Treasury Inspector General for Tax Administration 2022-40-037 (Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported)
Summary
Final Audit Report 2022-40-037 of the Treasury Inspector General for Tax Administration, issued May 6, 2022, reviews whether the IRS complied with annual improper payment reporting requirements of the Payment Integrity Information Act of 2019 for Fiscal Year 2021. The report finds the IRS generally compliant but states that the IRS inaccurately assessed the risk for the Economic Impact Payment program as not susceptible to improper payments. It states that the IRS did not complete a risk assessment for the Sick and Paid Family Leave Credit and the Employee Retention Tax Credit as required, and did not report the improper payment amount and rate for the Net Premium Tax Credit for FY 2021. TIGTA made three recommendations on self-employment transcript information from the Social Security Administration; the IRS agreed with one of the three.
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TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION
Programs Susceptible to Improper Payments
Are Not Adequately Assessed and Reported
May 6, 2022
Report Number: 2022-40-037
TIGTACommunications@tigta.treas.gov | www.treasury.gov/tigta
HIGHLIGHTS: Programs Susceptible to Improper
Payments Are Not Adequately Assessed and Reported
Final Audit Report issued on May 6, 2022 Report Number 2022-40-037
Why TIGTA Did This Audit What TIGTA Found
This audit was initiated The IRS was generally compliant with the reporting requirements
because TIGTA is required to contained in the Payment Integrity Information Act of 2019 for FY 2021.
annually assess and report on However, TIGTA identified concerns with two IRS programs. TIGTA found
the IRS’s compliance with the that the IRS inaccurately assessed the risk for the U.S. Coronavirus
reporting requirements Economic Impact Payment program as not susceptible to improper
contained in the Payment payments despite reports issued by TIGTA suggesting otherwise. IRS
Integrity Information Act of management reassessed and agreed that the program is susceptible to
2019. The objective of this improper payments. In addition, the IRS did not complete a risk
review was to determine assessment for the Sick and Paid Family Leave Credit and the Employee
whether the IRS complied Retention Tax Credit as required. The IRS did not complete the accurate
with the annual improper assessment until after our fieldwork had completed. As such, TIGTA was
payment reporting unable to review the IRS’s assessment of improper payment risk for
requirements for Fiscal Year FY 2021.
(FY) 2021. The IRS did not calculate and report the dollar amount and percentage
Impact on Tax rate of improper payments for the Net Premium Tax Credit for FY 2021.
Administration The IRS plans to report this for FY 2022 and cites significant demands
placed upon the Department of the Treasury and the IRS in connection
The Office of Management with the Coronavirus Disease 2019 crisis as the reason for the delay in
and Budget (OMB) defines an reporting.
improper payment as any
payment that should not have The IRS started receiving transcripts from the Social Security
been made, was made in an Administration in a digital manner in July 2019. However, IRS
incorrect amount, or was management states that the Social Security Administration does not
made to an ineligible provide signed statements to the IRS for individuals who admitted to
recipient. The IRS currently fraudulently reporting self-employment income for purposes of claiming
has identified four programs the Earned Income Tax Credit. This information would assist the IRS in
that meet the OMB’s developing fraudulent intent and applying a 10-year ban on the individual
definition of a high-priority claiming the credit in the future. Finally, TIGTA found that processes are
program susceptible to needed to prioritize transcripts with impending statutes and that the
improper payments. The Additional Child Tax Credit should be considered when determining
OMB defines high-priority whether potential tax changes meet the IRS’s dollar criteria for selecting
programs as programs with self-employment transcript cases.
improper payments resulting What TIGTA Recommended
in monetary losses that
TIGTA made three recommendations in this report to improve the use of
exceed $100 million annually.
self-employment transcript information obtained from the Social Security
Administration. This included reviewing transcripts more frequently and
prioritizing those with short statutes, revising processes for filtering
short-statute transcripts to not just look at the tax year but also consider
the number of days remaining before statute expiration, and considering
the Additional Child Tax Credit when computing the potential tax change
and using this amount when selecting workable cases.
The IRS agreed with one of the three recommendations. IRS management
revised the case selection criteria and updated the tax calculation to
include the disallowance of the Additional Child Tax Credit when
computing the potential tax change, when applicable.
U.S. DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220
TREASURY INSPECTOR GENERAL
FOR TAX ADMINISTRATION
May 6, 2022
MEMORANDUM FOR: COMMISSIONER OF INTERNAL REVENUE
FROM: Michael E. McKenney
Deputy Inspector General for Audit
SUBJECT: Final Audit Report – Programs Susceptible to Improper Payments Are
Not Adequately Assessed and Reported (Audit # 202240001)
This report presents the results of our review to determine whether the Internal Revenue Service
complied with annual improper payment reporting requirements for Fiscal Year 2021. This
review is part of our Fiscal Year 2022 Annual Audit Plan and addresses the major management
and performance challenge of Reducing Fraudulent Claims and Improper Payments.
Management’s complete response to the draft report is included as Appendix IV.
Copies of this report are also being sent to the Internal Revenue Service managers affected by
the report recommendations. If you have any questions, please contact me or Russell P. Martin,
Assistant Inspector General for Audit (Returns Processing and Account Services).
Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
Table of Contents
Background .....................................................................................................................................Page 1
Results of Review .......................................................................................................................Page 3
Assessment of Fiscal Year 2021 Compliance With
Improper Payment Reporting Requirements ............................................................Page 3
The Net Premium Tax Credit Improper Payment Amount
and Rate Are Still Not Included in the Treasury
Department’s Agency Financial Report .......................................................................Page 5
The Economic Impact Payment Program Was Incorrectly
Rated As Not Susceptible to Significant Improper
Payments .................................................................................................................................Page 6
The Use of Additional Self-Employment Data From the
Social Security Administration Could Reduce Improper
Payments .................................................................................................................................Page 7
Recommendation 1: ...................................................................Page 9
Recommendation 2: ...................................................................Page 11
Recommendation 3: ...................................................................Page 12
Appendices
Appendix I – Detailed Objective, Scope, and Methodology ................................Page 13
Appendix II – Programs Identified for Improper Payment
Risk Assessments for Fiscal Year 2021 .........................................................................Page 15
Appendix III – Prior Improper Payment Reports by the
Treasury Inspector General for Tax Administration ................................................Page 16
Appendix IV – Management’s Response to the Draft Report .............................Page 17
Appendix V – Glossary of Terms ....................................................................................Page 21
Appendix VI – Abbreviations ...........................................................................................Page 23
Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
Background
The Office of Management and Budget (OMB) defines an improper payment 1 as any payment
that should not have been made, was made in an incorrect amount, or was made to an ineligible
recipient. Agency Inspectors General are responsible for evaluating agency information related
to improper payments.
On March 2, 2020, the Payment Integrity Information Act of 2019 (PIIA) 2 repealed several
improper payment laws but set forth similar improper payment reporting requirements. 3 For
example, agencies must conduct a program-specific risk assessment for each program or
activity identified by the agency as exceeding $10 million in annual outlays at least once every
three years, provide the methodology for identifying and measuring improper payments, and
report on actions the agency intends to take to prevent future improper payments. In addition,
the following remains in effect:
• Executive Order 13520, Reducing Improper Payments, signed by the President on
November 20, 2009, increased Federal agencies’ accountability for reducing improper
payments while continuing to ensure that Federal programs serve and provide access to
intended beneficiaries. It requires Federal agencies to provide agency Inspectors General
with detailed information on efforts to identify and reduce the number of improper
payments in Federal programs with the highest dollar value of improper payments.
• OMB revised Circular A-123 Appendix C, Requirements for Payment Integrity
Improvement, issued June 2018. Appendix C provides agencies and Inspectors General
with guidance on improper payment determinations and reporting. According to the
OMB, the goal of the revised Appendix C is to transform the improper payment
compliance framework to create a more unified, comprehensive, and less burdensome
set of requirements. Every year, each agency Inspector General must review its agency’s
improper payment reporting in the Agency Financial Report (AFR) and any
accompanying material, such as that provided on www.paymentaccuracy.gov, to
determine if the agency complies with improper payment legislation and OMB guidance.
The OMB revised the Circular again effective Fiscal Year (FY) 2021.
• On December 20, 2019, Congress enacted the Consolidated Appropriations Act of 2020. 4
This Act directed the Internal Revenue Service (IRS) to make the elimination of improper
payments an utmost priority and to implement, within 270 days, all open and
unimplemented recommendations from the Treasury Inspector General for Tax
Administration (TIGTA) and the Government Accountability Office that address improper
payments or report on impediments to implementation of each open recommendation.
1
See Appendix V for a glossary of terms.
2
Pub. L. No. 116-117, 134 Stat. 113.
3
Improper Payments Information Act of 2002; Improper Payments Elimination and Recovery Act of 2010,
Pub. L. No. 111-204, 124 Stat. 2224; Improper Payments Elimination and Recovery Improvement Act of 2012,
Pub. L. No. 112-248, 126 Stat. 2390; Fraud Reduction and Data Analytics Act of 2015, Pub. L. No. 114-186,
130 Stat. 546.
4
Pub. L. No. 116-93, 133 Stat. 2317.
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
Process to identify IRS programs for improper payment risk assessment
Each program with annual outlays over $10 million must conduct an improper payment risk
assessment at least once every three years. The Department of the Treasury
(Treasury Department) identifies the programs that the IRS must assess for the risk of improper
payments each fiscal year. For FY 2021, the Treasury Department selected eight program fund
groups that required certification by the programs that there were no material changes to the
program since the last risk assessment was completed and selected 14 IRS programs that
required a risk assessment. 5
The IRS uses two types of risk assessments:
• Qualitative Risk Assessment – used to assess a program’s internal controls that could
lead to susceptible improper payments. The OMB requires agencies to conduct risk
assessments after the first 12 months of the program and at least once every three fiscal
years thereafter. Once the IRS determines that a program is susceptible to improper
payments, it must produce a statistically valid estimate of the improper payments the
following fiscal year.
• Quantitative Risk Assessment – used to review a sample of disbursements to formulate
the overall estimated improper payment rate. Quantitative assessments are required
annually for programs that are identified as susceptible to improper payments.
For any program identified as susceptible to significant improper payments, the IRS must also
provide the following information for the Treasury Department’s annual AFR in the following
fiscal year:
• The rate and amount of improper payments.
• The root causes of the improper payments.
• The actions taken to address the root causes.
• The annual improper payment reduction targets.
• A discussion of any limitations to the IRS’s ability to reduce improper payments.
The Treasury Department and the IRS continue to request relief from reporting erroneous
refundable tax credit claims under the PIIA
As we reported in May 2021, 6 the Treasury Department and the IRS informed the OMB in
October 2020 that the tax system is primarily a collection system and not a payment program.7
The Treasury Department and the IRS acknowledged that refundable tax credits currently fall
under the scope of the PIIA but do not believe that the refundable tax credits meet the
definition of payments in the traditional sense. Therefore, the Treasury Department believes the
credits should be reported only under the Tax Gap framework that comprehensively assesses
the tax collection system and no longer be reported under improper payment requirements.
5
Appendix II provides the list of the 14 IRS programs identified for improper payment risk assessments for FY 2021
and the type of risk assessment completed for each program.
6
TIGTA, Report No. 2021-40-036, Improper Payment Rates for Refundable Tax Credits Remain High (May 2021).
7
IRS, Business Case to Eliminate Redundant Reporting of Refundable Tax Credits (Oct. 30, 2020).
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
As we previously reported, in December 2020, officials at the Treasury Department and the IRS
met with OMB officials to further discuss the request. On January 2021, the OMB requested
additional information, and responses were provided on February 2021. The OMB immediately
advised that it would provide a response on next steps once the full OMB leadership team was
in place. However, as of February 23, 2022, the IRS stated that it had not received a response
from the OMB.
