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TIGTA Report 2023-46-026 — Additional Actions Needed to Reduce IRS Accounts Management Inventories to Pre-Pandemic Levels
Record facts
| Court | Treasury Inspector General for Tax Administration (TIGTA) |
|---|---|
| Filed | 2023-05-10 |
Summary
A final audit report of the Treasury Inspector General for Tax Administration, Report Number 2023-46-026, issued May 10, 2023, assessing IRS efforts to reduce backlogs in its Accounts Management function inventories. It states that as of December 31, 2022 the IRS reported 6.2 million cases in the Accounts Management inventory and 445,000 cases in the Form 1040-X inventory, and that initiatives announced March 10, 2022 did not return inventories to pre-pandemic levels by the end of the calendar year. The report finds fewer surge team employees were available than anticipated and that the loss of employees from other functions led to an estimated $2.6 billion in lost or delayed revenue. It estimates the IRS could save more than $322.2 million a year by automating the processing of Forms 1040-X. It makes 13 recommendations, of which the IRS agreed with 10 and disagreed with three.
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Full text
1
Additional Actions Are Needed to Reduce Accounts
Management Function Inventories to Below
Pre-Pandemic Levels
May 10, 2023
Report Number: 2023-46-026
TIGTACommunications@tigta.treas.gov | www.treasury.gov/tigta
TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION
HIGHLIGHTS: Additional Actions Are Needed to Reduce Accounts
Management Function Inventories to Below Pre-Pandemic Levels
Final Audit Report issued on May 10, 2023
Report Number 2023-46-026
Why TIGTA Did This Audit
In March 2022, TIGTA reported on
the persistent over-aged Accounts
Management function inventory
and made 19 recommendations for
improvements. IRS management
agreed with 16 of our
recommendations; however, as of
December 5, 2022, eight remain
unimplemented.
This audit continues our
assessment of the IRS’s efforts to
reduce significant backlogs in the
Accounts Management function
inventories during Calendar
Year 2022, including Forms 1040-X,
Amended U.S. Individual Tax
Return.
Impact on Tax Administration
The Accounts Management
function is responsible for assisting
individual and business taxpayers
with tax law and tax account
inquiries, including making
adjustments to taxpayer accounts
when necessary.
As of December 31, 2022, the IRS
reported that it had 6.2 million
cases in its Accounts Management
inventory and 445,000 cases in its
Form 1040-X inventory. Delays in
working these inventories not only
increase taxpayer burden but also
cost to the Federal Government
(i.e., interest paid).
What TIGTA Found
On March 10, 2022, the IRS announced its plans to address the
continuing backlog of tax returns and other tax account work during
the 2022 Filing Season. These initiatives, referred to as the Get Healthy
Plan, were intended to return the IRS to healthy inventory levels by the
end of Calendar Year 2022. The IRS defines “healthy” inventory levels
as pre-pandemic inventory levels.
TIGTA reported previously that the Accounts Management function
inventories would not return to pre-pandemic levels by the end of
Calendar Year 2022. Although management took actions to address
concerns identified during this review, backlogs of inventory remain for
the 2023 Filing Season. TIGTA identified the following contributing
factors to the remaining backlogs.
While the employees assigned to the Accounts Management function
Surge Team contributed to the additional closures of its inventory,
there were fewer employees available than anticipated. In addition, the
loss of employees from other IRS functions resulted in an estimated
$2.6 billion in potential lost or delayed revenue, due to fewer
examination and collection cases being worked.
Furthermore, the Form 1040-X Surge Team’s closure rates were less
than one-half of the normal employees’ closure rates. Automating the
processing of these amended returns would reduce the burden on
taxpayers waiting for their amended returns to be processed, and the
benefits far outweigh the associated costs. For example, TIGTA
estimated that the IRS would potentially save more than $322.2 million
in yearly processing costs by automating the processing of
Forms 1040-X. This is in addition to any interest saved.
What TIGTA Recommended
TIGTA made 13 recommendations to the IRS, including that
management establish goals and a plan for all inventory types to reach
pre-pandemic levels, and that they prioritize funding and
implementation of automated processing of Forms 1040-X.
The IRS agreed with 10 recommendations. The IRS disagreed with
three recommendations, including that management establish goals
and a plan for all inventory types to reach pre-pandemic levels.
U.S. DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20024
TREASURY INSPECTOR GENERAL
FOR TAX ADMINISTRATION
May 10, 2023
MEMORANDUM FOR: COMMISSIONER OF INTERNAL REVENUE
FROM:
Heather M. Hill
Deputy Inspector General for Audit
SUBJECT:
Final Audit Report – Additional Actions Are Needed to Reduce Accounts
Management Function Inventories to Below Pre-Pandemic Levels
(Audit # 202240622)
This report represents the results of our review to assess the Internal Revenue Service’s efforts to
address the backlogged Accounts Management inventory, including Forms 1040-X, Amended
U.S. Individual Income Tax Return (i.e., amended returns). This review is part of our Fiscal Year
2023 Annual Audit Plan and addresses the major management and performance challenge of
Improving Taxpayer Service.
Management’s complete response to the draft audit report is included as Appendix IV. If you
have any questions, please contact me or Diana M. Tengesdal, Acting Assistant Inspector
General for Audit (Returns Processing and Account Services).
Additional Actions Are Needed to Reduce Accounts
Management Function Inventories to Below Pre-Pandemic Levels
Table of Contents
Background .....................................................................................................................................Page 1
Results of Review .......................................................................................................................Page 4
Management Took Actions to Address Concerns
Identified During This Review ..........................................................................................Page 4
Recommendations 1 and 2: .....................................................Page 4
Recommendations 3 and 4: .....................................................Page 5
Surge Team Members Assisted in Reducing Inventories,
but This Came at a Significant Cost to the Government .......................................Page 6
Management Needs to Develop a Plan and Goals to
Ensure That Inventories Return to Pre-Pandemic Levels ......................................Page 9
Recommendation 5: ...................................................................Page 10
Form 1040-X, Amended U.S. Individual Income Tax Return,
Inventories Will Remain Above Pre-Pandemic Levels Through
the 2023 Filing Season .......................................................................................................Page 10
The Benefits of Automating the Processing of
Amended Returns Outweigh the Associated Costs ................................................Page 12
Recommendation 6: ...................................................................Page 13
Recommendation 7: ...................................................................Page 14
Improvements Are Needed to Reduce the Taxpayer Relations Inventory .....Page 14
Recommendations 8 and 9: .....................................................Page 15
Recommendation 10: ................................................................Page 16
Improvements Are Needed to Ensure Timely Receipt of
the Accounts Management Function’s Inventory ....................................................Page 16
Recommendation 11: ................................................................Page 16
Recommendation 12: ................................................................Page 17
Recommendation 13: ................................................................Page 18
Appendices
Appendix I – Detailed Objective, Scope, and Methodology ................................Page 19
Appendix II – Outcome Measures .................................................................................Page 21
Appendix III – Prior TIGTA Report Recommendations and Status ....................Page 23
Appendix IV – Management’s Response to the Draft Report .............................Page 25
Additional Actions Are Needed to Reduce Accounts
Management Function Inventories to Below Pre-Pandemic Levels
Appendix V – Glossary of Terms ....................................................................................Page 36
Appendix VI – Abbreviations ...........................................................................................Page 37
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Additional Actions Are Needed to Reduce Accounts
Management Function Inventories to Below Pre-Pandemic Levels
Background
The Internal Revenue Service (IRS) Accounts Management function is responsible for assisting
individual and business taxpayers with tax law and tax account inquiries, including making
adjustments to taxpayer accounts when necessary. The Accounts Management function has
10 sites nationwide that work paper inventory; seven sites are supported by an Accounts
Management Campus Support Site, and three sites are supported by a Submission Processing
Tax Processing Center.1
Figure 1 shows that as of November 23, 2022, IRS management reported having
23,483 employees working in the Accounts Management function.
