Treasury Inspector General for Tax Administration 2024-300-008 (Post-Pandemic Actions Have Contributed to Declines in Automated Collection System Level of Service and Collection)
Summary
Final Audit Report 2024-300-008 of the Treasury Inspector General for Tax Administration, issued December 20, 2023, evaluates IRS actions to improve Automated Collection System (ACS) call sites' business results and level of service in light of the Coronavirus Disease 2019 pandemic, and reviews ACS Support's business results and operations. The report states that from FY 2018 to FY 2022, ACS calls answered per full-time equivalent dropped by 35 percent, and that scheduled ACS inventory workdays were suspended in March 2022. It states that call site FTEs increased by 48 percent from FY 2019 to FY 2022 while balance due and delinquent return dispositions generally declined. TIGTA made four recommendations, and the IRS agreed to all four.
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TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION
Post-Pandemic Actions Have Contributed to Declines
in Automated Collection System Level of Service
and Collection Inventories
December 20, 2023
Report Number: 2024-300-008
TIGTACommunications@tigta.treas.gov | www.tigta.gov 1
HIGHLIGHTS: Post-Pandemic Actions Have Contributed to Declines in
Automated Collection System Level of Service and Collection Inventories
Final Audit Report issued on December 20, 2023 Report Number 2024-300-008
Why TIGTA Did This Audit What TIGTA Found
This audit was initiated to evaluate ACS management actions such as pausing collection notices and
the effectiveness of the IRS’s suspensions of call site inventory workdays, as well as staffing
actions to improve Automated challenges, have impacted ACS and ACS Support business metrics
Collection System (ACS) call sites’ and overall production. In addition, virtual training and maximizing
business results and level of service telework in response to the Pandemic also may have contributed to
(LOS), including the current status declines in productivity.
of performance in light of the
ACS Support’s closures per full-time equivalent (FTE) decreased
Coronavirus Disease 2019
significantly from pre-Pandemic Fiscal Years (FY) 2018 and 2019 to
pandemic (hereafter referred to as
subsequent FYs 2020 through 2022. TIGTA also found declining
the Pandemic). ACS sites consist
trends in LOS call metrics.
primarily of employees who
answer telephone calls from
taxpayers who have received
collection notices from the IRS.
ACS Support is comprised of
employees who assist in the
ongoing operations, such as
incoming correspondence at ACS
sites. TIGTA also reviewed ACS
Support’s business results and From FY 2018 to FY 2022, ACS calls answered per FTE dropped by
operations. 35 percent, i.e., 885 fewer ACS calls answered per FTE.
When taxpayers do not respond to In March 2022, scheduled ACS inventory workdays were suspended.
collection notices requesting Inventories consist of cases that need processing outside of incoming
payment of delinquent taxes or to telephone work. While call site FTEs increased by 48 percent from
file a delinquent return, they may FY 2019 (pre-Pandemic) to FY 2022, there was a general decline in
be assigned to the ACS in an balance due and delinquent return dispositions, which does not
attempt to satisfy their tax liability support the continued suspension.
or address their return
delinquency. Inconsistencies in ACS Support managers’ interpretation and
definition of “portable work,” i.e., tasks capable of being worked by
Impact on Tax Administration employees in a telework environment, led to inefficiencies. Two of
The ACS is a critical part of the the five ACS Support sites incorporated an additional step in their
IRS’s overall Collection program work processes to allow tax examiners to telework, while the
and plays a vital role in securing remaining three sites based telework decisions on the availability of
and protecting the revenue of the portable work.
United States. Telework studies were performed in which some ACS collection
representatives participated, but ACS Support employees were not
included. Further, taxpayer customer satisfaction was not taken into
consideration in these studies.
What TIGTA Recommended
TIGTA made four recommendations to help the IRS address the
impact of the Pandemic on ACS and ACS Support business metrics
and overall production.
The IRS agreed to all four recommendations and plans to take
corrective actions.
U.S. DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20024
TREASURY INSPECTOR GENERAL
FOR TAX ADMINISTRATION
December 20, 2023
MEMORANDUM FOR: COMMISSIONER OF INTERNAL REVENUE
FROM: Matthew A. Weir
Acting Deputy Inspector General for Audit
SUBJECT: Final Audit Report – Post-Pandemic Actions Have Contributed to
Declines in Automated Collection System Level of Service and Collection
Inventories (Audit # 202230011)
This report presents the results of our review to evaluate the effectiveness of the Internal
Revenue Service’s (IRS) actions to improve Automated Collection System (ACS) call sites’
business results and level of service, including the current status of performance in the light of
the Coronavirus Disease 2019 pandemic. We also reviewed ACS Support’s business results and
operations. This review was part of our Fiscal Year 2022 Annual Audit Plan and addresses the
major management and performance challenges of Improving Customer Service and the
Taxpayer Experience and Improving Tax Reporting and Payment Compliance to Reduce the Tax
Gap.
Management’s complete response to the draft report is included as Appendix II. If you have any
questions, please contact me or Phyllis Heald London, Acting Assistant Inspector General for
Audit (Compliance and Enforcement Operations).
Post-Pandemic Actions Have Contributed to Declines in
Automated Collection System Level of Service and Collection Inventories
Table of Contents
Background .....................................................................................................................................Page 1
Results of Review .......................................................................................................................Page 4
Multiple Management Actions Such As Pausing Collection
Notices and Transitioning Employees to Telework May Have
Impacted Business Metrics and Overall Production ...............................................Page 4
Recommendations 1 through 4:..............................................Page 20
Appendices
Appendix I – Detailed Objectives, Scope, and Methodology ..............................Page 21
Appendix II – Management’s Response to the Draft Report...............................Page 23
Appendix III – Glossary of Terms....................................................................................Page 27
Appendix IV – Abbreviations ...........................................................................................Page.28
Post-Pandemic Actions Have Contributed to Declines in
Automated Collection System Level of Service and Collection Inventories
Background
The Automated Collection System (ACS) is a critical part of the Internal Revenue Service’s (IRS)
overall Collection program and plays an important role in securing and protecting the revenue
of the United States. As of Fiscal
Year (FY) 2022, the ACS is second
only to the collection notice stream
in terms of revenue collected on
delinquent taxpayer accounts. 1
The first step in the collection
process involves mailing taxpayers
a series of systemic notices
(referred to as the notice stream)
asking for payment of delinquent
taxes or to file a delinquent return, if required. When taxpayers do not respond to these
delinquency notices, they may then be assigned to the ACS in an attempt to satisfy their
outstanding tax liability or address their return delinquency.
The ACS is organizationally placed under the IRS Small Business/Self-Employed Division’s
Collection operation. Collection representatives in the ACS assist taxpayers, mainly through a
taxpayer-initiated, telephone-based operation, in resolving delinquent balance dues or unfiled
tax returns (known as Taxpayer Delinquent Accounts (TDA) or Taxpayer Delinquency
Investigations (TDI), respectively). In addition to telephone assistance, collection representatives
work ACS inventory that require actions, such as sending the taxpayer a letter requesting a
delinquent return or following up on requested documentation. ACS Support tax examiners and
clerks assist ACS call sites through processing of incoming ACS-related correspondence. There
are 19 ACS call sites and five ACS Support sites around the country.
As a result of the Coronavirus Disease 2019 (COVID-19) pandemic (hereafter referred to as the
Pandemic), the Office of Management and Budget (OMB) issued an evacuation notice on
March 17, 2020, declaring that the Government must immediately adjust operations and services
to minimize face-to-face interactions. The OMB directed agency heads to review, modify, and
implement risk-based policies and procedures to safeguard the health and safety of Federal
workplaces to restrict the transmission of COVID-19. This included factors such as maximizing
telework across the Federal workforce (including mandatory telework, if necessary) while
maintaining mission-critical workforce needs.
Prior to the Pandemic, the ACS and ACS Support generally did not allow employees to telework.