Results of Review
For FY 2021, the IRS calculated and reported the following dollar amount and percentage rate of
improper payments for three of its high-priority programs susceptible to improper payments:
• Earned Income Tax Credit (EITC) – The IRS estimates 28 percent ($19.0 billion) of the
total EITC payments of $68.3 billion were improper.
• Additional Child Tax Credit (ACTC) – The IRS estimates 13 percent ($5.2 billion) of the
total ACTC payments of $39.4 billion were improper.
• American Opportunity Tax Credit (AOTC) – The IRS estimates 26 percent ($1.9 billion) of
the total AOTC payments of $7.1 billion were improper.
Assessment of Fiscal Year 2021 Compliance With Improper Payment
Reporting Requirements
Our review found that the IRS was generally compliant with the reporting requirements
contained in the PIIA for FY 2021. Figure 1 provides a summary of our evaluation of the IRS’s
compliance with the various improper payment reporting requirements for FY 2021.
Figure 1: Compliance With Improper Payment Requirements for FY 2021
Source of IRS
Improper Payment Requirement
Requirement Compliance
Published payment integrity information with the annual
PIIA
financial statement.
Posted the annual financial statement and accompanying
PIIA/Executive Order
materials to agency website.
Conducted Improper Payment (IP) risk assessments for each
program with annual outlays greater than $10 million at least PIIA
once in the last three years. 8
8
The IRS incorrectly completed a qualitative risk assessment for U.S. Coronavirus Refundable Credits for the
Recovery Rebate Credit rather than the Sick and Paid Family Leave Credit and the Employee Retention Tax Credit.
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
Source of IRS
Improper Payment Requirement
Requirement Compliance
Adequately concluded whether programs are likely to make
IPs and Unknown Payments (UP) 9 above or below statutory PIIA
threshold. 10
Published IP and UP estimates for programs susceptible to IPs
and UPs in accompanying materials to the annual financial PIIA
statement. 11
Published corrective action plans for each program for which
an estimate above the statutory threshold was published in PIIA
the accompanying materials to the annual financial statement.
Published an IP and UP reduction target for each program for
which an estimate above statutory threshold was published in PIIA
the accompanying materials to the annual financial statement.
Demonstrated improvements to payment integrity or reached
PIIA
a tolerable IP and UP rate.
Developed a plan to meet the IP and UP reduction target. PIIA/Executive Order
Reported an IP and UP estimate of less than 10% for each
program for which an estimate was published in the PIIA
accompanying materials to the annual financial statement.
Established targets for reducing and recovering improper
Executive Order
payments.
Provided the methodology for identifying and measuring
Executive Order
improper payments.
Provided plans and supporting analysis for ensuring that the
initiatives undertaken do not unduly burden program access Executive Order
and participation by eligible beneficiaries.
Reported all unimplemented recommendations to Congress Consolidated
related to improper payments. 12 Appropriations Act
Source: TIGTA’s review of the IRS’s compliance with improper payment requirements for FY 2021 for the
programs listed in Appendix II.
9
Unknown payments are payments made by a program for which it is still unknown whether the payment is proper or
improper. Payments are reported as unknown so that a program does not unintentionally over- or underreport the
payment type results.
10
We disagreed with the IRS’s assessment that the U.S. Coronavirus Economic Impact Payment program is not
susceptible to improper payments. However, IRS management subsequently reassessed the program and agreed the
program is susceptible to improper payments.
11
Per OMB guidance, Net Premium Tax Credit (PTC) improper payments were required to be reported beginning in
FY 2020. However, the Treasury Department notified the OMB on August 2020 (for FY 2020) and April 2021 (for
FY 2021) that it would delay reporting Net PTC information due to significant demands placed upon the Treasury
Department and the IRS in connection with the Coronavirus Disease 2019 (COVID-19) crisis. Although the IRS did not
report the Net PTC improper payment rate for FY 2021, the OMB guidance issued in June 2021 allows them to
prioritize COVID-19 work over financial reporting requirements.
12
Our review was limited to unimplemented recommendations from reports specific to improper payment reporting
and not on all TIGTA reviews with recommendations that may reduce improper payments of refundable credits.
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
However, the IRS is still not be in compliance with the goal to reduce the overall improper
payment rate for the EITC, ACTC, and AOTC to less than 10 percent. As we have previously
reported, the OMB advised the IRS that, as an alternative to reducing the improper payment rate
to less than 10 percent, a reduction target may remain constant given the complexities of the
programs as long as the complexities are clearly explained in a footnote in the AFR, which the
IRS did. 13 In addition, the IRS did not report the dollar amount and percentage rate of improper
payments for the Net Premium Tax Credit (PTC) for FY 2021. The IRS plans to report this for
FY 2022 and cites significant demands placed upon the Treasury Department and the IRS in
connection with the Coronavirus Disease 2019 (COVID-19) crisis as the reason for the delay in
reporting.
Finally, we disagreed with the IRS’s initial improper payment rating of the risk associated with
the U.S. Coronavirus Economic Impact Payment (EIP) program as not susceptible to improper
payments. IRS management subsequently reassessed the program and agreed the program is
susceptible to improper payments. In addition, the IRS did not complete a risk assessment for
the Sick and Paid Family Leave Credit or the Employee Retention Tax Credit as required. IRS
management noted that they misinterpreted which U.S. Coronavirus Refundable Credit fund
account was required by the Treasury Department to have a risk assessment performed for
FY 2021. The required risk assessment was completed in FY 2022 after our fieldwork was
completed. As such, we were unable to determine the sufficiency of the IRS’s assessment of
improper payment risk for FY 2021.
