July 26, 2010
ICE Updates Best Practices for IMAGE Program
Employers seeking to participate in the ICE Mutual Agreement between
Government and Employers (or IMAGE) program must agree to certain
conditions, including adhering to IMAGE Best Employment Practices:
- Use E-Verify to verify the employment eligibility of
all new hires.
- Use the Social Security Number Verification Service
(SSNVS) and make a good faith effort to correct and
verify the names and Social Security numbers of the
- Establish a written hiring and employment
eligibility verification policy.
- Establish an internal compliance and training
program related to the hiring and employment
verification process, including completion of Form I-9,
how to detect fraudulent use of documents in the
verification process, and how to use E-Verify and SSNVS.
- Require the Form I-9 and E-Verify process to be
conducted only by individuals who have received
appropriate training and include a secondary review as
part of each employee's verification to minimize the
potential for a single individual to subvert the
- Arrange for annual Form I-9 audits by an external
auditing firm or a trained employee not otherwise
involved in the Form I-9 process.
- Establish a procedure to report to ICE credible
information of suspected criminal misconduct in the
employment eligibility verification process.
- Establish a program to assess subcontractors'
compliance with employment eligibility verification
requirements. Encourage contractors to incorporate IMAGE
Best Practices and when practicable incorporate the
verification requirements in subcontractor agreements.
- Establish a protocol for responding to letters
received from federal and state government agencies
indicating that there is a discrepancy between the
agency's information and the information provided by the
employer or employee (for example, "no match" letters
received from the Social Security Administration).
- Establish a tip line mechanism (inbox, e-mail, etc.)
for employees to report activity relating to the
employment of unauthorized workers, and a protocol for
responding to employee tips.
- Establish and maintain appropriate policies,
practices and safeguards against use of the verification
process for unlawful discrimination, and to ensure that
U.S. citizens and authorized workers do not face
discrimination with respect to hiring, firing, or
recruitment or referral for a fee because of citizenship
status or national origin.
- Maintain copies of any documents accepted as proof
of identity and/or employment authorization for all new
ICE is holding a training event on August 9 and 10,
which will address implementation of the new IMAGE
practices. Other topics will include Establishing an
immigration compliance program, proper hiring
procedures, fraudulent document detection, use of
E-Verify, and anti-discrimination procedures.
Join GT for events in conjunction with the government sponsored
training by ICE on its IMAGE program on August 9 and 10, 2010 at The
Ritz Carlton in Pentagon City. Both the ICE and GT registrations are
complimentary. Register for this event at