However, due to the OMB’s evacuation notice, the IRS issued its own directive to work from
home with an original expiration date of September 26, 2020. As a result, ACS management
issued equipment such as laptops, Ethernet cords, extra monitors, and headsets to collection
representatives so that they could transition to answering incoming taxpayer telephone calls
1
In the IRS “notice stream,” taxpayers with delinquent liabilities or returns are generally issued a series of two to four
notices. Cases not resolved during the notice stream may be transferred to the ACS where an appropriate ACS letter
may be issued six to 10 weeks after the fourth notice.
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Post-Pandemic Actions Have Contributed to Declines in
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from home. Pursuant to additional guidance, the IRS extended its original evacuation orders to
March 26, 2021. This extension allowed the IRS to mandate telework for those with portable
work. 2 The IRS telework mandate included employees with or without current telework
agreements as well as those with Telework Enhancement Act of 2010 misconduct violations. 3
The IRS subsequently executed two additional evacuation orders through September 23, 2021,
and March 23, 2022, respectively.
Finally, on March 23, 2022, the IRS Human Capital Office (HCO) notified all employees of the
plan to return all personnel to the physical workplace by providing a Return to Office framework,
which identified three return to office phases, the groups of employees impacted by each phase,
and the anticipated return timelines for each group, to allow for fully resuming normal
operations by the week of June 25, 2022. Within the HCO communication, IRS management and
employees were provided a Return to Office Playbook to assist them with how to reopen the
19 ACS call sites, including all five ACS Support sites. 4
Pause in collection actions
On March 25, 2020, the IRS announced the People First Initiative with the issuance of IRS News
Release IR-2020-59. 5 The goal of the People First Initiative was to temporarily adjust and
suspend key compliance programs to help people facing the challenges of the Pandemic, which
included halting collection notices and enforcement actions, e.g., levies and liens, for the period
starting April 1, 2020, through July 15, 2020. In response to the People First Initiative, the IRS
issued several Servicewide Electronic Research Program guidance announcements to stop the
collection notice stream and enforcement actions. 6 The IRS’s suspension of enforcement actions
impacted all levy and lien issuances in the ACS function.
The IRS is required to issue certain statutory notices. For example, Internal Revenue Code
(I.R.C.) § 6303 requires the IRS to issue a notice and demand for tax within 60 calendar days after
making a tax assessment, when the taxpayer has a balance due. I.R.C. § 7524 requires the IRS to
issue an annual written notice to each taxpayer of their continued tax delinquency on balance
due accounts, and Treasury Regulations require notices be issued to taxpayers when proposed
installments are rejected and existing installment agreements are terminated or modified. 7 After
the start of the Pandemic, the IRS had numerous suspensions of notice and enforcement
activities, as shown in Figure 1.
2
Portable work is defined as work that can be: 1) accomplished effectively outside of the traditional office/team
setting and 2) accomplished independently of other co-workers, support staff, and/or the employee’s supervisor
without any adverse impact on individual/team or overall office productivity or customer service impact.
3
5 U.S.C. § 6501, et seq. (2018).
4
The Return to Office Playbook was a collaboration with the Senior Commissioner's Representative – Continuity of
Operations and the IRS’s Operations Support partners.
5
IRS, News Release IR-2020-59, IRS unveils new People First Initiative; COVID-19 effort temporarily adjusts, suspends
key compliance program (March 25, 2020).
6
The People First Initiative provided taxpayers relief from compliance actions pertaining to the following: installment
agreements; offers in compromise; liens; levies; seizures; passport certifications to the State Department; private debt
collection; and field, office, and correspondence audits.
7
Treas. Reg. § 301.6159-1(d)(1) and (e)(4).
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Post-Pandemic Actions Have Contributed to Declines in
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Figure 1: IRS Notice and Enforcement
Suspensions Occurring After Start of the Pandemic
Enforcement Activity Paused Date Enforcement Activity Resumed
2020
ACS related levies (including Automated March
Levy Programs), liens, and TDI
creation suspended. 8
All notices suspended, including April
statutory notices.
June Statutory notices resumed.
October TDI creation and manual liens resumed.
November Notice stream resumed.
2021
January ACS manual levies resumed. 9
TDI creation suspended. February
July Automated Levy Programs resumed.
August ACS systemic levies and systemic
liens resumed. 10
October TDI creation resumed.
Moratorium issued on ACS manual and December Manual levies resumed by end of
systemic levies. December 2021.
2022
ACS manual and systemic levies and the January Systemic levies resumed (for five calendar
Automated Levy Programs were days).
paused again.
Systemic liens and TDI creation were January
also suspended.
Non-statutory notices in the notice February Statutory notices continue to be issued.
stream suspended.
Source: Servicewide Electronic Research Program communications and IRS management confirmation of
continued suspended activities as of May 2023.
These suspensions mainly took place as a result of the IRS correspondence backlogs. For
example, if a taxpayer’s return, payment, or correspondence was part of the backlog and not yet
8
See Appendix II for a glossary of terms.
9
A manual levy is a paper levy that is manually prepared and mailed by an ACS employee, Internal Revenue Manual
(IRM) 5.19.4.1.6(2)a. (Mar. 25, 2022).
10
Systemic levies are generated in the ACS by the ACS systemic levy program, IRM 5.19.4.1.6(2)(c) (Mar. 25, 2022).
Similar to systemic levies, the ACS also generates systemic liens through the Automated Lien System.
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Post-Pandemic Actions Have Contributed to Declines in
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processed, the pause would prevent the taxpayer from receiving erroneous notices. As of
July 13, 2023, the suspension of balance due progression status notices (except those required
by law) remains in place. The suspension of delinquency notices has also paused lien and levy
issuances over several periods, impacting the work performed by the ACS and ACS Support
because some enforcement actions would be incomplete without the issuance of certain
suspended letters/notices. 11 In addition, requiring maximum telework from March 17, 2020,
through June 25, 2022, has potentially impacted the ACS and ACS Support in numerous ways.
This review attempts to evaluate the impact of the IRS’s reactions to the Pandemic and
subsequent events on the ACS’s Level of Service (LOS) and business results as well as ACS
Support operations.
Results of Review
Multiple Management Actions Such As Pausing Collection Notices and
Transitioning Employees to Telework May Have Impacted Business Metrics
and Overall Production
ACS and ACS Support business metrics and overall production have generally not recovered to
pre-Pandemic levels. A number of factors may have impacted the IRS’s ability to improve
performance, including:
• Suspension of collection notices and difficulties assigning work.
• Staffing challenges and high balance due call volumes.
• Suspension of ACS inventory workdays for call sites and assistance with surge efforts.
• Virtual training.
• Expanded use of telework.
In April 2023, the OMB issued guidance to agencies on measuring, monitoring, and improving
organizational health and organizational performance in the context of evolving agency work
environments.12 The guidance stresses the importance of establishing assessments of both
organizational health and performance to evaluate the impact (both positive and negative) that
the work environment (including telework) has on the agency’s performance of its mission. On
August 4, 2023, the IRS provided the OMB its draft Post-Reentry Workforce Environment Plan.
IRS management’s plan does not address how the adverse or beneficial impacts of telework will
be identified but indicates that management will continue their efforts for a Telework and
Productivity Report Project plan to explore avenues to enhance telework, organizational health,
11
For example, generally a levy cannot be issued unless the taxpayer first receives a Collection Due Process notice.
I.R.C. § 6330 allows taxpayers the right to a Collection Due Process hearing before the issuance of the first levy on a
delinquent module, and I.R.C. § 6320 allows taxpayers to elect a Collection Due Process hearing after the filing of the
first Notice of Federal Tax Lien on a delinquent module where taxpayers can raise various issues including collection
alternatives.
12
OMB, Memorandum M-23-15, Measuring, Monitoring, and Improving Organizational Health and Organizational
Performance in the Context of Evolving Agency Work Environments (Apr. 13, 2023).
