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TIGTA Report 2022-20-007 — Cybersecurity and Telework During the COVID-19 Pandemic

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CourtTreasury Inspector General for Tax Administration (TIGTA)
Filed2021-12-17

Summary

A final audit report of the Treasury Inspector General for Tax Administration, Report Number 2022-20-007, issued December 17, 2021 to the Commissioner of Internal Revenue. It reviews cybersecurity related to IRS telework during the COVID-19 pandemic at the request of the U.S. House of Representatives Committee on Oversight and Reform. The report states the IRS did not acquire new remote connections software but purchased additional licenses, that approximately 26,000 employees were teleworking in March 2020 and nearly 60,700 by September 2020, and that $37 million was received and allocated for equipment and licenses. It describes remote access by virtual private network with two-factor authentication, collaboration platforms including Zoom for Government and Cisco WebEx with file sharing disabled, and a telework agreement waiver through March 23, 2022. It makes no recommendations.

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1 
 
 
 
 
 
 
Cybersecurity and Telework  
During the COVID-19 Pandemic 
 
 
December 17, 2021 
 
Report Number:  2022-20-007 
 
 
 
 
 
 
 
 
 
 
TIGTACommunications@tigta.treas.gov   |   www.treasury.gov/tigta 
 
TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION 

HIGHLIGHTS:  Cybersecurity and Telework During the COVID-19 Pandemic 
Final Audit Report issued on December 17, 2021 
Report Number 2022-20-007 
 
 
Why TIGTA Did This Audit 
The U.S. House of Representatives 
Committee on Oversight and 
Reform requested the Department 
of the Treasury Office of Inspector 
General identify any vulnerabilities 
created or exacerbated by the 
Department of the Treasury’s use 
of remote access software to 
facilitate telework during the 
Coronavirus Disease 2019 
(COVID-19) pandemic and whether 
any such vulnerabilities were 
effectively mitigated.  TIGTA 
coordinated with the Office of 
Inspector General and completed 
this review to address the 
Committee’s request relative to the 
IRS.    
Our overall objective was to review 
cybersecurity related to IRS 
telework during the COVID-19 
pandemic. 
Impact on Taxpayers 
The United States has recently 
been the target of several 
high-profile cyberattacks.  As 
cybersecurity threats against the 
Federal Government and other 
entities continue to grow, 
protecting the confidentiality of 
taxpayer information continues to 
be a top concern for the IRS.  
 
 
 
 
 
 
 
 
 
 
 
What TIGTA Found 
The IRS stated it did not acquire new remote connections software to 
support telework during the COVID-19 pandemic but did purchase 
additional licenses.  In March 2020, approximately 26,000 IRS 
employees were teleworking.  As of September 2020, nearly 
60,700 employees were teleworking.  Remote access to IRS systems is 
allowed via a virtual private network, and IRS policy requires 
two-factor authentication.  The IRS received and allocated $37 million 
for equipment and licenses for teleworking employees. 
The IRS stated it uses or plans to start using several collaboration 
platforms, such as Zoom for Government and Cisco WebEx, to 
connect internal and external stakeholders virtually.  Utilizing these 
applications minimized the impact of the COVID-19 pandemic but 
also increased the potential for data breaches and unauthorized 
disclosure.   
The IRS stated that, for meetings supported by Zoom for 
Government and Cisco WebEx, participants could only attend by a 
direct invitation from the IRS host.  In addition, file sharing was 
disabled for both platforms.  The IRS is also working to complete its 
testing of Microsoft Teams and is beginning the implementation with 
a small group of pilot users in the production environment.  The IRS 
had guidance in place to prevent the unauthorized dissemination of 
Controlled Unclassified Information, Personally Identifiable 
Information, and Sensitive But Unclassified information.   
The IRS stated in September 2020, it implemented a scalable 
information technology asset management program, which improved 
the accuracy of compliance and other internal inventory reporting 
needs.  This asset management program matured its capabilities to 
provide visibility into asset data by integrating additional 
configuration and asset inventory data of laptop computers, virtual 
workstations, and Personal Digital Assistants. 
The IRS waived the requirement for employees to have an approved 
telework agreement and encouraged, but did not require, new 
teleworkers to complete the telework training program.  While these 
telework policies will be waived through March 23, 2022, the IRS 
stated it will reassess periodically and may lift the waiver earlier. 
The IRS has continuous monitoring and network scanning in place to 
identify vulnerabilities, and these processes were not impacted by the 
transition to telework.  The IRS performs vulnerability scanning 
six days a week, and the scan results are ingested into an analytics 
and reporting tool, providing stakeholders continuous visibility into 
vulnerability data about their assets.  The IRS has various network 
management programs, including configuration compliance 
scanning, audit log management, incident monitoring, and malicious 
code detection. 
What TIGTA Recommended 
TIGTA made no recommendations. 