The Net Premium Tax Credit Improper Payment Amount and Rate Are Still Not
Included in the Treasury Department’s Agency Financial Report
Per OMB guidance, Net PTC improper payments were required to be reported beginning in
FY 2020. However, the Treasury Department notified the OMB on August 2020 (for FY 2020)
and April 2021 (for FY 2021) that it would delay reporting Net PTC information due to significant
demands placed upon the Treasury Department and the IRS in connection with the COVID-19
crisis. The IRS states it anticipates reporting in FY 2022. Although the amount and rate were not
reported, the IRS’s methodology to calculate the Net PTC was completed in May 2020. In
addition, the latest IRS estimates of improper payments of Net PTC (for FY 2019) show that
27.4 percent ($540.9 million) of the total Net PTC payments were improper. As such, the
improper payment estimate calculated by the IRS associated with Net PTC payments meets the
PIIA guidelines for rating as a high-priority program. 14
Our analysis of Tax Year 2020 tax returns processed as of August 5, 2021, found 3.8 million
returns that obtained nearly $29 billion in PTCs that were either received in advance or claimed
at the time of filing. A total of $2.2 billion in Advance Premium Tax Credits (APTC) claimed by
these filers was in excess of the amount of the PTCs to which they were entitled. However,
Section 9662 of the American Rescue Plan Act of 2021 temporarily suspended the requirement
13
The AFR describes five barriers to reducing refundable tax credit improper payments. The five barriers are
1) complexity and lack of data to verify statutory eligibility requirements; 2) lack of correctable error authority;
3) high turnover of eligible taxpayers; 4) unscrupulous and incompetent tax return preparers; and 5) fraud.
14
The OMB defines a high-priority program as programs with improper payments resulting in monetary losses that
exceed $100 million annually.
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
to reconcile advance payments of the PTC on Tax Year 2020 returns. Figure 2 compares PTC
statistics for Tax Years 2018 through 2020.
Figure 2: PTC Statistics for Tax Years 2018 Through 2020
Tax Year 2018 Tax Year 2019 Tax Year 2020
Tax Returns Tax Returns Tax Returns
Processed as of Processed as of Processed as of
May 2, 2019 July 30, 2020 15 August 5, 2021 16
Total Tax Returns
4.8 million 4.6 million 3.8 million
With PTC or APTC
Sum of APTC and PTC Claimed at Filing in
Excess of the APTC $37.7 billion $35.9 billion $29.0 billion
Total APTC Amount $36.4 billion $34.6 billion $27.3 billion
Total PTC Claimed in Excess of the APTC $1.3 billion $1.3 billion $1.6 billion
Tax Returns With Excess APTC Payments –
(taxpayer receives more APTC payments than the PTC amount to which they are entitled)
Total Tax Returns 2.6 million 2.4 million 1.4 million
Total PTC Amount $13.5 billion $12.8 billion $7.2 billion
Total APTC Amount $18.0 billion $17.1 billion $9.4 billion
Total APTC Reported in Excess of the PTC $4.5 billion $4.3 billion $2.2 billion
Source: TIGTA’s analysis of Individual Master File. Totals may not add due to rounding.
The Economic Impact Payment Program Was Incorrectly Rated As Not
Susceptible to Significant Improper Payments
The IRS completed a qualitative risk assessment for the EIP program in July 2021 and rated the
program as not susceptible to significant improper payments. We disagree with the IRS’s
conclusion based on our own assessment using the same factors and criteria the IRS used.
Specifically, the OMB defines high-priority programs as programs with improper payments
resulting in monetary losses that exceed $100 million annually.
OMB guidance encourages agencies to review the results of audits by the Inspectors General
and take into account whether they impact the risk of improper payments in the program
evaluated. In May 2021, we reported that, of the more than 157 million EIPs processed, the IRS
had issued more than 4.4 million EIPs totaling nearly $5.5 billion to potentially ineligible
individuals as of July 16, 2020. 17 This included payments made to deceased individuals,
potentially nonqualified dependents, nonresidents, individuals in U.S. Territories who already
received payments from the Territories, and individuals with filing status changes. In fact, the
IRS updated its Frequently Asked Questions directing taxpayers to return the erroneous
payments it had issued for deceased taxpayers.
15
Tax Year 2019 returns selected through July 30, 2020, due to the IRS extending the filing season to July 15, 2020.
16
Tax Year 2020 returns selected through August 5, 2021, due to the IRS extending the filing season to May 17, 2021.
17
TIGTA, Report No. 2021-46-034, Implementation of Economic Impact Payments (May 2021).
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
Inaccurate risk ratings allow the IRS to avoid the reporting of required information to the
Treasury Department for inclusion in the annual AFR. Such information would include the rate
and amount of improper payments, the causes of improper payments, the IRS’s plans to address
them, reduction targets, and limitations to the IRS’s ability to reduce improper payments
(including legislative limitations).
IRS management subsequently indicated that they agreed two risk factors should be changed
and agreed that the EIP program should be rated as susceptible to significant improper
payments based upon the qualitative risk assessment criteria. The IRS updated and resubmitted
its qualitative risk assessment to the Treasury Department in March 2022.
IRS management also stated that temporary programs, such as the EIP, that provide emergency
stimulus relief are not ongoing programs. Management stated that, by the time improper
payment estimates, root cause analysis, and correction action plans could be developed for such
programs, the programs will have expired. For example, the IRS’s methodology for quantifying
improper payments uses three years of National Research Program data. Management states
that these data for the EIP would not be available until FY 2024.
The Use of Additional Self-Employment Data From the Social Security
Administration Could Reduce Improper Payments
In March 2016, we reported that Social Security Administration (SSA) information provided to
the IRS relating to misreported self-employment (SE) income was not being effectively used by
the IRS to recover fraudulent or erroneously claimed refundable credits. 18 In response to a prior
TIGTA recommendation, steps were taken to begin receiving the SE income transcripts 19 from
the SSA in a digital manner in July 2019. However, IRS management states that the SSA does
not provide signed statements to the IRS for individuals who admitted to fraudulently reporting
SE income for purposes of claiming the EITC as the SSA believes sharing this information
violates the Privacy Act. 20 This information would assist the IRS in developing fraudulent intent
and applying a 10-year ban on the individual claiming the EITC, thus reducing improper
payments of the EITC. According to the IRS, it has been working with the SSA since April 2019
to obtain this information in a manner that the SSA believes would be consistent with its
interpretation of the relevant laws. Figure 3 provides an overview of our recommendations from
March 2016 and the status of these recommendations.
