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Management Challenges
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Reports
Delays in Management Actions Contribute to the Continued Tax Processing Center Backlogs
On September 16, 2021, we notified the Director, Submission Processing, Wage and Investment Division, that the IRS needed to identify when to stop coding and editing9 prior year tax returns to prevent having to rework these returns (a situation that occurred during the 2020 Filing Season). For example, the IRS needed to send 822,994 business tax returns back to the Code and Edit function at the beginning of Processing
Year 2021 to be re-edited to allow for processing. This occurred because these tax returns, although edited, had not been entered into the IRS’s tax processing system by the end of Processing Year 2020. This resulted in an inefficient use of the IRS’s resources because IRS employees needed to re-edit the tax returns. We recommended that the IRS develop a plan to not only limit the number of returns that would require rework, but also any potential downtime in the Code and Edit function so that resources can be maximized for processing tax returns.
On September 29, 2021, we notified the Director, Submission Processing, Wage and Investment Division, of our observation that paper-filed
information returns were being sorted and batched. According to both Tax Processing Centers, a decision had not yet been made regarding if the information return documents will be processed or destroyed. As we reported in September 2021,10 the IRS faced similar decisions during Processing Year 2020 and destroyed approximately 30 million paper-filed information return documents around March 19, 2021, because the documents could no longer be processed through its systems. We recommended that the IRS determine if/when Processing Year 2021 paper-filed information return documents would be processed. As an alternative to destroying these documents, we recommended that management evaluate and consider scanning the information return documents using the Service Center Recognition Image Processing System while forgoing the data validation process.
On September 17, 2021, we notified the Director, Submission Processing, Wage and Investment Division, of our concerns with the processing of a backlog of taxpayer address changes using a first-in/first-out method. As of August 27, 2021, the Ogden Entity function had more than 173,000 address change requests in its ending inventory. In our discussions with Ogden Entity function management, they estimated that due to the backlog of inventory, more than 50 percent of the address change requests the staff were working had already been made by other means, e.g., the filing of a tax return that automatically updates the taxpayer’s address. As such, Entity function employees were needlessly expending
resources working address change requests for which the address was already updated. We recommended that the IRS evaluate changing the order in which address changes are worked to a last-in/first-out method.
On October 21, 2021, we notified the Director, Submission Processing, Wage and Investment Division, of our concerns related to the accuracy of
information communicated to taxpayers regarding transcript request methods. For example, our review of information posted on IRS.gov found that non-paper-based methods for requesting tax transcripts were not communicated clearly. Whereas, the Form 4506-T, Request
for Transcript of Tax Return, and Form 4506, Request for Copy of Tax Return, provide information for automated self-help service tools. We also found that the instructions on the Forms 4506 and 4506-T do not align with the website wording and could cause confusion for taxpayers. We recommended that IRS management update IRS.gov to provide clear communications on available resources. This includes updating the Forms 4506 and 4506-T tip sections to match IRS.gov language and conducting outreach to encourage individual taxpayers to obtain tax transcripts using the various automated methods.
On September 16, 2021, we notified the Director, Submission Processing, Wage and Investment Division, of our concerns about the printing
capacity of the new electronic fax (e-fax) equipment in the Error Resolution System functional area, noting that this new equipment can only print about 20,000 to 30,000 pages/month (approximately 240,000/year) whereas, the prior equipment printed roughly 2 million documents
per year. In addition, in the three months since Ogden received this new equipment, it has burned out and needed new parts. Although Ogden ordered new multifunctional print devices, those were not to be delivered until January 2022. As a workaround, Ogden used two printers
that had a capacity of about 15,000 pages per month. We recommended that the Submission Processing function collaborate with Managed Print Services and the Information Technology organization to identify and expeditiously resolve all instances of printer capacity, break/fix, etc.
issues that are causing work stoppages in the Tax Processing Centers.
