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Impact of the New USCIS Guidelines for Lawful Permanent Residents on I-9 Verification

The USCIS announced on January 12 that starting this month, they will be replacing the stickers that are currently used to extend the validity of the Permanent Resident Card. This document, also referred to as a “Green Card” or Form I-551, is currently issued to Lawful Permanent Residents, (LPRs), and is often used as a key document in the I-9 process.

The new process requires LPRs to file a Form I-90, the Application to Replace Permanent Resident Card, as their Green Cards approach the expiration date. The applicant will then be issued a form I-797 Notice of Action, which will serve as a receipt notice for the I-90. When the expiring Green Card is presented in tandem with the I-797, the Green Card’s validity is extended 12 months from the date on the front of the card.

USCIS further states that applicants who file a Form I-90 should receive their receipt roughly 7-10 days after USCIS receives the application. Read the USCIS announcement for further information.

For I-9 purposes, the combination of the expired Green Card and the I-797 serves as one List A document to be recorded in Section 2. When completing the I-9, employers should enter the information from this document combination as follows:

  • In the Document Number field, enter the card number provided on the expired Green Card.
  • In the Expiration Date field, enter the date that is 12 months from the “Card Expires” date on the expired Green Card.
  • In the Additional Information box, write “PRC Ext” and the I-90 receipt number from the Form I-797.

Employers who retain copies of documents presented during the I-9 process should retain copies of the Green Card and the I-797 with the I-9. Additionally, USCIS reminds employers that they should not reverify employees who present this document combination.

Updates like this can leave many employers feeling confused and unsure of what is required to maintain proper Form I-9 compliance.  CIC Plus compliance experts are here to help.  Along with a fully compliant I-9 Management system, employers of all sizes from every industry can rely on CIC Plus to assist them in ensuring proper Form I-9 compliance, regardless of the situational complexity.  For more information, please contact us.

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