Figure 1: Accounts Management Function Employees as of November 23, 2022
AM Employees
Working Cases
AM Employees
Working
Telephones
Employees
Detailed to AM
Employees
Detailed
From AM to SP
TOTAL
17,125
6,618
658
(918)
23,483
Source: Information from IRS analysts as of November 23, 2022.
AM = Accounts Management, SP = Submission Processing
The majority of the Accounts Management function case work is received from taxpayers
Most of the Accounts Management function’s inventory is received from taxpayers via
the mail. The time it takes for the Accounts Management function to receive and work its
taxpayer-initiated inventory affects how timely taxpayers receive a response from the IRS and
have their case resolved. It is also directly impacted by the Image Control Team’s (ICT) ability to
timely scan the inventory into the Correspondence Imaging Inventory (CII), the Accounts
Management function’s primary inventory management system. IRS management indicates that
higher inventory levels, as opposed to timely scanning, are a higher contributing factor to longer
wait times for taxpayers to receive case resolution.
The Accounts Management function’s goal is to close most of its inventory within 45 calendar
days of IRS receipt. At 45 calendar days, it generally classifies the inventory as over-aged.
Figure 2 provides an overview of the Accounts Management function’s inventory routing from
IRS receipt.
1 See Appendix V for a glossary of terms.
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Additional Actions Are Needed to Reduce Accounts
Management Function Inventories to Below Pre-Pandemic Levels
Figure 2: Overview of the Accounts
Management Function Inventory Routing
Source: Treasury Inspector General for Tax Administration (TIGTA)
graphic based upon Internal Revenue Manuals and walkthroughs
of sites.
Accounts Management function inventory
The Accounts Management function’s inventory is categorized into three high-level inventory
types:
•
Adjustments – this includes correspondence received from individual and business
taxpayers, more complex amended returns that are not worked by the Submission
Processing function, and carryback claims. This inventory impacts taxpayers as they are
waiting on a response from the IRS or waiting on an adjustment to their tax account,
which could result in a refund. Employees who work Adjustments inventory are tax
examiners (TE) and customer service representatives (CSR). The CSRs are the same
employees who answer telephone calls.
•
Taxpayer Relations – this includes refund inquiries, technical statutes, and accounts
maintenance (i.e., transcripts). A transcript is an internally generated case that indicates
IRS action or research needs to take place to correct a condition on a taxpayer’s account.
Technical statutes and the transcripts inventory have a less immediate impact on
taxpayers. For example, technical statutes are where the IRS is determining if time
remains on the statute of limitations to assess tax. As a result, this may have an
immediate impact on the IRS’s ability to make an assessment to protect revenue and
avoid barred assessments. Employees who work Taxpayer Relations inventory generally
are the TEs.
•
Miscellaneous – this includes identity theft victim assistance, Centralized Authorization
File, and other smaller inventories. The largest inventory is identity theft, which directly
impacts taxpayers. These cases are more complex and require specialized training that is
only provided to a limited number of Accounts Management function employees.
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Additional Actions Are Needed to Reduce Accounts
Management Function Inventories to Below Pre-Pandemic Levels
Individual amended return inventory
Form 1040-X, Amended U.S. Individual Income Tax Return, (i.e., amended return) is worked by
both the Submission Processing and Accounts Management functions. All inventory is screened
by the Submission Processing function, and the more complex cases may be forwarded to the
Accounts Management function.
Initiatives taken to help backlogs
In an attempt to address ongoing challenges, on March 10, 2022, the IRS announced its plans to
address the continuing backlog of tax returns and other tax account work during the
2022 Filing Season. These initiatives, referred to as the Get Healthy Plan, were intended to
return the IRS to healthy inventory levels by the end of Calendar Year 2022. The IRS defines
“healthy” inventory levels as pre-pandemic inventory levels. Figure 3 provides an overview of
the Get Healthy Plan initiatives.
Figure 3: Overview of the Get Healthy Plan Initiatives
Source: TIGTA analysis of the IRS’s Get Healthy Plan. CTC = Child Tax Credit,
RRC – Recovery Rebate Credit, TAC – Taxpayer Assistance Center
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Additional Actions Are Needed to Reduce Accounts
Management Function Inventories to Below Pre-Pandemic Levels
Results of Review
This report presents the results of our continued assessment of the IRS’s efforts to reduce
significant backlog of inventories in the Accounts Management function and amended tax
returns processed by the Submission Processing function. The results in this report are
presented as of the end of December 2022. In December 2022, we reported that the Accounts
Management function inventories would not return to pre-pandemic levels by the end of
Calendar Year 2022.2 We plan to continue to assess the IRS’s efforts to reduce these backlogs
during the 2023 Filing Season.3
Management Took Actions to Address Concerns Identified During This Review
One of the objectives of our continued assessment of the IRS’s efforts to reduce its backlogged
inventory is to recommend actions the IRS can take to address challenges that result in
inefficient processes, unnecessary increases in workload, and increased burden on taxpayers. As
such, we made a number of recommendations to IRS management throughout this review, via
what we refer to as an “e-mail alert,” in order to expedite the IRS’s ability to take corrective
action. During this review, we issued the following detailed e-mail alerts to IRS management
outlining our concerns and are providing the actions taken by IRS management to address
them.
Recommendation 1 (E-Mail Alert): On October 21, 2022, we notified the Directors,
Submission Processing and Accounts Management, Wage and Investment Division, of our
concern that employees, at least one ICT site, were stamping correspondence with a received
date before completing screening, which is intended to ensure that correspondence is either
scanned into the CII, routed to another function, or destroyed. In addition, employees at this
ICT site were not screening documents from individuals and businesses with the same level of
priority. The IRS’s internal guidance requires correspondence to be scanned and validated
within 10 calendar days of receipt by the ICT. These time frames are tracked and monitored
based on the date stamped on the correspondence by the ICT. We recommended that
management ensure that all sites understand and begin immediately stamping the ICT received
date after correspondence screening is completed, and that individual and business documents
are screened with equal importance.
Management’s Response to E-Mail Alert: IRS management agreed with the
recommendation and sent a reminder to all sites on November 1, 2022, and
February 22, 2023.
Recommendation 2 (E-Mail Alert): On October 28, 2022, we notified the Directors,
Submission Processing and Accounts Management, Wage and Investment Division, of our
concern that at least one IRS Campus Support Site was allowing correspondence screening to be
conducted by employees at their homes and in IRS locations not co-located with the mailroom.
2 TIGTA Report No. 2023-46-007, Backlogs of Tax Returns and Other Account Work Will Continue Into the 2023 Filing
Season (Dec. 2022).
3 TIGTA Audit No. 202340610, Continued Assessment of the IRS’s Efforts to Address the Backlogs During the 2023
Filing Season.
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Additional Actions Are Needed to Reduce Accounts
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Management stated that this was done in response to the pandemic and subsequent
remodeling of IRS office space. However, our walkthrough confirmed there was adequate space
in the IRS building where the mail is received and scanned for corresponding screening to be
completed. Management’s decision to continue to allow employees to telework unnecessarily
increased the risk that documents would either be lost, destroyed, or viewed by unauthorized
persons. It also increased the time it took for these documents to be scanned and available to
the Accounts Management function. We recommended that the IRS discontinue
correspondence screening via telework and ensure at all sites that screening must be conducted
in the same IRS facility where documents are being scanned by the ICT.
Management’s Response to E-Mail Alert: IRS management agreed with the
recommendation and discontinued telework screening on December 7, 2022. Screening
work remains in a secure IRS environment, and the IRS has confirmed with the sites that
screening is conducted in the same building where space allows.
