I-9 Verification is required of New PEO Co-Employees

United States Citizenship and Immigration Service (USCIS) has reconfirmed its longstanding position that PEOs are responsible for conducting I-9 employment eligibility verifications of their new co-employees when taking on new clients. While the employment arrangement with the client is a “continuing employment arrangement,” the employment by the PEO is a new hire and requires the PEO to complete an I-9.  In a letter to NAPEO, the agency reconfirmed the position taken by its predecessor agency (the INS) in 1999.   After the PEO relationship is established, employment eligibility for subsequent hires can be done under one single I-9 for both the PEO and the client.