assignment audit your understanding 9 1 (practice)

ISO 9001 - Clause 9.1 Monitoring, measurement, analysis and evaluation

ISO 9001:2015 clause 9.1 deals with monitoring, measurement, analysis, and evaluation. This clause requires an organization to establish a systematic approach to monitor, measure, analyze, and evaluate its quality management system (QMS).

The key elements of this clause are as follows:

• Monitoring: Organizations must monitor their QMS to ensure that it is effectively implemented and maintained. This can involve tracking key performance indicators (KPIs), internal audits, management reviews, and customer feedback.
• Measurement: Organizations must measure the performance of their QMS using quantitative data. This can include measuring the effectiveness of processes, product/service quality, and customer satisfaction.
• Analysis: Organizations must analyze the data collected during monitoring and measurement to identify trends, root causes of problems, and opportunities for improvement.
• Evaluation: Organizations must evaluate the performance of their QMS against established objectives and targets. This can involve reviewing KPIs, conducting internal audits, and analyzing customer feedback.

ISO 9001:2015 emphasizes the importance of using data-driven decision making to continuously improve the effectiveness of the QMS. By monitoring, measuring, analyzing, and evaluating their QMS, organizations can identify areas for improvement and take action to address them. This helps to ensure that the organization is meeting customer needs, complying with regulatory requirements, and achieving its business objectives.

ISO 9001- Clause 9.1.1 General

ISO 9001:2015 clause 9.1.1 is a general requirement for monitoring, measurement, analysis, and evaluation. It states that an organization must determine what needs to be monitored and measured, and the methods to be used to ensure valid results are obtained.

• Determining what to monitor and measure: The organization must determine what needs to be monitored and measured to ensure that the QMS is effective. This can include processes, products, services, customer satisfaction, and other relevant factors.
• Determining the methods to be used: The organization must determine the methods to be used to monitor and measure the identified factors. This can include using surveys, audits, inspections, or other methods that are appropriate for the type of data being collected.
• Ensuring valid results: The organization must ensure that the results obtained from monitoring and measuring are valid. This can involve establishing procedures for data collection, analysis, and reporting that are consistent with the organization's quality policy and objectives.

By fulfilling the requirements of clause 9.1.1, an organization can ensure that it is collecting valid data that can be used to make informed decisions about the effectiveness of its QMS. This information can be used to identify opportunities for improvement, address nonconformities, and improve overall performance.

ISO 9001- Clause 9.1.2 Customer satisfaction

ISO 9001:2015 clause 9.1.2 specifically deals with monitoring and measuring customer satisfaction. This clause requires an organization to monitor and measure customer satisfaction in order to determine whether its products or services meet customer requirements and expectations.

• Determining the methods for monitoring and measuring customer satisfaction: The organization must determine the methods for monitoring and measuring customer satisfaction, which can include surveys, feedback forms, or other appropriate techniques.
• Collecting and analyzing customer satisfaction data: The organization must collect and analyze data on customer satisfaction in order to identify trends and opportunities for improvement. This can include analyzing customer complaints, feedback, and other relevant data.
• Using customer satisfaction data to improve the QMS: The organization must use the data collected on customer satisfaction to identify areas for improvement within the QMS. This can involve taking corrective actions to address customer complaints, making changes to products or services based on customer feedback, or other appropriate actions.

By fulfilling the requirements of clause 9.1.2, an organization can ensure that it is meeting customer requirements and expectations, and that it is continuously improving its QMS to meet the changing needs of its customers. This can help to increase customer satisfaction, improve customer retention, and enhance the organization's reputation in the marketplace.

ISO 9001- Clause 9.1.3 Analysis and evaluation

Clause 9.1.3 of the ISO 9001 standard is titled "Analysis and evaluation." This clause requires organizations to evaluate and analyze data and information to determine the effectiveness and suitability of the quality management system.