Recommendation 3 (E-Mail Alert): On November 1, 2022, we notified the Director, Accounts
Management, Wage and Investment Division, of our concerns that cases were incorrectly routed
to other IRS functions by Accounts Management function employees and of unclear instructions
to ensure that other IRS function employees returned cases to the originating Accounts
Management function employee. Incorrectly routing work results in unnecessary delays that
burden taxpayers and is an inefficient use of IRS resources. Our discussions with IRS employees
and our review identified that the internal guidelines for other IRS functions do not instruct
employees to return invalid CII cases to the originating Accounts Management function
employee. Instead, cases are being returned to the ICT function that then routes the cases back
to the originating Accounts Management function employee. We recommended that the IRS
identify and address the cause of Accounts Management function employees incorrectly routing
cases to other IRS functions and work with other IRS functions to update their Internal Revenue
Manuals to make it clear that incorrectly routed documents should be returned to the
originating employee.
Management’s Response to E-Mail Alert: IRS management agreed with the
recommendation. The IRS created a report of all rerouted CII cases and completed its
review of CII reroutes. Applicable procedures have been updated and the Internal
Revenue Manual sections have been clarified.
Recommendation 4 (E-Mail Alert): On November 1, 2022, we also notified the Director,
Accounts Management, Wage and Investment Division, of our concern that the IRS was not
hiring a sufficient number of mail clerks to help with opening and sorting the mail as well as
scanning documents into the CII. Hiring additional mail clerks would help reduce the backlogs
in the ICT function and result in taxpayers’ cases being worked in a timelier manner. We
recommended that management take steps to hire as many mail clerks as possible.
Management’s Response to E-Mail Alert: IRS management agreed with the
recommendation. The IRS analyzed available space at the sites and took action to hire as
many clerks as possible, resulting in the hiring of 214 clerks through March 27, 2023.
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Additional Actions Are Needed to Reduce Accounts
Management Function Inventories to Below Pre-Pandemic Levels
Although management took actions to address several concerns we brought to their attention
during this review, Figure 4 provides several other concerns we identified as contributing factors
to the remaining backlogs of inventory in the Accounts Management function and the
Forms 1040-X inventory that were not addressed adequately.
Figure 4: Factors Contributing to Remaining Inventory Backlogs
Source: TIGTA graphic based upon findings identified during our review.
Moreover, in March 2022, we reported on the persistent over-aged inventory and made
19 recommendations for improvements. IRS management agreed with 16 of our
recommendations; however, as of December 5, 2022, eight remain unimplemented.4
Surge Team Members Assisted in Reducing Inventories, but This Came at a
Significant Cost to the Government
On February 2, 2022, the IRS Commissioner announced an inventory Surge Team to assist the
Accounts Management function with its inventories. The Commissioner stated that the IRS had
identified employees as having prior Accounts Management function experience who would be
a part of the Surge Team, and IRS management subsequently identified about 1,200 employees.
Starting on February 28, 2022, the Surge Team members underwent up to four work days of
refresher training. The actual number of Surge Team members did not materialize and gradually
decreased from as many as 900 on February 28, 2022, to as few as 658 as of November 23, 2022.
According to IRS management, the decline of Surge Team members was due to employees who
either resigned, were promoted to other IRS functions, or were approved for hardships and
therefore did not participate in the Surge Team.
In May 2022, Wage and Investment Division leadership announced that they projected Surge
Team members would assist with closing about 600,000 cases by September 30, 2022. Our
analysis of closed CII cases as of November 27, 2022, identified that 476 Surge Team members
closed 617,494 (4.6 percent) of the 13.3 million CII cases since February 2022. As noted
previously, Adjustments is just one of three inventory types and is primarily made up of
correspondence from taxpayers and amended returns.
4 See Appendix III for the status of the IRS’s corrective actions.
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Additional Actions Are Needed to Reduce Accounts
Management Function Inventories to Below Pre-Pandemic Levels
We also found that the Accounts Management function used Surge Team members in other
areas such as answering telephones, processing third-party authorizations, clerical support, etc.
For example, 189 (23 percent) of the 818 Surge Team members who were detailed to Accounts
Management as of July 6, 2023, answered telephone calls and never closed any Accounts
Management function inventory. According to IRS management, these employees were not
used to work on the backlogged inventory because of agreements with the Union, which
stipulated that Surge Team members work in areas in which they had prior experience.
The majority of Surge Team members came from the Small Business/Self-Employed
(SB/SE) Division
In December 2022, we reported that the IRS took an “all-hands-on-deck” approach to address
staffing shortages and the backlog of work at the Tax Processing Centers.5 This approach also
extended to helping the Accounts Management function with its unprecedented inventory
levels. Figure 5 shows the distribution of the 818 employees detailed to the Accounts
Management function by other IRS functions, as of July 6, 2022.
Figure 5: Overview of 818 Employees Detailed to the
Accounts Management Function by Other IRS Functions
Source: TIGTA graphic created based upon a report provided by Accounts Management
function analysts as of July 6, 2022. Other includes Appeals; Chief Financial Officer;
Criminal Investigation; Large Business and International Division; Privacy, Governmental
Liaison, and Disclosure; Tax Exempt and Government Entities Division; etc.
5 TIGTA, Report No. 2023-46-007, Backlogs of Tax Returns and Other Account Work Will Continue Into the 2023 Filing
Season (Dec. 2022).
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Additional Actions Are Needed to Reduce Accounts
Management Function Inventories to Below Pre-Pandemic Levels
The decision to reassign hundreds of employees to assist with the backlog did not come lightly.
After evaluating a full range of options, the IRS documented its decision in a Risk Acceptance
Form and Tool approved by leadership of the SB/SE Division in March 2022 and by the
Deputy Commissioner for Services and Enforcement in April 2022. The SB/SE Division agreed to
transfer the maximum number of employees to assist with the inventory backlogs, noting that
the Government would experience lost or delayed revenue because of reduced assessments
from examinations and collections. In addition, the SB/SE Division noted that it would also be
affected by an increase in over-aged inventories.
Finally, the IRS noted that, based on the urgency of the situation, the negative impact to
taxpayers and the severe reputational risk to the IRS outweighed the billions of dollars of
potential lost or delayed revenue to the Government by delaying or forgoing certain compliance
actions. Figure 6 shows the IRS’s estimates of lost or delayed revenue by the various IRS
program areas through December 31, 2022.
Figure 6: Accounts Management Function Surge Team’s Impact on Other IRS Programs
Function/Office
Number of
Employees
Potential
Lost
Revenue
Potential
Lost/Delayed
Revenue
SB/SE Division Campus Collection
265
N/A
$2.1 billion
SB/SE Division Campus Examination
103
$310 million
N/A
SB/SE Division Field and Specialty
Examination
50
$39 million
N/A
Wage and Investment Division Return
Integrity and Compliance Services
48
$49 million
N/A
SB/SE Division Field Collection
47
N/A
$59 million
Large Business and International Division
3
$0.7 million
N/A
Totals
516
$398.7 million
$2.2 billion
Source: Estimates provided by IRS management for the respective functions listed in Figure 6.
Note: The number of employees shown in Figure 6 is less than Figure 5 as some employees were support
personnel and did not result in lost/delayed revenue. The IRS generally has 10 years to collect on an
outstanding balance, thus the collection of revenue may be delayed and not lost due to the backlogs.
