Employer compliance inspections

Overview: Employer inspections under the International Mobility Program

All employers who make an offer of employment to a foreign national referred to in subparagraph 200(1)(c)(ii.1) of the Immigration and Refugee Protection Regulations (IRPR) must comply with the conditions imposed under section R209.2.

Employers named on a work permit issued to a foreign national on or after December 31, 2013, may, if authorized under section R209.5, be inspected for compliance with the conditions set out in the IRPR. An inspection may be initiated from the first day of employment for which a work permit is issued up to a maximum of six years thereafter.

Inspections are administrative assessments of whether an employer has met the conditions required in the IRPR (sections R209.2 and R209.4). If, on the basis of information obtained during an inspection, an employer is determined to have committed a violation because that employer failed to comply with a condition and the failure to do so was not justified [under subsection R209.2(3) or (4) or subsection R209.4(2)], IRCC must inform the employer of the finding and, as per section R209.9, add their name to the public list , referred to in this section, effectively banning the employer from accessing the International Mobility Program (IMP) and the Temporary Foreign Worker Program (TFWP) for a specified period of time.

Depending on specific circumstances, employers found non-compliant with any of the conditions following an inspection may also have work permits for foreign nationals in their employ revoked using Ministerial Instructions.

Circumstances for an employer inspection

Under section R209.5, there are three circumstances (triggers) for an inspection: 1) known past non-compliance, 2) random selection and 3) reason to suspect.

Known non-compliance

An employer who has previously been found non-compliant with IMP or TFWP conditions

Random selection

Verification of employer compliance based on a random selection model

Reason to suspect

Receipt of information relating to an employer using the IMP and giving an officer reason to suspect non-compliance with one or more of the conditions set out under section R209.2

Information may come from a variety of sources, including but not limited to

  • an allegation or complaint received from
    • a call, letter or email received from a member of the public or a stakeholder (e.g., through tips or complaints website),
    • information received from Employment and Social Development Canada (ESDC), the Canada Border Services Agency (CBSA) or another IMP partner,
    • information received through diplomatic channels or parliamentarians,
    • information received from a non-governmental organization, union or similar organization,
    • information received from a province or territory;
  • new information reported in the media (print, radio, television, social media).

Any information received by an officer regarding a situation that could possibly trigger an inspection should be referred to the Case Management Branch (CMB), Investigation and Exceptional Cases Division for initiation of an inspection.

Initiating the inspection or verification

To initiate an inspection, the CMB may request that ESDC/Service Canada (SC) conduct the inspection activities on IRCC’s behalf, or the CMB will conduct the complete inspection.

If IRCC conducts the inspection

The CMB will send the employer a letter indicating

  • the reason for the inspection, including any applicable allegations of non-compliance and conditions being inspected;
  • a request for documentation that will provide proof of compliance;
  • a request for the employer to provide an indication of their justification as per subsection R203(1.1) and proof of the justifications if they believe they are non-compliant;
  • a deadline for submission of the documentation.

Inspection conditions imposed on employers [R209.4]

Inspections can involve employers having to answer questions and provide documents [R209.6], the examination of documents [R209.7], or on-site inspections [R209.8], including interviews with foreign workers or other employees (with consent).

Under section R209.4, for the purposes of inspections, employers must make reasonable efforts to do the following:

  • Report at any specified time and place to answer questions and provide documents, or ensure that a representative is available to provide assistance.
  • Provide any documents that are requested to verify compliance with specific conditions. Employers will be instructed to redact all personal information that IRCC is not authorized to collect.
  • Attend any inspection or ensure that a qualified or delegated employee attends any inspection, unless the employer was not notified of it.
  • Give all reasonable assistance to the person(s) conducting the inspection, which could include
    • allowing the officer to use copying equipment or providing copies to the officer as requested;
    • allowing the officer to take photographs or make video or audio recordings (with written consent);
  • allowing the officer to examine anything on the premises that is relevant to the inspection (it should be noted that employers may be found non-compliant if they refuse to cooperate during an inspection [R209.4]).

Note: an officer may consider that an employer has made reasonable efforts if they

  • meet any of the conditions above that are relevant to a particular inspection; or
  • have cooperated to the greatest extent possible during an inspection.

On-site inspections

On-site inspections will be conducted by ESDC/SC on behalf of IRCC.

