Frequently Asked Questions

The following lists questions by category that are specific to the University or are more commonly asked. In addition to this resource, I-9 Central has an extensive Q&A.

Completing Form I-9

Q: We onboard so many employees at one time, can I speed up the process by just summarizing the Form I-9 instructions and then have the employee complete Section 1/page 7?
A: No. You must make available to the employee the complete instructions to the form and the Lists of Acceptable Documents.
Q: Does Form I-9 need to be completed in a specific color of ink?
A: No. Form I-9 does not need to be completed in a specific color of ink.  However, the information written on the form must be readable for the entire retention period of the form.  The preferred medium is black or blue ink. *
Q: Should pages 7 and 8 of the I-9, the pages completed by the employee and employer, be copied separately or as a two-sided form?
A: The two page Form I-9 (pages 7 & 8), should be copied or printed as a two-sided form.

Section 1 - Employee Information & Attestation

Q: Can I have a new hire complete Section 1 of Form I-9 prior to their first day of work?
A: Yes. Once the individual has accepted the job offer, they can complete Section 1 of Form I-9. Section 1 of Form I-9 must be completed no later than the first day of employment.
Q: What address should employees use in Section 1?
A: Employees should provide the address where they currently live.
Q: Is it acceptable for employees to use a P.O. Box as their address in Section 1?
A: No, employees may not use P.O. Boxes as their address on Form I-9. The employee must put down the actual location of their residence. If the employee’s residence doesn’t have a house number and street name, he/she should write a description of the location.
Q: Is it mandatory for an employee to provide their Social Security number?
A: Providing a Social Security number is voluntary, unless the employee will be E-Verified, in that case, they must provide their Social Security number.
Q: Is it mandatory that employees provide their email address and telephone number in Section 1 of Form I-9?
A: No. Employees may provide their email address and telephone number. This is voluntary.

Section 2 - Employer Review & Verification

Q: How much time does an employer have to complete Section 2 of Form I-9?
A: Section 2 of Form I-9 must be completed and signed within three business days of the date of hire of the employee (the hire date means the first day of work for pay). For example, if your employee began work for pay on Monday, you must complete Section 2 by Thursday of that week. If the job lasts less than three days, you must complete Section 2 no later than the first day of work for pay.*
Q: What should be used as the employer’s business name and address in the Certification portion of Section 2?
A: Employer's Business or Organization Name - The Pennsylvania State University
Employer's Business or Organization Address – The office address of the individual signing the Form I-9 on behalf of Penn State
Q: To save time, can I prefill my information as the Employer in the Certification portion of Section 2?
A: Yes. The following may be may be prefilled:
  • Title of Employer Representative
  • Last Name & First Name
  • Employer's Business Name
  • Employer's Business Address
  • City or Town, State and Zip Code

Questions About Documents

Q: What is my responsibility as the employer’s representative regarding documents?
A: You must ensure that any document the employee presents is on the Lists of Acceptable Documents or is an acceptable receipt. You must accept any document(s) from the Lists of Acceptable Documents presented by the individual that reasonably appear on their face to be genuine and to relate to the person presenting them. If the document(s) do not reasonably appear on their face to be genuine or relate to the person presenting them, you must not accept them.*
Q: May I accept a photocopy of a document presented by an employee or view documents via webcam?
A: No. Employees must present original documents in person. The only exception is that an employee may present a certified copy of a birth certificate in person.
Q: May I accept an expired document?
A: No. Expired documents are no longer acceptable for Form I-9. However, you may accept Employment Authorization Documents (Forms I-766) and Permanent Resident Cards (Forms I-551) that appear to be expired on their face, but have been extended by USCIS. *
Q: Can I tell a new hire which documents I’d like them to present to verify identify and work authorization for I-9 purposes?
A: No. It’s up to the employee to choose which document(s) he/she wants to present from the Lists of the Acceptable Documents. You must accept any document (from List A) or combination of documents (one from List B and one from List C) that reasonably appear on their face to be genuine and relate to the person presenting them. If the employee will be E-Verified and they choose to present a List B document, the document must have a photograph.*
Q: When I review an employee’s identity and employment authorization documents, should I make copies of them?
A: Yes, it’s a Penn State practice to make copies of these documents, so we must do so for all employees. Photocopying documents does not relieve you of your obligation to fully complete Section 2 of Form I-9, nor is it an acceptable substitute for proper completion of Form I-9 in general.*
Q: If an employee enters an Alien Number or Admission Number when completing Section 1 of Form I-9, may I ask to see a document with that number?
A: No. Although it is your responsibility as an employer to ensure that your employees fully complete Section 1 at the time employment begins, the employee is not required to present a document to complete this section. When you complete Section 2, you may not ask to see a document with the employee’s Alien Number or Admission Number or otherwise specify which document(s) an employee may present.*
Q: An employee has attested to being a U.S. citizen or U.S. noncitizen national on Section 1 of Form I-9, but has presented me with Form I-551, Permanent Resident Card, or "green card.” Another employee has attested to being a lawful permanent resident but has presented a U.S. passport. Should I accept these documents?
A: In these situations, you should first ensure that the employee understood and properly completed the Section 1 attestation of status. If the employee made a mistake and corrects the attestation, he or she should initial and date the correction, or complete a new Form I-9. If the employee confirms the accuracy of his or her initial attestation, you should not accept a "green card" from a U.S. citizen or a U.S. passport from an alien. Although you are not expected to a be an immigration law expert, both documents in question are inconsistent with the status attested to and are, therefore, not documents that reasonably relate to the person presenting them.*
Q: My new employee presented two documents to complete Form I-9, each containing a different last name. One document matches the name she entered in Section 1. The employee explained that she had just gotten married and changed her last name, but had not yet change the name on the other document. Can I accept the document with the different name?
A: You may accept a document with a different name than the name entered in Section 1 provided that you resolve the question of whether the document reasonably relates to the employee. You may also wish to attach a brief memo to Form I-9 stating the reason for the name discrepancy, along with any supporting documentation the employee provides. An employee may provide documentation to support his or her name change, but is not required to do so. If, however, you determine that the document with a different name does not reasonably appear to be genuine and relate to the person presenting it, you may ask the individual to provide other documents from the Lists of Acceptable Documents.*
Q: Do all documents need to be reverified when they expire?
A: No. Employers should not reverify:
  • U.S. citizens
  • Lawful permanent residents who presented a Permanent Resident Card (Form I-551) for Section 2
  • List B documents