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Post-Pandemic Actions Have Contributed to Declines in
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and organizational performance measures. Further, the IRS is responsible for establishing a
comprehensive approach for measuring and evaluating customer satisfaction, employee
satisfaction, and business results. 13 However, in reviewing the telework studies in which ACS call
site employees participated, the Treasury Inspector for Tax Administration (TIGTA) found that
they did not include any customer satisfaction measures to address the level of overall
satisfaction as perceived by external customers. Moreover, ACS Support employees were
excluded from these telework studies.
Suspension of collection notices and difficulties assigning work has impacted ACS
Support inventory and productivity
From the start of the Pandemic in FY 2020 through FY 2022, we identified a decreasing trend in
ACS Support’s inventories influenced by the periodic suspension of collection notices (shown in
Figure 1). Figure 2 details ACS Support inventory levels from FY 2018 to FY 2022 for the
function’s three inventory categories: Collection Information Statement (CIS), TDA, and TDI
inventories. 14
13
IRM 1.5.1.1.3(1) (June 30, 2023).
14
Form 433-F, Collection Information Statement, is used to obtain current financial information necessary to
determine how a wage earner or self-employed individual can satisfy an outstanding tax liability.
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Figure 2: ACS Support Inventory Metrics for FYs 2018 Through 2022
FY
% change 2018
2018 2019 2020 2021 2022
Productivity to 2022
CIS Inventory
Receipts 40,007 40,414 23,314 22,703 26,881 (33%)
Closures 38,521 40,778 21,834 26,452 26,560 (31%)
Ending Inventory 4,910 4,546 6,026 2,277 1,787 (64%)
Balance Due (TDA) Inventory
Receipts 296,909 282,572 181,273 194,375 203,167 (32%)
Closures 277,111 285,847 157,769 224,258 198,834 (28%)
Ending Inventory 22,551 18,113 41,617 12,238 12,675 (44%)
Delinquent Return (TDI) Inventory
Receipts 84,445 84,397 58,321 103,910 92,178 9%
Closures 83,666 84,059 57,040 104,226 91,827 10%
Ending Inventory 598 821 2,102 1,786 1,371 129%
Total ACS Support Receipts 421,361 407,383 262,908 320,988 322,226 (24%)
Total ACS Support Closures 399,298 410,684 236,643 354,936 317,221 (21%)
Total ACS Support Ending
28,059 23,480 49,745 16,301 15,833 (44%)
Inventories
Source: ACS Monthly Assessment of Performance Reports and Monthly Monitoring Reports for FYs 2018
through 2021.
When comparing FY 2022 to pre–Pandemic FY 2018, total ACS Support inventory receipts
(correspondence) decreased for FY 2022 by 24 percent and closures decreased by 21 percent.
The primary inventories contributing to this decrease were CIS and TDA inventories. Collection
management cited the suspension of Collection enforcement programs (shown in Figure 1) as a
reason for low inventory levels. For example, the normal progression of cases into ACS
inventory is halted while collection notices are suspended. Similarly, this impacts the number of
cases that ACS Support has to work.
We also analyzed two measures of productivity for ACS Support: closures per full-time
equivalent (FTE) and response time as reflected by the over-age inventories shown in Figure 3.15
15
ACS Support has two measures of over-age based on the received date of the TDA/TDI/CIS correspondence: IRS
received date and site received date. The IRS received date is the date the taxpayer correspondence was first received
by the IRS, and the site received date is the date when the taxpayer correspondence is received by ACS Support.
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Post-Pandemic Actions Have Contributed to Declines in
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Figure 3: ACS Support Productivity by FTE and Over-Age Inventory
Over-Age Inventory FY 2018 FY 2019 FY 2020 FY 2021 FY 2022
ACS Support FTEs 532 499 503 603 560
Closures per FTE 751 822 471 588 566
Inventory over-age percentage based on IRS received date
CIS Inquiries
34% 36% 92% 48% 55%
> 60 Calendar Days
TDA Inquiries
24% 61% 96% 47% 66%
> 45 Calendar Days
TDI Inquiries
49% 24% 83% 59% 14%
> 30 Calendar Days
Inventory over-age percentage based on ACS received date
CIS Inquiries
7% 17% 74% 28% 28%
> 60 Calendar Days
TDA Inquiries
9% 15% 76% 11% 20%
> 45 Calendar Days
TDI Inquiries
27% 5% 65% 32% 3%
> 30 Calendar Days
Source: ACS Monthly Monitoring Reports for FYs 2018 through 2022.
We identified that closures per FTE decreased significantly from FYs 2018 to 2022 (from 751 to
566) and found significant reductions when comparing pre-Pandemic FYs 2018 and 2019 to
subsequent fiscal years. During this five-fiscal year period, ACS Support increased its FTEs by
5 percent. However, despite the increase in the FTEs, productivity has not recovered to
pre-Pandemic levels.
ACS Support management stated that the ability to assign work to its employees was one of the
challenges associated with having low inventory levels. As a result, ACS Support had to find
other ways to keep its employees productive. For example, a Support site can request inventory
from other ACS Support sites, referred to as “transshipped cases,” as a means to backfill its low
inventory levels. In addition, ACS Support has been approved to assist ACS call sites with their
pending installment agreement and independent review inventories.
We also found that cases in ACS Support inventory are aging. The goal of ACS Support is to
support ACS call sites by ensuring that related correspondence is processed in a timely manner.
IRS management stated that each inventory category has its own over-age metrics, as reflected
in Figure 3. ACS Support documents over-age cases when both the IRS received date and site
received date of CIS inquiry cases exceed 60 calendar days, when TDA cases exceed 45 calendar
days, and when TDI cases exceed 30 calendar days from the ACS Support received date.
Figure 3 highlights the following trends from the IRS received date from FYs 2021 to 2022:
• CIS over-age inventory increased by approximately 7 percent.
• TDA (balance due) over-age inventory increased significantly by approximately
19 percent.
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Post-Pandemic Actions Have Contributed to Declines in
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The significant increases during FY 2022 (from the IRS received date), reflect that the majority of
CIS and balance due inquiries were not worked timely. When reviewing over-age trends from
the ACS received date, we similarly found that in FY 2022, CIS and balance due inquires over-age
inventories continue to exceed pre-Pandemic over-age levels when compared to FY 2018 or
FY 2019. Moreover, while the overall ACS Support FTEs increased from FY 2018 to FY 2022, the
response time for addressing both over-age CIS and balance due inventories generally
increased.
ACS Support management speculates that the over-age issues may be a result of the decreasing
inventories. Specifically, management stated that as inventory levels go down, a greater number
of older cases remain that have not closed for one reason or another, creating a higher
proportion of older cases. Management added that ACS Support’s participation in surge efforts
(to assist with backlogs of returns) may be another contributing factor to the over-age issues.
However, ACS Support’s participation in surge efforts did not start until February 28, 2022, and
does not address the decline in closures per FTE productivity as shown in Figure 3. 16
Staffing challenges and high balance due call volumes may have contributed to the
declines in ACS LOS
Our review of ACS call site LOS showed a significant decline from 53 percent in FY 2018 to
35 percent in FY 2022 (see Figure 4). Specifically, since FY 2020, the LOS in FYs 2021 and 2022
has steadily decreased. The ACS’s primary measure of telephone effectiveness is the LOS, which
is generally calculated by dividing the ACS calls answered by the ACS call demand. The purpose
of this measure is to determine the relative success rate of taxpayers who call for ACS services
seeking assistance from a collection representative. Not all taxpayer call attempts are included
in the calculation of the LOS, as it only includes the relative success rate.
