E-Verify, DRDA, Sponsored Programs and You

Update: January 2011 -- Threshold raised to $150,000
From a memo to DRDA-net on February 4, 2010

To our friends in Research Administration:

We have received a number of calls relating to the e-mail below and wanted to provide some clarification as to roles and responsibilities related to the E-Verify process. We have been involved in the development of the process since its inception and, as always, want to ensure that the University maintains a strong compliance environment while attempting to minimize the impact on all of you.

First, you should know that the requirement currently only applies to federal contracts that are in excess of $150,000 (updated January 2011) ~~$100,000~~ that are signed by the University after September 8, 2009. We currently have eight contracts that fall into this category, but expect there to be more in the future.

DRDA and Sponsored Programs have instituted a few changes in our business processes and wanted to bring you up to date on how we are helping implement the E-Verify requirements.

DRDA will review award documents and amendments to determine if they contain the E-Verify requirement.
If the E-Verify requirements apply to the award or amendment DRDA will add a specific "pop-up" message to your Project Award Notice (PAN) or Project Award Change (PAC) that includes a weblink to the Human Resources information about E-Verify.
Sponsored Programs will remind you of the E-Verify requirement in the confirming e-mail that tells you that your project grant has been established or amended.
In addition, Sponsored Programs will send a copy of the confirming email to your unit's HR liaison and central HR to let them know that this award is subject to E-Verify.
Central HR will run queries on a daily basis to determine who has been appointed to these projects to ensure that the individuals have been E-Verified.

Your role is to ensure that appointments are made to the project on a timely basis and notify your unit's HR liaison as expeditiously as possible so your HR individual and central HR will know who to E-Verify.

We hope this clears up any concerns you may have about your responsibility under E-Verify. Please feel free to go to the HR website at: http://www.hr.umich.edu/everify/ or contact either one of us.

Look forward to seeing all of you at the RAN meeting next week. [Feb. 11, 2010]

Elaine Brock and Rob Barbret

-----Original Message-----

From: Timothy Wood, Senior Director, Human Resources
[mailto:dlday@umich.edu]
Sent: Tuesday, February 02, 2010 3:39 PM
Subject: E-Verify Implementation Update

Dear Deans, Directors and Department Heads:

If your unit provides contracted services to the U.S. government, federal regulations now require the university to electronically verify the identity and work eligibility of all faculty and staff on the contract whenever the requirement (known as the FAR E-Verify clause) is specified. The verification system is known as E-Verify, and all federal contractors must use this new system when required. The university began using E-Verify in December and will continue using it to verify faculty, staff, and new hires working on federal contracts.

WHO IS AFFECTED

Faculty, staff and temporary employees assigned to federal contracts must be validated through the government's E-Verify system, which cross checks information provided on I-9 Forms with data in Social Security Administration and Department of Homeland Security databases.
Approximately 450 faculty and staff members university-wide are currently paid on federal contracts.
Currently grants are not included in this requirement.

WHAT IS THE PROCESS

The individual(s) responsible for administration of any federal contracts in your unit should monitor the contracts for inclusion of the E-Verify requirement.
DRDA and the Office of Sponsored Programs are assisting by providing notice in standard communications when a new or amended contract includes the E-Verify requirement.
When E-Verify is required, the contract administrator should notify their HR Unit Liaison who will partner with University Human Resources to complete the E-Verify process within required time parameters.

If your unit receives federal contracts, you can help ensure university-wide compliance by making certain that PI's and your unit's contract administrator are aware of the E-Verify requirement, routinely monitor all contracts for this new federal obligation, and inform your unit's HR Liaison immediately upon receipt of a contract with the E-Verify clause.

For more information about E-Verify, visit: www.hr.umich.edu/everify or contact E-Verify Compliance initiative Project Manager, David Day at 734/763-2387 or by Email at dlday@umich.edu.

Sincerely,

Timothy M. Wood
Senior Director, Human Resources

Threshold updated: January 2011

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