The specific requirements of this clause are as follows:

• The organization shall analyze and evaluate appropriate data and information arising from monitoring and measurement activities.
• The analysis and evaluation shall be used to:
• Demonstrate conformity of the products and services provided;
• Ensure conformity of the quality management system;
• Continually improve the effectiveness of the quality management system.
• The organization shall determine, collect, and analyze appropriate data and information to demonstrate the suitability and effectiveness of the quality management system and to evaluate where continual improvement of the quality management system can be made.
• The results of analysis and evaluation shall be communicated to relevant personnel, including top management.

In summary, this clause requires organizations to analyze and evaluate data and information to ensure the effectiveness and suitability of their quality management system. This is important to ensure that the organization is providing products and services that meet customer requirements and that the quality management system is continually improving.

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How to Conduct an I-9 Audit

The Immigration Reform and Control Act of 1986 (IRCA) was established to prevent individuals who are not eligible to work in the United States from performing work. The act requires employers to complete an I-9 form for each employee within three days of hire.

Employers can demonstrate compliance by following the I-9 verification requirements and treating all new hires the same. This includes the following steps:

• Complete the I-9 form for all new hires. This form establishes that individuals hired are authorized to work in the United States.
• Permit employees to present any document or combination of documents acceptable by law. Employers cannot prefer one document over others for purposes of completing the I-9 form. As long as the documents are unexpired, allowed according to the list of acceptable documents on the most current Form I-9, and appear to be genuine and issued to the person presenting them, they should be accepted. Acceptable documents are listed at the end of the Form I-9.
• Update and reverify I-9s as needed. See How to Update or Reverify I-9 Forms .

Employers must ensure that all of their I-9s are properly completed and in order. Below is a step-by-step process on how to audit I-9 forms.

Step 1: Gather All I-9 Forms on File

Employers must check to see that there is a Form I-9 on file for every current employee who performs work for the employer in the United States. Employers should keep a list of current employees for whom they do not have a Form I-9.

Employers should not have an I-9 for nonemployees who may perform work, such as volunteers, independent contractors or consultants. If an employer does have an I-9 for these individuals, it should be removed from the employer's official Form I-9 file.

Employers should have two files of I-9s:

• Forms I-9 (electronic or paper) for current employees.
• Forms I-9 (electronic or paper) for terminated employees.

Each of these I-9s will be handled separately and in priority order. Current employees who have no Form I-9 on file are the highest priority, as their eligibility to work in the United States should be verified as quickly as possible. The next highest priority will be to review current employees' Forms I-9 on file to ensure they have been completed properly. The lowest priority will be handling I-9s of terminated employees.

Step 2: Obtain Forms I-9 for Current Employees Who Are Missing I-9s

Generally, any employee hired before Nov. 6, 1986, and still employed with the company is not required to have an I-9 form. However, all employees hired on or after this date and who do not have an I-9 on file will need to be contacted and instructed to bring documentation from List A or Lists B and C of Form I-9 .

Communication with the employees should be apologetic but firm. Employers should apologize that for whatever reason this documentation was lost or not collected at the beginning of employment. They should explain that the form must be completed under federal law and that the employee will not be able to continue working for the organization if he or she cannot provide these documents. Communicating with each employee individually on this matter is better than communicating to a group of employees. Verbal communication with the employee is sufficient; however, employers may also send an e-mail or a memo to the employee. Copies of all communications sent to employees who are missing I-9s should be kept in the Form I-9 audit file.

Organizations should establish a due date for employees to provide documentation. Requiring that the employee bring the items with him or her the next day he or she works is suggested. If employees have the necessary documentation on hand, the employer should sit down with them and complete the Form I-9 immediately. Employers must view the originals (not copies) of their documents. Current dates should be used when completing the Form I-9. The date of hire is the employee's actual date of hire, which may have been years earlier. Employers should attach a short memo to the corrected Form I-9 explaining that there was no I-9 on file and that the employee completed the I-9 at the time of the audit. This will demonstrate that the employer is making a good faith effort to be in compliance.