U.S. DEPARTMENT OF THE TREASURY 
WASHINGTON, D.C.  20220 
TREASURY INSPECTOR GENERAL 
FOR TAX ADMINISTRATION 
 
 
 
December 17, 2021 
 
 
MEMORANDUM FOR: COMMISSIONER OF INTERNAL REVENUE 
 
 
M. Weir for 
 
FROM: 
Michael E. McKenney  
 
Deputy Inspector General for Audit  
 
SUBJECT: 
Final Audit Report – Cybersecurity and Telework During the 
COVID-19 Pandemic (Audit # 202220022) 
 
This report presents the results of our review of cybersecurity related to Internal Revenue Service 
(IRS) telework during the Coronavirus Disease 2019 pandemic.  This audit is in response to a 
request from the U.S. House of Representatives Committee on Oversight and Reform to the 
Department of the Treasury Office of Inspector General and does not include any 
recommendations.  This review is part of our Fiscal Year 2022 Annual Audit Plan and addresses 
the major management challenge of Enhancing Security of Taxpayer Data and Protection of IRS 
Resources. 
Copies of this report are also being sent to the IRS managers affected by the information in the 
report.  If you have any questions, please contact me or Danny R. Verneuille, Assistant Inspector 
General for Audit (Security and Information Technology Services).   
 

 
 
Cybersecurity and Telework During the COVID-19 Pandemic 
Table of Contents 
Background .....................................................................................................................................Page 1 
Results of Review .......................................................................................................................Page 2 
Acquisition, Deployment, and Management of Remote Access Tools ............Page 2 
Distribution and Management of Virtual and Physical Assets ............................Page 4 
Remote Access Telework Security Policies and Operations .................................Page 5 
Appendices 
Appendix I – Detailed Objective, Scope, and Methodology ................................Page 8 
Appendix II – Congressional Request Letter ..............................................................Page 9 
Appendix III – Glossary of Terms ....................................................................................Page 13 
Appendix IV – Abbreviations ...........................................................................................Page. 15 
 

 
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Cybersecurity and Telework During the COVID-19 Pandemic 
Background 
The Federal Information Security Modernization Act of 2014 (FISMA)1 requires inspectors 
general to conduct an annual evaluation of cybersecurity policies and practices of their 
respective departments and agencies.  In June 2021, the U.S. House of Representatives 
Committee on Oversight and Reform2 requested that an assessment of any vulnerabilities 
created or exacerbated by the Department of the Treasury’s use of remote access software to 
facilitate telework during the Coronavirus Disease 2019 (COVID-19) pandemic, and whether any 
such vulnerabilities were effectively mitigated, be included with the annual FISMA reporting.3  
The request was addressed to the Department of the Treasury Office of Inspector General and 
recommended that the work be performed as a part of the annual FISMA assessment.  We 
coordinated with the Office of Inspector General and completed this review to address the 
Committee’s request relative to the Internal Revenue Service (IRS).  Due to the scope of the work 
requested, we performed an audit separate from our FISMA audit4 work to address the 
Committee’s concerns. 
The Federal Government adopted the widespread use of virtual private networks5 (VPN) and 
other remote access technologies to facilitate continuity of operations and allow agencies to 
continue to serve the Nation throughout a deadly pandemic.  However, this environment 
created additional cybersecurity vulnerabilities that could jeopardize the integrity of Federal 
information technology networks.  The National Institute of Standards and Technology stated 
that major security concerns associated with telework include the lack of physical security 
controls, the use of unsecured networks, the connection of infected devices to internal networks, 
and the availability of internal resources to external hosts.6 
The proliferation and growing sophistication of malicious state and nonstate cyber actors 
requires Federal agencies to be able to maintain and protect the integrity of their information 
technology systems—particularly if they adopt more flexible telework policies after the 
COVID-19 pandemic subsides.   
                                                 
