduate students). Compliance Officers will maintain a current list of trained Section 2 Processors, ensure clear communication on process and requirements to new employees and Section 2 processors, and provide any assistance to employees 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. See Compliance and Notification timeline below. The Compliance Officer must submit verification of the employee’s I-9 completion to HR to remove non-compliance and/or rehire the employee.
Section 2 Processors
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 in Summer/Fall 2024 or have taken myHR Learn training course December 2024 or later are permitted to meet remotely with employees for Section 2.
Form I-9 Compliance and Notification Timeline
The following targeted communications will be sent from HR if Form I-9 Section 2 is not complete.
- First Business Day Following Day 1: Employee sent reminder to meet with Section 2 Processor to complete Form I-9.
- Second Business Day Following Day 1: Employee and Employee's Manager (or Directory of Faculty Affairs for Faculty hires) sent reminders to complete Form I-9.
- Fourth Business Day Following Day 1: Notification of non-compliance sent to Employee, Employee’s Manager or Director of Faculty Affairs (for Faculty), I-9 Compliance Officer, and the assigned HR Business Partner (for non-faculty or non-temp employee). The employee may not work. I-9 Compliance Officer must submit proof of Form I-9 completion to allow for the employee to return to work.
- Seventh Business Day Following Day 1: Employee will be temporarily terminated. NetID will begin 14-day expiration period. Notification of temporary termination sent to Employee, Employee’s Manager or Director of Faculty Affairs (for faculty), I-9 Compliance Officer, and the assigned HR Business Partner (for non-faculty or non-temp employee). I-9 Compliance Officer must submit proof of Form I-9 completion to rehire Employee.
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