Sent on behalf of Rachele Brida:

As you may be aware, we will be doing some I-9 training over the next few weeks. We want to be sure that you’re aware of some questions and issues that we’re going to address at the training, prior to this information being communicated to staff.

We were hoping to implement changes to I-9 practices along with an electronic I-9 system. However, since we do not yet have confirmation regarding electronic I-9’s we feel that it is important to provide guidance on some key issues.

Duplicate I-9s

It has come to our attention that duplicate I-9s are sometimes being completed for existing Penn State employees when they begin working in a new unit at the University if their I-9s are not stored in Central OHR. A new Form I-9 should not be completed for current Penn State employees who begin working in your unit.

I-9s must be shared between Penn State units, administrative areas and campuses. Each employee should only have one I-9 for a period of employment. When a Penn State employee begins working in a new unit, the following should happen:

  • If the employee is going to work in 2 units, the original I-9 should be housed in the unit that completed the form and a copy should be sent to the other unit.
  • If the employee is no longer working for the unit that has the original copy of the I-9, the original I-9 should be sent to the unit where they are now working. The sending unit does not need to keep a copy of the form but should keep a log of the original forms sent including the employee’s name, date sent, name and unit of the person to whom the form was sent.

New I-9s every 3 years for wage, FT-2 employees, and Graduate Assistants

We have learned that some units are completing new I-9s on wage, FT-2, and Graduate Assistants every 3 years. A new I-9 should only be completed when someone is rehired by the University. I-9s do not expire after 3 years. If your unit is doing new I-9s every 3 years, this practice should be stopped. Form I-9 is also not considered to be good for 3 years, so we need to complete a new Form I-9 when we rehire an employee regardless of when the original I-9 was completed.

We realize that employees in wage, FT-2 and graduate assistant appointments may have breaks between appointments and/or work sporadically.

  • Employees are considered rehired if they do not have a reasonable expectation of continued employment. If an employee is terminated and they do not expect to return at the time of termination, a new I-9 will need to be completed if they should return to the University.
  • If there is an interruption in continued employment due to lack of work or seasonal employment, but the employee has an expectation that they will return to employment in a reasonable amount of time, this is not considered a break in service and a new I-9 should not be completed. As a general rule a break of six months or less would be considered a reasonable amount of time to return to employment. An example of a continuing employee may be a wage employee who does not work during the summer break, but expects to return at the beginning of the following semester. In this case a new I-9 would not need to be completed.

We are working on changes to IBIS. In the meantime, should IBIS request a new Form I-9 and stop you from reappointing an individual who does not need new paperwork, do not complete a new Form I-9. Instead, please e-mail Sharon Price at . She will assist you in processing this appointment.

Should you have any questions, please contact Sharon Price (, 814-865-9346).