Recently introduced bills in Congress suggest that immigration reform may include mandatory E-Verify provisions. The E-Verify Modernization Act of 2013, H.R. 478, sponsored by Congressman Phil Gingrey (R-Ga.), would “make the E-Verify Program permanent and mandatory, and to provide for certain changes to procedures for participants in the Program” by amending the Illegal Immigration Reform and Immigrant Responsibility Act of 1996, Pub. L. No. 104-208, 111 Stat. 3546 (Sept. 30, 1996). The Accountability Through Electronic Verification Act, S.B. 202, sponsored by Senator Charles Grassley (R-Ia.), would “expand the use of E-Verify[] to hold employers accountable.”