The Joint Operations Center is responsible for creating the call handling schedules for each ACS
call site, in addition to supporting other Small Business/Self-Employed Division and Wage and
Investment Division campus programs. The number of ACS taxpayer calls that can be answered
is dependent on the number of available employees at all ACS call sites and average time spent
assisting the taxpayer, which may also take into consideration the mix (type and volume) of
expected calls based on issued notices. Therefore, not all calls are answered because the ACS
does not have the resources.
Figure 4 reflects the overall call performance statistics for the ACS call sites for FYs 2018 through
2022.
16
ACS Support has assisted with five surge efforts. As of July 2023, one of the five surge efforts remains open with a
projected end date of September 23, 2023. ACS Support assigned an average of 16 FTEs per surge effort, ranging
from five to 30 FTEs.
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Figure 4: ACS Toll-Free Telephone
Performance Statistics for FYs 2018 Through 2022
FY
2018 2019 2020 2021 2022
ACS LOS Target 29% 30% 31% 48% 36%
ACS Actual LOS 53% 34% 40% 38% 35%
ACS Net Incoming Taxpayer
12,073,311 15,033,568 11,995,745 16,123,431 15,070,959
Call Attempts 17
ACS Calls Answered 5,924,227 4,663,706 4,206,875 5,653,432 5,005,247
ACS Calls Answered/ACS Net
49% 31% 35% 35% 33%
Call Attempts
ACS FTEs 2,338 2,057 2,687 3,186 3,036
ACS Calls Answered per FTE 2,534 2,267 1,566 1,774 1,649
ACS Average Speed of
24 38 24 28 38
Answer (Minutes)
ACS Average Handle Time
18 22 20 19 18
(Minutes)
Source: Joint Operations Center’s Enterprise Telephone Database Reporting Website and Monthly
Monitoring Reports for FYs 2018 through 2022.
Figure 4 compares ACS LOS established targets for FYs 2018 through 2022 against the achieved
ACS LOS for the same fiscal years. The ACS LOS target is based on the anticipated resources
and a variety of assumptions applicable to a particular fiscal year, e.g., FTEs, whether there will
be scheduled inventory days, hiring, overtime, notice pauses, and handling calls from other
business units. The ACS LOS target was met in FYs 2018 through 2020. However, the ACS fell
short of its target in FYs 2021 and 2022 with achieved LOS of 38 percent and 35 percent
respectively.
We also identified declining trends in other related LOS call metrics, as shown in Figure 4, such
as a decrease in calls answered per FTE and an increase in average speed of answer as follows:
• Average Calls Answered per FTE. In comparison to FY 2018 and FY 2019, ACS FTEs were
greater in FYs 2020 through 2022. Despite ACS FTEs increasing by 30 percent (2,338 to
3,036) from FY 2018 to FY 2022, ACS calls answered per FTE dropped by 35 percent
(2,534 to 1,649) for the same period, or 885 fewer ACS calls answered per FTE.
• Average Speed of Answer. The average speed of answer is the average length of time
callers wait on hold before connecting to a collection representative. The average speed
of answer increased by 14 minutes from FY 2018 to FY 2019, then declined by
14 minutes in FY 2020, but increased back to a 38-minute hold time in FY 2022.
17
The call attempts listed reflect the total number of incoming callers intended for ACS product lines and include
incomplete, disconnected, or abandoned calls. However, they exclude calls entering the ACS Conversation Interactive
Voice Response authenticated voice bot that was deployed in July 2022.
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Therefore, during FY 2022, taxpayers calling in were on hold an average of 38 minutes
before connecting to an ACS collection representative.
• Average Handle Time. The average handle time is the average time collection
representatives spend assisting taxpayers. Since FY 2019, this metric improved with
FY 2022 having the same average handle time as FY 2018 of approximately 18 minutes.
Management cited that the reason for not reaching the 48 percent LOS target in FY 2021 was
largely due to the increase in phone calls received, most of which were balance due. Figure 4
shows a significant increase in ACS Net Incoming Taxpayer Call Attempts from FY 2020 to
FY 2021, which coincides with the realignment between the Accounts Management (AM) and
ACS, where balance due calls were transitioned to be answered fully by the ACS over a five-year
period, from FY 2017 through FY 2021. However, ACS Net Incoming Taxpayer Call Attempts
decreased from FY 2021 to FY 2022 by more than 1 million net attempts to levels that are
consistent with those seen pre-Pandemic in FY 2019, and despite fewer incoming net call
attempts, ACS calls answered per FTE decreased from FY 2021 (1,774) to FY 2022 (1,649).
ACS management also stated that they look to maximize the LOS while balancing other business
needs. Although not included in the LOS calculation, some actions they have taken to enhance
the LOS are through online tools and include:
• Redesigning certain ACS notices and adding Quick Response Codes to provide taxpayers
with quicker access to online information.
• Developing ACS text chat, chat bots, and voice bots to provide general assistance to
taxpayers through use of online services and self-help options in lieu of the taxpayer
calling into the ACS toll-free telephone line.
• Adding a customer callback feature to provide taxpayers the option to keep their place
in the queue and receive a callback rather than continuing to wait on hold.
However, given the concerns we identified with call site performance statistics, ACS
management should continually monitor available ACS metrics to ensure that taxpayers are
receiving their right to quality service, while working to increase both their targeted and
achieved LOS.
Issues with hiring, staffing, and attrition may contribute to lower LOS
Our review of ACS hiring, staffing, and attrition in Figure 5 shows that beginning with the start of
the Pandemic in FY 2020, overall attrition of ACS call site employees has continued to increase
significantly through FY 2022.
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Figure 5: ACS Non-Management Staffing,
Hiring, and Attrition for FYs 2018 Through 2022
FY 2018 FY 2019 FY 2020 FY 2021 FY 2022
ACS Hiring Plan Goal 18 N/A 661 1,346 835 2,033 19
New ACS Employees (new to the
70 269 1,050 402 1,181
IRS)
New ACS Employees (internal
328 292 329 256 134
transfers)
Total ACS New Employees 398 561 1,379 658 1,315
ACS New Hires Goal
(100) 33 (177) (718)
Over-Age/(Shortfall)
Ending ACS Employee Balance 2,131 2,149 2,827 2,527 2,618
ACS New Employees/Total
19% 26% 49% 26% 50%
Employees
Total Attrition 243 312 572 728 946
ACS Attrition (IRS Separations
144 123 146 167 249
>5 years after the hire date)
ACS Attrition (internal transfers) 87 172 184 226 215
ACS Attrition (IRS Separations
12 17 242 335 482
within 5 years of hire date)
New Hires Over/(Under) Total
155 249 807 (70) 369
Attrition
Source: TIGTA analysis of ACS and ACS Support staffing, hiring, and attrition data, and hiring plan goals.
High attrition combined with an influx of new hires has resulted in a 50/50 ratio of new
employees to seasoned employees at the end of FY 2022. Developing new call site employees
to become proficient takes time. They must be trained properly and need experienced
employees to coach and monitor them on the job, which may reduce the number of calls
experienced employees (who are coaching new employees) can answer, thereby potentially
impacting call site LOS.
In FYs 2021 and 2022, the IRS had been unable to meet its ACS employee hiring plan goals.
Management stated that the reason for not meeting the hiring plan goal is a result of the IRS’
HCO only being given a specific number of Small Business/Self-Employed Division priority
allocations for each quarter. The ACS was limited to what was allocated to its operating unit and
unable to announce positions to fill its needs.
ACS management increased the number of employee vacancies in FYs 2020 through 2022 in
comparison to pre-Pandemic FY 2019. For example, Figure 5 shows the ACS new hiring plan
18
No hiring plan was available for FY 2018. Also, for FY 2019, ACS hiring plan goal includes ACS Support and
employees that work Collection Due Process cases who were unable to be identified and removed from ACS counts.
19
FY 2022 hiring is not complete. Report pulled as of February 13, 2023.