18
TIGTA, Report No. 2016-40-027, Social Security Administration Information on Misreported Self-Employment
Income Is Not Effectively Used to Recover Fraudulent or Erroneously Claimed Refundable Credits (Mar. 2016).
19
Transcripts notify the IRS of the tax year for which the individual stated the SE income was not earned and the
amount of income that was deleted from his or her SSA earnings record.
20
Privacy Act of 1974, 5 U.S.C. § 552a (2018).
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
Figure 3: Prior Audit Recommendations and Current Status
Recommendation Response Current Status
Ensure that all transcripts received from the SSA Agreed Implemented – The IRS considers all
identifying individuals that overreport SE income SE transcripts a referral, when there
and receive the EITC are reviewed as part of the IRS is sufficient time before the statute
strategy to recover and reduce improper EITC of limitations expires. 21
payments.
Establish processes to ensure that all SE transcript Agreed Condition still present – The IRS has
cases for which the SSA indicates the individual tried working with the SSA to get
attested to falsely reporting SE income for the Forms SSA-795, but the SSA says it
purpose of claiming the EITC are screened for the does not have the authority.
EITC bans. These processes should include
obtaining Form SSA-795, Statement of Claimant or
Other Person, to assist with the application of the
bans.
Work with the SSA to establish a method to transfer Agreed Implemented – The IRS began
SE transcript information to the IRS in an electronic receiving weekly, electronic transfers
format. in June 2019.
Once SE transcripts are received by the IRS Disagreed Condition still present – The IRS
electronically, establish processes to systemically receives data weekly but only
monitor transcripts to ensure that those with typically delivers cases to be worked
impending statute expirations are worked first. twice per year.
Develop measures to effectively evaluate the Agreed Implemented – The IRS provided
performance of the SSA SE Income Transcript TIGTA with FY 2021 performance
program, including developing a method to metrics such as the no-change rate
determine the program’s return on investment or and return on investment.
equivalent measure. These measures should be
used to ensure that sufficient resources are
allocated to the SSA SE Income Transcript program
to maximize the program’s outcome.
Source: TIGTA’s review of recommendations in TIGTA, Report No. 2016-40-027, Social Security
Administration Information on Misreported Self-Employment Income Is Not Effectively Used to Recover
Fraudulent or Erroneously Claimed Refundable Credits (Mar. 2016).
More timely review of transcripts could increase the value to identify potential improper
payments
The IRS receives SE transcripts weekly from the SSA; however, the transcripts are only reviewed
monthly or sometimes quarterly. In addition, transcript cases to be worked by tax examiners are
only sent two or three times per year. If the IRS reviewed the transcripts more often and
21
A statute of limitations is a time period established by law to review, analyze, and resolve taxpayer and IRS
tax-related issues.
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
prioritized more frequent delivery of short-statute transcripts, it could potentially work
additional cases and reduce improper payments of the EITC. 22
According to IRS management, cases are only sent two or three times per year because that is
what is established in the Campus Exam Workplan for these cases. The workplan is established
before the IRS knows how many transcripts it will receive from the SSA and how many will be
workable. Management states that the number of deliveries in a year does not impact its ability
to deliver all the cases that meet its criteria. As such, it should not be a problem for
management to deliver cases more frequently so that it does not continue to filter out and not
work short-statute transcript cases. In addition, management has not provided us with
information substantiating why it could not deliver cases more frequently, as it does for other
Campus Examination programs.
Recommendation 1: The Commissioner, Small Business/Self-Employed Division, should review
transcripts more frequently in an effort to prioritize sending transcripts with short statutes to tax
examiners more frequently so that additional transcript cases can be worked.
Management’s Response: The IRS disagreed with this recommendation. IRS
management stated that this audit report includes an assumption that, the day it
receives data from the SSA, the IRS can determine if the case is workable and start the
audit process immediately. However, as shared during the audit, there are numerous
steps to be completed before an SSA referral can be audited. The IRS is currently
working all short-statute cases that meet the filter criteria. As noted in TIGTA’s review,
the cases identified would likely not have been selected for other reasons. IRS
management also stated that their existing process is effective, and changing it, as
recommended, would not increase the volume of additional transcripts to be worked.
Management believes expending additional resources to review the data more
frequently and make additional deliveries would not be an effective use of resources.
Office of Audit Comment: In their response, management does not address
our concern that transcripts should be sent for work by tax examiners more
frequently than the two or three times a year they are presently sent to tax
examiners. In addition, management mischaracterizes information presented in
our review. Specifically, in their response, management noted that our review
found that cases identified by reviewing transcripts more frequently likely would
not have been selected for other reasons. In our report, we acknowledge that
there are other exclusion criteria that may impact case selection. However,
reviewing transcripts more frequently could reduce the number of transcripts
categorized as short-statute cases and as such could reduce the number of
transcripts that do not meet filter criteria from being removed from workable
inventory.
22
The IRS has other exclusion criteria that it considers after looking at the statute expiration date. As such, cases may
subsequently be excluded for other reasons and not worked.
