How G&A Partners Handles I-9 Verification: What Employers Actually Need to Know

If you’re using G&A Partners as your PEO and have questions about how I-9 verification actually works under their model, you’re asking the right question at the right time. Most business owners don’t get a straight answer on this from their PEO sales rep — and that’s a problem, because I-9 compliance under co-employment is genuinely more complicated than “we handle it for you.”

Here’s the core issue: when a PEO becomes your employer of record, the compliance picture doesn’t simplify as cleanly as the sales pitch suggests. USCIS and ICE don’t care whose name is on the HR contract when an audit notice arrives. Both the PEO and the worksite employer carry exposure — and the split of responsibility varies depending on your specific service agreement, your workforce composition, and how well your onboarding workflow is actually configured.

This guide is built for two audiences. If you’re evaluating G&A Partners and want to understand their I-9 process before signing, this will give you the right questions to ask. If you’re already a G&A client and want to tighten up your compliance posture, the steps below will help you identify what’s covered, what’s not, and where the gaps tend to hide.

One framing note before we get into it: this is not a G&A Partners brochure. It’s also not a generic I-9 explainer. The goal is to map out the practical mechanics of I-9 compliance specifically under G&A’s co-employment structure — referencing their technology platform, their E-Verify participation model, and the real-world workflow that governs your employees’ onboarding. Where things are genuinely unclear or require direct confirmation with G&A, that’s noted explicitly.

Let’s get into it.

Step 1: Understand Who Owns What in a PEO Co-Employment I-9 Setup

The single biggest misconception in PEO I-9 compliance is this: “My PEO handles it, so I’m covered.” That’s not how the law works, and it’s not how USCIS or ICE will treat you if an audit happens.

Under co-employment, G&A Partners becomes the employer of record for payroll tax and HR administration purposes. USCIS guidance does allow PEOs to complete and retain I-9 forms on behalf of worksite employers — so G&A can legitimately own the administrative workflow. But “administrative ownership” and “legal liability” are two different things.

Here’s what the split actually looks like in practice:

G&A Partners typically handles: I-9 form administration through their onboarding system, E-Verify case submissions as a designated agent, centralized record storage, and compliance reminders for re-verification.

The worksite employer retains: Day-to-day supervisory control over employees, independent knowledge of hiring decisions, and shared liability for I-9 violations that occur within their operations. If you have direct knowledge that an employee is unauthorized to work — regardless of what the I-9 says — you carry independent liability. G&A’s involvement doesn’t insulate you from that.

USCIS is explicit that the worksite employer is not fully off the hook simply because a PEO administers the I-9. Both parties are considered employers under the co-employment structure, and enforcement agencies have the authority to hold both accountable. Other PEOs handle this split differently — for example, Insperity’s I-9 compliance model takes a more prescriptive approach to defining worksite employer obligations in their service agreements.

The practical implication: you need to know what your specific G&A service agreement says about I-9 responsibilities. Not all PEO contracts are identical. Some assign more compliance responsibility to the PEO; others leave more on the worksite employer. Before assuming G&A covers everything, pull your contract and look for the section covering employment verification and I-9 administration. If it’s vague, ask for written clarification.

This isn’t about distrust — it’s about knowing where your exposure actually sits so you can manage it. Most compliance problems don’t start with bad intent; they start with unclear assumptions about who was supposed to handle something.

Step 2: Confirm G&A Partners’ E-Verify Participation and Enrollment Status

E-Verify and I-9 completion are related but separate obligations. The I-9 is a federal form requirement — every employer must complete it for every new hire. E-Verify is an electronic system that cross-checks I-9 data against federal databases to confirm work authorization. Completing an I-9 does not mean you’ve run E-Verify. These are two distinct steps.

G&A Partners participates in E-Verify as a designated agent. That means they’re authorized to submit E-Verify cases on behalf of client companies rather than each client needing their own standalone enrollment. This is standard for large PEOs and generally works well — but it requires you to confirm a few things specifically.

First, confirm that your specific worksite locations are enrolled under G&A’s master E-Verify account. Don’t assume. Ask G&A directly for your company’s E-Verify ID and written confirmation that new hires are being run through the system at onboarding. If you’ve added new locations or states since your original contract, those may not be automatically included.

Second, understand your federal contractor obligations if they apply. Federal contractors and subcontractors subject to the FAR E-Verify clause have specific requirements that can’t be delegated away simply by pointing to your PEO. In some cases, both the employer of record and the worksite employer may need to be listed in E-Verify. If you hold federal contracts, get legal confirmation on how this interacts with your G&A arrangement.

Third, watch for multi-state E-Verify gaps. Several states have their own independent E-Verify mandates — Arizona and Mississippi are among the strictest, but the list has grown. If you’re hiring remotely across multiple states, you need to confirm that G&A’s E-Verify process covers employees in states with independent mandates. Managing multi-state compliance through a PEO adds layers of complexity that need direct confirmation rather than assumption, regardless of which provider you use.