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goal increased more than 200 percent in FY 2022 (2,033) over FY 2019 (661). Although the
ACS’s new hiring goal for the last three fiscal years exceeds pre-Pandemic levels, the IRS has
fallen short of its goal for two of the three fiscal years, with FY 2022 having the highest shortfall
from meeting its hiring goal, achieving only 65 percent (1,315) of its targeted goal (2,033).
Supporting and training an inexperienced workforce places an additional burden thereby
impeding the ACS’s ability to improve its LOS. Considering all related issues surrounding such a
high proportion of an inexperienced workforce, the IRS HCO should collaborate with the ACS to
analyze the issues surrounding failing to meet hiring plan goals and attrition issues to promote
employee retention; otherwise, they risk not having adequate staffing to address taxpayer
needs.
Suspension of quarterly ACS inventory workdays for call sites and assistance with surge
efforts may result in uncollected balance dues or continued return delinquencies
From October 2021 through March 2022, management directed ACS collection representatives
to work inventory (casework outside of their regular telephone duties) once per quarter. As of
March 17, 2022, the IRS paused their quarterly inventory day policy due to resource issues.
Management stated that continued high call demand and assistance with surge efforts of
backlogged inventory due to the Pandemic were the reasons for this change in policy. While
ACS collection representatives no longer have any scheduled time to work inventory outside of
answering incoming calls, they will work this inventory when time permits, e.g., if their shift ends
after the telephone lines go down for the day. However, working this inventory at least one day
per quarter assured that some level of inventory management was performed.
ACS collection representatives’ work generally falls into two major categories: immediate,
i.e., customers calling in, and delayed, i.e., inventory processing or cases that need processing
outside of the incoming telephone work. Specifically:
• Cases in the immediate category have the same priority for selection.
• Cases in the delayed category consist of call site inventories (such as following up when
a taxpayer fails to send in requested correspondence or sending a notice requesting a
delinquent return) that need to be processed by ACS collection representatives. 20 These
cases have a priority scheme based on a combination of factors, such as case priority,
current organizational program needs, risk categories, and available staff to work the
inventory.
One of the issues impacting available resources provided by management for stopping
inventory workdays, was the temporary realignment of ACS staff to support working through the
IRS inventory backlogs. An example of these backlogs included assisting with unprocessed
paper tax return backlogs accumulated during the Pandemic outside of the ACS. The IRS
referred to these temporary transfers as “surge” efforts. We learned that there have been three
surge teams impacting the ACS, including:
• AM Surge: February 28, 2022 – December 31, 2022.
• Submission Processing Surge: March 28, 2022 – December 31, 2022.
20
As of September 2020, this inventory is defined as “ACS Function Units” and has a total of 12 subcategories.
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• ACS to AM Telephones Surge: January 30, 2023 – April 21, 2023.
On average, 136 ACS FTEs were reassigned to support these three surge efforts for over a year’s
time frame, from February 2022 through April 2023, as shown in Figure 6.
Figure 6: ACS FTEs Diverted to Surge Efforts
ACS to Submission ACS to AM
ACS to AM Surge
Processing Surge Telephone Surge
February 28, 2022, to March 28, 2022, to January 30, 2023,
December 31, 2022 December 31, 2022 to April 21, 2023
Total FY 2022 ACS FTEs 21 3,036 3,036 3,036
Reassigned ACS FTEs to
158 124 126
Surge Efforts
Percentage of ACS FTEs
5% 4% 4%
Assisting Surge Efforts
Potential Revenues Delayed
$401,134,956 $315,244,588 $318,709,788
or Lost 22
Potential Dispositions
70,809 55,647 56,259
Delayed or Lost 23
Source: TIGTA analysis of AM and Submission Processing Surge Efforts impact and ACS Monthly
Assessment of Performance Reports and Monthly Monitoring Reports for FYs 2018 through 2022.
While we understand the IRS’s decision to temporarily transfer ACS staff to support addressing
inventory backlogs, it is important to acknowledge that this decision may have resulted in over
$1 billion in potential revenues that were delayed or lost, as shown in Figure 6.
We also reviewed the general ACS dispositions and ending inventories to determine whether
there were any trends supporting the continued suspension of ACS call site inventories
(hereafter referred to as manual inventories). As shown in Figure 7, we found a general decline
in ACS TDA and TDI case dispositions and ending inventories for FYs 2018 through 2022.
21
FY 2022 FTEs are being used as FY 2023 FTEs are unavailable.
22
Potential Revenues Lost was calculated by allocating the percentage of ACS FTEs to the overall IRS estimated
potentially lost revenues for the ACS to AM surge and the ACS to Submission Processing Surge. No allocation was
required for the ACS to AM telephones surge as ACS employees represented all allocated FTEs for this surge effort.
IRS management described these revenues as “estimated delayed revenue;” however, we do not agree with their
description as there is no guarantee that the revenue will be realized and, therefore, we believe these to be more
accurately described as potentially delayed or lost revenues.
23
Potential Dispositions Lost were calculated by allocating the percentage of ACS FTEs to the overall IRS estimated
potentially lost dispositions for the ACS to AM surge and the ACS to Submission Processing Surge. No allocation was
required for the ACS to AM telephones surge as ACS employees represented all allocated FTEs for this surge effort.
IRS management described these dispositions as “estimated delayed dispositions;” however, we do not agree with
their description as there is no guarantee that the dispositions will be realized and, therefore, we believe these to be
more accurately described as potentially delayed or lost dispositions.
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Figure 7: ACS TDA and TDI Module Dispositions and Ending Inventories
FY 2018 FY 2019 FY 2020 FY 2021 FY 2022
Inventory
TDA Module Dispositions 3,895,215 3,972,918 2,913,329 2,623,733 2,777,104
TDA Modules in Ending Inventory 9,193,359 6,731,823 4,603,272 6,839,368 6,653,253
TDI Module Dispositions 263,455 513,538 589,153 512,739 280,121
TDI Modules in Ending Inventory 1,244,579 1,635,709 1,788,077 1,227,075 1,111,558
Source: Monthly Monitoring Reports for FYs 2018 through 2022.
The data show that TDA and TDI module dispositions and ending inventories in FY 2019 (the
year before the Pandemic) were higher than in FY 2022 by as much as 45 percent, as shown with
TDI module dispositions. This declining trend does not support the continued suspension of
ACS call site inventory days.
In responding to the impact of the continued suspension of call site inventory, management
stated that inventory not worked between the scheduled inventory days, during non-telephone
hours, or not resolved via taxpayer action will either remain in the ACS awaiting follow-up action
or be systemically moved out of the ACS, i.e., shelved or queued. For example, according to
TDA Collection Activity Reports for FY 2022 that collectively represent the ACS and ACS Support,
more than 1.1 million TDAs were transferred to the queue and more than 500,000 TDIs were
collectively shelved or transferred to the queue. When cases are shelved or put in the queue,
there is a greater risk that the IRS will not collect the related outstanding taxpayer liabilities or
obtain a delinquent return.
The ACS provided TIGTA a sample snapshot report reflecting the call site manual inventories as
of September 30, 2022. This snapshot report included total inventories of 553,317 cases of
which only 3,537 (less than 1 percent) were worked. The sample report also indicated that
collection representatives did not meet required follow-up dates in approximately 90 percent of
the total cases, i.e., follow-up dates were not met in 496,319 of the 553,317 cases. However, ACS
management does not currently have a cumulative report that tracks and monitors how much of
the manual inventories are worked versus those that are moved out of the ACS. The only report
they have to monitor these inventories is the snapshot report that provides information as of a
specific point in time. Further, management stated that the report cannot be created for
multiple days or a period of time, nor could individual reports be summed to produce an overall
report because reports may contain overlapping inventories.
Through the Inflation Reduction Act of 2022, the plan is to fund additional combined ACS and
ACS Support resources as follows: 1,355 new employees for FY 2023 and 304 new employees
for FY 2024. 24 While planned, these Inflation Reduction Act resources may not be realized.
