GB541 Unit 8 Compliance Audit Plan Example

Reviewing 3,950 Inherited I-9 Forms: A Unit 8 Compliance Audit Plan for an Acquisitive Veterinary Group

[Student Name]

Purdue University Global

GB541: Strategic HR Law and Risk Management

Unit 8 Compliance Audit Plan

[Instructor Name]

[Date]

The veterinary group, its hospitals and every count and cost are composite and illustrative; the federal rules described are real and summarized as of the course term, and the plan is educational, not legal advice.

1. Scope and Objective

The audit covers every Form I-9 Quillmere is required to keep at its 58 hospitals, its support office and the closed Columbus contact center. Its objective is to find and correct paperwork errors before a government inspection does, to confirm that each current employee's form shows the employer examined acceptable documents, and to identify process failures that produce errors in new forms. The audit does not reverify employees whose status was properly verified, and it does not ask any employee for new documents unless a form is missing or shows a Section 2 problem that only fresh documents can fix.

Quillmere does not participate in E-Verify, so the audit includes no E-Verify tests; that status is confirmed with counsel before fieldwork begins.

2. Counting the Population

Employers must keep each employee's form for three years after the date of hire or one year after employment ends, whichever is later (8 C.F.R. § 274a.2, 2024). Applying that rule to payroll records gives the population.

Active employees. About 2,900 people are currently employed, and each must have a form on file.

Former employees still inside the retention period. About 1,050 people who left Quillmere are still within the period calculated for each of them from hire and separation dates. Forms for anyone outside the period may be destroyed under the company's records schedule, but only after the audit, so that nothing is discarded while it might be needed.

Total. The population is 3,950 forms.

3. Method

3.1 Full review for acquired hospitals. The 21 acquired hospitals hold 1,140 forms. These hospitals followed their own previous owners' practices, so every form is reviewed.

3.2 Sample for the remaining hospitals. The other 2,810 forms come from hospitals that have used Quillmere's onboarding process for at least two years. A ten percent sample, 281 forms, is drawn at random within each hospital so that every hospital is represented in proportion to its headcount. If the sample error rate at any hospital exceeds five percent, all forms at that hospital move to full review.

3.3 Selection without bias. Forms are selected by hospital and by random number, never by name, national origin, citizenship or appearance. Choosing particular employees for closer scrutiny on those grounds would itself be unlawful discrimination (8 U.S.C. § 1324b, 2024).

3.4 Effort and cost. Reviewers need about twelve minutes a form. Reviewing 1,421 forms takes about 284 hours. At a loaded rate of $52 an hour for trained HR reviewers, staff time costs about $14,778. Outside immigration counsel reviews the error log, the correction memos and any form missing entirely, estimated at 29 hours at $355, or $10,295. The audit therefore costs about $25,073.

The audit is priced so that a full review of the acquired hospitals is affordable and the sample elsewhere is large enough to trigger a full review if it finds trouble.

4. Test Attributes

Each form is tested against five attributes, and any failure is logged with the form's hospital and hire date.

Attribute 1. Section 1 was completed and signed by the employee no later than the first day of work for pay.

Attribute 2. Section 2 was completed within three business days of the first day of work.

Attribute 3. The documents recorded in Section 2 are on the lists of acceptable documents, and the combination presented is valid, either one List A document or one from List B and one from List C.

Attribute 4. The employer did not request more or different documents than the rules require, which would be document abuse under the anti-discrimination provision (8 U.S.C. § 1324b, 2024). Copies of documents in the file are checked for this pattern.

Attribute 5. Required fields are complete, including the employer's certification, dates and, where it applies, the expiration date of an employment authorization document.

5. Correction Rules

Corrections follow one written rule so that a fix never looks like concealment.

5.1 Errors in Section 2. The reviewer draws a single line through the incorrect information, enters the correct information, and initials and dates the change on the date it is made. The original entry stays legible.

5.2 Errors in Section 1. Only the employee may correct Section 1. HR asks the employee to make the correction, initial it and date it.

5.3 Missing sections or forms. A missing Section 2 is completed now, after examining the employee's documents, and dated with today's date. A missing form is replaced with a new form dated today. Nothing is ever backdated.

5.4 No erasures. Correction fluid, erasing and replacement of pages are prohibited.

5.5 Explanatory memo. Each corrected form receives an attached memo stating what was wrong, what was corrected, who made the change and why.

5.6 Expired authorizations. If an active employee's employment authorization has expired without reverification, HR contacts the employee promptly, explains the requirement and completes reverification, following counsel's advice on timing.

Paperwork violations carry civil penalties for each form (8 U.S.C. § 1324a, 2024), and a good-faith correction made before an inspection is far better evidence of compliance than a stack of forms with uncorrected errors.

6. Ongoing Monitoring

After the audit, HR samples thirty new-hire forms per region each quarter across Quillmere's six regions, 180 forms in all, testing the same five attributes. Any region with an error rate above five percent in a quarter gets retraining for its hospital managers and a full review of that quarter's forms. Next year's evidence that onboarding works is a sustained error rate below five percent in every region for four consecutive quarters.

7. Reporting

The audit lead reports to the risk committee within ninety days with the error rate by hospital and attribute, the corrections made, any missing forms replaced and the root causes found. Monitoring results go to the committee each quarter. The register score for this exposure, currently twelve, is updated once the audit is complete.

References

8 C.F.R. § 274a.2 (2024). https://www.law.cornell.edu/cfr/text/8/274a.2

8 U.S.C. § 1324a (2024). https://www.law.cornell.edu/uscode/text/8/1324a

8 U.S.C. § 1324b (2024). https://www.law.cornell.edu/uscode/text/8/1324b