E-Verify

Research Administrator’s Network MeetingNovember 1, 2012

David Day, University Human Resources

Why is E-Verify important to us:

• $168M of federal contracts at UM have the E-Verify requirement

• Contracts & amendments with the requirement are routinely received

• Non-compliance with E-Verify requirements = loss of all federal contract dollars to all areas of UM (not just the non-compliant unit/dept.)

What is E-Verify• An internet based system operated by U.S.

Citizenship and Immigration Services (USCIS) in partnership with the Social Security Administration (SSA) and the Department of Homeland Security (DHS)

• Employee information is entered into E-Verify were it is checked against federal databases to confirm identity and employment eligibility

E-Verify at the U-M• E-Verify regulations took effect in September,

2009 and require federal contractors to participate in the E-Verify program– Applies to federal contracts not grants– Federal contracts of ≥$100,000 & ≥120 days– Applies to sub-contracts and sub-contractors

• U-M began using E-Verify in 2009 in accordance with the regulations

E-Verify at U-M• U-M enrollment requires us to E-Verify faculty,

staff & temporaries assigned to a federal contract containing the E-Verify requirement– Any faculty, staff, & temporaries paid from a contract

with the E-Verify requirement must be E-Verified• Individuals hired before 11/6/1986 are exempt

– Within 3 days for new hires & 30 days for existing employees transferring onto contract

– Can not prospectively E-Verify– Only have to E-Verify once while at UM

E-Verify at U-M• A Process Overview:

– A process exist to assist you with identifying federal contracts with the E-Verify clause

• ORSP & Office of Sponsored Programs are reviewing contracts for the FAR E-Verify clause

– Notices from these offices will assist in alerting you to the E-Verify clause

• University HR audits payroll records to determine which faculty, staff & temporaries were paid by a project with the E-Verify clause

– Can not rely on this “audit” due to timeliness requirements

E-Verify at U-M• E-Verify Timelines require:

– New UM hires onto covered contracts must be E-Verified within 3 days of hire

• New positions that will be paid by a covered federal contract should be identified at time of recruiting

– Current faculty, staff, temporaries assigned to covered federal contract must be E-Verified within 30 days

• From date that they begin work on the project

What you should do:

• Monitor all contracts & PAN notices for E-Verify requirement

• Identify the individuals appointed to or will be appointed to covered contracts

• Ensure appointments are processed on a timely basis

• Work with unit/department HR to coordinate getting employees E-Verified

E-Verify Resources

• More information on E-Verify is available at the following address;http://www.hr.umich.edu/everify/

• David Day, UHR, 763-2387 or dlday@umich.edu