Compliance conditions imposed on employers [R209.2]

The purpose of an inspection authorized under section R209.5 is to determine if an employer who provided an offer of employment under subparagraph R200(1)(c)(ii.1) has complied with the conditions stated in section R209.2. These conditions are imposed by operation of law (i.e., automatically) on issuance of the associated work permit. The conditions are applicable only during the period of the work permit but can be inspected for compliance up to six years after the work permit issuance.

Although IRCC may verify any of the conditions listed below individually as part of an employer inspection, it will be a standard practice to review all conditions during an inspection.

Although the conditions are imposed only for the period of the work permit, compliance with conditions can be inspected from the first day of the work permit issuance and up to six years after the work permit issuance. During this period, the following conditions can be inspected:

  1. The employer must remain actively engaged in the business in respect of which the offer of employment was made [R209.2(1)(a)(i)].
  2. The employer must comply with the federal and provincial laws that regulate employment and the recruiting of employees in the province in which the foreign national works [R209.2(1)(a)(ii)].
  3. The employer must provide the foreign worker with employment in the same occupation as that set out in the offer of employment and with wages and working conditions that are substantially the same as — but not less favourable than — those in the same offer [R209.2(1)(a)(iii)].
  4. The employer must make reasonable efforts to provide temporary foreign workers with a workplace that is free of abuse [R209.2(1)(a)(iv)] and, more specifically, free of
    1. physical abuse, including assault and forcible confinement;
    2. sexual abuse, including sexual contact without consent;
    3. psychological abuse, including threats and intimidation; and
    4. financial abuse, including fraud and extortion.
  5. The employer must be able to demonstrate that any information they provided in relation to an offer of employment under section R209.11 or on request of an officer during the associated work permit application [R200(1)(c)(ii.1)] was accurate [R209.2(1)(b)(i)].
  6. The employer must retain any document that relates to compliance with the imposed conditions [R209.2(1)(b)(ii)].

Assessing compliance conditions

Officers can request specific documents or information or simply ask the employer to provide whatever documents the employer determines are sufficient as proof of their compliance with the conditions. A list of possible documents that could be provided as proof is provided in Documents that may be used to verify employer compliance.

On receipt of the documents and any other information the employer provides as proof of their compliance or justification, an officer will review the documents and information to determine compliance with the conditions.

Employer is actively engaged in the business

To assess whether the employer of record is actively engaged in the business in which the offer of employment was made, all relevant documentation, including a Canada Revenue Agency business number, business licence or permit and the employer’s relevant income documents can be requested.

In addition to a business licence or permit and a relevant income document, the inspection initiation letter to the employer may request one or more of the following documents as proof of business activity:

  • an attestation by a lawyer, notary public or chartered accountant who is a member in good standing within their respective professional body, confirming that the employer is actively engaged;
  • an up-to-date commercial lease agreement; or
  • a formal letter from a legal business other than the employer’s, confirming the existence of a contract for goods and/or services being provided.

Additional information available to the public may also be used to make a determination on the active engagement in business of an employer who has made the offer of employment to the temporary foreign worker. Information sources include

  • Internet searches (e.g., Google, Better Business Bureau, Industry Canada, Canada 411);
  • provincial websites;
  • employer websites;
  • Job Bank advertisements.

Note: Any extrinsic information (e.g., publically available or not provided by the employer) used in making a decision on compliance must be revealed to the employer prior to a finding of non-compliance, and the employer must have an opportunity to respond to this information.

Compliance with federal, provincial and territorial employment and recruitment legislation

Compliance with federal, provincial and territorial (F/P/T) employment and recruitment legislation is checked up front as part of the work permit application process. For the purpose of inspections, the verification of compliance with F/P/T laws should focus only on the employer’s compliance record from the date of the work permit issuance.

Compliance in respect of this condition is focused on any federal or provincial laws that regulate employment and recruitment in the province in which the temporary foreign worker works. This includes, for example, labour law areas dealing with health and safety, unfair dismissal, the right to file complaints, leave and workplace privacy laws. It also includes recruitment laws that regulate the business of employment agencies and recruiters. More examples are provided below.

Regardless of the triggering event, there are some specific types of documentation for any F/P/T compliance issue that can or should be checked:

  • proof of registration – where required by provincial or territorial employment or recruitment legislation for employers and/or recruiters;
  • workers’ compensation clearance letter – declaring that the employer is registered with the workers’ compensation board and has an account in good standing;
  • other relevant official provincial or territorial documentation, including any documentation available directly from provinces by way of information sharing agreements or information available online to the general public.