1 Pub. L. No. 113–283 (2014); 44 U.S.C. § 3555. 
2 See Appendix II for a copy of the Congressional Request letter. 
3 According to the Telework Enhancement Act of 2010 (Pub. L. No. 111–292 (2010)), the term ‘telework’ or 
‘teleworking’ refers to a work flexibility arrangement under which an employee performs the duties and 
responsibilities of such employee’s position, and other authorized activities, from an approved worksite other than the 
location from which the employee would otherwise work.  On March 17, 2020, in response to the COVID-19 
pandemic, the Office of Management and Budget directed U.S. departments and agencies to maximize telework.  
Office of Management and Budget, Federal Agency Operational Alignment to Slow the Spread of Coronavirus 
COVID-19 (Mar. 17, 2020). 
4 Treasury Inspector General for Tax Administration, Report No. 2021-20-072, Fiscal Year 2021 IRS Federal Information 
Security Modernization Act Evaluation (Sept. 2021). 
5 See Appendix III for a glossary of terms. 
6 National Institute of Standards and Technology, Guide to Enterprise Telework, Remote Access, and Bring Your Own 
Device Security (July 2016). 

 
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Cybersecurity and Telework During the COVID-19 Pandemic 
Results of Review 
Acquisition, Deployment, and Management of Remote Access Tools 
Remote connections 
The IRS stated that it did not acquire new remote connections software to support telework 
during the COVID-19 pandemic and instead only purchased additional licenses.  The Enterprise 
Remote Access Project, operational since 2004, is the IRS’s VPN solution for remote network 
access.  It provides IRS employees the ability to securely connect to the IRS network while 
working remotely.  The application uses security protocols to establish a secure remote 
connection to one of the three IRS Treasury Internet Connection sites.  The user account is 
authenticated before access to the network is granted.  The Enterprise Remote Access Project 
provides a VPN-based remote access solution that meets the remote access requirements of all 
IRS employees and approved contractors.  The IRS reported7 that it completed upgrades to 
double the bandwidth capacity to support 60,000 employees working remotely by the end of 
Fiscal Year 2020.  
The Internal Revenue Manual (IRM) stated the policy regarding remote connections and VPNs 
prior to the pandemic, including authorization of remote access to information systems prior to 
allowing the connection, requiring the use of two-factor authentication, and providing remote 
access via the IRS-approved VPN.8  The IRS has since made minor editorial updates to the IRM. 
In September 2021, the Government Accountability Office issued a report9 from which we 
concluded10 that the IRS: 
• 
Utilized a VPN and had established methods for employees to log in to agency systems 
and services remotely. 
• 
Documented elements of a telework security policy, all relevant security controls and 
enhancements, and that it had assessed all of the relevant security controls and 
enhancements for protecting its systems that provide remote access. 
• 
Demonstrated that it consistently monitored progress toward completing remedial 
actions for any identified weaknesses. 
In March 2021, we issued an interim report11 stating that, prior to the pandemic (between 
October 2019 and early March 2020), the IRS had an average of 26,000 employees teleworking 
approximately 22 hours per week.  By September 2020, nearly 60,700 employees were 
                                                 
7 IRS, Publication No. 5453, Information Technology Annual Key Insights Report:  Fiscal Year 2020 Successes and 
Accomplishments (2021). 
8 IRM 10.8.1.4.1.16 (May 9, 2019). 
9 Government Accountability Office, GAO 21-583, Selected Agencies Overcame Technology Challenges to Support 
Telework but Need to Fully Assess Security Controls (Sept. 2021). 
10 The Government Accountability Office identified the audited agencies that were not meeting the listed standards, 
indicating that the agencies not specifically identified had met the standard.  
11 Treasury Inspector General for Tax Administration, Report No. 2021-IE-R002, Interim Report – The IRS Leveraged Its 
Telework Program to Continue Operations During the COVID-19 Pandemic (Mar. 2021). 

