I-9 Requirement and Database Matches

Current Law:

• All students working on campus must complete the I-9, an INS requirement, in order to prove that they are U.S. citizens or permanent residents eligible to work in the United States. Students who apply for financial aid complete the federal FAFSA required by the Department of Education. The federal FAFSA matches databases in INS and the Social Security Administration that satisfy the citizenship requirements for federal aid, including Federal Work-study.

Issue:

• The present system of clearing students for work on campus is duplicative, costly, and inefficient.

• Most students who work on campus are Federal Work-study students. Their citizenship status has already been established through the FAFSA database matches.

• Nevertheless, hundreds of students (at a small college), thousands (at a large university), must appear in person and present original documents establishing their citizenship to campus officials at the start of school. This creates lines, confusion, and delays for students. It creates costs for colleges and universities.

• Ironically, international students are exempt from the I-9 requirement because, even though they are not citizens, they are permitted by INS to work on campus.

Proposal:

• The Department of Education already recognizes the database matches as sufficient to allow students to qualify for federal aid funds. INS should recognize that students whose eligibility to work has been established through database matches with Social Security and its own database, should not have to complete the I-9 in order to work on campus.

Possible Objections:

• INS would have to accept the results of another agency (DOE) as sufficient for employment on campus.

Counter Argument:

• The data is already being matched with INS data in the first place.