Use the Basic Pilot Program for all hiring.

 

 

 

Establish an internal training program, with annual updates, on how to manage completion of Form I-9 (Employee Eligibility Verification Form) and how to detect fraudulent use of documents in the I-9 process.

 

 

 

Permit the I-9 and Basic Pilot Program process to be conducted only by individuals who have received this training—and include a secondary review as part of each employee’s verification, to minimize the potential for a single individual to subvert the process.

 

 

 

Arrange for semi-annual I-9 audits by an external auditing firm or a trained employee not otherwise involved in the I-9 process.

 

 

 

Establish a self-reporting procedure for the reporting to ICE of any violations or discovered deficiencies.

 

 

 

Establish a protocol for responding to no-match letters received from the Social Security Administration.

 

 

 

Establish a Tip Line for employees to report activity relating to the employment of unauthorized aliens, and a protocol for responding to employee tips.

 

 

 

Establish and maintain safeguards against use of the verification process for unlawful discrimination.

 

 

 

Establish a protocol for assessing the adherence to the “best practices” guidelines by the company’s contractors/subcontractors.