MSU Human Resources >> Ua >> I9 >> Coronavirus: I-9 Resources

Coronavirus: I-9 Resources

Completing an I-9 Form

On March 20, 2020, the Department of Homeland Security (DHS) issued an announcement that it will exercise discretion to defer the physical presence requirements associated with the Form I-9. Employers with employees taking physical proximity precautions due to COVID-19 will not be required to review the employee’s identity and employment authorization documents in the employee’s physical presence. MSU verifiers still must inspect the Section 2 documents remotely (e.g., over video link, fax or email, etc.) and obtain, inspect, and retain copies of the documents within three business days for purposes of completing Section 2.

Units are to follow the steps below when using this temporary provision:

  • Complete Section 2 of the I-9 by either electronic copies of the document(s) or by observing the employee’s documents via video communication.
  • Copies of the documents must also be obtained and attached to the I-9 in the I-9 system (even if they were observed via video link).
  • Units must still complete Section 2 in Equifax and attach copies of the document(s) on time within three days of the date of hire.
  • Units must check the box in the gray COVID-19 Exception box when completing Section 2.
  • Units are responsible for keeping track of employees whose Form I-9s are completed using the temporary provision and are responsible for ensuring the documents are physically inspected in-person once normal operations resume.

Once normal operations resume, verifiers need to:

  • Physically inspect the employee’s original document(s) in-person within three days after operations resume.
  • Units must click on the 'Covid19 Update' button located on the employee’s detail page in the electronic I-9 system.
    • Click Continue on the next page to confirm the documents have been physically inspected.

The Section 3 reverification of work authorization documents are acceptable via electronic inspection during the temporary provision period as well. MSU verifiers would need to follow the same guidelines to follow-up and inspect the original document (s) when normal business operations resume.

For additional I-9 system guidance and instruction please see the Enhanced-COVID-19 Provisional I-9 Process-Instructions (PDF). Any additional questions pertaining to the completion of I-9s using the temporary provision authorized by U.S. Department of Homeland Security, please email


NEW: Physically Inspecting Employee’s I-9 Documents

As MSU continues to develop and finalize plans for bringing employees physically back to their worksites, it’s important to keep in mind that we are reaching the end of the COVID-19 Exception issued by the Department of Homeland Security. Departments should develop a plan to complete the physical inspection of the I-9 documents while adhering to guidelines set forth by the Governor and laid out by their unit’s approved Return-to-Work Procedures and Protocols.

You should plan to meet with employees in-person unless the employee is out-of-state and/or more than two hours away from their department’s location. If an employee is out-of-state and an in-person meeting would require more than a two hour drive to complete this in-person meeting, please contact

Additional COVID-19 I-9 Resources

Expired List B Identification Documents

Beginning on May 1, identity documents found in List B set to expire on or after March 1, 2020, and not otherwise extended by the issuing authority, may be treated the same as if the employee presented a valid receipt for an acceptable document for Form I-9 purposes. Within 90 days after DHS's termination of this temporary policy, the employee will be required to present a valid unexpired document to replace the expired document. If the issuing authority has extended the document expiration date, you may enter the document expiration date and it will not be treated as a receipt. Verifiers should check the additional COVID-19 Document Expiration Notice checkbox on the document details page. Employees who are able to renew their Drivers Licenses or State IDs online are not included in this exception. Please refer to the Secretary of State website to read how the State of Michigan has extended the expiration date to September 30, 2020 for residents who may fall in this category. 

I-9 Verifier Access Role Changes

I-9 Verifiers with the role of Location Specialist or HR Specialist are unable to utilize many of the tools in the I-9 system required to process the COVID-19 provisional I-9 forms. I-9 System user roles can be updated by completing a IT Services generic e-ARM. You will need to change your role to HRUser or HRSupervisor. Employees requesting access for the first time must follow existing instructions for obtaining access to the I-9 System.

Hiring Out of State Employees

Many states are currently under COVID-19 social distancing restrictions. To complete an I-9 for an employee hired during this restriction period, the hiring unit may complete Section 2 by following the temporary provisions. Once normal business operations resume, the "physical inspection" portion of the process will need to be completed. When this occurs, it is best that an employee finds an individual that can act as MSU's Authorized Agent and provide HR with the name, email address and phone number of that individual. HR will set up special access for that individual to complete the "Physical Inspection" portion. If the employee is unable to provide their own individual agent, we can provide a list of participating CUPA-HR I-9 Reciprocal Institutions. This list may contain institutions that are not open to the public or are unavailable. Please email for questions about this process. 


Updated 8/10/2020