How to Conduct an Internal I-9 Employment Form Audit in 4 Steps

　　Conducting your own self-audit can be a straight-forward process. Here are four steps you can follow:
　　Designate a person to conduct the audit. For example, this might be someone internal, such as an HR representative or in-house counsel. It could also be external counsel. Alternatively, it could be a contractor hired just for the audit. Even if you use someone external, be sure to assist – not only in making corrections, but also use this opportunity to understand the types of training you might need and other things you can do to the correct the situation.
　　Generate lists of employees. First, generate a list of all active employees. This will be the initial scope of the audit. This is one of the first documents that ICE will request if they do an audit. Next, generate a list of all employees terminated within the last three years. This will be the secondary scope, as these need to be kept on file (see fourth step). These are still within your liability, so they are important. (Tip: don’t forget to include the employee start date in your spreadsheet.)
　　Use an audit checklist to determine the status of all forms and supporting documentation. More information on what should be included in an I-9 audit checklist can be found in a related article.
　　Finally, you should also be sure to purge I-9 forms according to retention rules. Get rid of them when you are legally able to limit your liability beyond that date. They must be kept either 1 year after date of termination or 3 years after the date of hire, whichever is longer.