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Additional Actions Are Needed to Reduce Accounts
Management Function Inventories to Below Pre-Pandemic Levels
Management Needs to Develop a Plan and Goals to Ensure That Inventories
Return to Pre-Pandemic Levels
In December 2022, we reported that the Accounts Management function inventories will not
return to pre-pandemic levels by the end of Calendar Year 2022.6 As a result, the IRS will once
again have a backlog of this work in the 2023 Filing Season. According to IRS management, this
was due to higher than anticipated receipts of incoming inventory. However, our review found
that a contributing factor was also that while the Accounts Management function established a
goal to reduce the Adjustments inventory to 1 million or less by the end of Calendar Year 2022,
there were not similar goals set for the Taxpayer Relations and Miscellaneous inventories. As
the Accounts Management function worked towards its goal to reduce the Adjustments
inventory, the other inventories increased during Calendar Year 2022.
When we asked management why they did not establish a goal for employees to work towards
for the other inventory categories, management stated that they focused the majority of their
resources on the Adjustments inventory because this could resolve other inventories and had a
larger impact to taxpayers. For example, if a taxpayer had an amended return waiting to be
processed, once the amended return was processed, this may help resolve a taxpayer’s refund
inquiry case. Moreover, when we asked IRS management how many TEs they would need to
significantly reduce the Taxpayer Relations inventory level, management could not provide an
answer.
Figure 7 shows that the Adjustments inventory made more progress towards reaching
pre-pandemic levels than the Taxpayer Relations and Miscellaneous inventories.
Figure 7: Accounts Management Function Inventory Changes by Inventory Type
Source: TIGTA graphic created based Accounts Management Inventory Reports from dates shown in
Figure 7.
We understand management’s logic for directing most of its resources to working the
Adjustments inventory; however, if the IRS plans to make significant progress to return all of its
paper-based inventories to pre-pandemic levels, it needs to establish a plan that includes goals
for its employees to work towards. For example, the Submission Processing function created a
6 TIGTA, Report No. 2023-46-007, Backlogs of Tax Returns and Other Account Work Will Continue Into the 2023 Filing
Season (Dec. 2022).
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Additional Actions Are Needed to Reduce Accounts
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spreadsheet for each of its inventories and established a goal for each inventory type, which it
then monitored weekly to show progress towards meeting its goals.
On November 1, 2022, we notified IRS management of our concern and recommended that
management take steps to ensure that adequate resources were provided to reduce the
Taxpayer Relations inventory. IRS management agreed with our concern and stated that they
have hired additional TEs for Fiscal Year 2023 and are looking for ways to reduce the inventory.
However, as stated previously, IRS management could not tell us how many TEs they needed to
reduce the inventory to pre-pandemic levels. It is important that the Accounts Management
function establish goals for each inventory type and a plan to meet those goals, which takes into
consideration any resource needs.
Recommendation 5: The Commissioner, Wage and Investment Division, should establish goals
for each of the Accounts Management function’s inventory types and develop a plan for
addressing those goals to ensure a timely return to pre-pandemic inventory levels.
Management’s Response: IRS management disagreed with the recommendation.
Management stated that limited resources and the numerous types of inventory do not
allow for goals to be established for each of the inventory categories. The Accounts
Management function is balancing trained resources to deliver goals for the toll-free
service while addressing paper inventories in a first-in, first-out order as opposed to
reaching a set goal by inventory type. The IRS will continue to monitor inventory levels
and manage resources to address inventory while moving towards more advanced
digitalization to achieve pre-pandemic inventory levels.
Office of Audit Comment: We remain concerned with management’s plan to
maintain the status quo in hopes that the inventory will return to pre-pandemic
inventory levels. When we brought our concern to management’s attention
during this review, management indicated they hired additional TEs for Fiscal
Year 2023 and would look for ways to reduce the inventory. However,
management did not know how many TEs were needed to reduce the inventory
to pre-pandemic levels. We continue to believe that establishing goals and
developing a plan to achieve those goals will help ensure that the other Accounts
Management inventories return to pre-pandemic inventory levels in a timely
manner.
Form 1040-X, Amended U.S. Individual Income Tax Return, Inventories Will
Remain Above Pre-Pandemic Levels Through the 2023 Filing Season
The IRS estimates that the Form 1040-X inventory will not be at pre-pandemic levels until
June 2023. As of December 31, 2022, there were 445,000 Forms 1040-X in ending inventory,
whereas, as of January 4, 2020, there were 124,000 Forms 1040-X in inventory. Since
January 1, 2022, the IRS has significantly reduced the Forms 1040-X inventory by more than
1.9 million. However, as shown in Figure 8, the inventory level remains above pre-pandemic
levels.
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Additional Actions Are Needed to Reduce Accounts
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Figure 8: Form 1040-X Inventory
1/4/2020
1/2/2021
1/1/2022
12/31/2022
Submission Processing Function
20K
1.3M
1.7M
224K
Accounts Management Function
104K
201K
707K
221K
Total
124K
1.5M
2.4M
445K
Source: Consolidated Submission Processing and Accounts Management Form-1040X Report as of
dates listed in Figure 8. K = Thousands, M = millions
In May 2022, the Accounts Management function agreed to assist the Submission Processing
function with addressing the high volume of Form 1040-X (i.e., amended return) inventory.
Leadership from the Accounts Management function agreed to provide a Surge Team consisting
of approximately 1,000 employees who were previously responsible for answering telephone
calls. Surge Team members received two weeks of classroom training and one week of
on-the-job instruction to prepare them for their new job responsibilities.
On average, Surge Team members processed amended returns slower than their
counterparts in the Submission Processing function
On average, Surge Team members closed cases at a rate less than one-half the number of cases
of the Submission Processing function’s Form 1040-X cases. For example, Surge Team members
closed an average of 2.8 cases per hour during Calendar Year 2022, whereas Submission
Processing function employees closed on average 6.9 cases per hour (from January through
June 2022). The IRS reports that since June 2022, the 1,015 Surge Team members closed more
than 1.9 million cases.
When we asked IRS management to explain why it was taking Surge Team members longer to
close a case, management stated that it was because Surge Team members were trained by the
Accounts Management function to perform more thorough reviews than intended by the
Submission Processing function. IRS management indicated they offered on-the-job training to
employees.
However, the closure rate did not adjust accordingly. Management indicated that despite the
closures being slower, they would not bring all the original Submission Processing function
Form 1040-X employees back to assist as these employees were needed to help other
Submission Processing function areas. As such, this structure remained throughout Calendar
Year 2022.
According to IRS management, they plan to reach pre-pandemic inventory levels for
Forms 1040-X during the 2023 Filing Season by moving the original employees in the
Submission Processing function back to processing Forms 1040-X and hiring an additional
200 employees to work this inventory specifically.
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The Benefits of Automating the Processing of Amended Returns Outweigh the
Associated Costs
The IRS’s plan to automate efforts for Forms 1040-X is not occurring soon enough. TIGTA
reported previously that the IRS needs to modernize its processing of Forms 1040-X.7 These
recommendations have included further automation during processing. In August 2020, the IRS
began accepting electronically filed (e-filed) Forms 1040-X, no longer requiring IRS staff to open
these Forms 1040-X and manually enter the data from these forms. As of May 16, 2022, the IRS
had electronically received nearly 3.5 million Forms 1040-X. Although the IRS now accepts
e-filed Forms 1040-X, the forms are still processed manually after they are received
electronically. At a high-level, this requires employees to determine if the return meets criteria
to be processed or should be routed to the Examination function, complete tax account research
to ensure that the original return amounts listed match IRS records, and ensure that the return
does not contain any mathematical errors, etc.
In June 2022, the Electronic Tax Administration Advisory Committee also encouraged the IRS to
continue working on automating processing after intake so that fewer returns will require
human intervention.8 The Committee noted that these e-filed amended returns also have the
benefits of the automated validity, fraud detection, and consistency checks. However, these
benefits will only be realized if the IRS fully automates the processing of Forms 1040-X.
