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Administrative (Non-Clinical) Policy
This administrative policy applies to the operations and staff of the University of Wisconsin Hospitals and
Clinics Authority (UWHCA) as integrated effective July 1, 2015, including the legacy operations and
staff of University of Wisconsin Hospital and Clinics (UWHC) and University of Wisconsin Medical
Policy Title: Verification of Work Authorization
Policy Number: 9.02
Effective Date: October 1, 2016
Chapter: Human Resources
The purpose of this policy is to ensure that the University of Wisconsin Hospitals and Clinics Authority
(UWHCA) complies with all state, local and federal laws related to employment eligibility, wage data
reporting, and fair employment practices.
II. POLICY ELEMENTS
A. The Immigration and Reform and Control Act of 1986 (IRCA) requires employers to hire only
persons who may legally work in the United States. UWHCA must verify the identity and
employment eligibility of anyone to be hired or rehired.
B. All employees are expected to have a valid Social Security number (SSN). UWHCA requires a
valid SSN so that it may properly credit each employee's Social Security (SS) Retirement
Account. The Recruitment department verifies employment eligibility and SSN data for all
employees. The Graduate Medical Education office, in conjunction with the Human Resources
(HR) department, completes this procedure and all procedures described below for the GME
C. All employees are required to provide a SSN due to utilization of the E-Verify system. If needed,
employees should apply for a SSN prior to hire, but if they are unable to do so, HR will direct the
employee to the SSA for assistance (800-772-1213 or
http://www.ssa.gov/ssnvisa/help_immigrant.htm). In most cases, the employee should be able to
procure a SSN within two (2) weeks of filing his or her application. The employee shall provide a
copy of the SSA receipt and shall report their SSN to Employee Relations upon receipt of their
SSN card. Employee Relations will follow up with employees who start work without a SSN, to
ensure that such employees have applied for and received a SSN.
D. UWHCA recognizes that English is not the native language for many. Therefore, UWHCA will
offer and provide translation services to carry out this policy.
E. UWHCA recognizes that some employees may require assistance with administrative matters
related to employment verification and will refer those employees to the Social Security
Administration (SSA) office or to local advocacy organizations for support and assistance.
UWHCA cannot promise confidentiality to employees who discuss their immigration status with
F. UWHCA is required to abide by all applicable laws and regulations regarding the verification of
employment eligibility. As such, UWHCA retains the right to modify its practices and procedures
as required by law.
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A. Verification of Work Authorization
1. UWHCA shall utilize the E-Verify system for verification of work authorization. UWHCA
shall initiate the E-Verify verification procedures for new employee within three business
days after date of hire. The E-Verify system will be used for all new employees.
2. UWHCA shall not take any adverse action against an employee based upon the employee's
perceived employment eligibility status while SSA or DHS is processing the verification
3. If a tentative non-confirmation finding is received, this does not establish and UWHCA
shall not interpret it to mean that the employee is not authorized to work. The employee
shall be given the full and fair opportunity to contest the finding as provided in the E-
Verify requirements. If an employee chooses to contest a tentative non-confirmation
finding, no adverse action shall be taken against the employee during that time.
4. If the employee does not choose to contest or if a final non-confirmation is issued,
UWHCA shall terminate the employee's employment.
5. UWHCA shall use the information obtained through the E-Verify system only to confirm
employment eligibility and for no other purpose.
6. Generally, anonymous tips of allegations of improper work authorization will not be
pursued for investigation, unless other factors indicate that the anonymous tip may be
credible. Any other information received from outside, non-governmental sources will be
referred to Employee Relations for evaluation before any investigation is commenced.
Information received from outside sources, if deemed reliable by Employee Relations, may
serve as a basis for investigation.
7. UWHCA will modify any of these procedures if informed by any federal or state agency
that they are inadequate to: prevent the employment of unauthorized workers, ensure that
benefits are correctly attributed; and/or prevent discrimination based on national origin.
B. I-9 Reverification Process
1. Rehire. Former employees rehired within three (3) years of the initial completion of the I-9
form, must update their original I-9 form, or a new I-9 form may be completed in the event
the prior form has been archived or is no longer available. The HR rep will record on the
original I-9 form in Section 3, the date of rehire, sign and date. All previously completed I-
9 forms will be attached to the new I-9 form.
2. U.S. Work Authorization Extension
a. Employee Relations will notify employees with work authorization expiration
dates, identified in Section 1 and/or 2 of the I-9 form, of the requirement to
provide documentation of the extension of U.S. work authorization.
b. Employee Relations notification will inform the employee that employment will
cease on the expiration date should the employee fail to take the proper steps to
extend his or her employment authorization.
c. For I-9 form purposes, except in instances where the employee has an employer-
sponsored visa, the renewal, update and/or extension of the work authorization,
as well as all related expenses, rest solely upon the employee. For employer-
sponsored visas, the employer is responsible only for fees that are mandated to be
paid by the employer.
d. The employee is responsible for providing Employee Relations with the work
authorization extension. Upon receipt, Employee Relations will complete Section
3 of the I-9 form, or complete a new I-9 form and attach it to the original I-9
form. Both forms must be retained together. The reverification and updating of
information must occur prior to the date of the expiration.
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C. Wisconsin Child Labor Permit
1. Child labor refers to the employment of anyone under the age of 18 (“minor") in any type of
business. Minors may be employed only in certain types of work until they turn 18 and are no
longer subject to the child labor law. They may also be employed only during certain hours of
the day and of the week. The time of day and types of employment in which they are allowed
to work depend on both the age of the minor and whether or not school is in session during
the period of their employment.
2. UWHCA is responsible for having a work permit on file for a minor before allowing him/her
to work at UWHCA.UWHCA is also responsible for making sure that minors work only the
3. The HR department will retain the Child Labor Permit in the employee's personnel file. In the
event the minor terminates employment and is then later rehired, a new Child Labor Permit
will not be required.
4. UWHCA will reimburse the minor for the Child Labor Permit fee after they have provided
proper reimbursement documentation to the Payroll department.
This Policy creates no rights, contractual or otherwise. Statements of policy obtained herein are not made
for the purpose of inducing any person to become or remain an employee of UWHCA, and should not be
considered "promises" or as granting "property" rights. UWHCA may add to, subtract from and/or modify
this Policy at any time. Nothing contained in this Policy impairs the right of an employee or UWHCA to
terminate the employment relationship at-will.
Sr. Management Sponsor: Vice President, Human Resources Operations
Author: HR Compliance/Corporate Counsel
Reviewer: Director, Employee Relations
Approval Committee: UW Health Administrative Policy & Procedure Committee
UW Health Chief Administrative Officer
Previous revision: 102013
Next revision: 102019