Return to on-site work

I-9 completion requirements change

Updated September 1, 2021


On March 19, 2020 the Department of Homeland Security (DHS) relaxed rules regarding the physical presence requirements associated with Employment Eligibility Verification (Form I-9). This exception is in place until normal University operations resume on September 13, 2021.

When remote review is allowed

Until September 13, 2021, I-9 coordinators may inspect Section 2 identity and employment authorization documents remotely over video (e.g., Zoom or Teams meeting) when new hires are not expected to physically come into the workplace because it is operating remotely due to COVID-19 precautions.

When inspecting Section 2 documents remotely, I-9 coordinators must:

  • Inspect documents within three business days for purposes of completing Section 2 by viewing documents over video. If the employee’s WA State driver license expired on or after March 1, 2020, refer to additional guidance under the driver license renewal date extension section below.
  • Upon inspection, check the box under “Document presented is a receipt”
  • Maintain written documentation of the remote onboarding and telework policy for each employee.
Once the exception for physical review has expired

By September 16, 2021 for staff and October 4 for student employees, I-9 Coordinators will need to meet with each active, remotely-onboarded employee to inspect their employment verification documents in person and complete the Amend Form I-9 business process to update Section 2 of the employee’s Form I-9. For student employees with an anticipated return to on-site work date of September 29, in-person review is required within three business days.

To identify remotely-onboarded employees:

  1. In Workday, enter R0669 Audit Form I-9 Receipts in the search field.
  2. In the Supervisory Organization field, select the “My Organizations” then select the Sup Orgs you support. Tip: To quickly select all the Sup Orgs you support, select Ctrl+A and then the space bar.
  3. In the Start Date field, enter 3/26/2020.
  4. Select OK.

Remotely onboarded employees may have been terminated, may not be working at a UW worksite due to COVID-19 restrictions and precautions, or may have been hired as remote employees. The table below describes these scenarios and how to respond.

Scenario Action required Process
Employee is no longer employed at UW Attach to the existing Form I-9 a statement explaining why amendments to the Form I-9 cannot be made. Follow the steps below to initiate the Amend Form I-9 process but in lieu of steps 5 – 8 below, enter in the Reason for Changes field the text “In-person review of identity and employment verification documents was not completed because the employee is no longer employed at the University of Washington.”

Note: The form can only be amended if the I-9 process was previously completed. Contact your HCM Service Partner for assistance.

Active employee was onboarded remotely, is not located in Washington state and is not employed at an out-of-state UW worksite The employee is required to complete in-person review with the assistance of an authorized representative as described in the Complete Form I-9 Remote Hire process guide.
  1. Review the Complete Form I-9 – Remote Hire process
  2. Ask the employee to follow the instructions found in the Employee section of the ISC guide.
  3. Once information is received in the mail, complete the Amend Form I-9 process as described below.
Active employee was onboarded remotely and is working remotely in state or works at another UW work site out-of-state The employee is required to travel to a UW work location to meet with an I-9 Coordinator for in-person review.
  1. Inform the employee of the requirement to meet in-person with an I-9 Coordinator.
  2. Complete in-person review and the Amend Form I-9 process as described below.

To amend the Form I-9 for active employees remotely onboarded

  1. With the R0669 Audit Form I-9 Receipts report open in Workday (don’t download to Excel), hover over the employee’s name and select the Related Actions icon that appears after the name (it looks like a twinkie).
  2. In the pop-up window, select View Form I-9 from the Personal data tab. Tip: Right-click to View Form I-9 then select See in New Tab to keep the original report open for easier reference.
  3. Select the Amend Form button.
  4. At the top of the page, select Section 2. Employer or Authorized Representative Review and Verification.
  5. De-select the Document presented is a receipt checkbox.
  6. Verify that the Expiration Date field is accurate.
  7. In the Overdue Reason field, select Other.
  8. In the Overdue Reasons Other field, enter COVID-19.
  9. In the Reasons for changes to Section 2 field, enter “Documents physically examined on MM/DD/YYYY” where the date is the day you physically inspected the employment verification documents.
  10. Select Submit.

For more information about the transactional details in Workday, please visit the I-9 user guide.

Expired driver license acceptability for List B documents

Consistent with Governor Inslee’s Proclamation 20-41, if the employee’s WA State driver license expired on or after March 1, 2020, the document expiration date is temporarily extended and the document is acceptable as a List B document for Form I-9. As of January 19, 2021 the extension is in effect until the end of the COVID-19 emergency or until rescinded.

For expired driver license review, the I-9 coordinator must:

  • Enter the document’s expiration date in Section 2 and enter “COVID-19 EXT” in the Additional Information field.
  • Attach a copy of the Department of Licensing’s webpage or other notice indicating that expiration dates have been extended.

If the employee’s driver license expired on or after March 1, 2020 and is from a state other than Washington, I-9 coordinators must check whether that state has extended the document expiration date due to COVID-19 by checking that state’s Motor Vehicle Administration or Department of Motor Vehicle’s website prior to making the additional notations described.