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Are employees who waive payment required to complete the I-9?

Yes. Employees who waive payment (ex. interns, volunteers, etc) are required to complete the I-9. According to the Department of Justice, anyone hired to work in exchange for wages or other types of remuneration are required to complete an I-9. Remuneration is "anything of value given in exchange for labor or services rendered by an employee." (U.S. Department of Homeland Security, Handbook for Employers). This includes, but is not limited to, library access, food, lodging, e-mail privileges, and tuition waivers.