The employee's name can be crossed off the audit list, and the employer can add the completed I-9 to its file of Forms I-9 for current employees.

Some employees may not be able to find their documents. The United States Citizenship and Immigration Services (USCIS) Handbook for Employers indicates that certain receipts may be acceptable for a specific period of time in lieu of the actual document. Generally, a receipt for a lost, stolen or damaged document may be acceptable for 90 days. There are also document receipts that may be presented for refugees and lawful permanent residents. Receipts that fall outside of the requirements established by USCIS may not be an acceptable replacement for a List A, List B or List C document.

If an employee does not provide the required documents within the appropriate time frame, the employer should either terminate his or her employment or place the employee on a leave of absence. The employee should be informed that he or she may be able to continue work for the organization once he or she provides proof of eligibility to work in the United States, if that is the intention of the organization.

Step 3: Audit Forms I-9 of Current Employees

This step is the most grueling part of the I-9 auditing process. A number of items must be properly completed to ensure compliance. In addition to the USCIS Handbook for Employers , USCIS also has a section on its website titled I-9 Central , which provides additional information on the entire I-9 process. Anyone conducting an I-9 audit should keep these resources handy as they answer many questions regarding the proper completion of the Form I-9.

Technical errors may be corrected on the existing I-9 form, but substantive errors may require completing a new I-9. For further information about technical versus substantive errors, see this USCIS resource on correcting Form I-9 .

Lastly, employers should clearly show a change is a correction; using a differently colored ink and ensuring changes are initialed and dated with the current date will help make this clear.

As employers begin to go through this process, they should separate the I-9s into two files. The first file contains I-9s that have been completed properly; these should be filed away. The second file contains I-9s that have errors. Step 4 discusses how to fix these errors.

Employers need to check the following information in each section of the Form I-9:

• The name, address, other names used and date of birth must be completed.
• For the current Form I-9, the Social Security number is voluntary except for employers that participate in the E-verify program.
• E-mail address and telephone number are optional fields.
• The employee must identify his or her immigration status and sign and date the form.
• The preparer or translator section is to be completed only if someone other than the employee completed Section 1 on behalf of the employee. (This translator section becomes a separate document titled Supplement A on the Form I-9 in effect as of Aug. 1, 2023.)
• The proper document must be entered into the appropriate column. For example, employers must ensure that a List B document is in fact listed under List B and not under List C or List A.
• All required information must be entered for each document.
• The documents listed must satisfy the requirement to provide both proof of identity and proof of eligibility to work in the U.S.
• The certification section must be completed, including the date the employee first began work.
• A representative of the company must sign and date the form with the date the employee's documents were examined and section 2 was completed.
• If Section 2 was completed remotely between March 20, 2020 and July 31, 2023 (due to the suspension of the physical document review requirements during COVID-19), explanatory notations by the employer should appear in the "Additional Information" box, including the date the documents were eventually physically reviewed.
• If an alternative method to a physical review of the documents was used, it should be noted in the Additional Information section (such as during COVID-19), or the box stating as much (on the Form I-9 current as of Aug. 1, 2023) should be checked. 

This section should be completed only if the employee's work authorization expired or if the employee has been rehired. It can also be completed if the employee had a name change, but this is not required. In most cases, Supplement B will not be attached to the I-9 (or Section 3 on earlier versions of the I-9 will be blank).

• Expired permanent resident cards and List B documents from the Form I-9 do not need to be reverified. These documents must not be expired when the I-9 is initially completed, but their subsequent expiration does not trigger the requirement to reverify the I-9.
• Active U.S. citizens and permanent residents should not be reverified.

Step 4: Correct Errors

Employers should start this step by making a list of the I-9 forms that contain errors. This will become the audit log showing the employer is making a good faith effort to ensure Form I-9 compliance. The log should contain three columns: employee's name, the error(s) and the actions that were taken to rectify the error. For now, the employer will populate the first two columns of the log: employee name and the error found.