On December 17, 2021, we notified the Commissioner, Wage and Investment Division, of our concern that the resources assigned to the RAIVS unit were not commensurate between the Kansas City and Ogden Tax Processing Centers. In our discussions, IRS management advised that taxpayer tax transcript requests had been previously transshipped from the Kansas City Tax Processing Center to the Austin Tax Processing Center with the last transshipment of work occurring in October 2021. On January 11, 2022, we notified the Director, Submission Processing, Wage and Investment Division, of the same concern noting that during our December 2021 walkthroughs, Kansas City management stated they have 70 full-time employees in the RAIVS/Income Verification Express Service’s unit. Whereas, Ogden management stated they have 183 full-time employees. As of December 10, 2021, the Kansas City RAIVS unit had over 751,000 unprocessed requests compared to a little more than 145,000 unprocessed requests in the Ogden RAIVS unit. We recommended that the IRS evaluate alternatives to address the volume of RAIVS inventory at the Kansas City Tax Processing Center. This should include an evaluation of the capacity to reallocate staffing at the Kansas City Tax Processing Center to assist the RAIVS unit, and/or realignment of work among the various Tax Processing Centers, i.e., transship inventory from
Kansas City to Ogden.
The Commissioner, Wage and Investment Division, should immediately take steps to address the imbalance of Tax Processing Center staffing and inventory to address the continued backlog of transcript requests.
The Commissioner, Wage and Investment Division, should develop a detailed strategy to show how current and future staffing resources, including available surge team members, will be used to address the significant backlog of amended returns in the Submission Processing function’s inventory.
The Commissioner, Wage and Investment, should ensure that the various products and IRS.gov landing pages are updated to reflect acceptable methods for faxing information to the IRS.
Compliance Efforts Are Needed to Address Refund Claims Reported on Form 1139 That Are Based on the CARES Act Net Operating Loss Carryback Provisions
Track and monitor examination results for the 25 “still open” examinations of Forms 1120 with reported NOL and an associated Form 1139 reported in Figure 4 of this report, excluding Joint Committee Refund cases which currently have specific monitoring requirements in place.
Use the examination results from Recommendation 1 to assess whether to increase the number of examinations of Forms 1120 with reported NOL and an associated Form 1139.
The Commissioner, SB/SE Division should review the examination results and computations of proposed NOL adjustments for the 25 “still open” Form 1120 examinations with associated Forms 1139, as referenced in Figure 4, excluding Joint Committee Refund cases which currently have specific review requirements in place, to determine if the interim guidance regarding NOLs is being properly followed.
Processing of Recovery Rebate Credit Claims During the 2021 Filing Season
On June 15, 2021, we alerted IRS management of our concerns with the systemic calculation of the allowable RRC amount. We recommended that IRS management review the returns we identified and provide us with any corrective actions they intended to take.
Conduct analysis of Tax Year 2020 tax returns processed after May 27, 2021, to identify additional individuals who received an RRC for a qualifying child for which the IRS has already paid an EIP or an RRC to someone else and take the actions needed to recover RRC payments that are determined to be erroneous.
Review the 7,022 individuals identified in which the IRS issued multiple RRCs for a qualifying child who was claimed on more than one tax return and take the actions needed to recover payments that are determined to be erroneous.
Conduct analysis of Tax Year 2020 tax returns processed after May 27, 2021, to identify additional individuals who received an RRC for a qualifying child who was claimed on more than one tax return and take the actions needed to recover payments that are determined to be erroneous.
Review the 75,594 tax returns identified in which the individual is potentially a nonresident alien and take the actions needed to recover the RRC payments that are determined to be erroneous.
Perform analysis of Tax Year 2020 tax returns filed after May 27, 2021, to identify additional tax returns with the same characteristics as those the IRS determined were filed by a nonresident alien and take the actions needed to recover erroneous RRC payments.
The Commissioner, Wage and Investment Division, should coordinate with the Territories to confirm and recover erroneous RRCs.
Review the nearly 6.9 million potentially eligible individuals we provided to the IRS who had not filed a Tax Year 2020 tax return as of May 27, 2021, and send a letter to those individuals who still have not filed a Tax Year 2020 return to encourage them to file a return and claim the RRC if eligible.
Review the 3.1 million eligible individuals we identified who filed a Tax Year 2020 return and proactively issue these taxpayers their credit.
Conduct additional analysis to identify tax returns filed after May 27, 2021, in which an individual is eligible for the RRC based on their Tax Year 2020 tax return and did not claim the credit, and proactively issue the taxpayer their credit.
