1. HOW TO SURVIVE AN ICE AUDIT
Jeannie McCall, MS, SPHR
Manager, Recruitment & Staffing
TECO Energy, Inc.
Tampa, FL

2. HOW TO SURVIVE AN ICE AUDIT
“ . . . the rearview mirror is always
clearer than the windshield.”
- Warren Buffett

3. Form I-9

4. Handbook For Employers
• 56 page instruction manual for completing the
Form I-9 available at www.dhs.gov
• Page 16 – most common wrongfully interpreted
instruction is Retention of Form I-9
Remember, Forms I-9 must be stored for 3 years
after the date you hire an employee, or 1 year after
the date you or the employee terminates
employment, whichever is later.

5. • A joint agreement between government
and business to restore the integrity of the
U.S. immigration system by strengthening
hiring practices
• Focus on reducing the size of illegal
workforce, sharing best practices, self-
policing.

6. IMAGE PROGRAM
WHAT THE BUSINESS MUST DO
• Ensure accuracy of wage reporting via SSNVS
(Social Security Number Verification Service)
• Establish a channel for employees to report
activity related to the employment of illegal aliens
• Establish I-9 auditing procedures (internal or
external)
• Develop an internal training program

7. IMAGE PROGRAM
WHAT THE BUSINESS MUST DO
• Submit a summary of current hiring practices
• Submit to an I-9 audit
• Use e-Verify
• Communicate IMAGE guidelines to other
companies in the network (sub-contractors)
• Submit an annual report to ICE

8. Form I-9,
Section 1
To be
completed
by the
employee

9. MOST COMMON MISTAKES
Section 1
• Pre-printed employee information
• Missed the check box
• Signature on the wrong line
• Dates
DOB (ie, 2010)
Today’s date (ie, 1965)
Military

10. Form I-9,
Section 2
Employer
Review and
Verification
Lists A, B
and C

11. MOST COMMON MISTAKES
Section 2
• B&C documents swapped
• B&C documents name non-match
• Wrong agencies noted
• Hospital Birth Certificate not an acceptable C
document
• Overdocumentation

12. Form I-9,
Certification
Section

13. MOST COMMON MISTAKES
Certification section
• Hire date missing or incorrect
• Signature missing
• Date missing

14. Form I-9,
Section 3
Updating and
Reverification

15. MOST COMMON MISTAKES
General
• Missing or wrongfully purged documents
HD plus 3 years or
Term date + 1 year
whichever is later
• Name changes not followed up
• Document copies attached or not attached?

16. EXPLANATORY ANNOTATION
FORM I-9 CORRECTION
During a Form I-9 (Employment Eligibility Verification) audit conducted December 21,
2008 through January 6, 2009, by the U.S. Department of Homeland Security (DHS),
Immigration and Customs Enforcement (ICE), Office of Investigations (OI) and as part
of the ICE Mutual Agreement between Government and Employers (IMAGE)
application process for TECO Energy, Inc., this employees Form I-9 required
correction.
The Form I-9 attached hereto and completed for
________________ (Employee Last Name, First Name, MI)
was corrected accordingly.
FORM I-9 CORRECTION(S) MADE BY COMPANY OFFICIAL:
Name of the Company Official: __________________________
Date of the Correction: ________________________________

17. IMAGE PROGRAM
BENEFITS TO INDUSTRY
• Two-year respite from I-9 audits/inspections
• Training
• Public Recognition
• Good faith participation can be a mitigating factor
in assessment of fines in future

18. PREPARE YOUR HR TEAM
• 56 page instruction manual for completing the
form I-9 available at www.dhs.gov
• Provide formal training on I-9 documentation to
your HR Team
• Communication for employees to address the
need to revisit the I-9 process with them
• Conduct an internal audit of your Forms I-9
• Use two pair of eyes for collection and purge
• Keep terminated I-9s in a separate file

19. CONTACT THE PRESENTER
Jeannie McCall, MS, SPHR
Manager, Recruitment & Staffing
TECO Energy, Inc.
pjmccall@tecoenergy.com
Or contact me on LinkedIn