Fully automating the processing of Forms 1040-X would also result in cost savings to the IRS
and reduce burden on taxpayers by decreasing the time taxpayers wait for their amended return
to be processed and their refunds paid. When we asked the IRS to provide us with a cost
estimate for a fully automated solution, the IRS stated that it would cost a total of $20 million
through Fiscal Year 2027 to implement. This seems minimal when compared to the costs for IRS
employees to manually process the Forms 1040-X. For example, the IRS estimates that it
currently costs $6.64 to process a Form 1040-X in the Submission Processing function and
$109.26 in the Accounts Management function.9 In contrast, the IRS can systemically process an
e-filed Form 1040 for $0.28. As such, we estimate that the IRS would potentially save more than
$322.2 million in yearly processing costs by automating the processing of Forms 1040-X.10 This
is in addition to any interest paid to taxpayers as a result of manual processing delays. As
interest rates continue to rise, this will result in increased interest paid by the IRS.
The National Taxpayer Advocate recommended that the IRS implement electronic amended
return processing to eliminate the delays caused by traditional paper processing, and Congress
fully fund the IRS’s information technology modernization needs to allow for expedited
7 TIGTA, Report No. 2014-40-028, Amended Tax Return Filing and Processing Needs to Be Modernized to Reduce
Erroneous Refunds, Processing Costs, and Taxpayer Burden (Apr. 2014) and TIGTA, Report No. 2019-40-042, Actions
Have Not Been Taken to Improve Amended Tax Return Review Procedures to Reduce Erroneous and Fraudulent
Refunds (July 2019).
8 Publication 3415, Electronic Tax Administration Advisory Committee Annual Report to Congress (June 2022).
9 On average, during Fiscal Year 2022, 63 percent of the 4.5 million total Forms 1040-X were processed by the
Accounts Management function.
10 Fiscal Year 2022 Submission Processing function closures of 1,660,662 x $6.64 = $11 million plus Fiscal Year 2022
Accounts Management function closures of 2,859,969 x $109.26 = $312.5 million less total Fiscal Year 2022 closures of
4,520,631 x $0.28 = $1.3 million equals $322.2 million.
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processing of original and amended tax returns.11 The Inflation Reduction Act of 2022
subsequently provided the IRS with more than $7.9 billion to use toward modernizing its
information technology environment and improving services to taxpayers.12 This additional
funding will allow the IRS to transform the way it interacts with taxpayers, providing for a more
taxpayer friendly and focused organization that offers more digital and streamlined options. IRS
management did not comment whether the additional funding would allow the IRS to prioritize
the automation of amended returns. However, IRS management stated that they are continuing
to develop a plan to show how the IRS will spend the additional funding while ensuring that
addressing tax return and correspondence backlogs, including amended returns, remains a top
priority.
Recommendation 6: The Commissioner, Wage and Investment, should prioritize funding and
implementation of automated processing of Forms 1040-X to increase efficiencies and reduce
taxpayer burden.
Management’s Response: IRS management agreed with the recommendation, and
funding was approved on February 28, 2023. The IRS will evaluate requirements and a
solution for automated processing of Form 1040-X based upon the feasibility of the
requirements. See Appendix II for management’s response to the outcome measure.
Management urged to identify solutions to reduce the backlog of Forms 1040-X to
pre-pandemic levels until an automated solution is implemented
The National Taxpayer Advocate also reported that the IRS was not proactively solving the
backlog of amended returns, stating that, “the IRS has committed to doing very little to
address the processing backlog to ensure taxpayers expeditiously get the refunds to which
they are entitled.” TIGTA performed on-site walkthroughs at the Tax Processing Centers in
Kansas City, Missouri; Austin, Texas; and Ogden, Utah, to observe the work being completed by
the staff, discuss any concerns or challenges they have, and identify opportunities for
improvement. As it relates to Forms 1040-X, they are not processed like original returns, where
refunds are processed first. However, Forms 1040-X are worked in first-in/first-out order. Thus,
potentially adding unnecessary delays for taxpayers due a refund and resulting in additional
interest paid.
Our analysis of 1.9 million e-filed Forms 1040-X accepted between January 18, 2022, and
October 22, 2022, found that 897,088 (47 percent) of the Forms 1040-X accepted by the IRS
were refund returns. We identified 309,083 cases in the Accounts Management function’s
inventory that were still open and could be prioritized by the IRS. On October 21, 2022, we
notified IRS management of our concerns that the IRS was not prioritizing amended returns
requesting refunds and provided them with the cases we identified. We recommended that
they prioritize working these Forms 1040-X and update their internal guidelines to reflect this
change. IRS management disagreed with our recommendation stating that working amended
returns in a first-in/first-out manner ensures fairness to all taxpayers.
11 National Taxpayer Advocate Annual Report to Congress 2021.
12 Public Law 117-169. This includes $3,181,500,000 for Taxpayer Services and $4,750,700,000 for Business Systems
Modernization.
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Management also stated that taxpayers often make mistakes on the Form 1040-X and could
incorrectly show the return as a refund when it is not. In addition, management stated that
prioritizing amended returns with refunds could unnecessarily delay the resolution for those
taxpayers filing an amended return in response to an examination. Finally, management noted
that because amended returns do not have a filing due date, balance due returns would
constantly be pushed to the back, thus increasing the risk of a barred assessment or a loss of
interest to the Government.
Although management’s rationale may support not prioritizing Forms 1040-X with refunds as a
long-term solution, we disagree that the reasons provided should prevent management from
exploring a short-term solution as they continue to work through their backlogged inventory.
The lack of actions to prioritize Forms 1040-X to reduce delays to taxpayers due a refund is a
great disservice to taxpayers.
Recommendation 7: The Commissioner, Wage and Investment Division, should implement
temporary solutions for the processing of Forms 1040-X to reduce the backlogs, reduce taxpayer
burden, and save IRS resources until an automated solution is implemented.
Management’s Response: IRS management agreed with the recommendation and
continues to take actions to reduce all inventory. Management has a Surge Team of
employees focused on Forms 1040-X only, and additional employees are moved to
process inventory as resources allow.
Improvements Are Needed to Reduce the Taxpayer Relations Inventory
We also identified the following concerns with the Accounts Management function’s ability to
timely and efficiently work the Taxpayer Relations inventory.
•
Manual refund requests are prepared for small dollar amounts. Our review found that
when certain conditions are present on a tax account, current procedures require that
Accounts Management function employees prepare a request for a manual refund to be
released by the Accounting function. According to IRS employees we spoke with during
our review, in many instances, these refunds are for small dollar amounts and a taxpayer
may not be waiting for a needed refund (e.g., a deceased taxpayer). As of
December 3, 2022, the IRS reported it had 24,492 transcripts in its Taxpayer Relations
inventory that require a manual refund of under $100. The IRS reports that it cost $71 to
issue a manual refund. As such, it can cost the IRS more to prepare the manual refund
request than the refund amount itself. We notified IRS management of our concern and
recommended that management consult with IRS Office of Chief Counsel on the legality
of adding a dollar tolerance and not generating transcripts or issuing manual refunds
below that dollar threshold. IRS management disagreed stating that all taxpayers are
entitled to their refund when it was greater than $1 and that manual refunds are
currently necessary due to programming limitations. We agree with the IRS’s assertion;
however, allowing a temporary deviation from its policy would help the IRS work through
its backlogged inventory more efficiently.