If IRS management does not proactively issue the RRC to individuals who filed a return and did not claim the credit, the IRS should notify these individuals that they are eligible to claim the RRC and should file an amended tax return to claim the credit.
On March 19, 2021, we alerted IRS management of our concerns that an incorrect amount of advance payments was being used to calculate the RRC for some taxpayers. We recommended that IRS management review the returns we identified and provide us with any corrective actions they intended to take.
Work with the BFS to ensure that individuals who were denied the RRC and have still not activated their EIP1 or EIP2 debit card as of December 31, 2021, have EIPs reversed in their tax account and are issued their RRC. These processes should include notifying Metabank that the debit cards in question are to be cancelled.
Work with the BFS to obtain recurring data during Processing Year 2022 to identify individuals who have not activated their advance ARPA RRC debit card at the time a return is filed and implement processes to reverse the advance payment so these individuals can receive the RRC on their Tax Year 2021 tax return.
We alerted the Commissioner, Wage and Investment Division, of our concerns that the IRS was unnecessarily burdening taxpayers whose RRC claims were identified for manual ERS review. We recommended the IRS develop processes to systemically adjust RRC claims using the computer-generated RRC calculation.
On April 6, 2021, we alerted IRS management of our concerns regarding ERS tax examiners incorrectly computing the RRC (see management’s action in response to Recommendation 1). We recommended the IRS review the returns we identified and take the actions necessary to ensure that these taxpayers receive the amount of the RRC
they are entitled to receive.
On March 12, 2021, we alerted IRS management of our concerns that some tax returns were not being identified by fraud filters. We recommended IRS management review the returns we identified and associated fraud filters to identify why these returns were not selected and make programming changes as necessary to ensure proper
identification of returns with potentially questionable claims.
Conduct analysis to identify Tax Year 2020 RRC claims processed after May 27, 2021, to identify other returns in which ERS tax examiners incorrectly calculated the number of allowable dependents and returns that were not reprocessed per IRS guidance after programming was corrected, and ensure that these taxpayers receive the correct amount of the RRC.
Review the 14,508 individuals identified in which the IRS issued an RRC to an individual who was claimed as a dependent on someone else’s tax return but did not check the dependent box and take the actions needed to recover payments that are determined to be erroneous.
Conduct analysis of Tax Year 2020 tax returns processed after May 27, 2021, to identify additional individuals who received an RRC and were also claimed as a dependent on someone else’s tax return but did not check the dependent box, and take the actions needed to recover the RRC payments that are determined to be erroneous.
Review the 238,680 individuals under the age of 25 identified as potential dependents and take the actions needed to recover payments that are determined to be erroneous.
Review the 15,741 individuals identified in which the individual incorrectly received an RRC and an EIP for the same qualifying child and take the actions needed to recover RRC payments that are determined to be erroneous.
The Child Tax Credit Update Portal Was Successfully Deployed, but Security and Process Improvements Are Needed
Evaluation of Department of Defense Military Medical Treatment Facility Challenges During the Coronavirus Disease-2019 (COVID-19) Pandemic in Fiscal Year 2021
Rec. A.1.a: The DoD OIG recommended that the Director of the Defense Health Agency, in conjunction with the Secretaries of the Military Departments, establish a working group to address the staffing challenges identified by Military Medical Treatment Facilities during this evaluation. The working group should establish milestones to streamline the hiring process to allow Military Medical Treatment Facilities to more quickly fill civilian staffing positions.
Rec. A.1.b: The DoD OIG recommended that the Director of the Defense Health Agency, in conjunction with the Secretaries of the Military Departments, establish a working group to address the staffing challenges identified by Military Medical Treatment Facilities during this evaluation. The working group should establish milestones to determine if salaries for Military Medical Treatment Facility civilian nurses are commensurate with each facility's local market and if military treatment facilities are able to hire nurses at those salaries. For locations where military treatment facility salaries are not commensurate with the local market, take appropriate actions that will reduce the disparity in those markets.