As employers work through each incorrect I-9, they can use the USCIS Handbook for Employers and Self-Audits and Correcting Mistakes to help them determine how to correct each error. Additionally, SHRM's How to Conduct an I-9 Audit offers step-by-step guidance. 

Below is a table that lists common Form I-9 mistakes and tips for correcting those mistakes.

In some instances, there may be so many errors that using the original I-9 would be prohibitive. In those instances, the employee should complete and sign a new I-9 using the current date (but the correct hire date should be entered in Section 2). The employer must verify employee's employment eligibility documents in Section 2. The original form should be stapled to the new I-9. Again, the employer should write a memo explaining why there are two I-9 forms and attach it to the I-9s.

Although not required, some employers choose to attach copies of the identification documents to the Form I-9. Aside from the E-Verify requirements to retain photocopies, an employer voluntarily choosing to retain photocopies must ensure that photocopies are kept for all employees. Information from the USCIS Handbook for Employers states:

If you participate in E-Verify and the employee presents a document used as part of Photo Matching, currently the U.S. passport and passport card, Permanent Resident Card (Form I-551) and the Employment Authorization Document (Form I-766), you must retain a photocopy of the document he or she pres­ents. Other documents may be added to Photo Matching in the future. If you do not participate in E-Verify, you are not required to make pho­tocopies of documents. However, if you wish to make photocopies of documents other than those used in E-Verify, you must do so for all employees. Photocopies must not be used for any other purpose. Photocopying documents does not relieve you of your obligation to fully complete Section 2 of Form I-9, nor is it an acceptable substitute for proper completion of Form I-9 in general.

If the employer's intent has been and will continue to be the practice of photocopying employment authorization and identity documents used for I-9s, and the employer is missing photocopies of some of these documents, the employer should ask employees for copies of those documents now. The employer should attach the copies to the I-9 and write a memo clearly indicating that it performed a Form I-9 audit, that the photocopy of the document was missing and that the employer obtained the copy during the audit process. The current date should be included, and the memo should be attached to the Form I-9.

If the employer's intent in the past was to obtain copies of employment authorization and identity documents, but it is changing this process for the future and not planning to photocopy moving forward, then the employer should write a memo to the Form I-9 audit file explaining that it conducted a Form I-9 audit and found the discrepancy that some I-9s prior to the audit date have photocopies and some do not. The memo should explain that the company has made a business decision not to keep photocopies of any of the I-9 employment authorization or identity documents in the future. This will show a good faith effort that the employer recognizes the error in having copies of some I-9 authorization documents and not others and explain why there will not be any copies after the audit date. It is not recommended that an employer discard any copies of employment authorization or identity documents from the past until the regular retention period for the Form I-9 has expired or after consulting with the attorney.

As the employer corrects each I-9 form, it should add the correction to its Form I-9 log.

Step 5: Terminated Employee I-9 Forms

Once an employee is terminated from employment, employers are required to retain I-9s for three years after the employee's date of hire, or for one year following his or her date of termination, whichever date is later . To determine the correct Form I-9 retention period for terminated employees, see Step 5 of the How to Retain and File I-9 Forms guide.

Employers should use a process similar to the one outlined in Step 4 to correct any errors they find on I-9s retained for terminated employees. Employers will be unable to correct any errors that require the former employee's input (e.g., missing documentation, missing signature). All corrections and instances in which the employer was unable to make corrections should be noted on the Form I-9 audit log and on a memo attached to the I-9.

Step 6: Complete the Audit

As corrections are made and missing I-9s begin to come in, an employer's task will be to organize the I-9s and clearly document the steps it took during the audit. Employers can refer to the guide on how to retain and file Forms I-9 for additional guidance on how to organize their I-9 files. Employers may wish to print this procedure to document the process they followed during the audit process. Employers should also retain the Form I-9 audit logs and communications to employees regarding the I-9 audit process. Employers may wish to keep the audit documentation in a separate Form I-9 audit file or to place this documentation in their files with the I-9 forms themselves.

I-9 Audit Checklist

USCIS I-9 Central

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