The U.S. Social Security Number field in Section 1 is considered an optional field on the Form I-9. However, if an employer is enrolled in E-Verify, the Social Security Number becomes a required field because an SSN is needed in order to create an E-Verify case.
In some cases, an employee may be eligible to work in the United States but may not yet have a SSN. In these cases, where a newly hired employee has applied for, but has not yet received their SSN (e.g., the employee is a newly arrived foreign national) and the I-9 is subject to E-Verify, we recommend that the employee marks the “I do not have a social security number” checkbox in Section 1 and completes and signs Section 1. The employer should proceed completing Section 2 as normal, and attach an explanation for the blank SSN to the employee’s I-9. As soon as the employee receives their SSN, the employer is expected to have the employee provide their SSN on the I-9, and then the employer must create a case in E-Verify. When creating a late case in E-Verify as a result of the SSN having been applied for but not received at the time Section 1 was completed, the employer should select “Awaiting Social Security number” as the late case reason when prompted by E-Verify.
The Update SSN Workflow permits the employer and employee to complete the update to the I-9 and submit the data to E-Verify without having to reorder (redo) the entire Form I-9.
Upon being notified that an employee has received their U.S. Social Security Number, the recruiter will first need to access the employee’s I-9 Section 1 PDF. They can do this by going to the Onboarding page for their applicant and clicking on the eye icon next to the completed Section 1.
After downloading a copy of the I-9 PDF, the recruiter will need to have the employee update the I-9 by writing in their Social Security Number in the appropriate field, and then initialing and dating the change nearby. The recruiter can use whatever method is secure and approved by their organization to get the PDF to the employee. In some cases, the recruiter might print out the PDF and have the employee correct the I-9 on-site. In other cases, the recruiter might need to securely email the PDF to the employee to have the employee print out the I-9 and make the correction at their own convenience.
After the recruiter receives the corrected I-9, they should go back into WFM and access the employee’s I-9 record. They can do this by going to I-9 Dashboard 2.0 and clicking on the row that contains the employee’s name. (The recruiter should click on blank space within the row and not on any of the links in the row. Clicking on a CTA in the row will redirect the recruiter to a different view.) This should expand the I-9 Details Panel for that employee. In the Details Panel, the recruiter should look in the Section 1 portion and click on the button labeled “Update SSN”.
There will be three required items needed at this point in order to proceed:
- The recruiter must enter the SSN that the employee wrote in Section 1 of their I-9.
- For validation purposes, we also require the recruiter to confirm the SSN.
- The recruiter will also need to upload a copy of the updated Section 1.
Why does the recruiter need to upload a copy of the PDF?
During ICE and other government audits, the officer inspecting the Forms I-9 relies heavily on an audit trail to determine whether the I-9 was completed properly and whether the employer is properly following the I-9 rules and regulations set forth by the government. When the I-9 is completed electronically, the I-9 provider (like Able) needs to provide an electronic audit trail to verify which fields were altered when and by whom. However, when the I-9 is completed on paper, the handwritten initials (or signature) and date act in place of the electronic audit trail.
Once the three items above are provided, the “Submit SSN Update” button can be clicked and the Details Panel will automatically scroll down to the Notes portion with a prefilled note. This note explains what action occurred and the reason for amending the I-9. The recruiter can modify this note if they wish or they may choose not to leave a note at all (although that’s not recommended). After the SSN is saved, the I-9 data will automatically be submitted to E-Verify. From here, the recruiter would need to take appropriate action based on the result from E-Verify.
Is it okay if an employer has an I-9 completed in different formats?
Yes, USCIS indicates that employers can store I-9s in either a single format or a combination of formats, such as paper or electronic. Employers can store the I-9 and any corresponding documentation in a manner that suits their business needs and the requirements to make available the I-9 and its assets for inspection. It is also recommended that the I-9s are securely stored to protect employees' personally identifiable information (source)
What should the employer do with the paper I-9 that the employee has updated by hand?
After the employer has ensured the paper I-9 is properly uploaded, they may destroy the paper form. (source)
There is no Candidate Experience for the Update SSN Workflow in Able WFM.
The candidate would need to inform their employer that they have received their SSN.
Once the recruiter provides the I-9 to the candidate, the candidate will be responsible for providing their SSN on the I-9 and initial and dating their change. Once the update is made, the candidate will need to provide the updated I-9 to their recruiter/employer.
Using Update Social Security Number depends on I-9 Dashboard. To enable I-9 Dashboard, speak with your Customer Success Manager.
Using Update Social Security Number can only be used if E-Verify is enabled.