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IMPORTANT: Please Review Your Department’s Compliance with I-9 Employment Eligibility Verification

Dear I-9 Preparers,

This is a reminder that, in accordance with the provisions of the federal Immigration Reform and Control Act of 1986, Rutgers University is required to verify employment eligibility for all new hires at the University. Under the guidelines set forth by the United States Citizenship and Immigration Services, the first section of the employee’s I-9 must be completed in the Guardian system on or before the end of the employee’s first day of work, and Section II must be completed no later than the end of the 3rd work day.

University Human Resources (UHR) runs a daily report to determine the University’s level of compliance with federal employment eligibility verification guidelines. At this time, many departments across the University have employees who are out of compliance with the deadlines for I-9 employment eligibility verification, exposing these departments to significant risk of substantial financial penalties for failing to comply with this federal mandate.

Under federal guidelines, if an employee does not have section 1 of the I-9 completed on or before the end of the first day of work and a compliant I-9 in the Guardian system with the status of “Approved” by the end of the employee’s 3rd day of work, he/she should not continue to work. In order to better comply with the I-9 employee eligibility verification guidelines, UHR will begin to terminate employee records in the HCM system for employees who are not in compliance with federal employment eligibility rules. Please keep in mind if an employee is terminated this will affect their benefits, accrued time, pension and any other benefits related to their employment here at Rutgers University.

To ensure your department’s compliance with the U.S. government’s I-9 process, please consider the following tips:

  • I-9 Completion Deadlines: Section I of the I-9 must be completed on or before the end of the first day of work (note that this deadline applies regardless of whether or not the employee has an active record in the University’s HCM / Payroll system). Section II must be completed no later than the end of the 3rd work day. These deadlines are set by the Federal government and are extremely important for compliance. If the employee does not have a compliant I-9 with the status of Approved by the end of the 3rd work day, he/she should not continue to work.
  • Employee ID Number: The new employee’s EmplID in PeopleSoft must be inputted into the Guardian system. This assists UHR with tracking compliance and reporting by allowing us to index employees via this unique identifier. If you do not know the EmplID when completing the employee’s I-9, please remember to go back and enter it once you do. As a general rule, you should try to have the employee’s new hire paperwork collected and submitted to HCM prior to the employee’s first day of work to create an easier onboarding experience and guarantee that the employee’s first paycheck is received in a timely manner.
  • Terminations: If the employee is being terminated in HCM and does not hold another active appointment at the University, the I-9 must also be terminated with the same effective date that was entered in the PeopleSoft system. If you are unsure if the employee has another active position, please contact the HR Compliance Coordinator, Cindy Hendricks at 848-932-3893 or by email at for assistance.
  • Transfers: When an employee is transferring from their current department to a new department due to an internal transfer or acceptance of a new position at the University, please contact the HR Compliance Coordinator, Cindy Hendricks at 848-932-3893 or by email at, advising of the transfer so that the system can be updated to match the I-9 location with the employee’s assigned department.
  • Class 9 Employees: Individuals with a Class 9 designation do not have an employer / employee relationship with Rutgers University, and are typically associated with the University as graduate or post-doctoral fellows. Individuals in this class designation should not have an I-9 created in the Guardian system. However, if the person has another class appointment, then the I-9 is required for that position.
  • Re-Verifications: For foreign nationals who are authorized to work in the United States on a work visa: when an employee’s work authorization has expired, the I-9 record needs to be updated with new approved documents or with the receipt notice showing the employee timely filed for an extension on or before the date that the current work authorization expires. If the record is not updated by the time the work authorization expires, the employee will no longer be eligible to work following the expiration of his or her work authorization.

Thank you in advance for your cooperation with the federal I-9 employment eligibility verification guidelines and other compliance initiatives at Rutgers.


Vivian Fernández
Senior Vice President for Human Resources and Organizational Effectiveness