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Reports
American Rescue Plan Act: Assessment of the Child Tax Credit Update Portal’s Capabilities and Related Processes
On January 25, 2022, we notified the Director, Return Integrity and Compliance Services, of potential inaccuracies and other areas of concern based on our review of information on www.ChildTaxCredit.gov. For example, the website references Publication 972, Child Tax Credit and Credit for Other Dependents, which the IRS made obsolete for Tax Year 2021, and did not reference thresholds for single or married filing separately taxpayers. We recommended that the IRS review our concerns and share them with the Department of the Treasury to address.
On January 28, 2022, we notified the Director, Return Integrity and Compliance Services, of our concerns with the reconciliation process when there are undelivered checks. This concern arises when the taxpayer files their Tax Year 2021 tax return but has a check for an advance Child Tax Credit payment that was returned undelivered after the taxpayer filed their tax return. In these situations, the taxpayer will not receive the
payment from the undelivered check and will need to work with the IRS, after filing their tax return, to recover their payment. We recommended that the IRS develop a process to continue to proactively identify and correct accounts with undelivered advance Child Tax Credit that post to accounts after the IRS processes the Tax Year 2021 tax return.
Fingerprinting and Employment Eligibility Verification Delays Due to the COVID-19 Pandemic May Increase Taxpayer Data Exposure Risks
The Chief Human Capital Officer should conduct periodic reviews of the Form I-9 SharePoint site and provide periodic reminders to hiring officials responsible for completion of Forms I-9 to determine whether or not those individuals are still pending physical inspection and update the records based upon the results of that review to ensure that the Form I-9 SharePoint site is a complete and accurate representation of the status of the deferred physical inspections.
SBA’s Handling of Potentially Fraudulent Paycheck Protection Program Loans
Establish clearly defined and detailed roles, responsibilities, and processes for all SBA offices and officials responsible for managing and handling potentially fraudulent PPP loans to reduce the risk of ineligible applicants receiving PPP forgiveness and the risk of fraud and financial loss in the PPP and when implementing similar future programs.
Provide lenders formal guidance to effectively and consistently handle potentially fraudulent PPP loans and ensure lenders have sufficient guidance when implementing similar future programs.
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
The Child Tax Credit Update Portal Was Successfully Deployed, but Security and Process Improvements Are Needed
Ensure that the ELC coaches comply with existing agency requirements related to the independent verification and validation of all ELC artifacts.
Ensure that the ELC coaches comply with existing agency requirements related to the independent verification and validation of all ELC artifacts.
Ensure that the ELC coaches comply with existing agency requirements related to the independent verification and validation of all ELC artifacts.
Prioritize remediation efforts on the two noncompliant SADI system servers that have weighted noncompliance scores of less than 90 percent.
Prioritize remediation efforts on the two noncompliant SADI system servers that have weighted noncompliance scores of less than 90 percent.
Prioritize remediation efforts on the two noncompliant SADI system servers that have weighted noncompliance scores of less than 90 percent.
Ensure that only authorized approving authorities provide status updates and grant final approval of ELC artifacts during required milestone reviews.
Ensure that only authorized approving authorities provide status updates and grant final approval of ELC artifacts during required milestone reviews.
Ensure that only authorized approving authorities provide status updates and grant final approval of ELC artifacts during required milestone reviews.
Establish a formal process, which includes routine updates, to identify primary and proxy approvers for all ELC artifacts.
Establish a formal process, which includes routine updates, to identify primary and proxy approvers for all ELC artifacts.
Establish a formal process, which includes routine updates, to identify primary and proxy approvers for all ELC artifacts.
The Chief Information Officer should ensure that systems supported by the CSPs have an approved IRS ATO prior to a system’s deployment.
The Chief Information Officer should ensure that systems supported by the CSPs have an approved IRS ATO prior to a system’s deployment.
The Chief Information Officer should ensure that systems supported by the CSPs have an approved IRS ATO prior to a system’s deployment.
The Chief Privacy Officer should establish a process that complies with Office of Management and Budget requirements regarding the selection, implementation, assessment, and continuous monitoring of privacy controls.
The Chief Privacy Officer should establish a process that complies with Office of Management and Budget requirements regarding the selection, implementation, assessment, and continuous monitoring of privacy controls.
The Chief Privacy Officer should establish a process that complies with Office of Management and Budget requirements regarding the selection, implementation, assessment, and continuous monitoring of privacy controls.
The Chief Privacy Officer should ensure that formal documentation is created that shows that all the privacy controls applicable to the SADI system are properly selected, implemented, and assessed.
The Chief Privacy Officer should ensure that formal documentation is created that shows that all the privacy controls applicable to the SADI system are properly selected, implemented, and assessed.