•
Paperwork associated with barred statutes takes time to complete and is taking away
resources that could be assigned to work other cases. During a walkthrough, Accounts
Management function employees indicated that they are still required to complete
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paperwork for barred statutes, even though most of the barred statute cases are the
result of the backlogs and not an IRS employee’s inaction. Internal guidelines require the
Accounts Management function employee to document the total net loss to the
Government, the reason for the statute expiration, the corrective action that will be taken
to prevent a recurrence, etc. The paperwork must then be reviewed by the unit manager,
department manager, operations manager, and the Campus Director, which is time
consuming. We notified IRS management of our concern and recommended that
management reduce or limit paperwork employees are required to complete, so they
can focus on eliminating the backlogged inventory that would in turn prevent future
barred statutes. IRS management agreed stating that they were exploring options to
reduce some of the paperwork and acknowledgement requirements. However, as of
January 10, 2023, IRS management has not made a decision or changed the policy and
could not provide a date when a decision would be made.
•
Inventory can be worked more efficiently if all types of work were in one consolidated
inventory system. During our walkthroughs, Accounts Management function employees
indicated that being able to work other Taxpayer Relations cases in the same inventory
management system, the CII, as other Accounts Management function inventory would
be helpful and allow inventory to be worked faster and more efficiently. We notified IRS
management of our concern and recommended that management coordinate with the
Information Technology organization to explore the possibility of adding Taxpayer
Relations inventories into the same inventory management system. IRS management
partially agreed. Management stated that this was explored previously and adding the
Taxpayer Relations inventory into the CII would lose many current benefits, such as
systemically closing transcripts that have been resolved without additional action
needed, etc. As an alternative, management stated that they are discussing other
inventory management options with programmers but have not provided any additional
details on these options.
The Commissioner, Wage and Investment Division, should:
Recommendation 8: Coordinate with the Information Technology organization to prevent
generating transcripts for manual refunds less than $100 and adjust the frequency that some
transcripts are generated to help management get through the inventory more efficiently.
Management’s Response: IRS management agreed with the recommendation.
Management has requested programming changes for potential implementation in
January 2025 that will allow systemic issuance of decedent refunds when the appropriate
personal representative information has been updated within the account.
Recommendation 9: Temporarily relieve employees in the Accounts Management function
from having to complete paperwork for barred statutes, so they can focus on eliminating the
backlogged inventory and prevent future barred statutes.
Management’s Response: IRS management agreed with the recommendation.
Management is developing a plan that balances streamlining the barred statutes
paperwork process with accountability responsibilities to reduce the backlog of aged,
barred statute cases.
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Recommendation 10: Coordinate with the Information Technology organization to explore
adding Taxpayer Relations inventories into the CII, so that all Accounts Management inventory is
located in the same inventory management system.
Management’s Response: IRS management agreed with the recommendation.
Management is working with the Information Technology organization Accounts
Management Services programmers to create a universal unassigned inventory, similar
to the CII system, which will streamline the work distribution process.
Improvements Are Needed to Ensure Timely Receipt of the Accounts
Management Function’s Inventory
Our review continues to find that improvements are needed to ensure the timely receipt of the
Accounts Management function’s inventory. Our analysis of cases received between
January 1, 2022, and November 27, 2022, found that it was taking, on average, 30 calendar days
to process documents once received by the ICT. This is significantly longer than what is allowed
according to the IRS’s internal guidance, which states that all cases must be prepped, scanned,
and validated within 10 calendar days of ICT receipt or 20 calendar days of IRS received date.
The following concerns contributed to the delays in receipts of the Accounts Management
inventory.
•
There are no timeliness standards for screening. IRS management has not established
any goals to measure the time it takes to screen correspondence. As such, IRS
management cannot accurately determine if the screening process is resulting in delays
in meeting the requirement that documents be prepped, scanned, and validated within
20 calendar days, as outlined in the internal guidance. On October 21, 2022, we notified
IRS management regarding the lack of timeliness standards and recommended that they
establish time frames for correspondence screening and a process to measure timeliness.
IRS management disagreed stating that the screening process is designed to be
completed daily, and there were no delays pre-pandemic. Management also stated that
adding an additional date stamp could slow down the process and would not help the
backlog. However, management provided us no support for their statements.
Management agreed to revisit the recommendation as they catch up, if they determine
the screening process is contributing to the delays in the ICT. We disagree that
management will know that the screening process is contributing to delays without a
timeliness standard documented and without processes to track the timeliness in which
it is completed at each site.
Recommendation 11: The Commissioner, Wage and Investment Division, should
establish time frames for and a process to measure correspondence screening timeliness
at each site.
Management’s Response: IRS management disagreed with the
recommendation. Management stated that prior to the campus closures
associated with the Coronavirus Disease 2019 pandemic, there was no significant
delay in the screening of correspondence. The current backlog in ICT operations
is due to the increased workload attributed to the pandemic relief provisions that
have driven an increased number of amended return filings, and not due to
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delays in correspondence screening. Any changes made to the process will only
create additional burdens to the overall ICT process and require additional
programming updates with minimal benefits.
Office of Audit Comment: Management contends that any changes in
their processes will create additional burdens; however, management has
not provided any documentation to support the basis for this
assertion. Without time frames and a process for measuring timeliness,
management cannot accurately evaluate what is contributing to delays.
•
Management is not using mail clerks to assist with screening documents. IRS
management’s policy has been to allow only the TEs and the CSRs to screen
correspondence. As noted previously, the TEs and the CSRs are responsible for working
the Accounts Management function’s inventory and answering telephone calls. On
October 28, 2022, we notified IRS management of our concern that they were not using
mail clerks to perform screening and recommended they rescind their policy and allow
all sites to use mail clerks, after providing them with adequate training. IRS management
disagreed stating that it is necessary for the TEs and the CSRs to perform
correspondence screening because of its technical nature; however, they did not provide
any evidence to support their position that mail clerks cannot screen correspondence.
Recommendation 12: The Commissioner, Wage and Investment Division, should
rescind the requirement that only the TEs and the CSRs perform correspondence
screening and encourage all sites to use mail clerks, after providing them with adequate
training.
Management’s Response: The IRS disagreed with this recommendation. The
IRS stated that the screening process was developed for the TEs and the CSRs
due to its technical nature and the necessary training and experience required to
properly identify the different types of correspondence work.
Office of Audit Comment: As noted previously, management did not
provide any information to support their position that mail clerks would
be unable to screen correspondence if they received adequate training.
•
Additional high-speed scanners could be helpful. Campus Support Sites assist the
Tax Processing Centers with scanning inventory. However, due to differences in the
scanner capabilities, how the Tax Processing Center prepares documents for scanning
differs from the way this is performed at the Campus Support Sites. This leads to
inefficiencies because the Campus Support Sites may have to re-prepare documents
received from the Tax Processing Centers before scanning them. If the Campus Support
Sites had the same types of high-speed scanners as the Tax Processing Centers, this
rework would not be necessary. Moreover, ICT functions at the Campus Support Sites
would be able to handle additional inventory, as was recommended in our prior report.13
Furthermore, additional scanners have not been added at the Tax Processing Centers
despite the IRS’s policy decision to scan all Forms 1040-X, which greatly increased the
inventory the ICT was required to scan. On November 1, 2022, we recommended that
13 TIGTA, Report No. 2022-46-027, Program and Organizational Changes Are Needed to Address the Continued
Inadequate Tax Account Assistance Provided to Taxpayers p. 5 (Mar. 2022).
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IRS management evaluate the costs of adding high-speed scanners at all Campus
Support Sites and additional high-speed scanners at Tax Processing Centers and request
the necessary funding to purchase them. IRS management stated they would consider
additional scanners as part of an ICT review they are conducting in response to our prior
recommendation; however, they did not provide an expected completion date.
Recommendation 13: The Commissioner, Wage and Investment Division, should
ensure prompt completion of the ICT review to determine if additional scanners will be
purchased.
Management’s Response: IRS management agreed with the recommendation
and is completing the ICT review. Through March 2023, the IRS has conducted
studies of ICT operations at six of the 10 sites and is evaluating the results to
determine whether the information thus far collected is sufficient for a
determination to buy more scanners.
