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SHRM: Proposed Form I-9 Should Be Simplified

    SHRM:  Proposed Form I-9 Should Be Simplified

    The proposed revised Form I-9 is too long, according to May 29, 2012 comments from the Society for Human Resource Management (SHRM) and American Council on International Personnel.

    “We would like to strongly suggest that the revised Form I-9 (which is three pages long, including the required list of acceptable documents) not require more sheets of paper than the current Form I-9 (which is two pages long, including the list of acceptable documents),” the associations wrote.

    They noted that the current Form I-9 may be printed double-sided and distributed as a one-sheet document. “The proposed revised Form I-9 would require at least two sheets of paper per form, resulting in unnecessary additional costs and administrative burdens in the production, completion, review and storage of each Form I-9,” they added. “We believe a clear form can be created which retains the current single-page format.”

    Multiple Sources of Instruction


    The instructions for the Form I-9 should be simplified as well, they remarked.

    Currently, there are three agency resources that can be used to understand and complete the Form I-9: I-9 Central, a web-based resource; the M-274 Handbook for Employers and the printed instructions accompanying the Form I-9.

    “It is not clear to employees and employers which of these three documents provides the most complete and/or up-to-date information,” the associations wrote. “If the agency persists in having multiple sources of information and instructions regarding the I-9 process, any lack of consistency among those multiple sources unnecessarily adds complexity and confusion to the I-9 process.”

    As noted in a March 12, 2012, letter from the American Immigration Lawyers Association (AILA) to the U.S. Citizenship and Immigration Services Verification Division, some inconsistencies between I-9 Central and M-274 involve:

    • Guidance on issues dealing with spelling of the name on Form I-9
    • Providing documentation supporting a name change
    • Clarification regarding acceptance of expired documents
    • Acceptability of laminated Social Security account cards

      “We wholeheartedly agree with AILA’s observations and comments on this point,” the associations wrote.

      Just 13 Minutes?

      They also urged that a more realistic estimate of how long it takes to complete the Form I-9 be provided.

      The current estimated burden for reviewing instructions and completing and retaining the Form I-9 is 13 minutes.

      “We would like to note that the instructions for Form I-9 have become increasingly complex and lengthy: the current M-274 is a 69-page document,” they noted. “We do not believe that any individual could read and understand that volume of material in the 13 minutes estimated for the entire I-9 process.”

      They added, “We believe it is important that the form reflect a realistic burden.”

      Allen Smith, J.D., is manager, workplace law content, for SHRM.








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