The ICE Mutual Agreement between Government and Employers (IMAGE) program is a joint government and private sector initiative that was introduced in July 2006 by the Dept. of Homeland Security (DHS), U.S. Immigration and Customs Enforcement (ICE) to help employers “self-police” with respect to complying with the federal immigration law’s prohibition against hiring workers who are ineligible to be employed in the United States.  The IMAGE program was started in response to an April 1999 Government Accountability Office (GAO) report entitled “Significant Obstacles to Reducing Unauthorized Alien Employment Exist,” which noted the high percentages of unauthorized workers employed in certain industries. 

    IMAGE raises a number of questions and concerns that advocates for workers must monitor closely.  The program’s requirement that employers verify their employees’ Social Security numbers through the Social Security Number Verification System and verify their employment eligibility through the Basic Pilot program are of particular concern.  Workers’ advocates have long distrusted the accuracy of the Social Security Administration and DHS databases and have known that some unscrupulous employers abuse these programs.  Various government reports have been issued that support the finding that DHS and SSA databases contain inaccurate and outdated information, which result in employment-eligible workers being denied employment.  (For more on this, see “The Basic Pilot Program: Not a Magic Bullet.”)  Advocates must also be on the lookout for instances of employers “prescreening” workers (before hiring them), or using the Basic Pilot or SSNVS selectively.  Workers often suffer adverse employment actions based on tentative nonconfirmations and because employers do not inform workers of their rights to contest tentative nonconfirmations.

    NILC’s issue brief detailing these and other concerns, “Facts about the IMAGE Program: ICE Mutual Agreement between Government and Employers,” is available to be downloaded as a PDF.