The simplest action here: request documentation of G&A’s E-Verify compliance process in writing. If you’re renewing a contract, this is a reasonable due diligence ask. If you’re evaluating them as a new client, it should be on your vendor checklist before you sign.

Step 3: Map Out the Onboarding Workflow G&A Uses for New Hire I-9 Completion

G&A Partners uses isolved as their HR technology backbone. New hire onboarding — including I-9 completion — runs through their isolved-based portal. Understanding how that workflow actually operates matters, because there’s a meaningful difference between a new hire completing a digital form and a legally compliant I-9.

Here’s how the process typically flows:

Section 1 is completed by the employee. Under G&A’s system, new hires are prompted to complete Section 1 digitally through the onboarding portal on or before their first day of work. This part is relatively straightforward — the employee attests to their work authorization status and provides their identifying information.

Section 2 is where things get more complicated. Section 2 requires physical examination of original employment authorization documents. Someone must look at the actual documents — not a scan, not a photo — and verify they appear genuine and relate to the employee presenting them. This is a USCIS requirement that cannot be waived by a digital onboarding system, no matter how sophisticated.

For employees who work on-site at your location, this typically means your HR staff or a designated manager completes Section 2. G&A’s system may prompt and track the process, but the physical document review still has to happen at your end unless G&A has a specific authorized representative arrangement in place for your account. How a PEO structures this step varies significantly — the TriNet I-9 verification process, for instance, uses a different authorized representative model that’s worth understanding as a point of comparison.

For remote employees, the complexity increases. USCIS allows authorized representatives to complete Section 2 on behalf of an employer — a notary, an HR consultant, even a trusted colleague in the employee’s area can serve this role. But the employer (or PEO acting as employer of record) must designate and instruct that representative. Ask G&A directly: do they use a third-party authorized representative network for remote hires? What’s their documented process? Who bears responsibility if the representative makes an error?

On timing: Section 1 must be completed by the employee’s first day of work. Section 2 must be completed within 3 business days of the employee’s start date. Confirm that G&A’s system sends automated reminders and flags incomplete forms before the deadline passes. Missing Section 2 deadlines is one of the most common I-9 violations — and “the system didn’t remind me” is not a defense that reduces penalties.

The common pitfall here is assuming that because the portal shows “onboarding complete,” the I-9 is fully compliant. Portal completion and I-9 compliance are not the same thing. Section 2 document inspection is a physical, in-person requirement. Make sure your team understands that and that your G&A workflow reflects it.

Step 4: Locate, Access, and Audit Your I-9 Records Stored with G&A

Under the co-employment model, G&A typically retains I-9 records on your behalf within their HR system. That’s convenient — but “convenient” only helps you if you can actually access those records when you need them. Many business owners have never pulled their own I-9 records from their PEO’s system. That’s a problem waiting to surface.

Log into G&A’s HR platform (isolved) and navigate to employee records. I-9 forms should be stored separately from general personnel files — this is a USCIS requirement, not just a best practice. If you’re having trouble locating them, contact your G&A account manager and ask specifically for access to your I-9 repository.

Once you have access, do a spot audit. Pull 10 to 15 employee records — a mix of recent hires and longer-tenured employees — and check for the following:

Section 1 completion date: Was it completed on or before the first day of work?

Section 2 completion date: Was it completed within 3 business days of the start date?

Document information: Are List A or the List B and C combination recorded correctly, with document numbers and expiration dates where applicable?

Re-verification dates: For employees with temporary work authorization, is there a Section 3 re-verification entry with a valid date?

Red flags to watch for: missing Section 2 dates, expired documents that weren’t re-verified, incomplete document list entries, or I-9s that appear to have been backdated. Any of these can create penalty exposure if an audit occurs.

Now, the exit planning piece — and this is critical. Confirm in your service agreement what happens to your I-9 records if you leave G&A. You are legally responsible for retaining I-9 records for 3 years from the hire date or 1 year after termination, whichever is later. That obligation doesn’t transfer to G&A and it doesn’t disappear when you switch PEOs. If G&A holds your records and you exit the relationship, you need a clear, documented process for receiving those records in a usable format. Get that in writing before you need it. Understanding how PEO contract exits are structured — including record transfer obligations — is worth reviewing before you’re in the middle of a transition.

Step 5: Handle Re-Verification and Expiring Work Authorization Correctly

Re-verification is consistently one of the most mishandled areas of I-9 compliance — not because it’s conceptually difficult, but because it requires ongoing attention rather than a one-time setup. When an employee’s work authorization document expires, the employer must complete Section 3 of the I-9 before that expiration date. Miss it, and you’re out of compliance.