To meet this condition, employers must not be convicted of any offence, or be found in violation of any federal, provincial or territorial law governing employment or recruitment from the date the worker arrives. In most cases, information about violations and convictions is readily available online (e.g., from federal or provincial websites); however, if extrinsic information (e.g., website information not provided by the employer) is used, prior to recommending a finding of non-compliance, officers must provide the employer with an opportunity to respond to any allegations.

Examples of federal, provincial and territorial laws

This is not an exhaustive list. Examples include but are not limited to

Occupation, wages and working conditions

Occupation

The occupation and duties must fall within the same National Occupation Classification (NOC) as those specified in the Offer of Employment provided under section R209.11.If the duties are not in the same NOC, the employer may be deemed non-compliant.

Variance in duties

Acceptable variations to job duties include only those that are covered by the same NOC but may not have been explicitly listed in the Offer of Employment. Any duties that fall outside of the approved NOC are considered as “not the same.”

Promotion or change of NOC

In cases where the employer has promoted or otherwise changed the foreign worker’s duties, the foreign worker must receive a new Offer of Employment and work permit prior to implementing the change.

If a new work permit for the promotion or change in occupation has not been previously approved and the temporary foreign worker is found to be working in an occupation other than what was stated on the Offer of Employment, this constitutes non-compliance by the employer. It could also lead to enforcement action against the foreign worker for unauthorized work.

Wages

“Substantially the same – but not less favourable – wages” means that

  • wages paid cannot be less than those outlined in the Offer of Employment provided as per R209.11;
  • any unusual deductions (such as recovery of the employer compliance fee, transportation costs) should be stated in the Offer of Employment.

Note: Wages under the IMP must meet the minimum wage requirement in the province of employment as per the condition to meet federal or provincial laws.

Note: Wages paid that are higher than those in the offer of employment, it may indicate a change in duties that would mean a different occupation than offered.

The offer of employment requires input of hourly wages in Canadian dollars. Foreign workers can be paid in Canadian currency or in another legal currency, so long as the foreign worker is paid the Canadian equivalent wage stated in the Offer of Employment throughout the period of employment. The foreign currency must be noted in the Offer of Employment information.

Wages paid in a foreign currency must be verified at the time of the work permit application to ensure they observe the minimum provincial or territorial wage laws.

Working conditions

Working conditions may include those non-wage related remuneration benefits and entitlements specifically detailed in the Offer of Employment, such as

  • location of employment;
  • statutory holidays, sick and vacation days;
  • hours of work (including overtime);
  • transportation costs (where applicable);
  • accommodations, conditions and costs (where applicable);
  • health or medical insurance; and/or
  • other non-taxable benefits.

Note: Many other working conditions and workplace standards (e.g., obligations around dismissals and rights to file complaints, occupational health and safety regulations and recruitment laws), are governed by provincial and territorial legislation. Employers of foreign workers must also comply with these laws in order to meet IMP requirements.

Acceptable changes

Employers are not required to inform IRCC of changes in working conditions. However, they will have to provide evidence of an acceptable justification [R203(1.1)] at the time of inspection should there be differences between the working conditions offered and those found during inspections.

For example, a reduction in hours could be justified by a work-sharing agreement, a documented illness or a documented request by the worker for a reduction in hours. In such cases, the employer should submit documentation to substantiate their claims regarding the change (e.g., a copy of the work-sharing agreement) during the inspection.

Abuse-free workplace

The employer must “make reasonable efforts to provide a workplace that is free of abuse, within the meaning of paragraph 72.1(7)(a)” of the IRPR.

Definition of abuse

Paragraph R72.1(7)(a) defines abuse as

  1. physical abuse, including assault and personal confinement;
  2. sexual abuse, including sexual contact without consent;
  3. psychological abuse, including threats and intimidation; and
  4. financial abuse, including fraud and extortion.

