Staff Resources / Human ResourcesForm I-9 Compliance Guide
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Effective January 20, 2025, NU announced a new I-9 policy to assist the university in remaining compliant with federal regulations for new employees starting at a unit of the university. The following information will help assist with MCC staying within policy, including a new MCC I-9 tracking system (Smartsheet solution).
The I-9 Compliance Officers for McCormick are Zac Davis (zachary.davis@northwestern.edu) and Kimberly Higgins (kimberly.higgins@northwestern.edu).
I-9 COMPLIANCE GUIDE OVERVIEW
New Hire Information Submission
Once offer of employment is accepted by a finalist candidate, the hiring department’s Business Administrator (BA) or Onboarding Facilitator will complete the McC New Hire Form via Smartsheet, ensuring all required information about new hires is accurately submitted. See below for more information on submitting the New Hire Form.
I-9 Compliance Monitoring by McC HR
Once a new hire is added, McC HR and Department Section 2 Authorizer will oversee the I-9 compliance process. This includes:
Section 1: Completion by the employee by the hire date
Section 2: Scheduling to complete with an I-9 Section 2 Processor within the first three business days after the hire date.
I-9 Form Section 2 Compliance Timeline:
Day 0: Employee’s official start date
Day 1: First business day after the start date
Day 3: Final day for Section 2 completion. Failure to complete by the end of this day results in non-compliance.
Day 4: Employee is officially out of compliance and should not work until compliance is restored.
Day 7: Employee is terminated in the system if compliance has not been achieved.
Example: A new hire starting on Monday, January 27, 2025, must have Section 2 completed by the end of the day on Thursday, January 30, 2025 to avoid being out of compliance.
Communication Timeline for Compliance Reminders
To keep new hires informed and on track with I-9 compliance requirements, the following communications will be sent:
| On or Before the First Day | The department/unit will send instructions to the new hire on how to complete Form I-9. |
| 1st Business Day | Central HR will send the first compliance reminder to the new hire, highlighting the need to complete Section 2. |
| 3rd Business Day |
McC HR will contact the new hire directly, informing them that Section 2 must be completed by the end of the day. |
| 4th Business Day |
If Section 2 remains incomplete, a formal notice is sent from Central HR to the employee. This communication will also copy the manager, HRBP, and I-9 Processor. |
| 7th Business Day | The employee will be terminated if Section 2 is not completed. Central HR will notify the employee, informing them they are ineligible to work until compliance is achieved. |
I-9 Exempt Employees
The following staff categories are exempt from completing Form I-9:- Undergraduate students paid on scholarship (7XXXXX account code)
- Graduate students* paid on a fellowship (7XXXXX account code)
- Visiting scholars solely paid on 7XXXXX account code
- Postdoctoral fellows supported by an NRSA grant
- Unpaid appointments and independent contractors
- Employees with continuous service at Northwestern since before November 6, 1986 (including Professor Emeritus appointments)
- Employees working on the Qatar campus
*For new graduate students, best practice is to proactively complete the form I-9 anticipating the switch from 7XXXXX account code to 6XXXXXX payroll account code within the first academic year.
Non-Compliance Procedures
Day 4 Non-Compliance:
- The employee is flagged in the system.
- Proof of Section 2 completion is required to remove the flag.
- Failure to remove the flag results in continued non-compliance and termination in the system.
- Employee will be temporarily terminated in the system.
- The employee’s NetID enters a 14-day expiration period.
- Rehire eligibility is contingent upon proving Section 2 completion.
Dynamic View Access in Smartsheet I-9 Tracking System for MCC Departments
Using the Smartsheet I-9 Compliance Tracking System
Hiring managers and designated department contacts are responsible for submitting the New Hire Form when a new employee is expected to start in their department. This process applies to anyone on payroll - staff, faculty, student workers, postdoctoral fellows, and non-student temporary employees.
Submitting the New Hire Form
The department contact will complete the form, providing as much information as possible about the new hire.
If information regarding Section 1 completion of Form I-9 is available, we encourage it to be included, as this will improve tracking and compliance monitoring.
We recommend selecting the option at the bottom of the form to request a copy of the submitted data. You will be prompted to enter the email addresses of the recipients who should receive this information.
Accessing and Tracking New Hires via Dynamic View
After submitting the form, the department contact should click the “Dynamic View” link.
This link provides access to a real-time departmental tracking page, allowing hiring managers to monitor the compliance status of each new hire they have entered. When a new hire is added, their compliance status will be indicated as follows:
- Pending: The employee has not completed their I-9 but is still within the compliance period.
- Pending (Late): The employee has not completed their I-9 within the 3-day post-hire date compliance period. They cannot work again (or schedule future work) until the they complete the form.
- Pending(Terminated): The employee has not completed their I-9 form within the 7-day post-hire date period and are temporarily terminated. They cannot work and will be inactive in the payroll system until I-9 form is completed. This can affect benefits status for ben-el employees.
- Complete (Late): The employee completed their I-9 after being out of compliance. MCC HR must send confirmation to Central HR to remove the late flag.
- Complete (Terminated): The employee completed their I-9 after being out of compliance and was terminated in the system. MCC HR must send confirmation to Central HR to remove the temporary term flag.
- Complete (Compliant): The employee completed their I-9 within the compliance period.
In addition, identified department I-9 Sec 2 Processors can update certain sections of the Dynamic View sheet:
Section 1 Completion:
- If the employee has completed Section 1, check the corresponding box in the “Section 1 Completed” column.
Section 2 Completion:
- Section 2 Scheduled date can be filled in if needed/known, especially if a new hire has fallen out of compliance.
- Section 2 Completion Date should be filled in when new hire has visited with the department or gone to central HR and should be verified in the I-9 Service Center.
- Section 2 Processor should be filled in. Should be either NU HR if done by central (1800 Sherman Ave) or name of MCC/Dept Sec 2 Processor.
- Please be sure to click the Save button in Smartsheet task bar to record changes.
- Please send the I-9 Sec 2 receipt generated by I-9 Service Center to MCC I-9 Compliance Officer Zac Davis (zachary.davis@northwestern.edu) and back up Kimberly Higgins (kimberly.higgins@northwestern.edu).
- Do not fill in Date HR Notified or Date HR Resolved columns.
If a new hire is out of compliance (late/terminated) McC HR will track & communicate the compliance status to central HR as employees complete their I-9 requirements.
Hiring managers and department contacts can access Dynamic View at any time to track their new hires and ensure compliance deadlines are met.
Updating the Tracking System
If there are changes in employee assignments or if additional team members require access to the tracking system, please contact McC HR to request the necessary updates.
Anyone can access the Dept Access sheet and review the department staff assigned as Onboarding Facilitators and I-9 Section 2 Processors.
This system helps maintain accuracy, transparency, and compliance throughout the hiring process. If you have any questions regarding access or usage, please contact MCC I-9 Compliance Officers Zac Davis (zachary.davis@northwestern.edu) and Kimberly Higgins (kimberly.higgins@northwestern.edu).