List of Acceptable Documents

Q: How do I find the document number on a Permanent Resident Card (Form I-551)?
A: The document number is 13 alphanumeric characters (3 letters and 10 numbers). This is a different number than the USCIS# or A#. The document number can be found on the back of the newest version of the Permanent Resident card and on the front of the previous version.
Q: What should be input on the IBIS Foreign National Data Screen for a Permanent Resident who presents a Permanent Resident Card (Form I-551)?
A: Input the following on the Foreign National Data screen:
  • Visa Type: NA
  • Perm Res: U (unconditional)
  • Perm Res End: 12/31/2099
  • Work Appr: Y
The unconditional coding indicates that the individual does not need to be reverified as their work authorization does not expire.
Q: Some employees have presented Social Security Administration printouts with their name, Social Security number, date of birth, and their parents’ names as proof of employment authorization. Are these printouts acceptable as a List C document?
A: No. Only a person’s Social Security card or a receipt for a replacement card issued by SSA is acceptable.*
Q: Is an unsigned Social Security card valid?
A: Yes. A signature on the card is not required for the card to be valid. You may accept an unsigned Social Security card as long as the card reasonably appears to be genuine and relate to the person presenting it.*
Q: Is a laminated Social Security card valid?
A: It depends. If the card states on the back “not valid if laminated” then the laminated Social Security card is not valid. The Social Security Administration (SSA) advises cardholders not to laminate Social Security cards. Metal or plastic reproductions of Social Security cards are not acceptable for Form I-9 purposes.*
Q: Is the Certificate of Naturalization an acceptable Form I-9 document?
A:Yes. The Certificate of Naturalization (Form N-550 or N-570) is an acceptable List C, #8 employment authorization document issued by the Department of Homeland Security.*

Retention of Form I-9

Q: What do I need to retain for each employee?
A: Only the pages of the Form I-9 on which you/the employer or the employee enter data must be retained. Only retain the two-sided Form I-9 (pages 7 & 8) and copies of the supporting document(s) (i.e., passport, driver’s license, social security card, etc.). Only forward these pages to OHR. Do not save or submit copies of the I-9 instructions (pages 1-6) or Lists of Acceptable Documents (page 9) to be stored with each individual Form I-9. Please no longer complete the I-9 Checklist.
Q: How long do we have to retain Form I-9?
A: We must retain the pages of the form on which the employee and the employer enter data, and copies of employee’s documents. Once an individual’s employment terminate, this paperwork must be retained for either 3 years after the date of hire or 1 year after the date employment ends, whichever is later.

