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Worksite Enforcement

Countryside Health Care of Milford partners with ICE

Left: David Consigli, Board Chairman, Countryside Healthcare of Milford - Right: Bruce M. Foucart, special agent in charge of HSI Boston
Left: David Consigli, Board Chairman, Countryside Healthcare of Milford - Right: Bruce M. Foucart, special agent in charge of HSI Boston
MILFORD, Mass. — Countryside Health Care of Milford has followed the town’s lead by partnering with U.S. Immigration and Customs Enforcement's (ICE) employment compliance program, IMAGE, or "ICE Mutual Agreement between Government and Employers."

The Town of Milford partnered with ICE in August to protect the integrity of their workforce, becoming the first municipality in New England with this distinction. Countryside Health Care of Milford took notice, and has also partnered with ICE.

"It is my pleasure to welcome Countryside Health Care of Milford to our IMAGE family," said Bruce M. Foucart, special agent in charge of ICE's Homeland Security Investigations (HSI) Boston. "When employers make a commitment to hire and maintain a lawful workforce, it's good not only for their business, but for the community and the nation. ICE actively pursues partnership with those employers that want to comply with employment eligibility verification requirements, including local governments throughout New England. By partnering with ICE, employers receive invaluable training and the tools necessary to ensure a lawful workforce. I am hopeful that other municipalities and companies will follow the actions of Countryside and the Town of Milford."

Countryside Health Care of Milford is a non-profit, municipal, skilled nursing and rehabilitation facility, reliably providing care to the greater Milford elders since 1825. Countryside Health Care of Milford offers a continuum of care that addresses all long-term care and short-term rehabilitation needs. The mission of Countryside Health Care of Milford is to provide resident-focused, comprehensive and interdisciplinary health care services within a secure and caring environment. They accomplish their organizational mission in an atmosphere of progressive management, continuous quality improvement and high ethical standards.

IMAGE program

Undocumented workers create vulnerabilities in today's marketplace by presenting false documents to gain employment, completing applications for fraudulent benefits and stealing identities of legal United States workers. To combat this, ICE initiated the IMAGE program in 2006. As part of the IMAGE program, ICE provides employers with education and training on proper hiring procedures, including use of employment screening tools such as E-Verify. IMAGE certified employers also undergo an audit of their I-9 forms to ensure current employees are eligible to work in the United States.

Employers that are certified with ICE through the IMAGE program pledge to maintain a secure and stable workforce and curtail the employment of unauthorized workers through outreach and education. ICE recently revamped IMAGE, simplifying program requirements.


All IMAGE members must participate in the U.S. Department of Homeland Security (DHS) E-Verify employment eligibility verification program. Through this program, employers can verify that newly hired employees are eligible to work in the United States. This Internet-based system is available throughout the nation and is free to employers. It provides an automated link to the Social Security Administration database and DHS immigration records.

HSI worksite investigations

Effective worksite enforcement plays an important role in the fight against illegal immigration. HSI has developed a comprehensive worksite enforcement strategy that promotes national security, protects critical infrastructure and targets employers who violate employment laws or engage in abuse or exploitation of workers.

An effective worksite enforcement strategy must address both employers who knowingly hire illegal workers, as well as the workers themselves. In worksite cases, HSI investigators adhere to high investigative standards, including the following:

  • HSI will look for evidence of the mistreatment of workers, along with evidence of trafficking, smuggling, harboring, visa fraud, identification document fraud, money laundering and other such criminal conduct; and
  • HSI will obtain indictments, criminal arrests or search warrants, or a commitment from a U.S. attorney's office to prosecute the targeted employer before arresting employees for civil immigration violations at a worksite.

HSI also works with the private sector to educate employers about their responsibilities to hire only authorized workers and how to accurately verify employment eligibility, through such tools as the IMAGE program.

I-9 audits

Employers are required to complete and retain a Form I-9 for each individual they hire for employment in the United States. This form requires employers to review and record the individual's identity and employment eligibility document(s) and determine whether the document(s) reasonably appear to be genuine and related to the individual. Additionally, an employer must ensure that the employee provides certain information regarding his or her eligibility to work, on the Form I-9.

"HSI will continue to hold employers accountable for hiring and maintaining a legal workforce," added Foucart. "We encourage employers to take the employment verification process seriously, as we expand the number of audits we are conducting throughout New England each year. HSI will continue to focus its attention on employers that are knowingly employing illegal workers."

Employers – non-profits, companies and municipalities – in the New England area that are interested in the IMAGE program can call HSI Boston at 617-565-6286, or visit www.ICE.gov/IMAGE.