If one department of the university signs an E-Verify memorandum of understanding (MOU), does that make the entire university an E-Verify employer?

If there is one central department that signs an MOU, completes Forms I-9 and creates E-Verify cases for all of the university’s new hires, then the entire university is an E-Verify employer. If separate departments of the university (for example, a physics research lab within the university), each sign an MOU, complete Forms I-9 and create E-Verify cases separately for their new hires, then each such department or research lab would be a separate E-Verify employer. In the case of the physics research lab, F-1 OPT STEM students may only be employed by the lab that has signed an MOU with E-Verify; those students may not work in any other department or lab within the university.