Finding Text
Type of Finding: (C) Finding that Does Not Rise to the Level of a Significant Deficiency (Other Matters) Involving Internal Control Over Financial Reporting Condition During our review of personnel documentation, we selected 8 employee personnel files for testing from a population of 8 employees for the year ended December 31, 2023. For 5 of 8 employees selected, management was unable to provide a completed Form I-9 (or evidence of compliant electronic completion/retention) upon request. Criteria Federal regulations require employers to complete and retain Form I-9 for each individual hired for employment in the United States and to make Forms I-9 available for inspection. Forms I-9 must generally be retained for three years after the date of hire or one year after employment is terminated, whichever is later. Effect Not properly completing and retaining Form I-9s may result in noncompliance with federal employment eligibility requirements and could expose the organization to potential fines, penalties, or sanctions. Additionally, inadequate personnel records weaken internal controls over human resources and payroll. Cause Staff responsible for onboarding were not trained on I-9 requirements, and management did not implement compensating review controls. Recommendation Management should implement a documented I-9 compliance process that requires Form I-9 completion within required timeframes for all new hires. Management should also review current personnel records to identify missing I-9s and remediate where permissible, retaining documentation of remediation actions. Views of Responsible Officials and Planned Corrective Action New Space will comply with federal employment eligibility requirements by ensuring a Form I-9 is completed for every employee within three business days of their start date. Employees must provide acceptable documentation as required, and completed forms will be securely maintained and retained for the required period. The Financial Analyst will periodically review personnel files to confirm compliance, and any missing or incomplete forms will be addressed promptly with documentation of corrective actions retained. Policy Owner: Financial Analyst; Implementation Date: January 31, 2024