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
The SSA continues to work with the OMB to make form revisions to provide the IRS with
information associated with individuals that fraudulently report self-employment income
to claim the EITC
As of January 2022, the IRS states that it has not applied any 10-year bans to taxpayer accounts
based upon SE transcripts. According to the IRS, the signed statements of fraud, which are
needed to apply the 10-year ban, are still not provided by the SSA. On March 2016, we
recommended that the IRS obtain copies of Form SSA-795 or other available SSA information to
assist the IRS with applying the EITC ban when individuals attest to falsely reporting SE income
for purposes of claiming the EITC. 23 As we reported, when an individual notifies the SSA that
they intentionally claimed SE income that was not earned for the purpose of claiming the EITC,
the SSA requires the individual to sign a Form SSA-795 affidavit. The signed statements help
reduce the burden on determining if fraud occurred, which allows the IRS to apply the 10-year
ban on claiming the EITC. IRS management agreed to work with the SSA to obtain this
information.
We subsequently reported in February 2020 that the SSA determined that it could not provide
Form SSA-795 to the IRS under the Privacy Act Statement in § 205a of the Social Security Act
(42 U.S.C. § 405a). 24 However, SSA management agreed to continue to work with the IRS to
modify Form SSA-7008, Request for Correction of Earnings Record, to include the information
the IRS needs to determine whether a 10-year ban should be applied.
During this review, IRS management stated that they continue to coordinate with the SSA on
obtaining Forms SSA-7008. IRS management noted that the delay results from the SSA working
through revisions to Form SSA-7008 with the OMB. As of February 2022, the SSA provided
information to the SSA Office of Inspector General which states that the SSA submitted a form
renewal request to the OMB in January 2020 for Form SSA-7008 and has not yet heard back
from the OMB. The SSA does not plan to request a revision to the form, to meet the IRS’s need,
until the OMB approves the renewal request. As such, there is no planned date for the SSA to
provide this critical information to the IRS. According to the SSA Office of Inspector General, it
is reviewing the SSA’s responses about its lack of authority for providing the Form SSA-795 to
the IRS for legal sufficiency. Because this is outside of the IRS’s control and we have shared our
concerns with the SSA Office of Inspector General, we are making no recommendations at this
time.
Prioritization of SE transcripts with impending statute expirations is needed
During FY 2021, the IRS received 8,948 SE transcripts 25 from the SSA, and the statute had already
expired by the time the IRS received the transcript for 5,620 (63 percent) of those transcripts.
For another 1,173 (13 percent) of the transcripts,26 the statute had not yet expired, but IRS
management decided that there was not enough time left to work the case before the statute
23
TIGTA, Report No. 2016-40-027, Social Security Administration Information on Misreported Self-Employment
Income Is Not Effectively Used to Recover Fraudulent or Erroneously Claimed Refundable Credits (Mar. 2016).
24
TIGTA, Report No. 2020-40-008, Authorities Provided by the Internal Revenue Code Are Not Effectively Used to
Address Erroneous Refundable Credit and Withholding Credit Claims (Feb. 2020).
25
The IRS received 9,027 records. However, we consider a transcript a unique taxpayer and tax year. Some taxpayers
can have multiple SE changes for the same tax year and we counted this as one transcript.
26
The IRS subsequently informed us that it was still reviewing 84 Tax Year 2018 cases as of October 2020.
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
expired. We disagree. In fact, our review found that all of these transcripts had more than
six months remaining on the statute from the day the transcript was received by the IRS from
the SSA. In addition, 830 (71 percent) transcripts had more than nine months remaining, and
557 (47 percent) had more than one year remaining on the statute. The largest number of days
remaining on any Tax Year 2018 statute was 529 days.27
We previously recommended that the IRS prioritize the transcripts with impending statute
expirations. However, IRS management disagreed with our recommendation and stated that the
IRS’s processes for sorting and prioritizing were sufficient. IRS management stated that the IRS
does have procedures in place to consider the same issue on the current audit year when the
referral year would be excluded due to a short statute (i.e., if Tax Year 2018 is excluded due to a
short statute, Tax Year 2019 will be considered for the same issue).
We continue to find that the IRS processes for prioritizing statute expiration transcripts are
insufficient. IRS management states that numerous steps must take place before an audit can
be opened, such as converting the transcripts into easily filterable data and collecting additional
tax information for filtering purposes. However, we disagree that the time required to complete
these tasks is insufficient given the number of days remaining on the statute for the cases we
reviewed (i.e., as much as 529 days). Figure 4 shows a summary of SE transcripts that the IRS
identified as workable or unworkable for FY 2021.
Figure 4: FY 2021 SE Transcripts
Description Count Percentage
Total SE transcripts received from the SSA 8,948 28 100%
Less: Transcripts with expired statutes (TY 2017 and prior) 5,620 63%
Less: Transcripts with short statutes (TY 2018) 1,173 13%
Less: Transcripts with suspended earnings (TYs 2019 and
429 5%
2020) 29
Less: Transcripts with net tax change below IRS’s dollar criteria 270 3%
Less: Transcripts identified as unworkable for other reasons 30 1,076 12%
Total Workable SE Transcripts Identified by the IRS 380 4%
Source: IRS Campus Case Selection function information for SE transcripts received from the SSA for FY 2021.
Recommendation 2: The Commissioner, Small Business/Self-Employed Division, should revise
processes for filtering short-statute transcripts to not only look at the tax year but also the
27
While there may be time left on the statute, this does not mean the case will always be worked due to other IRS
filters that are subsequently applied.
28
Transcript counts are defined as unique taxpayers and tax years reported by the SSA. Several SE income changes
for multiple tax years may be reported for the same taxpayer as well as multiple SE changes for the same tax year.
29
Income transferred by the SSA from an individual’s earnings record to the SSA’s Earnings Suspense File with the
expectation that it can eventually be matched to the person that actually earned the income.
30
Transcripts already selected for examination, those with an amended return filed, and numerous other reasons.
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
number of days remaining before statute expiration so that additional transcript cases can be
worked.
Management’s Response: The IRS disagreed with this recommendation. IRS
management stated that calculating the number of days remaining before statute
expiration would yield the same number of cases worked because of Fiscal Year 2021
referrals. Management also stated they are currently working all short-statute cases that
meet the filter criteria. They believe that their existing filtering process is effective and
that changing it, as recommended, would not increase the volume of additional
transcripts to be worked.