The Chief Privacy Officer should ensure that formal documentation is created that shows that all the privacy controls applicable to the SADI system are properly selected, implemented, and assessed.
The Chief Information Officer should ensure that the Cybersecurity function validates that all required NIST physical and environmental protection and media protection controls are implemented.
The Chief Information Officer should ensure that the Cybersecurity function validates that all required NIST physical and environmental protection and media protection controls are implemented.
The Chief Information Officer should ensure that the Cybersecurity function validates that all required NIST physical and environmental protection and media protection controls are implemented.
The Chief Information Officer should ensure that the IRS prioritizes completing the processes that will validate newly built servers being placed into the production environment meet minimum compliance requirements and initiate vulnerability scanning and remediation during the server build process.
The Chief Information Officer should ensure that the IRS prioritizes completing the processes that will validate newly built servers being placed into the production environment meet minimum compliance requirements and initiate vulnerability scanning and remediation during the server build process.
The Chief Information Officer should ensure that the IRS prioritizes completing the processes that will validate newly built servers being placed into the production environment meet minimum compliance requirements and initiate vulnerability scanning and remediation during the server build process.
Ensure that all CTC Update Portal and SADI system associated POA&Ms (listed in Appendix II) are completed timely based on IRS-defined timelines and processes.
Audit of North American Aerospace Defense Command and U.S. Northern Command Use of Coronavirus Aid, Relief, and Economic Security Act Funding
Rec. 1.a: The DoD OIG recommended that the Commander, North American Aerospace Defense Command and U.S. Northern Command, develop internal controls that implement emergency funding guidance and ensure proper use of emergency authorized funds.
Rec. 1.b: The DoD OIG recommended that the Commander, North American Aerospace Defense Command and U.S. Northern Command, develop internal controls that require North American Aerospace Defense Command and U.S. Northern Command officials to retain sufficient evidence, including a clear and accurate description of the goods and services purchased, that demonstrates how those goods and services supported the specific emergency.
Rec. 2.a: The DoD OIG recommended that the Director, Budget Operations and Personnel, Office of the Deputy Assistant Secretary of the Air Force (Budget) develop and implement internal controls that verify whether current and future emergency expenses meet specific funding requirements prior to reimbursement and retain sufficient evidence of verification.
Rec. 2.b: The DoD OIG recommended that the Director, Budget Operations and Personnel, Office of the Deputy Assistant Secretary of the Air Force (Budget) conduct a review of North American Aerospace Defense Command and U.S. Northern Command CARES Act transactions 1, 3, 5, 6, 14, 16, 17, 18, 24, and 25 to determine whether the purpose statute was violated. In addition, review the remaining 472 North American Aerospace Defense Command and U.S. Northern Command CARES Act transactions, which were not part of our sample, to ensure CARES Act funds were used as intended.
Rec. 2.c: The DoD OIG recommended that the Director, Budget Operations and Personnel, Office of the Deputy Assistant Secretary of the Air Force (Budget), in coordination with North American Aerospace Defense Command and U.S. Northern Command, make the appropriate accounting adjustments for transactions 1, 3, 5, 6, 14, 16, 17, 18, 24, and 25 to non-CARES Act funding if the Director's review concludes the purpose statute was violated. The Director's review could result in the potential monetary benefits of $19.2 million (in questioned costs) and $7.4 million (in unsupported costs).
Rec. 2.d: The DoD OIG recommended that the Director, Budget Operations and Personnel, Office of the Deputy Assistant Secretary of the Air Force (Budget) determine whether any purpose statute violations result in Antideficiency Act violations based on Recommendations 2.b. and 2.c.
Rec. 2.e: The DoD OIG recommended that the Director, Budget Operations and Personnel, Office of the Deputy Assistant Secretary of the Air Force (Budget) report any resulting Antideficiency Act violations to the Secretary of the Air Force, who then reports relevant information to the President and Congress.
Evaluation of SBA’s Disaster Assistance Loan Recommendation Services
Implement procedures to ensure contracting officers use effective proposal
analysis techniques to determine prices are fair and reasonable in accordance
with FAR 15.404
Implement procedures to require contracting officers to assess compliance with
size requirements when small businesses propose using subcontractors to
perform significant work requirements.
Request a formal size determination in accordance with FAR 19.302 to evaluate
whether the loan processing contractor exceeded the size standard and remedy
any violation in accordance with 15 U.S.C. 645(d).
Implement procedures to assess prospective firms’ ability to comply with
subcontracting limitations prior to contract award.
Implement procedures to monitor post-award compliance with subcontracting
limitations.
Before exercising options or awarding additional task orders against the contract,
assess alternative contracting actions, such as pursuing another contract using
competitive procedures to ensure fair and reasonable prices. SBA should then
document the determination in the award file.
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.