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Appendix I
Detailed Objective, Scope, and Methodology
The overall objective of this audit was to assess the IRS’s efforts to address the backlogged
Accounts Management inventory, including amended returns. To accomplish our objective, we:
•
Determined what actions the IRS took in response to our prior audit recommendations.
•
Met with IRS management to discuss their plans to prioritize inventories and their goals
to get inventories to pre-pandemic levels.
•
Determined the impact of Surge Team members assisting Accounts Management and
the impact it had on other IRS functions.
•
Assessed and monitored ICT, Accounts Management, and amended return inventories
during Calendar Year 2022 and compared to pre-pandemic levels and IRS goals.
•
Performed site visits and met with site employees and management to identify concerns
with working inventories and to identify opportunities to improve the efficiency in which
inventory is worked, thus helping to reduce the backlogs of inventory.
Performance of This Review
This review was performed at the IRS’s Tax Processing Centers located in Kansas City, Missouri;
Austin, Texas; and Ogden, Utah, as well as IRS Campus Support Sites located in
Andover, Massachusetts, and Holtsville, New York, during the period February through
December 2022. 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 Diana Tengesdal, Acting Assistant Inspector General for
Audit (Returns Processing and Account Services); Linna Hung, Director; Jeffrey Cullum, Audit
Manager; Lorenzo Moss, Lead Auditor; and James (Philip) Bailey, Auditor.
Validity and Reliability of Data From Computer-Based Systems
We performed tests to assess the reliability of data extracts from the CII and the Modernized Tax
Return Database. We evaluated the data by performing electronic testing of required data
elements and reviewing existing information about the data and the system that produced
them. In addition, we selected data from each extract and verified that the data in the extracts
were the same as the data captured in the source databases. We determined that the data were
sufficiently reliable for purposes of this report.
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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: IRS inventory reporting and
monitoring processes. We evaluated these controls by reviewing the Internal Revenue Manual,
meeting with IRS management, and reviewing relevant documentation provided by the IRS.
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Appendix II
Outcome Measures
This appendix presents detailed information on the measurable impact that our recommended
corrective actions will have on tax administration. These benefits will be incorporated into our
Semiannual Report to Congress.
Type and Value of Outcome Measure:
•
Taxpayer Privacy and Security – Potential; 60,261 documents received at the Brookhaven
Campus Support Site were screened at IRS employee’s telework sites and in IRS locations
not co-located with the mailroom, which increased the risk that documents would be
lost, destroyed, or viewed by unauthorized individuals (see Recommendation 2).
Methodology Used to Measure the Reported Benefit:
In response to our e-mail alert, IRS management agreed to ensure that screening work remains
in a secure IRS environment and to discontinue telework screening. During Fiscal Year 2022,
60,261 correspondence documents were received at the Brookhaven Campus Support Site and
screened at telework sites. As a result of our recommendation, these documents will now
remain secure and the privacy maintained for the associated taxpayers.
Type and Value of Outcome Measure:
•
Taxpayer Burden – Potential; 14,980,000 documents will be processed more timely by the
ICT and taxpayers notified sooner that the IRS received their correspondence
(see Recommendation 4).
Methodology Used to Measure the Reported Benefit:
In response to our e-mail alert, IRS management hired 214 additional mail clerks. The IRS
estimated that each mail clerk is able to process about 70,000 documents in the ICT each
calendar year. We multiplied the number of additional employees to be hired times the number
of documents they can process to estimate that 14,980,000 (214 x 70,000) documents will be
processed more timely and taxpayers notified sooner that their correspondence has been
received.
Type and Value of Outcome Measure:
•
Inefficient Use of Resources – Potential; $322,241,232 in potential savings if the IRS were
to automate the processing of Forms 1040-X (see Recommendation 6).
Methodology Used to Measure the Reported Benefit:
According to the IRS, it estimates that it would cost a total of $20 million through Fiscal
Year 2027 to implement a fully automated solution to process Forms 1040-X. In addition, the
IRS estimates that it currently costs $6.64 to process a Form 1040-X in the Submission
Processing function and $109.26 in the Accounts Management function. During Fiscal
Year 2022, the Submission Processing function processed 1,660,662 Forms 1040-X and the
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Accounts Management function processed 2,859,969 Forms 1040-X. In contrast, the IRS reports
that it can systemically process an e-filed Form 1040 for $0.28.
We estimate at least $322,241,232 in annual cost savings if the IRS implemented our
recommendation to prioritize the implementation of automating processing of Forms 1040-X.
•
Submission Processing function = 1,660,662 Forms 1040-X x $6.64 = $11,026,796
•
Accounts Management function = 2,859,969 Forms 1040-X x $109.26 = $312,480,213
•
Estimated automated processing costs = 4,520,631 Forms 1040-X x $.28 = $1,265,777
Total Cost = $11,026,796 + $312,480,213 – $1,265,777 = $322,241,232
Management’s Response: Although the IRS agreed that automating the Form 1040-X
processing will increase efficiencies and reduce taxpayer burden, they disagreed with this
outcome stating that an outcome measure should not be calculated until requirements and a
solution have been evaluated with the Information Technology organization. The evaluation
process and feasibility study of the automation could take several years due to the complexity
associated with Form 1040-X processing that must be done across multiple systems.
Management also disagreed with the outcome assuming that all Forms 1040-X will be e-filed.
Office of Audit Comment: Our outcome measure illustrates the potential benefit to the
IRS if it were to automate the processing of all Forms 1040-X. The dollar amounts were
calculated using estimated costs provided to us by the IRS during our audit. We agree
that the actual savings will be realized when management develops the solution.
Type and Value of Outcome Measure:
•
Taxpayer Burden – Potential; 309,083 open cases related to Forms 1040-X that indicate a
refund and could be prioritized by the IRS to ensure that taxpayers receive refunds
sooner (see Recommendation 7).
Methodology Used to Measure the Reported Benefit:
Our analysis of 1.9 million e-filed Forms 1040-X from the Modernized Tax Return Database
through October 22, 2022, found that 897,088 returns claimed a refund. Our review of the
refund Forms 1040-X identified 309,083 unique open CII cases through November 27, 2022.
Because these are electronic cases and remain open, the IRS could prioritize them.
Type and Value of Outcome Measure:
•
Inefficient Use of Resources – Potential; $1,738,932 potentially saved if the IRS prevents
the generation of transcripts for refunds less than $100 (see Recommendation 8).
Methodology Used to Measure the Reported Benefit:
As of December 3, 2022, the IRS reported that it had 24,492 transcripts in its Taxpayer Relations
inventory that require a manual refund of under $100. The IRS reports that it costs about $71 to
issue a manual refund (under $1 million). We estimate that the IRS could potentially save
$1,738,932 (24,492 x $71) by implementing our recommendation to prevent the generation of
these transcripts.
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Appendix III
Prior TIGTA Report Recommendations and Status
Recommendation
Status
Recommendation 1: Establish guidance/clarification on when
resources can be directed to the office to help with correspondence
screening inventory, ensure that sufficient staff is available to
screen in a timely manner, and establish processes to monitor
progress.
Agreed – Implemented. The IRS ensured that staff was brought into
Austin and the correspondence screening inventory was significantly
reduced.
Recommendation 2: Evaluate directing taxpayers to send inventory
intended for Accounts Management directly to Campus Support
Sites for processing to reduce backlogs at Tax Processing Centers
and improve services to taxpayers.
Disagreed – N/A. The IRS states that it does not have enough staffing
in Campus Support Sites and that it has had trouble hiring at these sites
in the past. The IRS also stated that space would be a concern.
