Why it matters
Late E-Verify case creation, an unremediated Tentative Nonconfirmation, or a Section 2 completed past the third business day are each independently citable findings — and they surface as a pattern, not a one-off, once ICE pulls the I-9 binder. Federal construction contracts carrying FAR clause 52.222-54 make E-Verify participation a contract term, not a courtesy; a lapsed case list can put award eligibility at risk. Reverifying against a List B document, which DHS explicitly disallows for reverification, is one of the most common self-inflicted findings on an otherwise clean file.
How we do the work
I-9 completion tracking
Section 1 logged by the employee's first day, Section 2 completed and signed by an authorized representative within 3 business days of the start date, tracked per hire against a standing deadline calendar.
E-Verify case creation
Case opened in E-Verify within the federal 3-business-day window from date of hire, case number and status logged against the same hire record. No case is created before Section 2 is complete.
Tentative Nonconfirmation (TNC) handling
Employee notified and referral instructions issued the same day a TNC posts, DHS or SSA contact deadlines tracked to close before the case lapses to Final Nonconfirmation.
Reverification and document expiration
List A and List C document expirations calendared per employee; reverification completed through Section 3 before lapse. List B documents are never reverified, per DHS rule.
Self-audit and retention
I-9 files retained per the 3-years-from-hire or 1-year-after-separation rule, whichever is later, with a standing self-audit pass run ahead of any ICE Notice of Inspection.
What you receive
- Per-employee I-9 tracking log (Section 1, Section 2, and Section 3 dates and deadlines)
- E-Verify case log matched to hire dates, confirming every case opened inside the federal 3-business-day window
- Tentative Nonconfirmation (TNC) referral documentation and closure tracking through DHS/SSA resolution
- Document expiration and reverification calendar (List A or List C only — never List B)
- Retention-compliant I-9 file set with a per-employee purge schedule (3 years from hire or 1 year after separation, whichever is later)
- Self-audit findings memo, delivered ahead of any ICE Notice of Inspection response deadline
I-9 and E-Verify administration runs as a compliance-admin module at an anchor rate of $349 a month. Headcount and hiring volume are confirmed in the countersigned engagement after a roster and hire-cadence review. Configure this service and see your estimate in the engagement builder.
Questions contractors ask
Will you actually create and manage our E-Verify cases, or just track deadlines?
Both, once the Employer Agent enrollment is active. Before that DHS/USCIS MOU is signed, we run I-9 completion tracking only. Once it's signed, we create cases, handle TNC referrals, and close cases under our agent designation, with your review at each step before anything is filed.
What counts as the 3-day clock for E-Verify?
Three business days from the employee's first day of work for pay, not from when Section 2 gets signed. We track both dates separately so a slow paperwork turnaround doesn't quietly blow the E-Verify deadline.
Do you handle federal contractor E-Verify requirements, like FAR clause 52.222-54?
Yes. Contracts carrying that clause require enrollment in and use of E-Verify for new hires and any employee assigned to the contract. We track that population separately from your general workforce so the contract-required case list stays clean.
Aeternus Dynamics uses AI-assisted tools to help prepare and check compliance documents; all deliverables are reviewed by a qualified human before submission or use. Aeternus Dynamics is not a law firm and does not provide legal advice. See our Terms & Disclosures.