Additionally, collection representatives are assigned inventory dependent on available direct
hours and program priorities, including LOS. As an example, when there are excess direct hours
that will lead to meeting the LOS, collection representatives are assigned time to work in either
two hour or more segments or inventory days. However, based on the facts presented, the IRS
24
Pub. L. No. 117-169, 136 Stat. 1818.
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should dedicate staff to ensure manual inventories worked by collection representatives are
always in process to avoid potential delayed collection actions and taxpayer burden.
Virtual training may be less effective than in-person training
Prior to the Pandemic, all ACS new hires had to complete their related new hire training
curriculum in an in-person setting. However, with the Pandemic starting in FY 2020, the ACS
was forced to reengineer its training to a virtual format; therefore, most new hires have
completed their new hire training virtually. 25 Our discussions with ACS managers and collection
representatives informed us that ACS virtual training has been a challenge and attempting to
virtually train hires who are completely new to the IRS has been a difficult task. For example,
some of the responses we received were that on-the-job training coaches were only available
virtually via Skype and it was difficult to get in touch with them in real time, the virtual training
did not include “hands-on” time with the on-the-job coach as the in-person training had, and
the virtual training was more reading than actual training.
In addition to the primary measure of telephone effectiveness, i.e., the LOS, the IRS also
measures performance through its Embedded Quality program, which includes the National
Quality Review System (NQRS). National reviewers use the NQRS to assess organizational
performance versus employee performance. The quality review process provides a method to
monitor, measure, and improve the quality of work. One of the measurement categories is
customer accuracy. Customer accuracy measures whether the customer was provided complete
and correct information to their case or issue.
We reviewed ACS Customer Accuracy Reports to analyze the impact related to new hires and
attrition. Figure 8 shows the ACS goal for customer accuracy for NQRS product reviews was
95 percent for FYs 2018 and 2019 and decreased to 90 percent for FYs 2020 through 2022.
Figure 8: NQRS Customer Accuracy by ACS Campus Directorship 26
FY 2018 FY 2019 FY 2020 FY 2021 FY 2022
NQRS Customer Accuracy Goal 95% 95% 90% 90% 90%
NQRS Customer Accuracy by Directorship
Andover Campus 93% 92% 92% 91% 89%
Atlanta Campus 95% 95% 94% 89% 87%
Fresno Campus 94% 92% 91% 90% 88%
Kansas City Campus 94% 93% 92% 91% 87%
Philadelphia Campus 93% 90% 91% 89% 86%
Overall NQRS Customer Accuracy 94% 92% 92% 90% 87%
Source: ACS Collection Quality Reports for FYs 2018 through 2022.
25
As of November 18, 2022, ACS virtual training remains in place with the exception of Puerto Rico, which had ACS
recruit curriculum in a face-to-face classroom environment the second half of FY 2022.
26
The red font means the goal was not met. In some places, it may appear the goal was met when it was not due to
rounding.
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Despite the reduction in the accuracy goal, the data reflect that the overall accuracy has
generally declined from FY 2020 through FY 2022 in comparison to FY 2019 pre-Pandemic
levels. These declining trends may be related to issues surrounding the Pandemic, such as hiring
and attrition issues as well as the need to create a virtual training solution in lieu of the existing
in-person training prior to the Pandemic.
Training new hires virtually may not be the best approach when the majority of new hires have
no IRS background and do not have immediate access to their on-the-job trainer when
questions arise. The ACS should review its virtual training curriculum and incorporate
appropriate adjustments, including a potential change to an in-person training curriculum to
ensure that all new hire employees have adequate training to accurately assist taxpayers in a
timely manner and improve customer accuracy ratings.
The expanded use of telework may have impacted ACS and ACS Support performance
In discussions with ACS managers and throughout this review, the transition to full-time
telework was determined to be another potential factor in lower LOS and productivity in the
ACS. In addition, our review found inconsistencies in telework practices in ACS Support.
In October 2014, the IRS began a series of technology demonstration studies to test the
feasibility of implementing telework in a customer service telephone environment. Selected ACS
collection representatives were incorporated into these telework studies starting with the
second telework technology demonstration study conducted from October 2016 through
March 2017. Some ACS collection representatives continued to participate in the third telework
technology demonstration study where tests were conducted from June 2018 through
May 2021. ACS Support tax examiners were not included in any of these telework studies.
Without any concrete data, the IRS cannot determine whether telework is having a positive or
negative impact on ACS Support employee performance. Also, customer satisfaction, an
important measure in telephone support performance, was not included in the telework studies.
Inconsistencies in defining portable work may risk unfair treatment related to telework
decisions in ACS Support
Our review found that some ACS Support managers are using inefficient and inconsistent
processes to establish remote work in pursuance of telework for their respective tax examiners.
Specifically, managers are inconsistent in their definition of “portable work,” i.e., tasks capable of
being worked by employees in a telework environment, and in the interpretation and
application of the terms of the IRS’s union contract with the National Treasury Employees Union
(NTEU), which governs telework decisions.
ACS Support provides assistance to the ACS organization through the processing of incoming
and outgoing correspondence related to ACS telephone operations.27 ACS Support employees
assist with resolving correspondence from taxpayers or their representatives involving TDAs or
TDIs. ACS Support clerks and tax examiners continue to maintain their pre-Pandemic job
responsibilities. For example:
27
IRM 5.19.6.1(6) (July 8, 2022).
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• ACS Support clerks are responsible for receiving, sorting, and batching incoming mail
into the AM System. 28
• ACS Support tax examiners are responsible for taking actions to resolve the incoming
taxpayer correspondence while having the physical correspondence at hand to reference.
Given the clerks’ responsibilities associated with processing incoming correspondence when
maximum telework was mandated during the Pandemic, there was no change to the
requirement for those employees to be in the office. However, as a result of the Pandemic,
clerks were tasked with additional work including creating digital files by scanning the paper
documents so that other employees, such as tax examiners, could access their assigned work
from their remote computer.
Prior to the Pandemic, ACS Support tax examiners were not generally afforded the opportunity
to telework as the nature of their work involves addressing incoming taxpayer correspondence
in “paper” format that is typically considered non-portable. As such, ACS Support tax examiners,
similar to the clerical employees, previously reported to their assigned site daily. In FY 2022,
when employees were called back into the office, management was required to follow the new
NTEU Agreement that was updated to include tax examiners as an occupation eligible for
frequent telework.29 Prior versions of the NTEU Agreement excluded ACS Support tax examiners
from the list of eligible occupations. Further, once the evacuation orders were lifted and Phase I
of the Return to Office process began, employees who had non-portable work were required to
report back to their post-of-duty.
We interviewed a combination of nine campus directors and department and operations
managers across the five ACS Support sites to identify how each site determines which
employees are granted the ability to telework. Management at two ACS Support sites stated
that they allow all but the clerical department to request frequent telework and cited the revised
Article 50 of the FY 2022 NTEU Agreement when making telework decisions. Article 50 was
updated in FY 2022 to add the ACS Support tax examiner as an eligible occupation to elect
frequent telework. These two sites do not limit telework based on the type of work and have
incorporated scanning documents as an additional step for the clerks to create portable work
for tax examiners, even when cases are not typically required to be in electronic form. These
managers also referenced the IRS’s goal to reduce its paper inventory to support scanning paper
correspondence into an electronic file.
Management at the three remaining support sites base their telework decisions on available
portable work. Their general view is that ACS Support is a “paper” function, with most of its
work being non-portable and therefore not eligible for telework. Management at these three
sites generally allow tax examiners working Collection Due Process and Taxpayer Advocate
Service cases or cases awaiting an answer or research to telework, as these cases are required to
be in electronic format and therefore considered portable. 30 Further, management at one site
28
The process of batching involves manually entering information from the taxpayer correspondence received into
the AM System. Information from the correspondence, such as the IRS received date, the document type, and batch
volume, is used to batch correspondence.