Charges or convictions for certain criminal offences could lead to an inspection

In addition to the types of abuse outlined in the IRPR, if IRCC receives information indicating that an IMP employer or one of their employees (both Canadian permanent residents and temporary foreign workers) has been accused of committing or convicted of the following abuse-related crimes, that employer will be inspected (based on the trigger “reason to suspect”), to determine whether reasonable efforts have been made to provide a workplace free of abuse:

  • physical or sexual assault in the workplace;
  • an offence causing death or bodily harm to an employee;
  • trafficking in persons (or a related offense);
  • uttering threats to cause death or bodily harm to an employee;
  • harassment in the workplace (including bullying); and
  • fraud/extortion against an employee (including withholding pay without reason and paying below what was agreed to in the Labour Market Impact Assessment).

Application of condition

For the purposes of an inspection, the “employer” is the person or organization who submitted the offer of employment under section R209.11.

Where an employer holds sole supervisory authority in the workplace (e.g., small employers, sole proprietors), they are solely responsible for complying with this condition.

However, for larger employers with more complex organizational structures, everyone who is in a supervisory role, particularly those responsible for supervising foreign workers, has a shared responsibility to enable employer compliance with this condition.

If abuse is perpetrated by a third party (defined as a person or organization acting on an employer’s behalf, such as a recruiter, consultant, subsidiary), the employer may be found responsible for the actions of that third party. In this case, the employer will be expected to demonstrate efforts to address the third party’s abuse.

If an employer is found to be directly responsible for abusing a temporary foreign worker, the employer will be deemed non-compliant and will be subject to applicable consequences.

The employer must demonstrate that positive, concrete steps have been taken to prevent workplace abuse and, where allegations of abuse are made or an actual incident has occurred, must take reasonable steps to respond and to prevent any reoccurrence.

Employer efforts to provide abuse-free workplace

To verify whether reasonable efforts have been made, the following three elements will be considered:

  1. An employer has made general efforts to prevent workplace abuse.
  2. The employer or anyone in a supervisory role or acting on the employer’s behalf has not actively participated in abuse, including failing to stop abuse of which they had knowledge.
  3. Where an allegation or incident of abuse occurred, steps were taken to address it and prevent it from happening again.

An employer will be deemed non-compliant where a determination is made of failure by the employer to demonstrate compliance with any of the elements, including the occurrence of abuse, and they are found to be actively responsible for the abuse, including failure to stop the abuse.

A. Efforts to prevent workplace abuse in general

Indicators of general efforts made by an employer to prevent workplace abuse from occurring may include, but are not limited to

  • development and distribution of policies and procedures that address situations of abuse in the workplace (e.g., what to do if an employee or supervisor is aware of or experiencing abuse);
  • mechanisms to address and resolve workplace abuse, which could include complaints policies & protocols, dispute resolution mechanisms, an employee representative or contact person, employee counselling, anonymous hotlines;
  • recent training (within the last two years) provided to employees and supervisors to identify and recognize abuse and to address it;
  • indication that the employer was aware or should have been aware of the risk of abuse relating to particular staff members, or particular situations where workers are or were at risk; and
  • indication that the employer took reasonable steps to ensure that employees with known abusive or violent tendencies do not have direct contact with foreign workers.

Officers should note that while all employers must make efforts to provide a work environment that is free of abuse and violence, not all employers will have the same types of policies and procedures in place to deal with matters of abuse. The employer must provide sufficient information to enable verification of compliance with the regulatory condition. However, officers can use the indicators listed above in their assessments.

B. Information suggesting that abuse in the workplace has occurred

Section 209.2(1)(a)(iv), requires employers to make reasonable efforts to provide a workplace free of abuse. In order to meet this condition, employers should be asked to demonstrate efforts taken to prevent abuse generally, as well as any measures taken to respond to specific allegations or instances of abuse that have occurred.

If an employer is found to be directly responsible for abusing a foreign worker, the employer will be deemed non-compliant and will be subject to applicable consequences. The employer will be considered actively responsible in situations where

  • the employer, a supervisor or a third party acting on the employer’s behalf has personally abused a foreign worker;
  • there is information to suggest that it is more likely than not that the employer or a supervisor or third party has directed, encouraged or supported abuse (including failing to act when they have knowledge of abuse) by another individual;
  • there is information to suggest that the employer, a supervisor or a third party has taken action to protect the abuser by discouraging or preventing a report of abuse to authorities, suppressing information pertaining to abuse or providing false or misleading information to authorities, including ESDC; or
  • there is information to suggest that the employer or a supervisor has knowingly placed another employee who has been convicted of a violent crime or abuse against an employee in a position that directly interacts with foreign workers.