 
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Cybersecurity and Telework During the COVID-19 Pandemic 
teleworking an average of 36 hours per week.  The number of teleworkers and average hours 
worked per week have remained relatively consistent from September 2020 through June 2021. 
Collaboration platforms 
The IRS stated that it utilizes or has plans to start utilizing several collaboration platforms to 
connect internal and external stakeholders virtually, including Skype for Business, Cisco WebEx, 
Saba Meeting, Zoom for Government (ZoomGov), and Microsoft Teams.  The use of such 
applications allowed the IRS to minimize the impact of the COVID-19 pandemic; however, it also 
increased the potential for data breaches and unauthorized disclosure.  
The IRS stated in the Fiscal Year 2020 Information Technology Annual Key Insights Report that it 
deployed Cisco WebEx to resume national settlement days virtually.  The IRS stated that the 
Cisco WebEx platform can support 800 users per server license and that it has 1,495 Martinsburg 
server licenses and 640 Memphis server licenses.  
In September 2020, the IRS stated that it purchased 1,100 Zoom Professional licenses, and it 
deployed ZoomGov to all IRS workstations.  The User and Network Services function’s ZoomGov 
team manages the administration of the application, including user roles.  The application is 
implemented using Single Sign On, which is by default a multifactor authentication mechanism.  
In the Fiscal Year 2020 Information Technology Annual Key Insights Report, the IRS also 
reported that it delivered ZoomGov to enable IRS Chief Counsel to participate in virtual court 
sessions.  The IRS stated that for the ZoomGov platform it has: 
• 
1,050 Professional Licenses which can each host 500 users. 
• 
50 Professional License Large Meeting licenses which can each host 1,000 users. 
The IRS is working to complete its testing of Microsoft Teams.  It is beginning the 
implementation of Teams with a small group of pilot users in the production environment.  The 
Cybersecurity function and the Privacy, Governmental Liaison, and Disclosure Office are partners 
in the implementation of Teams.  Together, they are working to create a secure, protected 
environment.  The Teams product was included in the Office 365 subscriptions and purchased in 
2019.  The Strategy and Planning function holds the Microsoft Enterprise Licensing Agreement.  
The IRS stated that its Applications Development function reviewed the Slack product, but that 
the IRS did not acquire it. 
Security of collaboration platforms 
The IRS stated that, for meetings supported by both ZoomGov and Cisco WebEx, participants 
can only attend by a direct invitation from the IRS host.  In addition, file sharing is disabled for 
both platforms.  The IRS had existing guidance in the IRM to prevent the unauthorized 
dissemination of Controlled Unclassified Information, Personally Identifiable Information (PII), 
and Sensitive but Unclassified (SBU) information.  The policies state that: 
• 
All collaborative technology must be approved by the appropriate authorizing official 
following an assessment of risk with mitigation. 
• 
E-mail messages, appointments, and other collaborative mechanisms containing 
confidential data must be encrypted when transmitted and stored. 

