The E-Verify Status Change Report Is Now a Fortnightly Job: Re-Verifying Revoked EADs Lawfully
DHS no longer sends individual Case Alerts when TPS, asylum, or parole EADs are revoked early. Pull the bi-weekly Status Change Report and run Supplement B without crossing into document abuse.
- Jurisdiction
- US Federal · 8 U.S.C. §§ 1324a & 1324b · 8 CFR § 274a.2(b)(1)(vii)
- Employer threshold
- All E-Verify participating employers (plus 4+ employee DOJ IER anti-discrimination coverage)
- Decision trigger
- Bi-weekly E-Verify Status Change Report flags a current employee's EAD card number as revoked
- Review cadence
- Reviewed on USCIS/E-Verify Status Change Report releases or DHS fine adjustments
Direct operational answer
E-Verify employers must pull the DHS Status Change Report every two weeks to identify active workers whose Form I-766 Employment Authorization Documents in categories A12, C08, C09, C11, or C19 were revoked before their printed expiration dates. Under 8 CFR § 274a.2(b)(1)(vii), 8 U.S.C. § 1324b(a)(6), and the hr.cafe fortnightly reverification protocol, HR matches the exact revoked card number, skips opening a new E-Verify case, and completes Form I-9 Supplement B using any valid List A or List C document chosen by the employee.
How a Plastic Card Expiring in 2028 Becomes Unlawful Overnight
Physical EAD cards stay in an employee's wallet even after DHS terminates the underlying parole, TPS, or pending application electronically. Relying on your HRIS tickler calendar misses mid-term revocations completely.
Picture a Thursday morning in a 220-person logistics operation. Your HRIS Form I-9 expiration report looks spotless: every Form I-766 Employment Authorization Document (EAD) on file carries a printed plastic expiration date in 2027 or 2028. Nobody received an email alert from E-Verify. Then an outside compliance audit opens the Reports tab inside E-Verify, downloads the Status Change Report, and finds four seven-year and two-year warehouse leads whose EAD card numbers were administratively invalidated months ago.
Understand the exact structural shift DHS rolled out between 2025 and late 2026 on E-Verify.gov:
- June 2025 shift from push alerts to pull reporting: DHS replaced automated individual "Case Status Alerts" for revoked parole EADs (category C11, such as CHNV humanitarian parole) with a centralized, downloadable Status Change Report inside the E-Verify Reports tab.
- August 11, 2026 five-category expansion & bi-weekly cadence: DHS expanded the Status Change Report on a bi-weekly update schedule to cover revoked EADs across five common eligibility codes: A12 (TPS granted, following TPS designation termination), C08 (pending asylum Form I-589 withdrawn, denied, or closed), C09 (pending adjustment of status Form I-485 withdrawn or denied), C11 (humanitarian parole terminated or revoked), and C19 (TPS initial applicant).
- Constructive knowledge exposure ($716 to $5,724+ per worker): Under 8 U.S.C. § 1324a(a)(2), continuing to employ an individual knowing they have become unauthorized carries inflation-adjusted civil fines starting at $716 to $5,724 per individual for first offenses (and higher for repeat orders). DHS treats an E-Verify employer's Status Change Report as direct notice of EAD invalidation.
Step 1 & Step 2: Pull Fortnightly and Match the Exact Card Number First
Appearing on the Status Change Report does not automatically mean an employee lacks work authorization today. Compare the exact Revoked Document Number on the report against your latest Form I-9 before calling anyone into HR.
Put a recurring 15-minute calendar block on the 1st and 15th of every month for your people operations I-9 owner (Corporate Administrators and Program Administrators can filter by E-Verify case date or export the CSV). Run a quiet file check before speaking to the employee or their supervisor:
- Filter out already-separated workers: If the E-Verify case belongs to a former employee who separated last year, log "Separated on [Date] — No Action Needed" on your audit sheet and stop.
- Compare the exact Revoked Document Number against Section 2 or Supplement B: Look at the 13-character USCIS receipt/card number (for example, `IOE...`, `LIN...`, `EAC...`, `SRC...`, `WAC...`) listed in the Status Change Report's Revoked Document Number column and compare it character-for-character against the document currently establishing work authorization on the employee's Form I-9.
- Branch A — Card numbers DO NOT match (Close ticket quietly!): Suppose the employee joined in 2024 using a C11 parole EAD (`IOE0921...`) when you ran E-Verify, which is why that old card appears on the Status Change Report—but six months ago the employee already completed Supplement B presenting an unrestricted Social Security card (List C) or a new marriage-based C09/LPR card (`IOE0929...`). Because the revoked card is no longer the active document supporting Form I-9, take zero action and do not bother the employee!
- Branch B — Card numbers MATCH: The document currently supporting the employee's active Form I-9 has been invalidated by DHS, requiring prompt reverification on Form I-9, Supplement B.
