The I-9 and E-Verify Blog (02/21/12) Valentine Brown

Regardless of the reason for a voluntary audit, employers need to think through the entire process and all of the attendant results and consequences before conducting a voluntary Form I-9 audit. Employers must determine ahead of time what policies and procedures will be followed to respond to the results of the audit. The first task is to identify the worst possible outcomes of an audit based upon the employer’s individual company characteristics, preferably by working with experienced audit counsel who can assist in developing the worst case scenario list considered in the article.

The most common worst-case scenario that employers encounter during an audit is when Forms I-9 contain errors and the human resource department has to request assistance and possibly documents from employees to make corrections. Another troubling result of an internal audit is when fraudulent I-9 documents are identified. The final worst-case scenario cited in the article is when undocumented employees are identified during the I-9 audit.