 
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Cybersecurity and Telework During the COVID-19 Pandemic 
Access management 
The IRS stated that it used two-factor authentication since 2005.  It initially started using grid 
cards for two-factor authentication but is now using smart cards with a Personal Identification 
Number for access.  Prior to the COVID-19 pandemic, the IRM required two-factor 
authentication for all remote access to an IRS system and that systems must monitor and control 
remote access methods.  Personal Identity Verification cards are used to authenticate users on a 
VPN.  The IRS stated that, in the event of a Personal Identity Verification card failure, the user is 
granted temporary access to a secure site to obtain a grid card.  To accommodate potential 
Personal Identity Verification card failures, the IRS purchased 40,000 additional grid card 
licenses.  Procedures are in place to remove inactive accounts and for emergency removal of 
accounts when a user is no longer authorized to have one.  From March 15, 2020, through 
October 27, 2021, 350 unauthorized user accounts and more than 16,000 inactive user accounts 
were removed from IRS system access. 
In August 2020, we reported12 that the IRS had effective strategies and protocols to authenticate 
network user identities, but additional work was needed to authenticate devices.  In the report, 
we found that not all of the devices accessing the IRS network through a VPN were 
authenticated.  We asked the IRS about the current status of the device authentication solution.  
The IRS responded that the device solution has been delayed due to challenges with the vendor.  
Distribution and Management of Virtual and Physical Assets 
The IRS stated that, in September 2020, the Information Technology Asset Management 
Program implemented a scalable data integration and analytics platform, which improved the 
accuracy of compliance and other internal inventory reporting needs.  In addition, the 
Information Technology Asset Management Program operationalized a data remediation 
process and tool to improve overall asset data quality.  In Calendar Year 2021, the Information 
Technology Asset Management Program matured these capabilities by integrating additional 
configuration and asset inventory data of assets such as laptop computers, virtual workstations, 
and Apple micro–Personal Digital Assistants.   
According to the IRS, the Hardware Asset Management team manages the physical hardware 
assets, including laptop computers and smartphones, throughout their life cycles in the 
Knowledge, Incident/Problem Service Asset Management Asset Manager Database.  Inventory 
transactional updates are reported to the Hardware Asset Management team as asset 
movement occurs.  The Knowledge, Incident/Problem Service Asset Management Asset 
Manager does not track employees who are teleworking.  Assets assigned to teleworking 
employees are designated with the employee’s Place of Duty on record.   
The IRS also stated that the Logistics Management team manages the distribution of assets and 
virtual workstations, including the distribution and provisioning of physical and virtual devices 
through the Knowledge, Incident/Problem Service Asset Management Database’s authoritative 
source inventory transactions.  The IRS reported in the Fiscal Year 2020 Information Technology 
Annual Key Insights Report that, through the Depot to Home initiative, laptop computers were 
                                                 
12 Treasury Inspector General for Tax Administration, Report No. 2020-20-036, Strategies and Protocols to 
Authenticate Network User Identities Are Effective; However, More Action Is Needed to Verify the Identity of Devices 
(Aug. 2020). 

 
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Cybersecurity and Telework During the COVID-19 Pandemic 
shipped directly to more than 2,000 employees.  The IRS stated that it accounted for all laptop 
computer shipments and no shipments resulted in permanent loss.  
In our March 2021 interim report, we stated that, by May 2020, the IRS distributed more than 
12,600 laptop computers and nearly an additional 6,000 by October 2020.  No details were 
provided on smartphones or other information technology–related equipment.  Our report also 
indicated that growth of telework during this period was limited by the IRS’s ability to identify, 
prioritize, and issue laptop computers and other information technology equipment to 
employees who previously had not participated in the telework program.   
The IRS stated that, in July 2020, it received approximately $1.6 million to procure desktop and 
portable printers and monitors.  In September and October 2020, the IRS issued product awards 
for nearly 5,000 printers and more than 1,700 monitors.  The equipment began arriving in 
February 2021.  By August 31, 2021, all of the printers were delivered, while all but three 
monitors were delivered by October 31, 2021. 
The IRS also reported that, in December 2020, it received nearly $2 million of additional funding 
for desktop and portable printers.  In April 2021, the IRS issued the second product award, and 
items began arriving at the end of that month.  During this time, employees requested more 
than 9,800 printers.  As of October 15, 2021, 5,543 (57 percent) of the 9,780 printers ordered 
from the vendor were received.  An additional 4,237 printers are awaiting delivery from the 
vendor. 
In May 2021, we issued another interim report13 that identified a spend plan in May 2020 
allocating $35 million to Continuity of Operations for costs associated with purchasing laptop 
computers, wireless devices, and software licenses in support of employees teleworking.  A 
September 2020 amendment to the spend plan separated Continuity of Operations into 
$22 million funded by the Coronavirus Aid, Relief, and Economic Security Act14 and $15 million 
funded by the Families First Coronavirus Response Act.15  The September 2020 quarterly report 
on actual expenditures reported that more than half of the total funds had been spent but did 
not provide details on expenditures in each area. 
Remote Access Telework Security Policies and Operations 
Security policy changes for telework 
The IRS stated that information technology security policy is set at an organizational and system 
level and that there were no updates to the security policies specific to the COVID-19 pandemic.  
However, a June 2021 memorandum provided guidance on several items, including the 
connection of personally owned and non-Government–furnished equipment to IRS systems and 
network.  The IRS also issued several operational updates regarding telework, which included: 
• 
Teleworking from a vehicle with a wireless Internet connection – The IRS stated that 
vehicles generally do not provide reasonable security and protection of Government 
                                                 
13 Treasury Inspector General for Tax Administration, Report No. 2021-16-026, Interim Report – Status of Coronavirus 
Response Funding (May 2021). 
14 Pub. L. No. 116-136 (Mar. 27, 2020). 
15 Pub. L. No. 116-127 (Mar. 18, 2020). 