Ask G&A directly: does their system automatically flag employees with expiring work authorization documents? What’s the lead time on those notifications — 90 days, 60 days? Who receives the alert — your HR contact, G&A’s compliance team, or both? The answer to that last question matters more than most people realize. If the alert only goes to G&A’s system and no one on your team is looped in, you’re relying entirely on their follow-through.

There’s an important nuance here that trips up a lot of employers. You cannot re-verify U.S. citizens or lawful permanent residents. Their documents may expire, but their work authorization does not. Attempting to re-verify these employees can create discrimination liability under the anti-discrimination provisions of the Immigration and Nationality Act. Make sure whoever is handling re-verification on your end — whether that’s your HR team or G&A’s staff — understands this distinction clearly.

When G&A flags an expiring document, the workflow question becomes: who is responsible for collecting the new document from the employee? Is that your HR team, or does G&A’s compliance staff handle the outreach? Get this spelled out in writing. Ambiguity here is how re-verification deadlines get missed.

For remote employees, USCIS has provided some flexibility around re-verification in certain circumstances. Confirm whether G&A is actively applying current USCIS guidance on this and what their documented process looks like. This is especially relevant if you have a distributed workforce where physical document review at re-verification would require the same authorized representative logistics as initial Section 2 completion. The Justworks I-9 verification walkthrough offers a useful comparison point for how another PEO handles remote re-verification workflows.

One practical habit worth building: set a quarterly calendar reminder to cross-check G&A’s flagged re-verifications against your own headcount list. Automated alerts are helpful, but they’re not infallible. A manual cross-check takes 20 minutes and can catch gaps before they become violations.

Step 6: Prepare for an I-9 Audit — What G&A Covers and What Falls on You

ICE can issue an I-9 audit notice with as little as 3 business days’ notice. That’s not a lot of time to figure out where your records are, who’s responsible for responding, and what your documentation actually shows. The time to work through those questions is now, not when the notice arrives.

Under a PEO arrangement, both G&A Partners and the worksite employer may receive audit notices. Before that happens, you need clarity on who is the primary point of contact for audit response and who is responsible for assembling records. This should be explicitly addressed in your service agreement. If it isn’t, raise it with your G&A account manager and get a written protocol documented.

Here’s a reasonable breakdown of what each party should own in an audit scenario:

What G&A should provide: Copies of all I-9s for current and terminated employees within the retention window, E-Verify case results and confirmation numbers, and documentation of their internal compliance procedures and system configurations.

What the worksite employer must still own: Records of hiring decisions, supervisory documentation, any HR actions taken outside G&A’s system, and the ability to demonstrate that the employer had no independent knowledge of unauthorized workers. These are things G&A simply cannot provide on your behalf because they weren’t part of those decisions.

Self-audits are worth doing annually regardless of PEO involvement. USCIS and ICE generally treat proactively identified and corrected errors more favorably than errors discovered during an enforcement audit. Minor technical errors — a missing middle initial, a checkbox not filled — can often be corrected with a simple notation. Substantive violations carry higher penalty exposure and are harder to walk back once an auditor has them in hand.

Ask G&A whether their compliance package includes audit support services or attorney referrals. Some PEOs provide meaningful audit response support; others hand you a file and wish you luck. If you’re evaluating G&A against alternatives, reviewing a detailed PEO compliance review can help you benchmark what strong audit support actually looks like before you commit.

Is G&A Partners the Right Fit for Your I-9 Compliance Needs?

G&A Partners brings real strengths to I-9 compliance management. Their isolved-based onboarding platform provides a structured digital workflow, their E-Verify participation as a designated agent covers most standard hiring scenarios, and centralized record retention means your I-9s aren’t scattered across a spreadsheet or a filing cabinet. For companies with straightforward hiring profiles — primarily on-site employees in a limited number of states — their setup works well.

The gaps tend to surface in more complex situations. Remote employee Section 2 verification requires either a robust authorized representative process or a third-party network, and it’s worth confirming specifically how G&A handles this at scale. Multi-state E-Verify mandates add another layer of complexity that needs direct confirmation rather than assumption. And exit record transfer — what happens to your I-9s when you leave — is a detail that’s easy to overlook until you actually need it.

If your workforce is heavily remote, spans multiple states with independent E-Verify requirements, or includes a significant contractor or seasonal component, those factors should drive your evaluation. The right question isn’t just “does G&A do I-9s?” — it’s “does their specific workflow match my hiring profile and risk exposure?”

If you’re still in the evaluation stage, it’s worth comparing G&A against other PEO providers on compliance depth, not just pricing. Some providers have more developed remote verification infrastructure; others have stronger audit support programs. The differences matter more than most sales conversations suggest. A side-by-side look at Paychex PEO vs G&A Partners can surface meaningful differences in how each handles compliance obligations.

Before you renew your PEO agreement, compare your options. Most businesses overpay due to bundled fees and unclear administrative markups. We break down pricing, services, and contract structures so you can make a smarter decision.