Recommendation 3: Prioritize the development and
implementation of tools that will enable taxpayers seeking
assistance or responding to Accounts Management to correspond
with the IRS electronically, including the ability to directly upload
documents.
Agreed – Not Implemented. The IRS shows this recommendation as
implemented, but TIGTA remains concerned that actions taken to date
do not fully address the concerns raised by TIGTA. The IRS has piloted
technology uploading documents in other IRS functions. However,
Accounts Management is awaiting this functionality following IRS
modernization plans.
Recommendation 4: Evaluate establishing two distinct IRS
programs as part of the IRS reorganization under the Taxpayer First
Act – one dedicated to answering toll-free telephone calls and one
dedicated to working Accounts Management inventory – with
adequate staffing.
Agreed – Not Implemented. The IRS now reports an implementation
date of September 15, 2023.
Recommendation 5: Assess the availability of Campus Support
Sites’ ICT staffing or other resources that could be made available to
assist with clearing ICT backlogs at Tax Processing Centers.
Agreed – Implemented. Accounts Management has continued to
provide resources to the Submission Processing function to assist with
validating ICT inventory.
Recommendation 6: Provide us with plans to address concerns
identified with the new Fresno Campus Support Site, including
staffing the ICT.
Agreed – Implemented. Staffing was increased through voluntary
reassignments and external announcements. All scanners were being
used.
Recommendation 7: Complete a review of all 10 ICT sites to
determine what contributes to the ICT’s inability to timely scan and
validate documents. Develop an action plan to ensure that the
high-capacity ICT scanners and staffing are realigned to the
appropriate sites based on actual or expected inventory levels.
Ensure that responsibility of ICT operations is consolidated under
the appropriate function.
Agreed – Not Implemented. The IRS will perform a Lean Six Sigma
assessment to evaluate the potential for efficiency gains within the ICT
process by February 15, 2023. This will address opportunities to
improve procedures and the overall operation of the program.
Recommendation 8: Cross-train additional mail clerks at Campus
Support Sites to work ICT validations or consider shipping inventory
to sites with less inventory to be scanned.
Agreed – Implemented. Accounts Management is continuing to assist
the Submission Processing function in validations and transshipment of
ICT inventory.
Recommendation 9: Develop specific instructions and a common
template for all 10 ICT sites to consistently capture ICT inventory
information.
Agreed – Implemented. The IRS developed a common mechanism for
the Submission Processing and Accounts Management functions to
capture ICT inventory information starting in July 2022. A finalized
version was used beginning December 2022 and is shared between
both the Accounts Management and Submission Processing functions.
Recommendation 10: Update existing scanning software or obtain
a new software to address document capacity concerns.
Disagreed. The IRS determined the existing platform is sufficient to
handle current and future needs.
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Recommendation
Status
Recommendation 11: Ensure that programming is updated to
systemically reject electronic submissions of Forms 2848, Power of
Attorney and Declaration of Representative, and 8821, Tax
Information Authorization, without manually mailing a rejection
letter.
Agreed – Not Implemented. The IRS states that Optical Character
Recognition capability is critical for the ability to systemically issue
rejection letters and does not show implementation until
October 2024.
Recommendation 12: Ensure that the rejection letter used for
Forms 2848 and 8821 is updated to include language that a revised
form can be sent electronically.
Agreed – Implemented. Forms and letters were updated in
February 2022 to include the ability to electronically submit
authorization requests to a taxpayer's online account or submit
Forms 2848 and 8821 online through Tax Pro.
Recommendation 13: Develop an action plan to prioritize the
continued expansion of documents that can be sent in via e-fax and
converted into a CII image.
Agreed – Not Implemented. The IRS will perform a Lean Six Sigma
assessment to evaluate the overall efficiency of the ICT process by
February 2023. The evaluation will consider expansion of e-fax
services.
Recommendation 14: Identify priority work that needs to be
expedited by the ICT and assess the feasibility of creating an e-fax
number to receive this inventory.
Agreed – Not Implemented. The IRS will perform a Lean Six Sigma
assessment to evaluate the overall efficiency of the ICT process. The
evaluation will consider expansion of e-fax services.
Recommendation 15: Perform a reconciliation of each site’s
Accounts Management Inventory Report (AMIR) to the source
reports to identify inventory inconsistencies and reporting errors by
site.
Agreed – Implemented. In January 2022, the IRS performed a
reconciliation on the AMIRs for each site to identify the inventory
inconsistencies and reporting errors by sites. Minor discrepancies
were found at each of the sites, but the overall accuracy of the
reporting was greater than 99 percent.
Recommendation 16: Implement processes to provide oversight by
periodically performing reconciliations for each site.
Agreed – Not Implemented. The IRS will perform annual
reconciliations for each site and address any issues identified by those
reviews.
Recommendation 17: Develop specific and detailed instructions for
preparing the AMIR, including how controlled and uncontrolled
inventory should be captured.
Agreed – Implemented. The IRS has developed the instructions for
preparing the AMIR. In June 2022, Accounts Management met with
the sites to ensure consistency and understanding of report
preparation.
Recommendation 18: Develop a process to systemically pull all
controlled inventory for each site for the AMIR to ensure
consistency, reduce human error, and increase efficiencies.
Agreed – Not Implemented. The IRS is pursuing systemic changes to
pull controlled inventory. The requisite programming is subject to
budgetary constraints, limited resources, and competing priorities.
Consequently, an estimated date of October 2024 has been set.
Recommendation 19: Modify inventory reporting to report
unassigned controlled inventory separately on the nationwide AMIR
and limit the site specific AMIRs to only the inventory assigned to be
worked in each site.
Disagreed. The IRS disagreed and stated that implementing this
change would result in more complex reporting and would change the
meaning of the AMIR.
Source: TIGTA summary of the Joint Audit Management Enterprise System as of December 5, 2022, for
TIGTA Report No. 2022-46-027.
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Appendix IV
Management’s Response to the Draft Report
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Appendix V
Glossary of Terms
Term
Definition
Campus Support Site
IRS locations that handle incoming and outgoing mail operations where
Tax Processing Centers have closed. Campus Support Sites are located
in Fresno, California; Chamblee, Georgia; Florence, Kentucky; Andover,
Massachusetts; Holtsville, New York; Philadelphia, Pennsylvania; and
Memphis, Tennessee.
Centralized Authorization File
The Centralized Authorization File is a computerized system of records,
which houses authorization information from both powers of attorney
and tax information authorizations.
Correspondence Imaging
Inventory
The CII is an inventory system for scanning all Accounts Management
receipts into digital images and working the cases from those images.
Image Control Team
The ICT provides services for Accounts Management by scanning their
correspondence and forms sent in by taxpayers requesting adjustments
to their accounts.
Internal Revenue Manual
The Internal Revenue Manual is the source of instructions to IRS staff,
and includes policies, delegated authorities, procedures, instructions,
and guidelines related to the operation of the IRS.
Modernized Tax Return
Database
The database used to store original e-filed tax return data.
Statute of Limitations
The Internal Revenue Code states the IRS will assess, refund credit, and
collect taxes within specific time limits. These limits are known as
Statute of Limitations.
Tax Processing Center
The location where the IRS processes paper and electronic submissions,
corrects errors, and forwards data to the Computing Centers for analysis
and posting to taxpayer accounts. Tax Processing Centers are located in
Kansas City, Missouri; Austin, Texas; and Ogden, Utah.
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Appendix VI
Abbreviations
AMIR
Accounts Management Inventory Report
CII
Correspondence Imaging Inventory
CSR
Customer Service Representative
e-filed
Electronically Filed
ICT
Image Control Team
IRS
Internal Revenue Service
SB/SE
Small Business and Self-Employed
TE
Tax Examiner
TIGTA
Treasury Inspector General for Tax Administration
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 23291
Washington, D.C. 20026
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