 
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Cybersecurity and Telework During the COVID-19 Pandemic 
equipment and data.  If an employee is working with taxpayer data in their vehicle, there 
is a risk that bystanders could see through the vehicle’s windows, which could allow for 
inadvertent disclosure of PII. 
• 
Disposal and destruction of waste material containing PII or SBU data – The operational 
requirements stated that under no circumstance can employees burn paper with PII or 
SBU data and information at their telework locations.  In addition, employees under no 
circumstance are permitted to use non-Government equipment (such as shredders) to 
process IRS data.  Further, the IRS requires employees while teleworking to bring paper 
with SBU data into the office for proper disposal.  Employees are also required to keep 
paper with PII and SBU data secure in a locked receptacle.  Finally, employees must 
protect PII and SBU data in transit during transport to the office for proper disposal. 
The Privacy, Governmental Liaison, and Disclosure Office published a Privacy and Records 
Telework Policy checklist.  This included the requirements to follow a Clean Desk Policy while on 
telework, use IRS e-mail accounts to conduct official IRS business, and immediately report any 
breach of sensitive information or record loss. 
Our March 2021 interim report stated that the IRS waived the requirement for employees to 
have an approved telework agreement and encouraged, but did not require, new teleworkers to 
complete the telework training program.  The Human Capital Office stated that the IRS waived 
several other telework policies.  On September 30, 2021, the IRS extended the waiver of telework 
policies through March 23, 2022.  The IRS stated that it plans to reassess the situation 
periodically and may lift the waiver earlier.  It would provide employees with at least 30 days 
advance notice before requiring them to return to the office. 
Continuous monitoring 
The IRS stated that it has continuous monitoring and network scanning in place to identify 
vulnerabilities and that these processes were not impacted by the IRS’s transition to telework.  
The IRS performs vulnerability scanning six days a week, and the scan results are ingested into 
an analytics and reporting tool, providing stakeholders continuous visibility into vulnerability 
data about their assets.  The IRS has various network management programs, including 
configuration compliance scanning, audit log management, incident monitoring, and malicious 
code detection. 
In its September 2021 report, the Government Accountability Office concluded that the IRS has: 
• 
Assessed all of the relevant security controls and enhancements for protecting its 
systems that provide remote access. 
• 
Demonstrated that it consistently monitored progress toward completing remedial 
actions for any identified weaknesses. 
In September 2021, we reported16 that the IRS purchased and deployed an Endpoint Detection 
and Response solution, which analyzes various items such as processes running on workstations, 
memory artifacts, and other data points.  As of September 21, 2021, 86,593 (98 percent) of the 
eligible 88,595 workstations had a successful deployment of the Endpoint Detection and 
                                                 
16 Treasury Inspector General for Tax Administration, Report No. 2021-20-065, The Endpoint Detection and Response 
Solution Has Been Deployed to Most Workstations and Is Operating As Intended, but Improvements Are Needed 
(Sept. 2021). 

 
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Cybersecurity and Telework During the COVID-19 Pandemic 
Response solution.  The collected data are correlated and compared to rules that have been 
established or associated with known indicators of compromise.  If anything is detected, an alert 
is generated.  We found that the alerts generated were properly tracked and worked.  No alerts 
in the sample period were elevated to an incident.  
Network protection 
The IRS fully implemented the Common Communication Gateway, which was approved by the 
Department of Homeland Security to be a Trusted Internet Connection up to version 2.0.  
According to the IRS, there are no identified and approved use cases for Trusted Internet 
Connection version 3.0.  Until the version 3.0 standard is finalized and the IRS receives direction 
from the Department of the Treasury, the IRS will continue with the traditional use case and the 
version 2.0 implementation. 
 

