I-9 reverification for drivers: expiring work permits, ended TPS, and taking a driver off the schedule

Most drivers never need reverification. The Form I-9 you completed on the first day stands unless the driver’s work authorization, or the document that proved it, has an end date. When it does, the driver must show you proof of continued authorization by that date on Supplement B, or you cannot keep the driver working. Below are the rule for the date, the documents you may accept, how work permit renewals changed in October 2025, and the 2026 endings of Temporary Protected Status for several countries. For fines and what a government inspection looks like, see the I-9 audit guide. For how E-Verify fits with the form, see E-Verify for NEMT companies.

When do you have to reverify a driver’s Form I-9?

You reverify when a driver’s employment authorization, or in most cases the document that shows it, expires, and you must do it no later than that date (8 CFR 274a.2(b)(1)(vii)). The expiration date a driver wrote in Section 1 may not match the date on the List A or List C document you recorded in Section 2. USCIS says to reverify by the earlier date.

Three things are not reverified:

• U.S. citizens and noncitizen nationals.
• Lawful permanent residents who showed a Form I-551 for Section 2, including conditional residents.
• Any List B document, which proves identity only.

A permanent resident who showed a temporary I-551 stamp or printed notation instead is reverified no later than the day the temporary I-551 expires. A driver who wrote N/A in the Section 1 expiration field, such as an asylee or refugee, is not reverified unless the driver chose to present evidence with an end date, such as a Form I-766.

Set a reminder from the dates on the forms themselves. USCIS suggests telling each affected driver at least 90 days ahead that they will need to present a List A or List C document, or an acceptable receipt, on or before the date.

Why is a driver’s license never reverified?

A driver’s license is a List B document. It proves who the driver is, not that the driver may work, and USCIS says to leave List B documents alone at reverification and rehire. A license that expires or is suspended is a different problem, and it has its own clock.

Keep the two apart in your calendar:

• Work authorization clock. Runs from the dates on the Form I-9 and ends with Supplement B.
• Driving clock. Runs from the license expiration, the yearly driving record, and any broker credential. It is the one your continuous MVR monitoring and credential tracking cover.

A driver can be fully cleared on one and expired on the other.

How do you complete Supplement B?

Examine the new document, record it, and sign. In order:

1. Ask for any unexpired List A or List C document. The driver chooses which. Acceptable receipts include one for a lost, stolen or damaged document.
2. Examine the document. It must appear genuine and relate to the driver. If it does not, USCIS says to let the driver present other documentation from the Lists of Acceptable Documents.
3. Record the title, document number and expiration date, if any, in the Supplement B block.
4. Sign and date the block, and enter the driver’s name at the top of the page. Attach it to the original form.
5. Use a new block for each later reverification. If the form you first used has since been replaced by a newer edition, put the new block on a Supplement B from the current edition and attach it. USCIS’s form page lists 01/20/25 as the current edition. It also still allows the 08/01/23 edition when the expiration date at the top of the page reads 05/31/2027, but not the 08/01/23 printing that expired 07/31/2026.

Do not ask for a particular document. The regulation on what counts as knowing says employers may not request more or different documents than the law requires, or refuse documents that reasonably appear genuine and relate to the person (8 CFR 274a.1(l)(2)). USCIS lists completing Supplement B only after the work authorization has expired as a common mistake, and ICE treats a Supplement B not signed and dated by the expiration date as a substantive violation.

Does a pending work permit renewal still keep a driver working?

Not for renewals filed on or after October 30, 2025. DHS ended the automatic extension for those filings in an interim final rule that took effect that day (90 FR 48799). New 8 CFR 274a.13(e) says the card and the work authorization are not automatically extended by a renewal request, except as provided by law or in a Federal Register notice for TPS-related documents.

For renewals filed before October 30, 2025, the earlier rule still applies. The card can be extended for up to 540 days when the request was timely, is in the same category, and meets the other criteria in 8 CFR 274a.13(d). The receipt notice that proves timely filing is what extends it. Reverification then falls on the end of the extension, not the date printed on the card. DHS also said that receipt notices issued on or after October 30, 2025 will no longer carry automatic-extension language.

Two practical effects for a fleet:

• Drivers should renew early. USCIS encourages renewal once the card is within 180 days of its expiration, to reduce the chance of a gap.
• A gap can now end a driver’s shifts. DHS wrote in the rule that employers must terminate employment of employees who have gaps in work authorization documentation and cannot reverify.

What do you do when TPS ends for a driver’s country?

