Employment Eligibility Policy [Effective 7/2/2026]

The purpose of this policy is to outline the legal requirements for verifying the identity and employment authorization of each person Rhode Island School of Design hires.

This policy is mandated by the federal government for each RISD student and non-student employee hired after November 6, 1986. The necessary actions do not need to be completed for the following individuals:

• hired before November 6, 1986
• independent contractors
• individuals providing labor to RISD who are employed by an agency providing contract services (e.g., temporary agency) or otherwise not paid by RISD’s payroll (e.g., unpaid interns)
• Individuals not physically working in the United States or its territories

• Independent Contractor: a self-employed individual in an independent trade, business, or profession who offers their services to the public. An independent contractor, as a matter of economic reality, is not economically dependent on an employer for work and is in business for themselves. An independent contractor has the freedom of control over their work, including the methods and means by which the work is completed. RISD may only direct the result of the work.
• Employee: an individual who, as a matter of economic reality, is economically dependent on the employer. An employee works for an employer, where the employer has the right to control the manner and means by which the work is performed.
• Form I-9: a form issued by the U.S. Citizenship and Immigration Services (USCIS) used to verify the identity and employment authorization of individuals hired for employment in the United States.
• Authorized Representative: an individual or entity designated by RISD to complete Section 2 of Form I-9 on RISD’s behalf by physically examining original identity and employment authorization documents, consistent with USCIS guidance.

RISD must complete and retain a Form I-9 for each employee hired after November 6, 1986, and may not discriminate against individuals on the basis of national origin, immigration status, or citizenship. An I-9 must be completed every time a person is hired, rehired, or when temporary employment authorization documents expire.

For all employees hired after November 6, 1986, an I-9 must be completed or reverified every time a person is hired, rehired or temporary employment authorization documents expire. Federal law requires all employers to verify the identity and employment eligibility of all persons hired to work in the United States. Accordingly, Section 1 of the Form I-9 must be completed on or before an employee’s first working day and all new employees will be required to complete fully the I-9 verification process and produce the appropriate documentation within three business days of starting work. All offers of employment are contingent upon a candidate’s fulfillment of this requirement and a failure to do so will result in termination in accordance with the timelines required by the USCIS.

RISD or its authorized representative must physically examine the documents provided, and may not permit documents to be provided via remote means such as webcam or other remote technology. RISD must review a document submitted for the I-9 process to determine if they are genuine, and must not accept documents that do not appear genuine, cannot verify the individual’s identity, or do not provide eligibility to work in the United States. Documents that do not appear to be genuine may be brought to the attention of General Counsel prior to further action. Additional inquiry of documents may be permitted where the employee name or other verifying information does not match, and any reasonable explanation for the discrepancy must be documented in an attachment to the I-9 file.

Responsible Parties

Human Resources (HR) - responsible for ensuring that all non-student employees complete Form I-9 within the timelines required by the USCIS. HR is further responsible for the maintenance, retention, and secure storage of Form I-9 records for all non-student employees in accordance with federal recordkeeping requirements.

Student Employment - responsible for ensuring that all student employees complete Form I-9 within the timelines required by the USCIS. Student Employment is further responsible for the maintenance, retention, and secure storage of Form I-9 records for all student employees in accordance with federal recordkeeping requirements.

Supervisors - responsible for ensuring that new student and non-student employees complete all required onboarding activities, including Form I-9 verification, prior to beginning work and in accordance with all applicable federal and state laws and institutional policies.

Employees - responsible for completing all required onboarding tasks, including the completion of Form I-9, within the timeframes established by the USCIS and institutional policy.

Anti-discrimination

At all times, it is critical to treat all new hires and employees equally under this Policy. All aspects of the I-9 process performed by RISD must be uniform with respect to every new hire and employee.

RISD cannot specify which document the employee may present to establish employment authorization and identity, so long as those documents provided are documents identified on the USCIS list of acceptable documents.

RISD does not require U.S. Citizenship or Permanent Residency of any applicants, unless pursuant to government contract. U.S. Citizens are not entitled to different or more favorable treatment.

For procedures relevant to specific employment scenarios, please seek guidance from Human Resources.

Policy Sanctions

RISD reserves the right to review alleged violations of this policy in conjunction with other appropriate offices and under other applicable College policies, procedures, and collective bargaining agreements, including but not limited to those listed under Related Policies. Failure to comply with this policy and other Related Policies is subject to disciplinary action and sanctions per applicable disciplinary procedures.

Violations of this policy may include the revocation of hiring privileges or disciplinary action to a supervisor or manager for allowing work to be performed by a student or non-student employee without completing all required onboarding tasks, including the completion of Form I-9, within the timeframes established by the USCIS and institutional policy.

• Student Employee Pay Policy
• Nondiscrimination Policy & Procedures

This policy was created on

This policy was last reviewed/modified on: 6/18/2026

Next scheduled review: 5/1/2028

Issuing Office

Human Resources

Responsible Officer

Vice President, Human Resources

Vice President, Enrollment Management

Individuals/offices required for review and changes

General Counsel's Office

Director, Employment