DHS Announces New IMAGE Associates ProgramFriday, June 6, 2008
(American Meat Institute)
DHS has announced its new IMAGE Associates program which has similar requirements to the IMAGE program but provides an enrolling company a two-year transition period for completing an I-9 audit retroactively.
A comparison of the requirements of the IMAGE Associates Program with the requirements of the existing IMAGE Program, include these primary differences:
- IMAGE requires an ICE I-9 audit of the current workforce prior to allowing the employer to participate. In this process ICE would run DHS issued document numbers and Social Security numbers through E-Verify. Once this audit is completed and the employer is accepted into IMAGE, the employer would not be subject to another I-9 audit and inspection for two years.
IMAGE ASSOCIATE allows deferral of the ICE audit until 2 years after the signing of the agreement unless the employer requests an earlier audit; however it would require that employers enroll in the Social Security Number Verification Service (SSNVS) to verify the validity of the Social Security numbers of the current workforce. In effect, ICE is requiring that the SSA part of E-Verify (verification of the validity of SSNs) be conducted of the current workforce. The only difference is that the company would do it, not ICE. This still would burden the employer with implementing a no-match procedure for SSNs that ICE would later audit. Presumably, if the employer continued to employ persons who’s SSNs could not be confirmed, then the employer faces legal exposure.
- Two years after the IMAGE Associate agreement is signed, the employer would be required to seek full IMAGE membership.
- IMAGE requires a participant to file an annual report with ICE to track results and assess the effect of participation in IMAGE. The report would include information about persons removed from employment; instances and resolution of no-match letters; organizational changes; identification of vulnerabilities; and listing of technical violations.
- IMAGE ASSOCIATE does not appear to have an annual reporting requirement.
For m ore information on the program, click here: (http://www.meatinstitute.org/ht/a/GetDocumentAction/i/13346)share on facebook share on twitter