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Preparing for the Possibility of a Department of Homeland Security (DHS) Notice of Inspection (NOI)

The University of California Office of the President (UCOP) has underscored the importance of audit preparedness in the event the Department of Homeland Security (DHS) issues a Notice of Inspection (NOI) to a UC location. 

NOIs are primarily delivered via certified mail or hand delivered to a business owner, manager, or legal representative. Although NOIs are rare, it is critical that campus departments are informed of the immediate steps to take following notification.

Immediate Action Items

Immediate department action is essential. The University of California requires locations to provide notice to current employees of any inspection of I-9 Employment Eligibility Verification forms or other employment records conducted by an immigration agency by posting a Notice within 72 hours of receiving notice of the inspection.

If you receive an NOI:

1. Contact CRU Immediately

Contact CRU immediately via the HR Admin form, using the I-9 Tracker topic.

Include the following:

  • Subject: NOI – Department name
  • Copy of the NOI document 

2. Post the NOI

Post the NOI, which will be completed and provided by the UCLA Lead Tracker Administrator, to inform current employees within 72 hours of receiving the notice.

The notice should be posted where employee postings are typically displayed and include:

  • scope of NOI (this information will be provided to you by the UCLA Lead Tracker Administrator in CRU and sent to the department for posting). 
  • a copy of the NOI and any accompanying documents.

3. Review Form I-9 Audit Guidelines

Review our guidelines for Providing Form I-9 to Auditors.

Tracker users are not permitted to provide Form I-9 to auditors or other agencies.

Best Practices for I-9 Managers and Processors

Monitor Tracker I-9 Dashboards

Monitor your Tracker I-9 dashboards to ensure that Form I-9s are completed timely and the identified compliance issues are resolved.

Regularly Audit Form I-9s

Audit your I-9s regularly to ensure that at a minimum you have an I-9 for every active employee, regardless of pay status.

Leverage Tracker's Audit Notes

Leverage Tracker’s Audit Notes feature (under the I-9 Summary Tab of the employee’s I-9 Record).

Reconcile Termination Dates in Tracker

Reconcile termination dates in Tracker to ensure they are reflective of the termination date in UCPath. If the employee has been hired in multiple departments, create a case with CRU to assist with the termination date validation. Regularly review Form I-9 records and timely purge the records.

Please refer to the Tracker I-9 Purge Status website for additional information.

Although Notices of Inspection from USCIS/DHS are rare, it is important to take a proactive approach to risk mitigation and be ready in the event of an audit, especially when preparation time is limited. When USCIS/DHS sends a NOI, employers are required to provide I-9 forms and related documentation within 72 hours of receiving the Notice.

These are the only immediate steps required for campus departments upon receipt of an NOI. Once UCLA Lead Tracker Administrator is informed, they will collaborate with Campus Counsel, UCOP, and Labor Relations to complete audit requirements.

Your campus department may be contacted by the UCLA Lead Tracker Administrator following the notice to request I-9 Form corrections or other action items. Timely participation will be required to meet the limited audit timeline.

Our objective is not to raise concern but to emphasize the importance of a rapid response in the rare event the University is issued an NOI. This includes ensuring that physical mail is checked regularly to avoid any delays.

By sharing these critical steps, we aim to ensure campus departments are prepared for the swift action NOIs require. 

Questions

If you have any questions or concerns, please create a case with CRU.