Check the TPS page in USCIS’s I-9 Central for the country, then follow its dates. Employees who hold Temporary Protected Status often have a Form I-766 with category A12 or C19 on it. A card that has passed its printed date may still be valid if DHS extended it by Federal Register notice, and USCIS says to accept it only while that extension is in effect. Reverify when the extension ends, no later than the date work authorization expires. USCIS adds that TPS holders do not have to prove they are nationals of a designated country when they complete the form.

The picture changed quickly in 2026. USCIS cites the Supreme Court’s June 25, 2026 decision in Mullin v. Doe for these terminations, which its Temporary Protected Status page lists with these effective dates:

Other countries, from USCIS’s notices:

• Haiti. The I-9 Central notice of July 29, 2026 says cards in category A12 or C19 are no longer valid, that employers completing the form must reverify those employees, and that an employer cannot continue to employ a person who does not provide proof of current employment authorization.
• Venezuela. Documents issued on or before February 5, 2025 with an October 2, 2026 expiration date stayed valid through that date. The date passed on October 2, so reverify any driver who relied on one.
• Honduras, Nepal and Nicaragua. These ended in 2025. A December 31, 2025 district court order vacating those terminations was stayed by the Ninth Circuit on February 9, 2026.
• Lebanon. The designation was extended through November 27, 2026.
• Sudan and Ukraine. The September 3, 2026 notices say both designations are set to end on October 19, 2026, and that expired cards extended by a USCIS notice are valid only until then. A driver relying on one needs a different List A or List C document by that date.
• El Salvador. The September 3 notice named September 9, 2026 as the end of extended cards, but USCIS’s El Salvador page now says an announcement will be made later and that Salvadorans with TPS keep their protection, including work authorization, until it is. Ask for current USCIS paperwork and check that page before you act.

This list will keep moving, so confirm each country on USCIS’s page before you act. A driver whose TPS has ended may hold another status or document that shows work authorization, so ask for any unexpired List A or List C document at reverification and do not assume.

What if the driver cannot show proof, or the date has already passed?

A driver who cannot show proof of current work authorization cannot keep working, and the decision is not discretionary. USCIS says you cannot continue employing a person who does not provide proof of current employment authorization, and federal law makes it unlawful to continue to employ a person knowing the person is or has become unauthorized (8 U.S.C. 1324a(a)(2)). Knowing includes information you could have learned with reasonable care, and the regulation lists failing to complete the form properly as an example (8 CFR 274a.1(l)(1)). Fines run $716 to $5,724 per worker for a first offense of knowingly continuing to employ and $288 to $2,861 per individual for a paperwork violation (8 CFR 274a.10(b)), and the I-9 audit guide shows how ICE sets the amount.

On the day proof is not shown:

1. Take the driver off the schedule and move the driver’s upcoming trips to other drivers.
2. Tell your brokers. MTM’s portal guidance asks providers to contact their Vendor Account Manager when a driver no longer drives for them so the driver is removed from the company. BlueCare Tennessee’s provider manual has the NEMT provider give its broker a written attestation before the agreement and every six months that it will not knowingly use anyone who is not authorized to work, and it points to a one-year bar from state contracts under Tennessee law for a contractor found to have knowingly done so.
3. Pay for every hour worked through the last day. The guide to firing a NEMT driver covers final pay deadlines by state.
4. Keep the form. Do not destroy it. The retention guide gives the keeping periods.

If you find a missed reverification on a form for a driver who is still working, correct it in the open: enter the actual date you completed Supplement B, never a backdate, which ICE lists as evidence of fraud, and add a signed, dated note to the file. The I-9 audit guide covers self-audits and corrections. If the driver returns later with a new document, treat it as a rehire, which the guide to rehiring a former NEMT driver explains.

How do you reverify without singling anyone out?

Reverify from the dates on your forms, using one process for every driver. Do not choose who to reverify by accent, appearance, or what country you think a driver comes from. The regulation says knowledge that an employee is unauthorized may not be inferred from a foreign appearance or accent (8 CFR 274a.1(l)(2)), and USCIS says TPS holders do not have to show their nationality. Let each driver pick which acceptable document to show, never turn away a document that reasonably appears genuine and relates to the driver, and write down the same steps every time.

When a driver comes off the board

When a driver leaves the schedule in the middle of a week, the trips that driver was due to run need new drivers before the next shift. On the dispatch board, dispatch assigns each trip to another driver in one motion, and Ryder Go can plan the day again in one click. The hours the driver worked up to the last day stay on timecards in reports.