USCIS Proposes a New Smart Form I-9 – But is it Enough?

The USCIS (U.S. Citizenship and Immigration Services) recently proposed changes to the Form I-9 used for employment eligibility verification, which many people are calling a “Smart” Form I-9 because it supports some data validation and efficiencies when it is completed on a desktop computer. With the new smart form, employers must be able to download it to their computer and fill it out electronically in order to take advantage of the new limited set of field validations, drop-down lists and on-screen instructions.

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Over time, the agency has made efforts to try and improve the paper form and instruction manual, however the process remains difficult and fraught with error. More than 50% of paper forms are flawed and could incur fines ranging from $100-$1,100 per affected record. The proposed changes are great first steps that will begin to help hiring professionals improve their I-9 efficiency and reduce some level of risk.

However, the benefits of the USCIS smart form just scratch the surface when compared to a more automated and full-featured approach built by a reputable technology company, like Tracker’s I-9 Complete solution.

There’s a vast difference between the proposed form and a well designed electronic I-9 software application in terms of the value they provide and effectiveness in getting the job done. The proposed USCIS smart form will still require significant work to ensure compliance.

For example:

  • It does not check PO boxes, nor does it validate US Passport, EAD (I-766) or Permanent Resident Card (I-551) document numbers.
  • It also does not track for employment authorization reverifications, receipt reverification or purge eligibility. You will need to manage these processes manually.
  • It isn’t designed to have the usability of a software tool; the workflow is clunky and involves lots of clicks and repetitive data entry.
  • It doesn’t have electronic signature capabilities, meaning employers will have to print the form and have both employee and employer sign it.
  • There’s no E-Verify integration, creating a process gap that requires duplicitous data entry that could lead to errors.
  • It does not have any security measures in place such as password protections or data encryption. In addition, there’s no audit trail to monitor changes made.
  • It is a one size fits all approach without the technical capacity to handle unique and complex hiring workflows, or the tracking capability required for volume hiring. It is most practical for small organizations with low volume.

In contrast, Tracker’s I-9 Complete is a full-featured, enterprise solution that helps organizations in high growth or volume hiring industries manage their I-9 process with flexibility and simplicity. Its rock-solid compliance logic makes it nearly impossible to perform an unlawful practice. Request a demo of Tracker’s I-9 and E-Verify solution and take the first step toward flawless compliance.


Tracker is the most trusted partner for I-9 and E-Verify compliance software, with thousands of customers, including the top U.S. employers. We are the only I-9 software company with a perfect 13-year record with federal agencies and systems.