The DHS March 20 announcement allows for remote inspection of documents and providing a “COVID-19” annotation in the Section 2 “Additional Information” field. How should employers handle this annotation if they use an electronic Form I-9 that does not have this field?

The employer can physically or electronically attach a note to an employee’s Form I-9 providing the information that ICE guidance has requested in the Form I-9 “Additional Information” field. Any notation should clearly explain the situation and be signed and dated by the employer.