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Reports
American Rescue Plan Act: Assessment of the Expanded Child and Dependent Care and Earned Income Tax Credits
On February 17, 2022, we notified the Director, Submission Processing, Wage and Investment Division, of our concern with three business rules and recommended that IRS management update the business rule programming to identify and evaluate returns for both refundable and nonrefundable CDCC claims.
Ensure that programming is updated for Processing Year 2023 to identify taxpayers who reported an obviously invalid care provider TIN on Form 2441.
Develop a tool or programming for Error Resolution to ensure that tax returns claiming prior year expenses are systemically identified to determine if the maximum CDCC had been claimed in the prior year, before processing the return and potentially releasing erroneous refunds.
Work with the Department of the Treasury, Office of Tax Policy, to advance legislation to treat a tax return as filed only when it is accepted. This would remove the legal risks associated with rejecting tax returns with conditions that indicate the taxpayer is ineligible for refundable credits claimed on the return.
If legislation is enacted, develop programming to reject e-filed returns meeting certain conditions, such as those noted in this report.
The Commissioner, Wage and Investment Division, should ensure that the compliance filter criteria for identifying individuals claiming self-only EITC who are not eligible for work is updated to include the *************************.
The Commissioner, Wage and Investment Division, should establish processes to compare subsequent legislative changes with compliance filter
programming to identify and make necessary changes, as needed.
The Commissioner, Wage and Investment Division, should review the 774,559 returns with self-only EITC from potentially ineligible ******** and take actions needed to recover credits that are determined to be erroneous.
The Commissioner, Wage and Investment Division, should complete examinations for all 61 tax returns we identified to ensure taxpayers receive the correct CDCC amounts.
American Rescue Plan Act: Review of the Reconciliation of the Child Tax Credit
Review all of the 6,833 taxpayers with excess Child Tax Credit identified during our review and take appropriate actions to ensure that the taxpayers receive the correct amount of the Child Tax Credit.
Identify additional taxpayers after May 5, 2022, who received excess Child Tax Credit as a result of tax examiner error and take appropriate actions to ensure that these taxpayers receive the correct amount of the Child Tax Credit.
Review the 105 taxpayers who potentially did not receive all of their eligible Child Tax Credit identified during our review and take appropriate actions to ensure that they receive the correct amount of the Child Tax Credit.
Evaluate the priority of programming to ensure that processes and procedures are developed to identify and correct tax examiner entries input during the error correction process that exceed statutory limits, including a process to systemically reprocess corrected returns through Error Resolution programming before being released for processing.
On February 17, 2022, we notified IRS management of our concerns with undeliverable payments that post after the processing of the tax return. In these instances, the IRS processed the tax return as if the payment was received by the taxpayer. As a result, the taxpayer would receive less Child Tax Credit than they are eligible to receive. We recommended that the IRS develop a process to identify undeliverable payments after
processing of the TY 2021 tax return.
Identify taxpayers with advance payments who have yet to file a TY 2021 tax return and send a reminder notice, similar to the Department of the Treasury, using the advance payments as part of the criteria.
Work with the Commissioner, Small Business/Self-Employed Division, to create a process to recover potentially erroneous advance payments from taxpayers who have not filed a TY 2021 tax return.
American Rescue Plan Act: Continued Review of Premium Tax Credit Provisions
The Commissioner, Wage and Investment Division, and the Commissioner, Small Business/Self-Employed Division, should consider expanding the use of soft notices to address potentially erroneous PTC claims. These notices should provide individuals with information specific to the eligibility or reporting requirements related to the potential error the IRS identified and suggest the filing of an amended return, if an error has
occurred.
The Commissioner, Wage and Investment Division, should notify the 317,418 taxpayers we identified, who potentially received less PTC than they were entitled or repaid more APTC than required, that they may qualify for additional PTC or overpaid APTC and encourage them to file an amended Tax Year 2021 return, if applicable.
The Commissioner, Wage and Investment Division, should notify the 317,418 taxpayers we identified, who potentially received less PTC than they were entitled or repaid more APTC than required, that they may qualify for additional PTC or overpaid APTC and encourage them to file an amended Tax Year 2021 return, if applicable.
The Commissioner, Wage and Investment Division, should develop processes, such as the use of courtesy letters to notify individuals of their potential eligibility, to proactively assist taxpayers who, based on available tax return and Exchange data, potentially claimed less PTC than entitled or paid more APTC than required.
The Commissioner, Wage and Investment Division, should develop processes, such as the use of courtesy letters to notify individuals of their potential eligibility, to proactively assist taxpayers who, based on available tax return and Exchange data, potentially claimed less PTC than entitled or paid more APTC than required.
On October 26, 2022, we notified the Director, Submission Processing, of our concerns regarding taxpayers who are potentially eligible for additional PTC based on their unemployment status during Tax Year 2021. We recommended that the Director, Submission Processing, notify these taxpayers that they may qualify for additional PTC or be able to reduce the amount of excess APTC they must repay and encourage them to file an amended Tax Year 2021 return, if they qualify.