 
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Cybersecurity and Telework During the COVID-19 Pandemic 
Appendix I 
Detailed Objective, Scope, and Methodology 
The overall objective of this audit was to review cybersecurity related to IRS telework during the 
COVID-19 pandemic, as requested by the U.S. House of Representatives Committee on 
Oversight and Reform.  To accomplish this objective, we: 
• 
Reviewed our related audit reports and those issued by the Government Accountability 
Office as well as relevant IRS policy and documentation, e.g., the IRM and the 
Information Technology Annual Key Insights Report. 
• 
Requested and reviewed information from IRS personnel within the Cybersecurity and 
the User and Network Services functions to determine whether the IRS implemented and 
monitored security controls over networks, hardware, and software used to facilitate 
telework. 
Performance of This Review 
This review was performed with information obtained from the IRS Information Technology 
organization’s Cybersecurity and User and Network Services functions’ management offices, 
located in the New Carrollton Federal Building in Lanham, Maryland, and the IRS Headquarters 
in Washington, D.C., during the period of September through November 2021.  We conducted 
this performance audit in accordance with generally accepted government auditing standards.  
Those standards require that we plan and perform the audit to obtain sufficient, appropriate 
evidence to provide a reasonable basis for our findings and conclusions based on our audit 
objective.  We believe that the evidence obtained provides a reasonable basis for our findings 
and conclusions based on our audit objective.   
Major contributors to the report were Danny Verneuille, Assistant Inspector General for Audit 
(Security and Information Technology Services); Jena Whitley, Director; Myron Gulley, Audit 
Manager; Mark Carder, Lead Auditor; Daniel Preko, Senior Auditor; and Danielle Synnestvedt, 
Auditor. 
Internal Controls Methodology 
Internal controls relate to management’s plans, methods, and procedures used to meet their 
mission, goals, and objectives.  Internal controls include the processes and procedures for 
planning, organizing, directing, and controlling program operations.  They include the systems 
for measuring, reporting, and monitoring program performance.  We determined that the 
following internal controls were relevant to our audit objective:  the IRM Cybersecurity policies 
and procedures, including telework policies set in place prior to the pandemic and any interim 
communication, and the IRM privacy policies and procedures, including data protection and its 
importance as a primary telework consideration.  We evaluated these controls by interviewing 
Cybersecurity function personnel; Privacy, Governmental Liaison, and Disclosure Office 
personnel; and the Treasury Inspector General for Tax Administration’s Office of Inspections and 
Evaluations personnel about their work in the area of the IRS’s pandemic preparedness as it 
relates to telework.  We also reviewed relevant documentation. 

 
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Cybersecurity and Telework During the COVID-19 Pandemic 
Appendix II 
Congressional Request Letter 
 

 
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Cybersecurity and Telework During the COVID-19 Pandemic 
 
 
 
 

 
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Cybersecurity and Telework During the COVID-19 Pandemic 
 
 

 
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Cybersecurity and Telework During the COVID-19 Pandemic 
 
 
 

 
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Cybersecurity and Telework During the COVID-19 Pandemic 
Appendix III 
Glossary of Terms 
Term 
Definition 
Audit Log 
A chronological record of information system activities, including records of 
system accesses and operations performed in a given period. 
Common Communication 
Gateway 
The demilitarized zone, which provides Internet connectivity and external 
data connectivity to Federal, State, and local government agencies and tax 
partners. 
Continuous Monitoring 
The process implemented to maintain a current security status for one or 
more information systems on which the operational mission of the 
enterprise depends.  The process includes:  1) the development of a 
strategy to regularly evaluate selected information assurance controls and 
metrics; 2) recording and evaluating relevant events and the effectiveness 
of the enterprise in dealing with those events; 3) recording changes to 
controls or changes that affect risks; and 4) publishing the current security 
status to enable information-sharing decisions involving the enterprise. 
Controlled Unclassified 
Information 
A designation that refers to unclassified information that does not meet the 
standards for National Security Classification under Executive Order 12958, 
Classified National Security Information (April 17, 1995), as amended 
March 25, 2003, but 1) is pertinent to the national interests of the 
United States or to the important interests of entities outside the Federal 
Government and 2) under law or policy requires protection from 
unauthorized disclosure, special handling safeguards, or prescribed limits 
on exchange or dissemination.  Henceforth, the designation Controlled 
Unclassified Information replaces “Sensitive But Unclassified.” 
Demilitarized Zone 
A network segment inserted as a “neutral zone” between an organization’s 
private network and the Internet. 
Encrypted 
The process of converting plain text to cipher text by means of a 
cryptographic system. 
Fiscal Year 
Any yearly accounting period, regardless of its relationship to a calendar 
year.  The Federal Government’s fiscal year begins on October 1 and ends 
on September 30. 
Grid Card 
A method of identifying users in which the user is asked to input a series of 
characters based on a preregistered pattern on a grid (that the user knows) 
and a grid of pseudo-random characters generated by the authenticator.  
This method results in a different series of characters each time the user 
authenticates. 
Malicious Code 
Software or firmware intended to perform an unauthorized process that will 
have adverse impact on the confidentiality, integrity, or availability of an 
information system.  A virus, worm, Trojan horse, or other code-based 
entity that infects a host.  Spyware and some forms of adware are also 
examples of malicious code. 

