Form I-9 Compliance – A Growing Concern in Healthcare
Immigration has been a key political topic for a number of years. If the early presidential rhetoric is indicative of what’s in store for 2016, it’s not likely to go away anytime soon. U.S. Immigration Customs Enforcement (ICE) has been the tip of the immigration enforcement spear for just as many years with raids, E-Verify, fines, and contradictory state positions on each. There were 642 companies that were fined $16M dollars in administrative penalties last year and hundreds who were criminally prosecuted as well.
Healthcare delivery has changed in a multitude of ways, which have driven down participation in traditional employment models in favor of part-time, per diem, and on-call or as needed workforces. Many of these employees seldom report to or work from an employer’s brick and mortar location.
Changing to a less than full-time work environment creates a number of workforce management related challenges to healthcare providers that onboard new hires remotely. Many of these potential issues and risks relate to having Form I-9 completed accurately and efficiently, a strict requirement to avoid any potential fines. What can be done to minimize the risk and improve the overall onboarding process?
Key steps healthcare providers can take to ensure a “good faith effort” at complying with Form I-9 requirements include:
- Standardized processes: With a detailed, uniform remote hiring process and documentation of a standard operating procedure (SOP), it will be easy to not only meet the growing demand for remote work arrangements, but also do so compliantly. For instance, having a designated authorized representative to complete Section 2 of Form I-9 can ensure consistency and minimize the chance for errors.
- Knowledge transfer: The ability to pass information, best practices, and guidance to those authorized representatives to ensure Section 2 is completed correctly is essential to any successful remote I-9 process.
- Adopt the right technology: A good electronic platform can help to provide added security, visibility, and compliance while simplifying the overall remote hiring process. A comprehensive platform can also minimize costly mistakes and errors through field validation tools, while enabling centralized control for improved management and reporting.
Remote Healthcare Professional Hiring and Form I-9
Some of the most challenging employees to onboard are casual, part-time, or per diem HCP populations. Given increasing and ever changing compliance concerns around Form I-9, the need has never been more present for an automated, compliant solution in healthcare. Case in point, ICE regularly targets low wage industries for enforcement efforts. In 2014 the restaurant industry suffered the greatest number (5,118) of DOL-related FLSA overtime and minimum wage violations. Not surprisingly ICE hasn’t been far behind. What may surprise you is that healthcare is number two in terms of violations with 1,581 according to the DOL. Yet working with a partner that can provide access to authorized agents across the country to help complete Form I-9 remotely while offering a comprehensive technology platform to streamline the process has helped many healthcare providers ensure an efficient and compliant approach to onboarding the remote HCP employee populations.