Office of Audit Comment: Using the tax year alone and not calculating the
number of days remaining before statute expiration will continue to result in
transcripts being incorrectly removed from workable inventory.
The ACTC should be considered when determining whether potential tax changes meet
the IRS’s dollar criteria for selecting SE transcript cases
As part of its SE transcript case review process, the IRS evaluates how the SE income reported on
the SE transcript would change the amount of any EITC and computes a net tax change, i.e., how
much the total amount of taxes owed would change. However, the IRS does not include all
refundable credits in its computation of net tax change. Specifically, the IRS does not include
the potential changes to the ACTC when computing the net tax change for case selection.
Similar to the EITC, the ACTC also requires earned income. The ACTC is also subject to adjusted
gross income limits, and the credit is phased out for higher adjusted gross income amounts. An
adjustment to SE income could reduce the amount of ACTC a taxpayer is entitled to receive.
Therefore, the IRS is not accurately computing the potential net tax change for case selection
and potentially excluding transcripts that may yield a higher net tax change if ACTC amounts
were also considered. As shown in Figure 4 above, the IRS excluded 270 SE income transcripts
in FY 2021 because the potential net tax change was less than the IRS’s established dollar criteria
for selecting and working the case. Our review found that 97 (36 percent) of the 270 transcripts
that the IRS excluded received the ACTC. The net tax change for the 97 cases could have been
increased to meet the IRS’s dollar criteria by including potential changes to the amount of the
ACTC.
Recommendation 3: The Commissioner, Small Business/Self-Employed Division, should revise
case selection criteria to include the ACTC when computing the potential tax change on SE
transcript income reported by the SSA.
Management’s Response: The IRS agreed with this recommendation and has revised
the case selection criteria and updated the tax calculation to include the disallowance of
the ACTC when computing the potential tax change, when applicable.
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
Appendix I
Detailed Objective, Scope, and Methodology
Our overall objective of this audit was to determine whether the IRS complied with the annual
improper payment reporting requirements for FY 2021. To accomplish our objective, we:
• Determined the reporting requirements listed in the PIIA and Executive Order 13520 and
evaluated whether the IRS complied with the reporting requirements for FY 2021
• Evaluated the adequacy of the IRS’s FY 2021 risk assessments for the IRS revenue
program funds identified by the Treasury Department, including completion of required
risk assessment questionnaires for new and existing programs.
• Reviewed the IRS’s methodology to calculate EITC, ACTC, AOTC, and Net PTC improper
payment rates for FY 2021.
• Reviewed the IRS’s coordination with the Department of Health and Human Services and
Centers for Medicare and Medicaid Services for reporting the Net PTC improper
payment rates.
• Followed up on prior audit recommendations regarding the IRS’s use of SE income
transcripts received from the SSA.
Performance of This Review
This review was performed with information obtained from the Chief Financial Officer and
Small Business/Self-Employed Division offices located in Washington, D.C., and Atlanta, Georgia,
respectively, during the period October 2021 through March 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 Russell P. Martin, Assistant Inspector General for Audit
(Returns Processing and Account Services); Linna K. Hung, Director; Jeffrey D. Cullum, Audit
Manager; Laura R. Christoffersen, Lead Auditor; and Nathan J. Cabello, Auditor.
Validity and Reliability of Data From Computer-Based Systems
During this review, we relied on data received from the IRS’s Individual Master File 1 databases
for Processing Year 2021 that were available on TIGTA’s Data Center Warehouse.2 We also
obtained extracts of FY 2021 transcript data the IRS receives from the SSA. We evaluated the
data by performing electronic testing of required data elements and reviewing existing
1
The IRS database that maintains transactions or records of individual tax accounts.
2
A TIGTA repository of IRS data.
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
information about the data and the systems that produced them. We determined that the data
were sufficiently reliable for purposes of this report.
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 controls in place to ensure
that the IRS met the annual improper payment reporting requirements established in the PIIA
and Executive Order 13520. We tested these controls by reviewing and analyzing relevant
documents and holding discussions with IRS management and the Treasury Department’s Risk
and Control Group.
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
Appendix II
Programs Identified for Improper Payment
Risk Assessments for Fiscal Year 2021
The following IRS programs were identified by the Treasury Department for improper payment
risk assessments for FY 2021.
Type of Total Non-Federal
IRS Program
Assessment Disbursements
Headquarters Disbursement Earned Income Credit Quantitative $57.6 billion
Additional Child Tax Credit Quantitative $27.8 billion
American Opportunity Credit Quantitative $2.8 billion
Premium Tax Credit 1 Quantitative $60.0 billion
Refund – Corporations Qualitative $16.1 billion
Informant Reimbursement Qualitative $62.8 million
Taxpayer Services Qualitative $2.0 billion
Tax Law Enforcement Qualitative $3.6 billion
Operations Support Qualitative $3.0 billion
Business Systems Modernization Qualitative $271.3 million
US Coronavirus Payments Qualitative $274.7 billion
US Coronavirus Refundable Credits Qualitative $713.8 million
Private Collection Agent Program Qualitative $60.2 million
Special Compliance Personnel Program Account Qualitative $18.3 million
Source: IRS Office of the Chief Financial Office.
1
A risk assessment was required; however, the IRS requested an exemption for reporting an estimate for the PTC for
FY 2021, as implementing COVID-19 programs was determined to be a priority.
