The ICE Mutual Agreement between Government and Employers (IMAGE) program is a joint government and private sector initiative that was introduced in July 2006 by the Dept. of Homeland Security (DHS), U.S. Immigration and Customs Enforcement (ICE) to help employers self-monitor with respect to complying with the federal immigration law’s prohibition against hiring workers who are ineligible to be employed in the United States. To participate, employers must meet several requirements: enroll in the federal E-Verify program; submit to an ICE audit of their I-9 forms that new employees complete and related documents; establish a written hiring and employment verification policy that includes a yearly internal audit; and sign a partnership agreement with ICE. The agency says it will train IMAGE participants on proper hiring procedures, fraudulent document detection, use of E-Verify and anti-discrimination procedures.
The rise in participants in the U.S. Immigration and Customs Enforcement’s IMAGE program comes as the Obama administration steps up employer audits. . In fiscal year 2011, the agency conducted 2,496 I-9 audits, up from 2,196 the previous year and far above the 503 in the 2008 fiscal year. ICE initiated 3,291 worksite enforcement cases in fiscal year 2011, versus 1,191 in fiscal year 2008. Initially the IMAGE program fell flat as it held relatively no advantage for private companies to sign up. One of the clauses in partnering with IMAGE is to submit your company to an I-9 audit. And any discrepancy in maintaining I-9 records would end up in costly fines, hence only those organizations with error proof records would be willing to go through with this audit.
Recently IMAGE has given fresh incentives for companies to join with them. Officials with U.S. Immigration and Customs Enforcement (ICE) claim that the benefits of the ICE Mutual Agreement between Government and Employers (IMAGE) program can include lower fines, enhance a company’s image, and reduce the employment of illegal immigrants and the use of fake identification documents. Being “IMAGE certified” can also help a company promote itself to score contracts with other companies and government agencies that place high importance on immigration compliance.
Whether to participate in the IMAGE program would depend on how confident you are with your federal compliance measures taken up in your company. If you’re reasonably confident about the state of your I-9 forms it might be a good faith measure to partner with IMAGE. Another advantage would be that IMAGE partners must submit to a full I-9 audit to join, so it’s less likely they’ll be audited in the future and the possibility of more internal compliance problems is pretty minimal. Best Western International, Chick-fil-A Inc., Hyatt, Kelly Services, Lexmark, Smoothie King and Toyota Motor Engineering and Manufacturing North America are among the leading companies to have joined IMAGE in order to better comply with federal regulations.