Step 3: Re-Verify on Form I-9 Supplement B Without Committing Document Abuse
Panicked HR teams violate 8 U.S.C. § 1324b(a)(6) by demanding "a letter from USCIS" or running a second E-Verify case. Never ask for specific documents, never reverify List B identity, and never open a duplicate E-Verify case.
This is the exact razor's edge where ICE worksite enforcement meets DOJ Immigrant and Employee Rights Section (IER) discrimination penalties. That same federal anti-discrimination statute polices job-posting visa preferences and pre-offer ID demands. Follow four unbreakable rules under 8 CFR § 274a.2(b)(1)(vii) and 8 U.S.C. § 1324b(a)(6):
- Rule 1 — NEVER create a new E-Verify case: E-Verify rules strictly prohibit creating a new E-Verify case to reverify an existing employee! Reverification happens exclusively on Form I-9, Supplement B (formerly Section 3).
- Rule 2 — Employee chooses ANY unexpired List A or List C document: Hand the employee the official Form I-9 Lists of Acceptable Documents. Never say "bring me a green card," "show me your new asylum EAD," or "bring an official USCIS letter proving your TPS wasn't revoked." For example, an employee whose C08 asylum EAD was closed because they were just granted asylum or lawful permanent residence is authorized to work incident to status and may present an unrestricted Social Security card (List C #1) or Form I-94 with asylum stamp! Demanding a specific USCIS card when the employee tenders a valid List C document is textbook § 1324b(a)(6) document abuse.
- Rule 3 — Never reverify List B identity documents, and never accept the same revoked EAD: Driver's licenses (List B) are never reverified. Conversely, the employee cannot re-present the exact same EAD card number flagged as revoked on the Status Change Report, even if its printed date still reads 2028.
- Rule 4 — Apply a consistent "reasonable amount of time" window: DHS guidance instructs employers to complete Supplement B "within a reasonable amount of time." Set one uniform written policy across 100% of employees (for example, 7 to 10 business days from notification) so managers never give favored workers 30 days while firing another worker on the spot.
E-Verify Status Change Report Triage & Supplement B Decision Matrix
| Report Scenario | File Check Result | Lawful HR Action | Illegal Trap to Avoid |
|---|---|---|---|
| 1. Card Number Mismatch | Employee already reverified earlier with a newer EAD number or unrestricted List C card. | Log mismatch in audit binder; close review with zero employee contact. | Pulling employee off shift or demanding they "re-prove" their newer valid document. |
| 2. Active Match — New Valid Doc | Revoked card is active I-9 doc; employee presents unexpired List A or List C doc (e.g., unrestricted SSN card, new category EAD, LPR card). | Inspect physical (or E-Verify DHS Alternative video) doc, complete Supplement B, attach copies if applicable. Do NOT run new E-Verify case. | Rejecting a valid List C unrestricted SSN card and demanding "a USCIS approval notice." |
| 3. Employee Claims DHS Error | Employee insists their C08/C09/TPS EAD was reinstated or listed by mistake. | Allow uniform reasonable window (e.g., 7–10 business days) to present any valid List A/C doc or contact USCIS (888-897-7781); escalate to immigration counsel if DHS issued written reinstatement. | Accepting an expired/revoked card indefinitely based purely on a pending fee receipt that does not grant auto-extension. |
| 4. Unable to Present Valid List A/C | Uniform reasonable window expires and employee has no unexpired List A or List C work authorization. | Proceed with respectful administrative separation (or short unpaid leave policy if applied equally to all I-9 expirations); issue timely final pay. | Keeping the unauthorized employee off-the-books as a 1099 contractor (triggers criminal/enhanced § 1324a penalties!). |
Step 4: Handling the Human Conversation With Dignity and Zero Retaliation
Losing a seven-year lead over a federal TPS or parole revocation rattles the whole floor. Keep shift supervisors out of immigration paperwork and execute clean final-pay compliance.
When an employee cannot produce alternative List A or List C work authorization before your uniform reasonable window closes, coordinate manager support so the exit stays dignified and legally clean:
- Keep medical/immigration status confidential from peers: Tell the line manager only when scheduling coverage becomes necessary ("Alex's employment eligibility documentation could not be renewed by Friday's deadline; HR is handling separation and rehire eligibility"). Never announce immigration details on team Slack channels.
- Never convert to 1099 contractor status: Under 8 U.S.C. § 1324a(a)(4), using an independent contractor contract to retain labor knowing the individual lacks US work authorization carries identical—and often aggravated willful—penalties.
- Pay 100% of earned wages and accrued PTO on state involuntary-termination clocks: Losing work authorization requires full, timely payment of all earned wages (immediately upon involuntary separation in states like California and Massachusetts—see our final-paycheck compliance rules) and eligible rehire coding once new work authorization is obtained.
