Mark A Ivener, A Law Corporation

ICE Proposes New IMAGE Application

U.S. Immigration and Customs Enforcement (ICE) has filed a 60-day notice for a new information collection application with the Office of Management and Budget for the ICE Mutual Agreement between Government and Employers (IMAGE) program, which is the outreach and education component of the Office of Investigations (OI) Worksite Enforcement program.

According to ICE, IMAGE “is designed to build cooperative relationships with the private sector to enhance compliance with immigration laws and reduce the number of unauthorized aliens within the American workforce.” Under this program, ICE partners with businesses representing a cross-section of industries. A business initially completes and prepares an IMAGE membership application so that ICE can properly evaluate the company for inclusion in the IMAGE program. ICE noted that the information provided by the company “plays a vital role in determining it suitability for the program.”

As part of IMAGE, ICE and U.S. Citizenship and Immigration Services (USCIS) provides education and training to the company on proper hiring procedures, fraudulent document detection, use of the E-Verify employment eligibility verification program, and anti-discrimination procedures. Employers seeking to participate in IMAGE must agree to:

  • Complete a self-assessment questionnaire;
  • Enroll in E-Verify;
  • Enroll in the Social Security Number Verification Service;
  • Adhere to IMAGE Best Employment Practices;
  • Undergo an I-9 audit conducted by ICE; and
  • Review and sign an IMAGE partnership agreement with ICE.

Upon enrollment and commitment to the Department of Homeland Security’s “best hiring practices” program (see the next article in this issue), participants are deemed “IMAGE Certified,” a distinction DHS said it believes will become an industry standard. DHS said that it also intends to use the results of the IMAGE program and participation in IMAGE by partners in industry to guide the agency in shaping future worksite enforcement policy and legislation.

Additional information is available at The notice is available at Comments will be accepted for 60 days until August 10, 2010, and should be sent to the person named in the notice.

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About the Author

Mark A. Ivener, A Law Corporation, a nationally recognized law firm, has successfully assisted hundreds of clients in immigration matters.