Most employers think of Form I-9 as a one-time task: the employee fills out Section 1, someone reviews documents in Section 2, and the form goes into storage. For many employees, that is true. But two situations bring an employer back to the form after the first day: an employee's work authorization is about to expire, or a former employee is rehired. Both are handled through Supplement B, the Reverification and Rehire section of the current Form I-9.
Supplement B is short, but it trips up a lot of HR teams. Some employers reverify too often, which can create discrimination risk. Others miss reverification deadlines, which can lead to paperwork violations or employing someone who is no longer authorized to work. This guide walks through when to use Supplement B, when not to, and how to keep the process clean.
What Supplement B replaced
Before the August 2023 edition of Form I-9, reverification and rehire details went into Section 3 of the form. The current edition moved that information to a separate page called Supplement B. The purpose is the same, but there is a practical difference: Supplement B can be completed and attached as many times as needed, so employers no longer have to complete a new Form I-9 just because Section 3 ran out of room. Employers should only print or attach the Supplement B page when it is actually needed.
When reverification is required
Reverification applies when an employee's employment authorization has a time limit. In general, employers must reverify no later than the date the employee's employment authorization expires. That usually comes up when:
- The employee listed an expiration date for work authorization in Section 1, for example as a noncitizen authorized to work until a specific date.
- The employee presented a List A or List C document in Section 2 that shows a temporary work authorization expiration date, such as an Employment Authorization Document.
When reverification is due, the employee presents an unexpired document showing continued employment authorization. The employee chooses which acceptable document to present from List A or List C. The employer records the document title, number, and expiration date in Supplement B, along with its own name, signature, and the date.
A good habit is to remind employees well before the expiration date. That gives them time to renew their documents and gives HR time to complete Supplement B without a last-minute rush. Reminders should go to every employee in the same situation in the same way.
When not to reverify
This is where many compliance problems begin. Employers should not reverify:
- U.S. citizens and noncitizen nationals. Their work authorization does not expire.
- Lawful permanent residents who presented a Form I-551 Permanent Resident Card in Section 2. The card itself may expire, but the person's status as a permanent resident does not depend on the card.
- List B identity documents. An expired driver's license or state ID card after hire does not trigger reverification.
- Expired List A documents that show identity only after hire, such as a U.S. passport that expires while the person is employed.
Reverifying these employees, or asking for specific documents during reverification, can be treated as unfair documentary practices under federal anti-discrimination rules. The safest rule of thumb is simple: reverify only work authorization that is time-limited, and let the employee choose which acceptable document to present.
Rehires: when you can use Supplement B
When a former employee returns, employers often have a choice. If the person is rehired within three years of the date the original Form I-9 was completed, the employer can either complete a new Form I-9 or use Supplement B on the existing form.
To use Supplement B for a rehire, the employer records the employee's name and the date of rehire. If the employee's previous work authorization has expired, or the employee was originally hired with temporary authorization that has since lapsed, the employer must also reverify by recording an unexpired document from List A or List C that the employee presents.
If the original Form I-9 is more than three years old, or the employer cannot find it, the employer must complete a new Form I-9 for the rehired employee. A new form is also a reasonable choice when the original form contains errors that would be carried forward, or when it is simply easier to start fresh.
If the employee's name has changed since the original form was completed, employers may also record the new name in Supplement B. That is optional for current employees but helps keep records consistent.
Supplement B and E-Verify
Employers enrolled in E-Verify should know how Supplement B fits with their case process. In general, E-Verify should not be used to reverify an existing employee's expiring work authorization. For rehires, an employer may choose to create a new E-Verify case. If the employer completes a new Form I-9 for the rehire, it typically creates a new case for that hire. Employers should follow the rules in their E-Verify Memorandum of Understanding and the current E-Verify user manual for their specific situation.
Recording Supplement B correctly
A few practical points help keep Supplement B accurate:
- Keep it with the original form. Supplement B belongs with the employee's existing Form I-9, and it should be retained for as long as that form must be kept.
- Use the right section. Each completed reverification or rehire gets its own Supplement B block, with its own signature and date.
- Check the alternative procedure box if it applies. Qualified E-Verify employers that examine reverification documents remotely under the DHS alternative procedure should check that box in Supplement B and keep copies of the documents.
- Don't reverify into a new Section 2. Reverification goes in Supplement B, not on a new Section 2, unless the employer is completing an entirely new Form I-9 for a rehire.
- Track expiration dates. A missed date is one of the most common reasons reverification goes wrong.
Common Supplement B mistakes
These issues show up again and again during internal audits:
- Reverifying permanent residents when their green card expires.
- Reverifying identity documents like driver's licenses.
- Asking for a specific document, such as a new Employment Authorization Document, instead of letting the employee choose.
- Missing the reverification date because expiration dates live in a spreadsheet nobody checks.
- Using Supplement B for a rehire after the three-year window instead of completing a new Form I-9.
- Leaving out the rehire date or signature, which makes the record incomplete.
Each of these can usually be prevented with a consistent process and an automated reminder system.
How Clear I-9 helps
Clear I-9 by TRAK handles reverification and rehires inside the same digital workflow your team uses for new hires. Automated expiration tracking and reminders flag time-limited work authorization before it lapses, and the system is designed to reverify only the employees and documents that actually require it. Workflows, reporting, and tracking show which Supplement B tasks are open, electronic signatures keep remote reverifications moving, and secure document imaging keeps copies with the right form. If you use E-Verify, instant E-Verify connects your cases to the same record.
Want to see how Clear I-9 handles reverification and rehires? Request a demo of Clear I-9 and we'll walk you through it.
This article is for general information only and is not legal advice. For guidance on your specific situation, consult qualified employment counsel and the official USCIS resources.