Where there is evidence of a possible provincial or territorial offence or criminal behaviour on the part of the employer or other employees, IRCC will notify the relevant authorities in accordance with applicable procedures and directives related to information sharing.

C. Efforts to respond to or prevent the reoccurrence of abuse

Reasonable efforts to provide a workplace free of abuse after an incident of abuse or an allegation of abuse for which the employer will not be considered actively responsible require the employer to demonstrate concrete changes of practice or policy, such as

  • indication of relevant disciplinary action such as the dismissal of a staff member considered to be a risk to cause future abuse;
  • modification to any of the policies, protocols, training or mechanisms listed in section A, or the creation of policies, protocols, training or mechanisms, etc.;
  • other organizational changes to improve the awareness, safety or protection of individuals such as additional security measures (locks, lights, individuals on call, etc.); new reporting factors (e.g., managers performance reviews are based on implementation of new abuse awareness);
  • full cooperation with the relevant authorities investigating allegations or instances of abuse.

For this element, the employer must provide satisfactory responses to requests made in accordance with the department’s inspection authorities. Where IRCC has determined that abuse has occurred, the onus is on the employer to provide sufficient evidence of reasonable efforts to prevent abuse from reoccurring. In addition, where IRCC has determined that there is not sufficient evidence to conclude that abuse has occurred, but that there is sufficient information to cause reasonable concern that abuse may have occurred, the onus is also on the employer to provide sufficient evidence of compliance with this element.

To demonstrate sufficient efforts to respond to actual instances of workplace abuse, employers must be able to explain the specific actions taken. Such actions could include a high-level description of a process that includes some or all of the following:

  • assessment of the facts;
  • support measures for the person who made the allegation (e.g., receipts for medical care, counselling);
  • referral to relevant federal or provincial authorities, where appropriate (e.g., police);
  • result and action taken (e.g., firing the perpetrating employee or ensuring they will not have contact with temporary foreign workers);
  • employer follow-up with the victim(s); and
  • follow-up on efficacy of any changes made.

Verifying the accuracy of information provided

Employers must be able to prove that the information they provided in the Offer of Employment or on request of an officer during the work permit application process was accurate.

All information provided and attestations made on the Offer of Employment must be true and accurate. If an employer wishes to change any of the information stated in the Offer of Employment and remain compliant, they must do so before the work permit is issued. Any changes to the information on the Offer of Employment after work permit issuance will require the submission of a new Offer of Employment and a new work permit application.

Where it is determined that an employer has provided false, inaccurate or misleading information on the Offer of Employment, knowingly omitted information or knowingly provided false or misleading information during an inspection, IRCC may find that the employer did not make reasonable efforts to comply with the condition.

Document retention by employers

The compliance regulations enable IRCC to compel employers to produce documents for the purpose of verifying compliance. Employers are required to retain all documents to substantiate the accuracy of information provided in the Offer of Employment and to demonstrate their compliance with the conditions set out in paragraphs R209.2(1)(a) and (b) from the first day of the associated work permit issuance to six years thereafter.

Decision-making

The instrument of designation and delegation designates specific positions within IRCC as decision makers in regards to inspections and determinations.

Justification

Subsection R203(1.1) sets out specific justifications that may apply if an employer has not complied with conditions imposed under section R209.2.

Specifically, these justifications are the following:

  1. change in a federal, provincial or territorial law (e.g., increase in minimum wage);
  2. change to a collective agreement (e.g., increase or decrease in salary);
  3. changes in economic conditions, impacting all employees equally (e.g., economic downturn causing layoffs);
  4. administrative error made in good faith if the employer subsequently provided compensation (e.g., missed paycheque);
  5. unintentional accounting or administrative error if the employer subsequently provided compensation (e.g., wrong compensation value entered into payroll system);
  6. circumstances similar to points a) to e) (may require compensation if similar to point d) or point e); or
  7. force majeure (e.g., fire or flood destroys place of business).

Compensation

The IRPR requires that on determination that the reason actual wages paid are different than those set out in the offer of employment is due to circumstances similar to point d) or point e), the employer must either provide compensation or, if compensation is not possible, demonstrate sufficient efforts to do so. During an inspection, the employer must inform IRCC of what compensation has been provided to all temporary foreign workers who suffered a disadvantage resulting from the employer’s error.