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
Appendix III
Prior Improper Payment Reports by the
Treasury Inspector General for Tax Administration
Issuance Report
Report Title
Date Number
May 2021 2021-40-036 Improper Payment Rates for Refundable Tax Credits Remain High
Improper Payment Reporting Has Improved; However, There
April 2020 2020-40-025 Have Been No Significant Reductions to the Billions of Dollars of
Improper Payments
Some Refundable Credits Are Still Not Classified and Reported
May2019 2019-40-039 Correctly As a High Risk for Improper Payment by the Internal
Revenue Service
The Internal Revenue Service Is Not in Compliance With Improper
April 2018 2018-40-032
Payment Requirements
Revised Refundable Credit Risk Assessments Still Do Not Provide
April 2017 2017-40-030
an Accurate Measure of the Risk of Improper Payments
Without Expanded Error Correction Authority, Billions of Dollars in
April 2016 2016-40-036 Identified Potentially Erroneous Earned Income Credit Claims Will
Continue to Go Unaddressed Each Year
Assessment of Internal Revenue Service Compliance With the
April 2015 2015-40-044
Improper Payment Reporting Requirements in Fiscal Year 2014
The Internal Revenue Service Fiscal Year 2013 Improper Payment
March 2014 2014-40-027 Reporting Continues to Not Comply With the Improper Payments
Elimination and Recovery Act
The Internal Revenue Service Was Not in Compliance With All
February 2013 2013-40-024 Requirements of the Improper Payments Elimination and
Recovery Act for Fiscal Year 2012
Source: www.treasury.gov/tigta/oa_auditreport.
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
Appendix IV
Management’s Response to the Draft Report
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
Appendix V
Glossary of Terms
Term Definition
A credit for individuals who receive less than the full amount of the
Additional Child Tax Credit
nonrefundable Child Tax Credit. The ACTC may result in a refund even if no
(ACTC)
tax is owed.
Advanced Premium Tax A tax credit that is paid in advance to a taxpayer’s insurance company to
Credit (APTC) help cover the cost of premiums.
Agency Financial Report Presents the Treasury Department’s financial and performance information
(AFR) for the fiscal year, with comparative prior year data where appropriate.
A credit for qualified education expenses paid for an eligible student for
American Opportunity Tax
the first four years of higher education. A partially refundable Federal tax
Credit (AOTC)
credit used to help parents and college students offset the costs of college.
Data Center Warehouse A TIGTA repository of IRS data.
Earned Income Tax Credit A tax credit used to offset the impact of Social Security taxes on low-income
(EITC) families and to encourage them to seek employment.
Excess Advanced Premium When the APTC is more than the allowed PTC (APTC minus PTC = Excess
Tax Credit APTC). This is treated as a tax liability.
The period from January through mid-April when most individual income
Filing Season
tax returns are filed.
Any yearly accounting period, regardless of its relationship to a calendar
Fiscal Year (FY) year. The Federal Government’s fiscal year begins on October 1 and ends
on September 30.
High-Priority Program Program identified as susceptible to significant improper payments.
Any payment that should not have been made or that was made in an
incorrect amount under statutory, contractual, administrative, or other
Improper Payment
legally applicable requirements (including both overpayments and
underpayments).
Improper Payment Rate Amount in improper payments divided by the amount in program outlays.
The IRS database that maintains transactions or records of individual tax
Individual Master File
accounts.
When the PTC exceeds the APTC (PTC minus APTC = Net PTC). Net PTC
Net Premium Tax Credit reduces a taxpayer’s tax liability and, if it is more than the tax liability,
results in a refundable tax credit.
A payment to liquidate an obligation generally equal to cash
Outlay
disbursements (the measure of Government spending).
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
Term Definition
A payment in excess of what is due. When an overpayment occurs, the
Overpayment improper amount is the difference between the amount due and the
amount that was actually paid. Overpayments are monetary loss IPs.
Any disbursement or transfer of Federal funds to any non-Federal person,
non-Federal entity, or Federal employee that is made by a Federal agency,
Payment
contractor, grantee, or a governmental or other organization administering
a Federal program or activity.
Refundable tax credit that helps eligible individuals and families cover the
Premium Tax Credit (PTC) premiums for their health insurance purchased through the Health
Insurance Marketplace.
The calendar year in which the tax return or document is processed by the
Processing Year
IRS.
Activities or sets of activities recognized as programs by the public, OMB,
Program or Congress as well as those that entail program management or policy
direction.
A technique used to quantify risk associated with IPs and UPs. For
example, a qualitative IP risk assessment methodology prioritizes the
Qualitative Risk
identified IP and UP risks using a predefined rating scale. Risks will be
Assessment
scored based on their probability or likelihood of occurring and the impact
on IPs and UPs in the program should they occur.
Quantitative Risk A review of a sample of disbursements to formulate the overall estimated
Assessment improper payment rate for the program.
Annual IPs and UPs (i.e., the sum of monetary loss IPs, non–monetary loss
IPs, and UPs) in the program exceeding (1) both 1.5 percent of program
Significant Improper
outlays and $10,000,000 of all program or activity payments made during
Payment
the fiscal year reported or (2) $100,000,000 (regardless of the IP percentage
of total program outlays).
The Tax Gap is the estimated difference between the amount of tax that
Tax Gap
taxpayers should pay and the amount that is paid voluntarily and on time.
A 12-month accounting period for keeping records on income and
Tax Year expenses used as the basis for calculating the annual taxes due. For most
individual taxpayers, the tax year is synonymous with the calendar year.
A payment that is less than what is due. When an underpayment occurs,
the improper amount is the difference between the amount due and the
Underpayment
amount that was actually paid. An underpayment is a non–monetary loss
IP.
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Programs Susceptible to Improper Payments Are Not Adequately Assessed and Reported
Appendix VI
Abbreviations
ACTC Additional Child Tax Credit
AFR Agency Financial Report
AOTC American Opportunity Tax Credit
APTC Advanced Premium Tax Credit
COVID-19 Coronavirus Disease 2019
EIP Economic Impact Payment
EITC Earned Income Tax Credit
FY Fiscal Year
IP Improper Payment
IRS Internal Revenue Service
OMB Office of Management and Budget
PIIA Payment Integrity Information Act
PTC Premium Tax Credit
SE Self-Employment
SSA Social Security Administration
TIGTA Treasury Inspector General for Tax Administration
UP Unknown Payment
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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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