A proposed federal rule could require recipients and subrecipients of federal funding—including universities, healthcare
organizations, nonprofits, and governments — to use E-Verify for employees and potentially certain contractors. The
proposal could also require verification of existing employees working on federally funded projects, creating new I-9,
tracking, training, and technology challenges. Organizations may need to monitor downstream partners and report final
nonconfirmations. Although the rule is not final, HR leaders should assess their current processes and prepare for
potential compliance obligations.

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