Rec. A.1.c: The DoD OIG recommended that the Director of the Defense Health Agency, in conjunction with the Secretaries of the Military Departments, establish a working group to address the staffing challenges identified by Military Medical Treatment Facilities during this evaluation. The working group should establish milestones to establish a central authority with the knowledge of the Services' requests for individual and large group deployments of medical staff coming out of Military Medical Treatment Facilities and the associated risks to health care delivery.
Rec. A.1.d: The DoD OIG recommended that the Director of the Defense Health Agency, in conjunction with the Secretaries of the Military Departments, establish a working group to address the staffing challenges identified by Military Medical Treatment Facilities during this evaluation. The working group should establish milestones to assess the ability of Military Medical Treatment Facilities to rapidly receive augmentation of medical staff from the Reserve Components.
Rec. A.2.a: The DoD OIG recommended that the Director of the Defense Health Agency, in coordination with the Secretaries of the Military Departments establish the manpower requirements for the coronavirus disease-2019 mission within the Military Medical Treatment Facilities for the staff required to support testing, vaccinations, contact tracing, and acute respiratory clinics.
Rec. A.2.b: The DoD OIG recommended that the Director of the Defense Health Agency, in coordination with the Secretaries of the Military Departments identify the medical personnel requirements within the Military Medical Treatment Facilities, including clinicians, nurses, and support staff, needed for future long-term pandemic response and biological incidents.
Rec. B: The DoD OIG recommended that the Assistant Secretary of Defense (Health Affairs) develop DoD policy for the maximum consecutive hours to be worked, maximum shifts per week, and coverage of duties when absent, for Military Health System staff (at minimum, active duty military and civilian physicians, nurses, respiratory therapists, and lab technicians) working in Military Medical Treatment Facilities to reduce the physical impacts leading to fatigue and burnout, and develop the appropriate waivers of this policy for Military Health System staff.
Rec. C: The DoD OIG recommended that the Assistant Secretary of Defense (Health Affairs) direct a new or existing working group to develop a plan to implement the recommendations in the Military Health System COVID-19 After Action Report and to develop and monitor milestones for each recommendation.
Audit of Entitlements for Activated Army National Guard and Air National Guard Members Supporting the Coronavirus Disease–2019 Mission
Rec. 1.a: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, in coordination with the Under Secretary of Defense for Personnel and Readiness, update the DoD Financial Management Regulation, volume 7A, "Military Pay Policy - Active Duty and Reserve Pay," chapter 27, "Family Separation Allowance" to clearly state that the permanent duty station of a Reserve Component member on temporary duty status is the member's primary residence for the purpose of determining Family Separation Allowance entitlement.
Rec. 1.b: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, in coordination with the Under Secretary of Defense for Personnel and Readiness, update the DoD Financial Management Regulation, volume 7A, "Military Pay Policy - Active Duty and Reserve Pay," chapter 27, "Family Separation Allowance" to clarify that Family Separation Allowance entitlement determination is based on the commuting distance between the member's primary residence and their temporary duty location.
Rec. 2.a: The DoD OIG recommended that the Chief, National Guard Bureau, in coordination with the Director of the Army National Guard and the Director of the Air National Guard, develop and implement policies and procedures to require the Army National Guard and Air National Guard to complete a review of proof of residency documentation when the member's primary residency is established or changed for the Basic Allowance for Housing entitlement to ensure consistency throughout all Army National Guard and Air National Guard units and organizations within every state, territory, and the District. The policies and procedures should also include requirements that: * document a member's primary residence address; * require members to provide proof of their primary residence address; * certify the primary address of members and review supporting documentation; and * provide oversight to ensure primary residence address information is complete and accurate.
Rec. 2.b: The DoD OIG recommended that the Chief, National Guard Bureau, in coordination with the Director of the Army National Guard and the Director of the Air National Guard, develop and implement policies and procedures to outline the process and frequency of recertification for Basic Allowance for Housing entitlement that Army National Guard and Air National Guard officials will use to verify and fully document the dependency status of members to provide clarification to the DoD Financial Management Regulation, volume 7A, chapter 26. These procedures should include: * how recertifications will be completed; * which members will complete a recertification; and * how Army National Guard and Air National Guard officials will provide oversight to ensure that information is complete and accurate.
