IMAGE

ICE Mutual Agreement between Government and Employers

U.S. Immigration and Customs Enforcement (ICE) is responsible for enforcing the nation’s immigration and customs laws. One known vulnerability is the presence of undocumented workers who have secured jobs by fraudulent means, including presentation of false documents, completion of fraudulent benefit applications and theft of identities. To combat unlawful employment and reduce vulnerabilities that help illegal aliens gain such employment, the Department of Homeland Security (DHS) recently introduced the ICE Mutual Agreement between Government and Employers (IMAGE) program. The goal is to assist employers in targeted sectors to develop a more secure and stable workforce and to enhance fraudulent document awareness through education and training.

IMAGE Program

By voluntarily participating in the IMAGE program, companies can reduce unauthorized employment and the use of fraudulent identity documents. As part of IMAGE, ICE and U.S. Citizenship and Immigration Services (USCIS) will provide education and training on proper hiring procedures, fraudulent document detection, use of the Basic Pilot Employment Verification Program and anti-discrimination procedures. Employers seeking to participate in IMAGE must first agree to

• Submit to an I-9 audit by ICE, and
• To ensure the accuracy of their wage reporting, verify the Social Security numbers of their existing labor forces, utilizing the Social Security Number Verification System (SSNVS).

Upon enrollment and implementation of DHS’s best hiring practices, program participants will be deemed “IMAGE Certified”-a distinction DHS believes will become an industry standard. The results of the IMAGE program and participation in IMAGE by partners in industry will serve to guide DHS in shaping future worksite enforcement policy and legislation.

All IMAGE participants gain membership to DHS’s Basic Pilot Employment Verification Program, administered by USCIS. Through this employee authorization verification program, employers can verify that newly hired employees are eligible to work in the United States. This Internet-based system is available in all 50 states and is currently free to employers. It provides an automated link to the Social Security Administration database and DHS immigration records. To sign up for participation in the Basic Pilot Employment Verification Program, visit the registration Web site https://www.vis-dhs.com/EmployerRegistration/.

Best Hiring Practices

	Use the Basic Pilot Employment Verification 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), how to detect fraudulent use of documents in the I-9 process, and how to use the Basic Pilot Employment Verification Program.
	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 annual I-9 audits by an external auditing firm or a trained employee not otherwise involved in the I-9 and electronic verification process.
	Establish a self-reporting procedure for reporting to ICE 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.
	Submit an annual report to ICE to track results and assess the effect of participation in the IMAGE program.

For more information on the IMAGE Program, please visit the IMAGE FAQ page. You may request an information packet via the IMAGE Information Packet Request form.