COMPLIANCE OVERVIEW

							                          COMPLIANCE OVERVIEW
  Department of Human Resources, Office of Faculty/Professional Affairs and Office of
                                 General Counsel


OFFICE/DEPT.:                    Department     of   Human     Resources, Office  of
                                 Faculty/Professional Affairs, and Office of General
                                 Counsel

COMPLIANCE FUNCTION:             Form I-9 Requirements

INDIVIDUALS RESPONSIBLE:         Jorge Pineda - HR, Medical
                                 Mary Eymann-Reyes, Maria Vicente - HR, Gables/RMSAS
                                 Elizabeth Gould - F&P Affairs, Medical
                                 Bill Tallman - F&P Affairs, Gables/RSMAS
                                 Kyle Lewis Paige, Esq. - Office of General Counsel

DATE OF REPORT:                  September 15, 2003

SOURCE OF REQUIREMENTS:          Federal – Immigration and Nationality Act (8 U.S.C. 274a
                                 et seq.)

DETAILS OF COMPLIANCE:           Section 274a of the Immigration and Nationality Act
                                 prohibits the employment of any person who is not
                                 authorized to work in the United States, and establishes the
                                 procedures whereby an employer verifies employment
                                 eligibility. Section 274a requires employers to complete,
                                 within three (3) business days of hire, a Form I-9,
                                 Employment Eligibility Verification Form, for every
                                 employee hired after 1986, including U.S. citizens and
                                 nationals. The University ensures that the employee
                                 completes Section 1 and examines the original documents
                                 produced by the employee that evidence the employee’s
                                 identity and employment eligibility. Once the University
                                 has verified the authenticity of the documentation and the
                                 eligibility of the employee to work, the employer must
                                 complete Section 2 of the Form I-9.

TRAINING:                        Internal training sessions are conducted every year for
                                 those individuals responsible for I-9 compliance. A
                                 Handbook for Employers, prepared by the federal
                                 government, which outlines the procedures relating to the I-
                                 9, is given to every individual responsible for I-9
                                 compliance.
QUALITY CONTROL:        Each unit charged with I-9 compliance is responsible for
                        monitoring such compliance. The Office of General
                        Counsel provides oversight on the process and guidance on
                        particular I-9 issues or problems. Also, the Office of
                        General Counsel conducts an internal audit approximately
                        every three years.

DOCUMENTATION EFFORT:   The Form I-9 is retained in the applicable human resources
                        unit for three (3) years after the date employment begins or
                        one (1) year after the employee’s employment is
                        terminated, whichever is later. The Form I-9 must be
                        available for inspection within three (3) days of request by
                        the BCIS, the Office of Special Counsel or the Department
                        of Labor.

ASSESSMENT:             Compliance with the Form I-9 requirements is subject to
                        audit by the Bureau of Citizenship and Immigration
                        Services (BCIS). An external audit has never been
                        conducted by BCIS. The Office of General Counsel
                        conducts internal audits approximately every three years.