29
Frequent telework involves regular and recurring duties that may be performed at the approved telework site for
more than 80 hours each month (not including overtime, credit hours, or compensatory time worked).
30
ACS Support groups that work Collection Due Process and Taxpayer Advocate Service cases are deemed to have
portable work as all cases are in an electronic format and not in a paper format.
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reviews inventory weekly and will adjust the number of tax examiners allowed to telework
and/or the number of telework days allowed for the week based on available portable work.
Separately, some ACS Support employees assisting the IRS’s efforts to whittle down the backlog
of unprocessed paper tax returns (which the IRS refers to as the “surge team”) are excluded from
teleworking. 31 Managers at this location understand that the NTEU Agreement designates the
tax examiner as an eligible position for frequent telework; however, they base their telework
decisions on assigned work and whether the work is required to be portable.
ACS Support management’s approval of telework for their tax examiners involves inefficient
processes that need to be reviewed and implemented in a more uniform manner according to
the provided definition of what is portable and non-portable work. ACS Support sites that
continue creating portable work (when not required to do so) by adding an extra step to allow
their tax examiners to telework may be increasing inefficiencies and negatively impacting their
productivity, thereby threatening the timeliness in addressing taxpayer inquiries. Additionally,
inconsistencies in the interpretation of the NTEU Agreement and definition of portable work
threaten the fairness of telework determinations for ACS tax examiners. As a result, ACS Support
may risk unnecessary grievances by employees in those sites that do not create portable work
for their tax examiners.
Telework studies of ACS collection representatives identified some areas of concern;
however, the studies excluded ACS Support tax examiners and measures of customer
satisfaction
In response to the Pandemic’s evacuation notices, and as previously stated, the IRS issued its
own directive that involved transitioning ACS call site staff to answer incoming taxpayer
telephone calls from home. The transition to telework for ACS call site staff took approximately
one month, and supervisors who we interviewed noted that one challenge resulting from the
Pandemic has been managing teleworking call site employees and the fact that management
cannot physically observe their teams. As a result of these statements, we suggested to IRS
management that they study the impact that extended telework is having on ACS and ACS
Support’s performance. Management responded that a study could not be performed because
the ACS work streams have all been disrupted since the Pandemic and operations are not back
to normal.
However, during our exit conference with IRS management, the IRS provided information on a
series of telework studies, indicating that these studies should satisfy TIGTA’s request to analyze
the impact of telework on ACS and ACS Support. ACS collection representatives participated in
the last two studies and ACS Support tax examiners did not. The studies were performed over
the following three data periods:
• Prior to the Pandemic:
o Technology Demonstration I, October 2014 – February 2015. The AM and the
Contact Center Support Division conducted this study. Both ACS and ACS
Support employees did not participate in this study.
o Technology Demonstration II, October 2016 – March 2017. The AM, the ACS, and
the Contact Center Support Division conducted this study. Some ACS collection
31
One ACS Support site is fully assisting with the surge team efforts and, therefore, its employees cannot telework.
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representatives participated in this study; however, ACS Support employees did
not participate.
• Started prior to and completed during the Pandemic:
o Technology Demonstration III, June 2018 - May 2021. The AM, the ACS, and the
Contact Center Support Division conducted this study. Some ACS collection
representatives continued to participate in this study; however, ACS Support
employees did not participate. The three data periods reviewed included two
pre-Pandemic reviews (June 10, 2018, through December 15, 2018, and
January 28, 2019, through December 19, 2019), and one review during the
Pandemic (October 1, 2020, through May 31, 2021).
Various tests were performed as part of Technology Demonstration III including but not limited
to reviews on call quality, call clarity, and inventory analysis. For example, in this study, when
testing for call quality, the first two data periods (pre-Pandemic) found no significant differences
between ACS collection representatives’ performance on call quality when teleworking or
working in the site. The third data period within this study showed mixed results and
conclusions could not be made across all tests. This may be due to the fact that in response to
the Pandemic, the majority of call site representatives were teleworking during the third data
period and therefore comparisons could not be drawn against non-teleworking employees. For
this reason, the results from this last data period may not have made reliable comparisons. In
addition, these tests across all three data periods did not include any measure of external
customer satisfaction from the public.
The IRS reported an overall observation from the Technology Demonstration III study that
employees and managers expressed greater satisfaction and work life balance. However, this
study also identified certain issues such as background noise and employees in a non-secure
environment due to speaking to family or guests in the employee’s home office area where
Personally Identifiable Information could be overheard. ACS collection representatives with a
non-secure environment, while teleworking, failed to comply with I.R.C. § 6103, which protects
taxpayer information from disclosure to unauthorized individuals. Observations of ACS Support
tax examiners who telework were not performed; therefore, it is not known if disclosure risks
may also have been present.
As mentioned previously, the OMB issued guidance in April 2023 on assessing organizational
health and performance and instructs agencies to ensure feedback from the public is
incorporated into their frameworks and that they focus on improvements and service elements
that most effectively improve trust and reduce burden on the public. IRS management
submitted their draft Post-Reentry Workforce Environment Plan in response to this OMB issued
guidance. However, the draft response is written in a very generic manner and is not specific to
any business unit. For example, it does not include any post-reentry workforce planning for ACS
or ACS Support. To support the IRS’s overall Post-Reentry Workforce Environment Plan, ACS
and ACS Support management should continually monitor available ACS metrics to evaluate
potential risks with ACS collection representatives and ACS Support tax examiners who telework
and develop strategies to mitigate those risks, such as any adverse impact to its LOS, the
security of taxpayer information, ACS productivity, and taxpayer customer service.
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The Director, Campus Collection, Small Business/Self-Employed Division, should:
Recommendation 1: Dedicate staff to ensure that manual inventories worked by collection
representatives are always in process to avoid potential delayed collection actions and taxpayer
burden.
Management’s Response: The IRS agreed with this recommendation and started
inventory days during the fourth quarter of FY 2023 and will schedule at least one
inventory day per site during FY 2024 based on factors such as telephone demand.
Recommendation 2: Review the virtual training curriculum and incorporate appropriate
adjustments, including a potential return to an in-person training curriculum to ensure that all
new hire employees have adequate training to accurately assist taxpayers in a timely manner
and improve customer accuracy ratings.
Management’s Response: The IRS agreed with this recommendation stating that they
are in the process of revising the ACS new hire curriculum. Once completed, the material
will be available via the Integrated Talent Management System. In addition, the IRS
confirmed Campus Collection has begun transitioning back to in-person training for new
hires and will continue this in FY 2024.
Recommendation 3: Establish a consistent approach between ACS Support sites when defining
portable work in an effort to improve efficiency.
Management’s Response: The IRS agreed with this recommendation and will have
Campus Collection collaborate with impacted stakeholders to clarify portable work as it
pertains to the business unit, and it will be communicated to ACS Support sites once a
consistent approach has been established.
Recommendation 4: Continually monitor available ACS and ACS Support metrics to evaluate
potential risks with ACS collection representatives and ACS Support tax examiners who telework
and develop strategies to mitigate those risks, such as any adverse impact to its LOS, the
security of taxpayer information, productivity, and taxpayer customer service.
Management’s Response: The IRS agreed with this recommendation and will have
managers utilize various metrics to mitigate risks and improve efficiencies. Campus
Collection is currently purchasing additional scanners and will distribute them to various
campus locations to convert paper correspondence to an electronic format and is in the
process of upgrading laptops for collection representatives and tax examiners to
improve speed, efficiency, and to minimize disruptions in service.
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Appendix I
Detailed Objectives, Scope, and Methodology
The overall objective of this audit was to evaluate the effectiveness of the IRS’s actions to
improve ACS call sites’ business results and LOS, including the current status of performance in
light of the Pandemic. We also reviewed ACS Support’s business results and operations. To
accomplish our objectives, we:
• Interviewed ACS and ACS Support management, via conference calls and site visits, and
obtained relevant documentation to evaluate: the processes of both business units, the
types of inventories worked by both business units, and the impact from the Pandemic
on each business unit.