Rec. 2.c: The DoD OIG recommended that the Chief, National Guard Bureau, in coordination with the Director of the Army National Guard and the Director of the Air National Guard, develop and implement policies and procedures to require Army National Guard and Air National Guard officials to review and document the status of a military member married to another military member regardless of which Military Service, Reserve or Active Component, or Army National Guard or Air National Guard unit the member's spouse belongs to, and identify which member will claim any applicable dependents.
Rec. 2.d: The DoD OIG recommended that the Chief, National Guard Bureau, in coordination with the Director of the Army National Guard and the Director of the Air National Guard, develop and implement policies and procedures to specify the methods for confirming eligibility and paying Family Separation Allowance for Army National Guard and Air National Guard members, in accordance with the DoD Financial Management Regulation, volume 7A, chapter 27, and include the: * timeliness of payments; * determination of Family Separation Allowance eligibility for back to back orders; * members assigned to their normal duty locations; and * requirement to track members to know when they return to their primary residence.
Rec. 2.e: The DoD OIG recommended that the Chief, National Guard Bureau, in coordination with the Director of the Army National Guard and the Director of the Air National Guard, develop and implement policies and procedures to establish formal dissemination and communication procedures for National Guard Bureau policies related to entitlements provided to the Army National Guard and Air National Guard, including the policies in the preceding recommendations. The procedures should require: * creation of a central location where policies and procedures will be kept for easy access by all states, territories, and the District; and * confirmation of receipt from all of the states, territories, and the District when procedures are communicated or obtained.
Rec. 3: The DoD OIG recommended that the Chief, National Guard Bureau, in coordination with the Director of the Army National Guard and the Director of the Air National Guard, develop and implement additional internal control procedures for the review of transactions manually submitted by the Army National Guard and Air National Guard to the payment system prior to payment to ensure the completeness and accuracy of transactions.
Program and Organizational Changes Are Needed to Address the Continued Inadequate Tax Account Assistance Provided to Taxpayers
On September 20, 2021, we notified the Director, Accounts Management, that the Austin site was not requiring Accounts Management screeners to come into the office to perform their duties, resulting in a significant backlog and delays in inventory being routed to Accounts Management to be worked. We recommended that the IRS establish consistent guidance and clarification on when resources can be directed to the office to help with screening inventory, to ensure that sufficient staff is available to screen documents in a timely manner, and establish processes to monitor the progress,
The Commissioner, Wage and Investment Division, should update existing scanning software or obtain a new scanning software to
address document capacity concerns.
The Commissioner, Wage and Investment Division, should ensure that programming is updated to systemically reject electronic
submissions of Forms 2848 and 8821 when missing one of the five essential elements (name, address, signature, etc.) without manually mailing a rejection letter.
The Commissioner, Wage and Investment Division, should ensure that the rejection letter used for Forms 2848 and 8821 is updated
to include language that a revised form can be submitted electronically via an IRS Tax Pro Account25 or through Taxpayer Digital Communication.
Develop an action plan to prioritize the continued expansion of documents that can be sent in via electronic fax and converted into a CIS image.
The Commissioner, Wage and Investment Division, should develop an action plan to prioritize the continued expansion of documents that can be sent in via electronic fax and converted into a Correspondence Imaging System (CIS) image.
The Commissioner, Wage and Investment Division, should Identify priority work that needs to be expedited by the Image Control Team (ICT) and assess the feasibility of creating an electronic fax number to receive this inventory.
On July 12, 2021, TiGTA notified the Director, Accounts Management, of concerns regarding inaccuracies as it related to the compiling and reporting of the Accounts Management Inventory Report (AMIR). TIGTA recommended that the IRS perform a reconciliation of each Accounts Management site’s AMIR to the source reports to identify inventory inconsistencies and reporting errors by site
The Commissioner, Wage and Investment Division, should complete the inventory reconciliations for the four remaining Accounts
Management site’s to identify and correct inventory inaccuracies and inconsistencies and implement processes to provide oversight by periodically performing reconciliations for each site so that any future inconsistencies and errors are identified and corrected in a timely manner.
