Administrative Guideline - 2111b Verification of Employment Eligibility

In order to comply with Federal law the following verification of employment eligibility procedures will apply:


Form I-9 must be completed within three (3) business days of the date of the hire. If an individual is employed for less than three (3) days, the form must be completed before the end of the employee's first working day.

The following individuals do not need to complete Form I-9:

A.      persons hired before November 7, 1986

B.      persons who are employed by a contractor providing contract services

C.      persons who are independent contractors

The Director of Human Resources is also responsible for re-verifying employment eligibility of employees whose employment eligibility documents carry an expiration date.


All employees hired after November 6, 1986, will need to provide a document or documents that establish identity and employment eligibility. The following lists identify acceptable documents:


Documents that establish identity and employment eligibility:

A.      United States passport

B.      certificate of United States Citizenship (INS Form N-560 or N-561)

C.      Certificate of Naturalization (INS Form N-550 or N-570)

D.      unexpired foreign passport which:

contains an unexpired stamp which reads "Processed for I-551. Temporary Evidence of Lawful Admission for permanent residence. Valid until ________________________. Employment authorized;" or
has attached thereto a Form I-94 bearing the same name as the passport and containing an employment authorization stamp, so long as the period of endorsement has not yet expired and the proposed employment is not in conflict with any restrictions or limitations identified on the Form I-94
E.       Alien Registration Receipt Card (INS Form I-151) or Resident Alien Card (INS Form I-551), provided that it contains a photograph of the bearer

F.       Temporary Resident Card (INS Form I-688)

G.      Employment Authorization Card (INS Form I-688A)


Documents that establish identity:

A.      for individuals sixteen (16) years of age or older:

  • State-issued driver's license or State-issued identification card containing a photograph. If the driver's license or identification card does not contain a photograph, identifying information should be included, such as name, date of birth, sex, height, color of eyes, and address.
  • school identification card with a photograph
  • voter's registration card
  • United States Military card or draft record
  • identification card issued by Federal, State, or local government agencies
  • military dependent's identification card
  • Native American tribal documents
  • United States Coast Guard Merchant Mariner Card
  • driver's license issued by a Canadian government authority

B.      for individuals under age sixteen (16) who are unable to produce one (1) of the documents listed above:

  • school record or report card
  • clinic doctor or hospital record
  • day care or nursery school record


Documents that establish eligibility:

A.      Social Security number card, other than one which has printed on its face "not valid for employment purposes"

NOTE: This must be a card issued by the Social Security Administration; a facsimile (such as a metal or plastic reproduction that people can buy) is not acceptable.

  • an original or certified copy of a birth certificate issued by a State, county, or municipal authority bearing an official seal
  • unexpired INS employment authorization
  • unexpired reentry permit (INS Form I-327)
  • unexpired Refugee Travel Document (INS Form I-571)
  • Certification of Birth issued by the Department of State (Form FS-545)
  • Certification of Birth Abroad issued by the Department of State (Form DS-1350)
  • United States Citizen Identification Card (INS Form I-197)
  • Native American tribal document
  • identification card for use of Resident Citizen in the United States (INS Form I-179)


The Director of Human Resources must retain Form I-9 for three (3) years or for one (1) year past the end of the employment of the individual, whichever is longer. Such forms will be retained in a separate file and shall be considered to be confidential and used only for employment eligibility verification purposes.


U.S. Immigration and Naturalization Service (INS) or Department of Labor (DOL) Officers are required to give employers three (3) days advance notice before an inspection. The Director of Human Resources will assemble the I-9 forms in preparation for the inspection. Failure to provide the I-9 forms could result in civil monetary penalties for each employee for whom the form was not completed, retained, or presented.


The Board will retain a photo copy of either the employee's driver's license or passport showing the employee's identity and valid social security number.

P.L. 99-603

Immigration Reform and Control Act of 1986