Does a USCIS A-Number Change? What Actually Changes on New Cards
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An expired green card or an expired driver's license never triggers Form I-9 reverification. Permanent residence doesn't end when the card does, and a driver's license only proves identity. The USCIS Handbook for Employers (M-274) lists both among the documents employers should not reverify after they expire, along with U.S. passports and passport cards.
That rule got expensive in June. The Department of Justice settled with Whirlpool over an electronic I-9 system at its Amana, Iowa plant that allegedly prompted HR to reverify exactly those documents and to ask non-citizen employees for paperwork they didn't need to show. If your HRIS or I-9 software sends expiration reminders, it's worth knowing which documents it's reminding people about.
DOJ's Immigrant and Employee Rights Section (IER) opened its investigation in November 2021 after an employee filed a charge. In a settlement agreement signed in June 2026, IER said it found reasonable cause to believe that from at least November 2019 through December 2021, the Amana location's electronic Form I-9 systems prompted the company to ask non-U.S. citizen workers for additional and unnecessary documents at reverification, and to reverify non-citizen workers when their Permanent Resident Cards or List B documents expired. IER also said workers who didn't meet those requirements were terminated.
Whirlpool denies the allegations. It agreed to pay $125,000 in civil penalties, set aside up to $100,000 in back pay for affected workers, train its HR staff, and send IER certain Forms I-9 from the plant every two months for the three-year term of the agreement.
The detail HR teams should notice is where the problem sat. According to IER, it was in the system prompts. The software asked for more than the rules allow, and people did what the software asked. The settlement is logged on our ICE Worksite Enforcement Tracker alongside the rest of 2026's enforcement actions.
Reverification follows work authorization that has an end date. Being a non-citizen isn't the trigger. Plenty of non-citizens, including permanent residents, refugees, and asylees, have work authorization that doesn't expire. Even E-Verify's own "Work Authorization Docs Expiring" alert only fires for two documents, the Employment Authorization Document (Form I-766) and the Form I-94.
| What the employee presented or entered | Reverify? | Why |
|---|---|---|
| U.S. passport or passport card | Never | Citizenship doesn't expire. M-274 §8.1 lists both as do-not-reverify. |
| Permanent Resident Card (green card) that later expires | Never | Permanent residence continues after the card expires (M-274 §7.1). |
| Expired green card with a Form I-90 or N-400 receipt that extends it | Never | The receipt extends the card's validity, and M-274 §7.1 says reverification is never required when these expire. |
| Conditional resident's two-year green card, unexpired when presented | No | USCIS instructs employers not to reverify it. |
| Driver's license, state ID, or any other List B document | Never | List B proves identity only. Reverification is about work authorization. |
| Unrestricted Social Security card | Never | It shows work authorization with no end date. |
| Employment Authorization Document (Form I-766) | Yes, by the date it expires | Temporary work authorization, unless an automatic extension applies. |
| Foreign passport with Form I-94 (H-1B, L-1, and similar) | Yes, when the authorization ends | Work authorization is tied to the status on the I-94. |
| Section 1 "noncitizen authorized to work" with an expiration date | Yes, by that date | M-274 §6.1 requires reverification no later than the date authorization expires. |
| Temporary I-551 stamp in a passport or on an I-94, or an immigrant visa endorsed as temporary I-551 evidence | Yes | The card or another acceptable document is due when the stamp expires, or one year after admission or I-94 issuance if it has no date. |
| Expired conditional-resident card with a Form I-751 or I-829 receipt | Yes, before the extension ends | The receipt extends the card for a set period only (M-274 §7.1). |
| Employee listed on E-Verify's Status Change Report | Yes, using Supplement B | Applies to E-Verify employers when DHS revokes or terminates an EAD. |
Receipts are a separate track. A receipt for a lost, stolen, or damaged document gives the employee 90 days to show the replacement, and following up on that deadline is part of doing the I-9 correctly. It isn't reverification, and it doesn't make the replacement document something to reverify later.
When reverification does apply, the employee chooses any unexpired document from List A or List C, you record it in Supplement B, and you never open a new E-Verify case for it.
I-9 modules track expiration dates because a missed reverification is a substantive violation. The trouble starts when the logic keys off dates and citizenship status instead of work authorization.
The most common version is a reminder rule that fires for every document in Section 2 with an expiration date. That sweeps in driver's licenses, state IDs, and green cards, and it sends the employee a notice asking for something new. A close second is a rule that treats anyone who didn't check "U.S. citizen" in Section 1 as needing reverification, which puts permanent residents in the same queue as H-1B workers. The letter template matters too. A notice that asks for an "updated green card" or "current ID" is telling the employee which document to bring, and employees at reverification get to choose.
None of this requires anyone to decide to single people out. In the Whirlpool case, the prompts themselves were the problem, and a setting nobody has opened in years can produce a pattern of requests that looks the same to an investigator as a policy would. It's one more version of the gaps we covered in the HRIS I-9 integration gap.
We'll look at your reverification setup with you. Our compliance team can walk through which documents your current system flags and what it asks employees to bring. Schedule a free compliance call, or ask about a full I-9 audit.
Turn the rule off before it sends another one. Don't take action against an employee for not producing a document they were never required to show, and don't hold up schedules or pay while you sort it out. IER runs a free employer hotline at 1-800-255-8155 for questions about a specific situation.
The exposure is real. Unfair documentary practices carry civil penalties of $236 to $2,364 per affected individual under DOJ's current penalty table, and settlements like Whirlpool's add back pay and years of reporting on top.
No. If a permanent resident presented an unexpired green card when they were hired, you don't reverify when the card expires. DOJ's guidance says asking for a new card based on citizenship status may violate the anti-discrimination rules.
No. A driver's license is a List B document, which proves identity only. Reverification only covers work authorization, so List B documents are never reverified, whoever presented them.
If the card was unexpired when the employee presented it, don't reverify when it expires. It's different if the employee presented an expired conditional card together with a Form I-751 or I-829 receipt. That combination is a List C document with a limited extension, and you reverify before the extension ends.
Not for Form I-9 purposes. Asking a permanent resident for a new card because the old one expired is exactly the kind of request IER treats as a potential unfair documentary practice.
No later than the date it expires, unless an automatic extension applies. The employee can present any unexpired List A or List C document, including an unrestricted Social Security card, and you record it in Supplement B.
No. E-Verify's own user manual says not to create a new case for reverification. It happens on the Form I-9 in Supplement B.
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