| Correct!
Answer: C.
Although the government stated that employers should begin
using the new form immediately, it has allowed a period
of 60 days for employers to make the business-related adjustments
necessary to begin using the new form. This has effectively
created a grace period for employers.
A plain reading of the federal register notice would lead
to the conclusion that the deadline for beginning to use
the new form is May 8, 2013. However, government websites
and announcements have listed May 7, 2013 as the deadline.
The American Immigration Lawyers Association (AILA) initially
received confirmation that May 8th was the deadline; the
government later indicated that this may not be the correct
date. A final announcement in early April confirmed (once
and for all) that May 7th is the official deadline.
D and E are also good answers. Employers can begin using
the form any time before May 7th. I generally recommend
taking advantage of the grace period to
- read and digest the revised M-274 Handbook
for Employers, available here;
- update your company policies and protocols
to reflect changes to the form; and
- provide training (preferably from a
qualified attorney) to the individuals responsible for
completing the form to ensure that they are aware of the
changes and are equipped to properly implement them.
Question:
When must I start using the new Form I-9 (released March
8, 2013)?
a)
You should have started using it on March 8th,
2013.
b)
You must start using it on or before May 8th,
2013.
c)
You must start using it on or before May 7th,
2013.
d)
Only after I have updated my policies and protocols to reflect
the form's changes.
e)
Only after my team has been trained on the form's changes.
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