The American Council on International Personnel (ACIP) and the Society for Human Resource Management (SHRM) submitted changes and comments in connection with the revision of Form I-9, Employment Eligibility Verification. Following is the summary of general recommendations that have been put forward in the I-9.

  1. Length of Revised Form I-9: The revised I-9 is 3 pages long including list of acceptable documents. ACIP & SHRM have put forward a suggestion to not increase the number of pages from the current one. It was also suggested that the current Form I-9 may be printed double-sided and distributed as a one-sheet document. The proposed revised Form I-9 would require at least two sheets of paper per form, resulting in unnecessary additional costs and administrative burdens in the production, completion, review and storage of each Form I-9. A clear form can be created which retains the current single-page format. For employers who complete literally tens of thousands of Forms I-9 per year, these increased costs and burdens would be substantial and did not seem justified by the changes proposed to the Form I-9.
  2. Electronic Form I-94: The proposed I-9 does not take into consideration the US Customs and Border Protection (CBP) initiative to introduce electronic I-94. The revised Form I-9 and instructions still refer to Form I-94 in its paper-based format and do not make any references to the electronic Form I-94. It is suggested that the revised Form I-9 clearly addresses how the electronic Form I-94 may be used in the I-9 context.
  3. Handbook for Employers (M-274): It is suggested that the Handbook for Employers (M-274) should be more prominently noted in the proposed instructions to the revised Form I-9. The M-274 carries significant importance in guiding employers in completing the I-9 process, but is referenced in only a few places in the instructions; as a result, the existence (much less importance) of the M-274 would not be clearly evident to someone who is new to the I-9 process.
  4. Consistency with I-9 Central and M-274: Currently, there are three agency resources that users can utilize to understand the I-9 process and complete the form: I-9 Central (an electronic web-based resource), the M-274 Handbook for Employers, and the printed instructions accompanying Form I-9. It is not clear to employees and employers which of these three documents provides the most complete and/or up-to-date information. Multiple sources of information and instructions regarding the I-9 process, any lack of consistency among those multiple sources unnecessarily adds complexity and confusion to the I-9 process. One resource for current instructions and information regarding the I-9 process is another suggestion put forward by the agencies.
  5. Time to Complete Form I-9: The current estimated burden for “reviewing instructions and completing and retaining” each Form I-9 is listed as 13 minutes. The instructions for Form I-9 have become increasingly complex and lengthy: the current M-274 is a 69-page document; the instructions accompanying the proposed revised Form I-9 are six pages making it impractical to complete the I-9 in the estimated 13 minutes. It is suggested that the form reflect a realistic burden on the public, both to enable the agency to understand the cost and resources required by employers, and to create realistic expectations for employers who must budget the time and resources required for the I-9 process.
  6. Electronic Version of Form I-9: The final recommendation was for an electronic form as an electronic version of the Form I-9 will enable employers to complete the form in a shorter amount of time and would eliminate a need for a paper-based format of the form. An electronic version of Form I-9 would enable employers to more accurately review their responses and make sure that they are in compliance with the regulatory requirements.