July 27, 2006
The Department of Homeland Security announced a new initiative yesterday to help businesses do a better job of ensuring that their workforces are made up of authorized workers. IMAGE (“ICE Mutual Agreement between Government and Employers”) offers increased collaboration between the Immigration & Customs Enforcement agency of DHS and private employers to reduce employment of undocumented workers. The IMAGE program requires that employers agree to: 1) receive federal training; 2) submit to an ICE I-9 audit; 3) register and use the Employment Verification Program; and 4) adhere to a list of ICE “Best Business Practices” that includes:
- creation of internal training programs for employment verification;
- establishment of regular I-9 audits by neutral parties;
- creation of protocols for Social Security no-match letters;
- creation of an employee “tip line” to report violations;
- creation of safeguards to prevent unlawful discrimination;
- self-reporting of violations to ICE;
- regular assessment of adherence to Best Practices by subcontractors;
- annual reports to ICE on effectiveness of program.