• Reviewed all relevant ACS and ACS Support strategies, plans, policies, and Internal
Revenue Manual (IRM) guidelines.
• Identified the impact that AM and Submission Processing surge efforts had on the ACS:
the FTEs, Potential Revenues Lost, and Potential Dispositions Lost.
• Reviewed the IRS’s Collection Activity Reports, Monthly Monitoring Reports, and the
Monthly Assessment of Performance Reports to determine the impact that the Pandemic
has had on ACS and ACS Support business results related to:
o ACS TDA and TDI Dispositions.
o ACS Support CIS/TDA/TDI receipts, closures, closures per FTE, and over-age
inventory.
• Reviewed the Joint Operation Center’s Enterprise Telephone Database to assess ACS
toll-free telephone performance for FYs 2018 through 2022. Specifically, we reviewed:
o ACS LOS Target.
o ACS Actual LOS.
o ACS Net Incoming Taxpayer Call Attempts.
o ACS Calls Answered and Calls Answered per FTE.
o ACS Average Speed of Answer.
o ACS Average Handle Time.
• Evaluated the result of IRS telework studies in which ACS participated in from
October 2016 through May 2021.
• Reviewed the draft Post-Reentry Workforce Environment Plan response related to the
OMB Memorandum M-23-15 to identify the IRS’s strategy to assess the impact
associated with the expanded use of telework in ACS and ACS Support.
Performance of This Review
This review was performed at the ACS and ACS Support site in Fresno, California, with
information obtained from the Small Business/Self-Employed Division located in
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Automated Collection System Level of Service and Collection Inventories
Washington, D.C.; all remaining ACS call sites (Oakland, California; Denver, Colorado;
Jacksonville, Florida; Atlanta, Georgia; Des Moines, Iowa; Andover, Massachusetts;
Detroit, Michigan; Kansas City, Missouri; Brookhaven, New York; Buffalo, New York;
Cincinnati, Ohio; Philadelphia, Pennsylvania; San Juan, Puerto Rico; Memphis, Tennessee;
Nashville, Tennessee; Austin, Texas; Ogden, Utah; and Seattle, Washington); and ACS Support
sites located in Atlanta, Georgia; Kansas City, Missouri; Cincinnati, Ohio; and Philadelphia,
Pennsylvania, during the period February 2022 through June 2023. 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
objectives. We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.
Major contributors to the report were Matthew A. Weir, Assistant Inspector General for Audit
(Compliance and Enforcement Operations); Phyllis Heald London, Director; Javier Fernandez,
Audit Manager; Carrie Mares, Lead Auditor; James Dovan, Auditor; and Laura R. Christoffersen,
Applied Research and Technology Data Analyst.
Data Validation Methodology
This review did not rely on computer-processed data. However, we did use information
contained in various IRS system reports such as the IRS’s Collection Activity Reports and
Monthly Assessment of Performance Reports, the ACS’s Inventory Production Reports and
Monthly Monitoring Reports, and reports from the Joint Operations Center’s Enterprise
Telephone Database Reporting website.
ACS Support’s CIS/TDA/TDI inventory data, focusing on the receipts and closures, were reviewed
using both the IRS’s Monthly Assessment of Performance Reports and the ACS’s Inventory
Production Reports. The ACS Support’s CIS/TDA/TDI inventory data for FYs 2018 and 2019 were
reviewed and matched between each report. As a result of the inventory data matching, we
determined that the information in these reports were sufficiently reliable for purposes of this
review.
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 objectives: IRS management reports
designed to monitor the status of ACS inventories and the LOS. To assess these controls, we
reviewed reports from FY 2018 through FY 2022 to evaluate any significant trends. We also
interviewed ACS and ACS Support management and reviewed relevant sections of the IRM and
the IRS’s response to the Pandemic including its Return to Office Playbook as it pertained to the
ACS and ACS Support.
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Post-Pandemic Actions Have Contributed to Declines in
Automated Collection System Level of Service and Collection Inventories
Appendix II
Management’s Response to the Draft Report
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Post-Pandemic Actions Have Contributed to Declines in
Automated Collection System Level of Service and Collection Inventories
Page 24
Post-Pandemic Actions Have Contributed to Declines in
Automated Collection System Level of Service and Collection Inventories
Page 25
Post-Pandemic Actions Have Contributed to Declines in
Automated Collection System Level of Service and Collection Inventories
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Post-Pandemic Actions Have Contributed to Declines in
Automated Collection System Level of Service and Collection Inventories
Appendix III
Glossary of Terms
Term Definition
A levy program in which selected Federal tax debts are matched with State
Automated Levy Programs taxing authorities, municipal taxing authorities, and Federal agencies
disbursing funds such as salary, pension, and vendor payments.
Average length of time a collection representative spends assisting the
Average Handle Time
customer.
Average length of time a caller spends in a secondary application before
Average Speed of Answer
connecting to an agent.
I.R.C. § 6330 gives the taxpayer the right to appeal before a proposed levy
action and after a jeopardy levy, a Disqualified Employment Tax Levy, a levy
Collection Due
on a Federal contractor, and a levy on State tax refunds. The IRS notifies
Process Notice
taxpayers of their Collection Due Process rights by issuing a notice
explaining their right to request a hearing.
The duties of a collection representative are varied and include collecting
unpaid taxes and securing tax returns from delinquent taxpayers that have
Collection Representative
not complied with previous notices along with securing, verifying, and
updating levy sources and timely issuing notices of tax levy.
Any yearly accounting period, regardless of its relationship to a calendar
Fiscal Year year. The Federal Government’s fiscal year begins on October 1 and ends
on September 30.
A measure of labor hours in which one FTE is equal to eight hours
Full-Time Equivalent
multiplied by the number of compensable days in a particular fiscal year.
The body of law that codifies all Federal tax laws, including income, estate,
gift, excise, alcohol, tobacco, and employment taxes. These laws constitute
Internal Revenue Code Title 26 of the United States Code. The United States Code is a
consolidation and codification by subject matter of the general and
permanent laws of the United States.
The primary, official source of IRS “instructions to staff” related to the
Internal Revenue Manual
organization, administration, and operation of the IRS.
The primary measure of service to taxpayers. It is the relative success rate
of taxpayers who call for live assistance on the IRS toll-free telephone lines.
Level of Service
The IRS’s measure is titled Customer Service Representative Level of
Service.
Manual liens are issued on an individual basis by collection representatives
Manual Lien
when lien criteria are met.
An employee located in a field office who conducts examinations through
Tax Examiner correspondence. However, the tax examiner position is also used for many
other types of positions located in various IRS offices.
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Post-Pandemic Actions Have Contributed to Declines in
Automated Collection System Level of Service and Collection Inventories
Appendix IV
Abbreviations
ACS Automated Collection System
AM Accounts Management
CIS Collection Information Statement
COVID-19 Coronavirus Disease 2019
FTE Full-Time Equivalent
FY Fiscal Year
HCO Human Capital Office
I.R.C. Internal Revenue Code
IRM Internal Revenue Manual
IRS Internal Revenue Service
LOS Level of Service
NQRS National Quality Review System
NTEU National Treasury Employees Union
OMB Office of Management and Budget
TDA Taxpayer Delinquent Account
TDI Taxpayer Delinquency Investigation
TIGTA Treasury Inspector General for Tax Administration
Page 28
To report fraud, waste, or abuse,
contact our hotline on the web at www.tigta.gov or via e-mail at
oi.govreports@tigta.treas.gov.
To make suggestions to improve IRS policies, processes, or systems
affecting taxpayers, contact us at www.tigta.gov/form/suggestions.
Information you provide is confidential, and you may remain anonymous.
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