E-Verify Requirements for Grants

As we begin a new fiscal year, we wanted to review the Federal Employment Eligibility Verification requirements for covered federal contracts/awards. If you have federal awards in your area, you need to read this article and become familiar with the requirements as your department is responsible for compliance with these regulations (if applicable to your contract/award) on behalf of the University.

Federal Acquisition Regulation (FAR) rule requires federal contractors to use E-Verify to electronically verify the employment eligibility of employees working under covered federal contracts. This rule reinforces that the Federal government does business only with organizations that have a legal workforce.

Although E-Verify has been around since 1997, as of September 8, 2009, the government started adding the requirement to contracts and subcontracts through the Federal Acquisition Regulation (FAR)

clause 52.222- 54:Employment Eligibility Verification. (E-Verify does not apply to grants/subgrants.) When the FAR clause 52.222-54 is present, either as a direct clause or a flow-through clause on a subcontract, the University must comply with the regulation to verify that each individual who is directly appointed to/paid from the Federal contract is verified through E-Verify.

The Office of Research and Sponsored Programs (ORSP) identifies federal contracts where the E-Verify requirement is applicable at the time of award and communicates this requirement to the Principal Investigator/Project Director (PI/PD) and Grants Accounting.

• Grants Accounting will identify the account as E-Verify in the Oracle Grants Module.
• The PI/PD will receive the notification of the E-Verify requirement on the LEO award letter that is issued by email when the account has been established and via a separate email that provides the link to the form required.

The PI/PD is responsible for communicating this requirement to new hires and existing employees working on accounts where E-Verify is required and notifying Human Resources of these employees. Please refer to the E-Verify form that provides instructions on the process at the following link:

Notice to Employee and Student Employee E-Verify Procedure. Additional information can be obtained here: E-Verify Policy

The University is required to track these employees and will document E- Verify on the employee record once the form has been completed by the employee and processed by Human Resources. The employees who are required to meet the E-Verify requirement can be queried in the Payroll Detail dashboard by selecting Yes on the “E-Verify Awards Only?” prompt below.

IMPORTANT: Failure to comply will result in the employee’s ineligibility to continue working on the federal award and payroll will not be allowed to be charged to the federal award.

 Questions? Contact Grants Accounting at financecustomercare@ohio.edu.