Copy-Ready Fortnightly Audit Log & Private Employee Reverification Notice
Deliver this neutral written notice in a private 1-on-1 meeting alongside the official Form I-9 Lists of Acceptable Documents whenever a Status Change Report card number matches your active I-9.
PRIVATE WRITTEN NOTICE — FORM I-9 SUPPLEMENT B REVERIFICATION
Date: [Date] | Employee Name: [Full Name] | Uniform Reverification Deadline: [Date + 10 Business Days]
Hi [First Name],
As an E-Verify participating employer, we routinely review updates published by the U.S. Department of Homeland Security (DHS) in the E-Verify Status Change Report. Our latest review indicates that DHS flagged Employment Authorization Document (EAD) card number [Last 4 Digits: XXXX], which is currently recorded on your Form I-9, as administratively invalidated prior to its printed expiration date.
What We Need to Complete Together by [Deadline Date]:
1. To continue employment, federal law requires us to reverify your employment authorization on Form I-9, Supplement B on or before [Deadline Date].
2. Enclosed is the official Form I-9 Lists of Acceptable Documents. You may choose to present ANY unexpired List A document OR ANY unexpired List C document establishing employment authorization (you do NOT need to present a List B identity document, and we are not requesting any specific document). Note that we cannot accept the specific EAD card number flagged as invalidated on the DHS report.
3. If you believe DHS listed your EAD card number in error, you may contact E-Verify Employee Hotline / USCIS directly at 888-897-7781 (TTY 877-875-6028) while gathering acceptable List A or List C documentation.
Please schedule 10 minutes with [HR Contact Name & Email] on or before [Deadline Date] to complete Supplement B. If you obtain new employment authorization after separation, you remain welcome to reapply in good standing.Download and archive a dated PDF/CSV of the E-Verify Status Change Report on the 1st and 15th of every month (even when 0 rows return, proving continuous good-faith monitoring in an ICE audit).
Never ask employees about their TPS country, asylum case, or USCIS letters; route all questions privately to HR and never offer informal cash or 1099 workarounds.
Verify complex automatic-extension Federal Register notices (where applicable vs. terminated TPS designations) and ensure uniform reverification windows across all facilities.
Primary statutes, regulations, and enforcement dockets
- DHS / USCIS E-Verify — Guidance for E-Verify Employers on Invalidated EADs & Status Change Report — Official E-Verify employer portal hosting the bi-weekly Status Change Report instructions across A12, C08, C09, C11, and C19 EAD categories.
- USCIS Handbook for Employers M-274 (Section 6.1) — Reverifying Employment Authorization on Supplement B — Authoritative federal instructions on completing Form I-9 Supplement B, employee document choice, and prohibiting List B identity reverification.
- 8 CFR § 274a.2(b)(1)(vii) — Continuing Employment & Reverification Regulations — Codifies federal Form I-9 reverification rules and employer obligations when temporary employment authorization expires or terminates.
- DOJ Civil Rights Division (IER) — Avoiding Discrimination in Form I-9 and E-Verify Reverification (8 U.S.C. § 1324b) — Primary enforcement guidance barring employers from demanding specific USCIS documents or rejecting valid List C unrestricted Social Security cards.
Practitioner questions on the edge cases
Should we run a new E-Verify case after completing Form I-9 Supplement B for an employee on the Status Change Report?
No! E-Verify rules strictly prohibit creating a new E-Verify case for an existing employee during reverification. Simply inspect the employee's chosen unexpired List A or List C document (in person, or via the DHS live-video Alternative Procedure since you are an E-Verify employer in good standing) and record it on Form I-9, Supplement B.
Why did an employee whose C08 asylum EAD was revoked hand us an unrestricted Social Security card instead of a new EAD?
When USCIS approves an underlying asylum application (or adjustment of status to permanent resident), it closes the pending application—which can flag the old pending-application EAD—while granting status authorized to work incident to status! An unrestricted Social Security card (without "VALID FOR WORK ONLY WITH DHS AUTHORIZATION" wording) is a completely valid List C (#1) document for Supplement B reverification, and rejecting it violates 8 U.S.C. § 1324b(a)(6).
How many days is a "reasonable amount of time" for an employee to complete Supplement B after appearing on the report?
While DHS does not codify a fixed day count, immigration compliance counsel generally set a written, consistently applied window of 7 to 10 business days from the date HR notifies the employee—short enough to show prompt good-faith action upon constructive notice, yet fair enough for an authorized worker to retrieve an unrestricted Social Security card or newly issued EAD from home.
What if our Status Change Report comes back completely blank with zero rows?
Export or screenshot the dated zero-row confirmation screen on the 1st and 15th of each month and save it in your compliance folder anyway. If ICE serves a Notice of Inspection later, dated bi-weekly logs prove affirmative good-faith compliance procedures.
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