Correcting Form I-9

Q: If a mistake is discovered on Form I-9, how can we make a correction?
A: If you discover a mistake on Form I-9, correct the existing form, redo a section of the form or prepare a new Form I-9.
  • If you choose to correct the existing Form I-9:
    • You may only correct errors made in Section 2 or 3; section 1 errors should be corrected by the employee
    • Line out the incorrect portions, enter the correct information, and initial and date the correction
    • Do not conceal changes, do not use correction fluid
  • To correct multiple errors in one section, a section of the form may be redone on a new Form I-9 and attached to the old form. Please only use this option after consulting with Recruitment and Compensation.
  • A new form can be completed if there are “major errors” such as entire sections being left blank or Section 2 being completed based on unacceptable documents. Please only do a new Form I-9 after consulting with Recruitment and Compensation. If you do a new Form I-9:
    • Retain the old form
    • Attach a short memo to both the new and old Forms I-9 stating the reason for your action.
Q: What should I do if I discover that correction fluid has been used on an I-9?
A: Never use correction fluid or a pen to “black out” an error. Errors should not be concealed. If changes have been made to a Form I-9 with correction fluid or by “blacking out” information, attach a note to the form explaining what happened.
Q: What if one or more Sections of a Form I-9 are completed late?
A: If any portion of Form I-9 was not completed in a timely manner, you must attach a written explanation to the Form I-9 explaining why this occurred. DO NOT backdate signatures on the Form I-9 or misstate the hire date to make the form appear to be completed in a timely manner.
Q: What should we do if we realize that we are missing Form I-9 for an employee?
A: Contact Recruitment and Compensation for assistance in looking for the form. If the paperwork is not immediately located, the following must take place:
  • Immediately provide the employee with a Form I-9.
  • Allow employee 3 business days to provide acceptable documents.
  • DO NOT backdate signatures on the Form I-9, or misstate the hire date to make the form appear to be completed in a timely manner.

Remote I-9s

Q: At times, it may be necessary to hire an employee who will work remotely and will not be near a Penn State campus to complete their paperwork, including Form I-9. How do we ensure that these individuals properly complete Form I-9?
A: We’ll need the assistance of a third party to act as an authorized representative of the University to complete Form I-9 for remote hires. An authorized representative could be a Human Resource professional usually from another college or university, a notary public or an attorney. The authorized representative should be a Human Resources professional whenever possible. These individuals are familiar with the Form I-9, so errors are very limited. Notaries and attorneys are often not familiar with the form which results in errors, and they usually charge for their services which should be paid for by your campus/unit. Therefore, it’s recommended that I-9s for remote new hires are completed by a Human Resources professional whenever possible. Once you find a contact/authorized representative, put the employee in touch with them directly. Be sure to give the new hire a link to the Form I-9 including the Lists of Acceptable Documents so they’ll know what documentation to bring when they meet with the authorized representative. The authorized representative will oversee the completion of Section 1 of Form I-9 and complete Section 2. If they are not familiar with Form I-9, they'll need to read the directions to the form and you may want to speak to them to ensure that they know how the form is to be completed. Be sure to let them know:
  • The start date for Section 2 (The employee's first day of employment)
  • We make copies of the documents presented to prove identify and work authorization, so we’ll need them to make copies of the documents to be submitted with Form I-9.
  • The following instructions for Section 2/Certification signature box:
    • The authorized representative should complete the following in reference to themselves:
      • Signature of Employer or Authorized Representative
      • Date signed
      • Title of Employer or Authorized Representative
      • Last Name and First Name
    • The following should remain blank to be filled in by Penn State with Penn State information as the employer:
      • Employer’s Business or Organization Name
      • Employer’s Business or Organization Address
Q: What is the best way to make a correction if the authorized representative makes a mistake on an employee’s Form I-9?
A: The authorized representative acts as an agent of the employer. Therefore, either the authorized representative or the employer may make corrections to Form I-9 as needed. To make corrections, you or the authorized representative may line through the incorrect information, and initial and date the change.*
Q: When logging I-9 information in IBIS for I-9s completed remotely, what “authorized by” name should we put on the I-9 screen?
A: The “authorized by” name for remote I-9s in IBIS should be the name of the University employee who was responsible to ensure that the form was completed

Shared Employees/Employee Transfers

Q:How should I handle Form I-9 for an existing Penn State employee who is going to start working in my unit whose I-9 is not stored in Central OHR?
A: I-9s must be shared between Penn State units, administrative areas and campuses. Each employee should only have one I-9 for a period of employment. When a Penn State employee begins working in a new unit, the following should happen:
  • If the employee is going to work in 2 units, the original I-9 should be housed in the unit that completed the form and a copy should be sent to the other unit.
  • If the employee is no longer working for the unit that has the original copy of the I-9, the original I-9 should be sent to the unit where they are now working. The sending unit does not need to keep a copy of the form but should keep a log of the original forms sent including the employee’s name, date sent, name and unit of the person to whom the form was sent.
Q: I am concerned about “inheriting errors” as we’re sharing I-9s among the units/campuses. What should I do if an individual transfers to my unit and when I receive their I-9, it has errors?
A: Contact Recruitment and Compensation to determine how to address the issue and correct the errors.
Q: Does every unit input I-9 information into IBIS for wage employees?
A: There are some units that do not input I-9 information into IBIS for their wage employees. Should you need assistance locating an I-9 for an existing employee who is transferring to your unit, contact Recruitment and Compensation.

*Questions taken from I-9 Central or Handbook for Employers - Guidance for Completing Form I-9