 
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Cybersecurity and Telework During the COVID-19 Pandemic 
Term 
Definition 
Multifactor Authentication 
Verifying the identity of a user, process, or device using two or more factors 
to achieve authentication, often as a prerequisite to allowing access to 
resources in an information system.  Factors include:  1) something you 
know, e.g., password/Personal Identification Number; 2) something you 
have, e.g., cryptographic identification device, token; or 3) something you 
are, e.g., biometric. 
National Settlement Days 
A program in which the IRS spends certain days 1) coordinating efforts that 
aim to resolve/settle cases in U.S. Tax Court and 2) coming to a settlement 
agreement with taxpayers who owe back taxes. 
Personal Identification 
Number 
A short numeric password (six to eight digits) used as an authenticator by 
the Personal Identity Verification card to authenticate the cardholder. 
Personal Identity 
Verification Card 
A Government-issued identity credential that contains a contact and a 
contactless chip.  The cardholder’s facial image is printed on the card along 
with other identifying information and security features that can be used to 
authenticate the user for physical access to Federally controlled facilities 
and logical access to Federally controlled information systems. 
Personally Identifiable 
Information 
Information that can be used to distinguish or trace an individual’s identity, 
such as their name, Social Security Number, and biometric records, alone or 
when combined with other personal or identifying information that is 
linked or linkable to a specific individual, such as date and place of birth 
and mother’s maiden name. 
Sensitive But Unclassified 
Any information that requires protection due to the risk and magnitude of 
loss or harm to the IRS or the privacy to which individuals are entitled 
under 5 U.S.C. § 552a (the Privacy Act of 1974), which could result from 
inadvertent or deliberate disclosure, alteration, or destruction. 
Slack Product 
A messaging application for business that connects people to the 
information they need by way of dedicated spaces called channels (i.e., 
regardless of your location, time zone, or function). 
Smart Card 
A plastic card about the size of a credit card, with an embedded microchip 
that can be loaded with data. 
Trusted Internet 
Connection 
A Federal initiative for which the primary goals are to consolidate and 
secure Federal agency external connections using a common set of security 
controls and to improve the Federal Government’s incident response 
capability. 
Virtual Private Network 
A secure way of connecting to a private Local Area Network at a remote 
location, using the Internet or any insecure public network to transport the 
network data packets privately, using encryption. 
 

 
Page  15 
Cybersecurity and Telework During the COVID-19 Pandemic 
Appendix IV 
Abbreviations 
COVID-19 
Coronavirus Disease 2019 
FISMA 
Federal Information Security Modernization Act of 2014 
IRM 
Internal Revenue Manual 
IRS 
Internal Revenue Service 
PII 
Personally Identifiable Information 
SBU 
Sensitive But Unclassified 
VPN 
Virtual Private Network 
 

 
 
 
 
 
 
 
To report fraud, waste, or abuse,  
call our toll-free hotline at: 
(800) 366-4484 
By Web: 
www.treasury.gov/tigta/ 
Or Write: 
Treasury Inspector General for Tax Administration 
P.O. Box 589 
Ben Franklin Station 
Washington, D.C. 20044-0589 
 
 
Information you provide is confidential, and you may remain anonymous.

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