1. Rehire
A rehire occurs when a former employee is hired back within three years of the date of the original Form I-9.
Employer Options:
Option A: Complete a new Form I-9 altogether, or
Option B: Use Supplement B to update and re-affirm the original I-9.
What’s required:
Confirm that the original I-9 is still accurate (name, DOB, SSN, etc.).
If the employee is still authorized to work (and documentation is valid), simply note the rehire date on Supplement B.
If the employee’s work authorization has expired, you must also reverify their authorization (see below).
👉 Key Point: For a rehire, you’re essentially saying: “We already did the I-9; nothing’s changed except they’re back on payroll.”
🔹 2. Reverification
A reverification is required when an employee’s employment authorization or documentation has expired.
When Required:
If the employee presented a time-limited work authorization at hire (e.g., an Employment Authorization Document (EAD), I-94 with work authorization, or certain visas).
Not required for U.S. citizens or permanent residents with an unexpired green card (since they are permanently work-authorized).
What’s required:
Complete Supplement B with the updated work authorization information.
Examine a new document from List A or List C showing continued work authorization.
Employer and employee sign and date Supplement B.
👉 Key Point: Reverification is about continuing work authorization, not about rehire status. It applies to current employees, not just returning ones.
⚖️ Legal Distinctions
Rehire = Employee leaves and comes back within 3 years. Employer can reuse prior I-9 (via Supplement B) or complete a new one.
Reverification = Employee is already on payroll, but their work authorization document expires. Employer must reverify with new valid documents (via Supplement B).
Overlap: If a rehire’s prior work authorization expired, the rehire process also requires reverification.
✅ Summary Rule of Thumb:
Rehire → Confirm employment eligibility still valid; re-date/sign on Supplement B (or complete new I-9).
Reverification → Update expiring work authorization only with acceptable new documents.