The Commissioner, Wage and Investment Division, should develop specific and detailed instructions for preparing the Accounts Management Inventory Report (AMIR), including how controlled and uncontrolled inventory should be captured
The Commissioner, Wage and Investment Division, should develop a process to systemically pull all controlled inventory for each
Accounts Management site for the Accounts Management Inventory Report (AMIR) to ensure consistency, reduce human error, and
increase efficiencies
The Commissioner, Wage and Investment Division, should modify Accounts Management inventory reporting to report unassigned
controlled inventory separately on the nationwide Accounts Management Inventory Report (AMIR) and limit the site-specific AMIRs to only
the inventory assigned to be worked in each site.
The Commissioner, Wage and Investment Division, should evaluate directing taxpayers to send tax account correspondence and
replies intended for Accounts Management directly to Campus Support Sites for processing to reduce backlogs at Tax Processing Centers and improve services to taxpayers.
The Commissioner, Wage and Investment Division, should prioritize the development and implementation of tools that will enable
taxpayers seeking assistance or responding to Accounts Management to correspond with the IRS electronically, including the ability to directly upload documents into Accounts Management’s inventory.
The Chief Taxpayer Experience Officer, in conjunction with the Director, IRS NEXT Office, should evaluate establishing two distinct IRS programs as part of the IRS reorganization under the Taxpayer First Act – one dedicated to answering toll-free telephone calls and one dedicated to working Accounts Management inventory – with adequate staffing to provide appropriate service to taxpayers using each channel.
On June 9, 2021, we notified the Director, Customer Account Services, that Submission Processing requested resources from Accounts Management to assist with clearing the Image Control Team (ICT) backlog and was told by Campus Support management that no resources could be made available to assist with reducing the ICT backlog. We recommended that the IRS assess the availability of Campus Support’s ICT staffing or other resources that could be made available to assist with clearing the ICT backlogs at Tax Processing Centers.
On September 3, 2021, we notified the Director, Accounts Management, of concerns relating to the newly stood-up Fresno Campus Support Site, including scanners not being used to the full extent possible. We recommended that IRS management provide us with it plans to address our concerns identified with the new Fresno Campus Support Site, including additional staffing to assist Image Control Team (ICT).
The Commissioner, Wage and Investment Division, should complete a strategic review of all 10 Image Control Team (ICT) sites to determine what contributes to the ICT’s inability to timely scan and validate documents. Based on the results of this review, initiate steps to address the concerns identified. This should include the development of an action plan to ensure that the high-capacity ICT scanners and staffing are realigned to the appropriate sites based on actual or expected inventory levels and that responsibility of the ICT operations are consolidated under the appropriate function.
The Commissioner, Wage and Investment Division, should cross-train additional mail clerks at Campus Support Sites to work Image Control Team (ICT) validations, freeing up additional resources in sites with higher inventories needing to be scanned, or consider shipping inventory to sites with less inventory to be scanned.
The Commissioner, Wage and Investment Division, should develop specific instructions and a common template for all 10 Image Control Team (ICT) sites to consistently capture ICT inventory information.
Fulfillment of Purchase Card Orders
Pandemic Purchase Card Use
We recommend that the BLM resolve the $11,321 in questioned costs due to insufficient documentation.
Increasing Transparency into COVID-19 Spending
OMB should, in coordination with the PRAC, offer resources for agencies that focuses on improving the quality of award descriptions to result in consistent use and application of this field across all agency submissions and to provide clarity on the intent and purpose of pandemic assistance.
OMB should develop and implement a plan, leveraging its resources and in coordination with the PRAC, to disseminate to individual agencies examples of insufficient award descriptions in need of remediation.
OMB should engage with Congress to consider legislating amendments to extend independent oversight of USAspending.gov data submissions, including developing new requirements in consultation with CIGIE and the PRAC for the review of agency award descriptions.
OMB should conduct a feasibility study, in coordination with relevant federal and non-federal stakeholders, as to how to better track and report subrecipient funding.
OMB should engage with Congress to consider legislating amendments to extend independent oversight of USAspending.gov data submissions, including developing new requirements in consultation with the CIGIE and the PRAC for the review of subrecipient reporting.