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    Important Guidance For Employers Conducting Internal Form I-9 Audits

    Posted by Bailey Wong on Fri, December 16, 2016

    To ensure ongoing compliance with the Immigration and Nationality Act (INA), employers are voluntarily conducting internal audits of Forms I-9 though they are not required by law. 

    "Guidance for Employers Conducting Internal Employment Eligibility Verification Form I-9 Audits" goes over the who, what, when, and why of Form I-9 Audits in a very detailed and easily understood manner. Read below for a brief overview.shutterstock_300476885.jpg


    Form I-9 Audits are done to verify the data and information on file is true and every employee is working legally. If multiple discrepancies and errors are found, it may be necessary to retrain the Human Resources department on the right documentation and what sections must be filled out. 


    The Form I-9 Audit is done to verify employment eligibility and to update/fix any deficiencies the employee or employer may have made at the time of completing the I-9. The attached guidance goes over every scenario of deficiencies and how to fix them. For example,

    "An employer may only correct errors made in Section 2 or Section 3 of the Form I-9. The best way to correct the form is to:

    • Draw a line through the incorrect information;
    • Enter the correct or omitted information; and
    • Initial and date the correction or omitted information."


    To prevent any penalties for violating the employer sanctions provision and the anti-discrimination provision of the INA, internal audits should not be performed due to race, religion, or citizenship of any employee. Language should also not be the basis for an audit, and if there are employees who need help with any paperwork deficiencies, a translator or preparer is allowed. 


    An employer choosing when to conduct an audit must be conscious of events and incidents leading up to the audit as it may be perceived as discriminatory.  

    Tags: Airport, Fixed Base Operator, Cargo Operator, Aircraft Operator, Corporate Flight Department, Operation, Blog, Maintenance Operator, Flight Training Provider

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    I got a gold star from the TSA inspector who inspected our flight school last year, but that's because my company paid me ground time to research AFSP and make a new AFSP student checklist. Even so, I had one (of 3) AFSP applicants rejected initially due to some of the errors you talk about in the blog. I just wanted to shoot you an email and say thanks for making the effort to clarify the process for all of us. I get the impression that there are a lot of the CFIs out there in the small flight schools who haven't got a clue about the AFSP process. So go ahead and feel good about yourself for helping all us lost boys stay in business and out of the trouble.


    - The CFI