Compensation may not be possible in the event of a dramatic change in economic conditions that directly impacts the business, in the event of force majeure or if the temporary foreign worker has already gone home.

Efforts to compensate

Where applicable, the employer must be able to demonstrate that they made sufficient efforts to provide compensation (e.g., cancelled cheques or attempted correspondence with the affected workers). If the employer cannot demonstrate sufficient efforts, they may be deemed non-compliant.

Inspection result: compliant or non-compliant

Based on a review of all available information, possible inspection outcomes are the following:

Compliant: The employer has complied with all conditions reviewed as set out in the regulations or has provided sufficient evidence that their failure to meet all the conditions as set out in paragraph R209.2(1)(a) is justified as it results from one of the situations identified in subsection R203(1.1).

An employer’s failure to comply with the conditions set out in paragraph R209.2(1)(b) is justified if the employer made all reasonable efforts to comply with the condition as per subsection R209.2(4). In the case of conditions set out in section R209.4, non-compliance may also be justified if it results from anything done or omitted to be done by the employer in good faith as per subsection R209.4(2).

Non-compliant: The employer fails to demonstrate that they are in compliance with the conditions under IRPR and the failure is not justified. Non-compliance is determined where the employer submitted documentation or information which, when assessed, indicates that

  • the employer has not complied with one or more of the conditions in section R209.2; and
  • the employer has failed to provide an acceptable justification; or
  • the justification provided requires the employer to undertake compensation and the employer has not done so.

A finding of non-compliance may also be made if an employer refuses to provide requested documentation or is otherwise uncooperative during an inspection as per section 209.4.

Note: The above-mentioned examples are not all-encompassing and analysts may encounter other irregularities that could lead to a recommendation of non-compliance.

Documents that may be used to verify employer compliance

Employers must cooperate and provide documents as requested in order to demonstrate compliance. Information must always be collected following departmental information collection authorities and privacy laws. In some cases, certain information provided by the employer will need to be redacted (e.g., social insurance numbers or other information that is not relevant to an inspection).

Documents employers may be asked to provide to demonstrate compliance include the following:

  • Business license or permit, T2 Schedule 125 Income Statement Information, T2 Schedule 100 Balance Sheet Information, commercial lease agreement, etc.—To demonstrate the genuineness of the job offer for foreign workers. In addition to these documents, a T4 Summary of Remuneration paid may be used to support the total wages paid to a foreign worker.
  • Provincial or territorial employer and recruiter registration certificate or license (where applicable)—To demonstrate compliance with federal and provincial or territorial employment and recruitment legislation.
  • Anti-abuse policies, codes of employee conduct, guidelines provided to staff, protection or support protocols to staff, training, steps taken to resolve complaints of abuse, anti-harassment policies, protocols, etc.—Evidence that the employer has made reasonable efforts to provide a workplace free of abuse. In assessing this, all available information will be weighed.
  • Payroll records—To ensure the appropriate prevailing wage and overtime are being paid and deductions are being made (Canada Pension Plan, employment insurance, income tax), and to explain any non-standard deductions.
  • Cancelled cheques, money orders or bank statements – To determine whether employers have provided temporary foreign workers with wages, working conditions and appropriate compensation.
  • Time sheets—To ensure workers are working the number of hours set out in their offer of employment. In most cases, this is usually defined as 30 or more hours per week.
  • A job description—To ensure foreign workers are working in approved occupations and under the same labour standards as their Canadian counterparts.
  • Registration with provincial or territorial workplace safety or workers' compensation clearance letter (if applicable)—To ensure the employer has registered for workplace safety insurance and is in good standing, to ensure that workers are covered in case of injury.
  • Travel itinerary or invoices (if applicable)—To determine if an employer provided round-trip transportation costs for foreign workers under their employment.
  • Accommodation information (if applicable)—Where the employer is providing accommodation, a copy of the rental agreement.
  • Private health insurance coverage (if applicable)—Proof the employer paid for private health insurance until the foreign worker was eligible for provincial or territorial health insurance coverage. The documentation provided as proof of payment should not include financial account numbers.
  • Employment contract—Employers may be required to submit a copy of the jointly-signed contract during an inspection to demonstrate compliance.

Note: This is not an exhaustive list. Employers should keep a record of all documentation in order to demonstrate compliance with program requirements.

Date Modified: