What options does a university have for enrolling in E-Verify?
Universities have two options for enrolling in E-Verify. If only certain components of the university, such as a department, college, school or campus, will hire employees and create E-Verify cases, the university may choose to have each of those separate components enroll in E-Verify and sign an MOU. Each component that enrolls in E-Verify and signs an MOU must list itself as a hiring site in E-Verify. A hiring site is a location where an individual is hired and completes a Form I-9.
For example, if a university research lab completes Forms I-9 for its new employees, it is considered a hiring site. The research lab could then enroll in E-Verify with its own MOU and create cases for new hires at the research lab. In this case, the research lab would only create E-Verify cases on new hires at the research lab; not all new hires at the entire university.
Alternately, if the human resources department typically completes Forms I-9 for all of the university’s new hires, it would be considered the university’s only hiring site. When the university enrolls in E-Verify, the human resources department will need to create E-Verify cases for all the university’s new hires. In this case, the university could not limit the creation of cases in E-Verify to new hires in specific departments.
Check with your legal counsel or human resources professional to determine whether separate enrollment for components of the university is appropriate. It is up to the university to determine how best to enroll in E-Verify.