On October 25, 2022, we notified the Director, Submission Processing, of our concerns with the draft Tax Year 2022 Form 8962 instructions. We
recommended that the IRS revise the instructions to inform taxpayers that they have an option to set a domestic violence indicator on their tax return.
Recurring Identification Is Needed to Ensure That Employers Full Pay the Deferred Social Security Tax
The Commissioner, Small Business/Self-Employed Division, should ensure that the 3,231 tax accounts are updated to reflect the correct balance due.
The Commissioner, Small Business/Self-Employed Division, should continue to identify new tax accounts with a Social Security tax deferral at least through Calendar Year 2024 to ensure that all unpaid deferrals are identified for collection as appropriate.
Additional Actions Are Needed to Reduce Accounts Management Function Inventories to Below Pre‑Pandemic Levels
Ensure that all sites understand and begin immediately stamping the ICT received date after correspondence screening is completed, and that individual and business documents are screened with equal importance.
Coordinate with the Information Technology organization to explore adding Taxpayer Relations inventories into the CII, so that all Accounts Management inventory is located in the same inventory management system.
The Commissioner, Wage and Investment Division, should establish time frames for and a process to measure correspondence screening timeliness at each site.
The Commissioner, Wage and Investment Division, should rescind the requirement that only the TEs and the CSRs perform correspondence
screening and encourage all sites to use mail clerks, after providing them with adequate training.
The Commissioner, Wage and Investment Division, should ensure prompt completion of the ICT review to determine if additional scanners will be
purchased.
Discontinue correspondence screening via telework and ensure at all sites that screening must be conducted in the same IRS facility where documents are being scanned by the ICT.
Identify and address the cause of Accounts Management function employees incorrectly routing cases to other IRS functions and work with other IRS functions to update their Internal Revenue Manuals to make it clear that incorrectly routed documents should be returned to the
originating employee.
We recommended that management take steps to hire as many mail clerks as possible.
The Commissioner, Wage and Investment Division, should establish goals for each of the Accounts Management function’s inventory types and develop a plan for addressing those goals to ensure a timely return to pre-pandemic inventory levels.
The Commissioner, Wage and Investment, should prioritize funding and implementation of automated processing of Forms 1040-X to increase efficiencies and reduce taxpayer burden.
The Commissioner, Wage and Investment Division, should implement temporary solutions for the processing of Forms 1040-X to reduce the backlogs, reduce taxpayer burden, and save IRS resources until an automated solution is implemented.
Coordinate with the Information Technology organization to prevent generating transcripts for manual refunds less than $100 and adjust the frequency that some transcripts are generated to help management get through the inventory more efficiently.
Temporarily relieve employees in the Accounts Management function from having to complete paperwork for barred statutes, so they can focus on eliminating the backlogged inventory and prevent future barred statutes.
PBGC Should Improve Its Special Financial Assistance Review Procedures
Design specific procedures for the SFA program to ensure (1) appropriate in-depth analysis and review of exceptions, as well as consistent review of historical data for outliers, one-time items and other anomalies, and (2) ensure the review and decision-making process for exceptions and historical data is fully documented in the concurrence package.
University of Cincinnati’s Use of Higher Education Emergency Relief Fund Student Aid and Institutional Grants
Require the University of Cincinnati to develop and implement a review process to prevent or detect payment errors when awarding emergency financial aid grants to students, including written policies and procedures detailing how the reviews shall be conducted and the results documented, in accordance with 2 C.F.R. section 200.303.
Require the University of Cincinnati to develop and implement written policies, procedures, and management review to ensure that its award determinations, eligibility criteria, and management decisions related to eligibility for its emergency financial aid grants to students are adequately documented and supported at the time award decisions are made, in accordance with 2 C.F.R. section 200.302(b)(3).
Require the University of Cincinnati to carefully document how its student aid eligibility criteria prioritized and continues to prioritize students with exceptional need throughout the HEERF grant performance period.
Require the University of Cincinnati to develop and implement written policies and procedures, including procedures that would identify and prevent improper revenue recognition and duplicate charges, to ensure that future calculations for charging lost revenue to its HEERF Institutional grant are reviewed for accuracy and consistency with its financial reporting policies and procedures.
Determine whether the University of Cincinnati implemented appropriate corrective actions to resolve the $797,965 in unsupported lost revenue costs it charged to its HEERF Institutional grant; and, if the corrective actions are inappropriate, require the University to either return the funds to the Department or reallocate the funds for allowable expenditures.
Determine whether the $1,916,041 that the University of Cincinnati charged to its HEERF Institutional grant for noncompetitive procurements was reasonable when compared to the costs of suitable alternatives; and, if the charges were inappropriate, require the University to either return the funds to the Department or reallocate the funds for allowable expenditures.
Require the University of Cincinnati to develop and implement written policies and procedures to ensure that procurements charged to its HEERF Institutional grant are in accordance with applicable Federal requirements; and it consistently follows its procurement policies and procedures, including maintaining sufficient documentation to support its rationale for noncompetitive procurements and the basis for and reasonableness of the contract price.
Require the University of Cincinnati to incorporate in its policies and procedures and implement the cash management requirements for minimizing the time between drawing down and disbursing Federal grant funds, and remitting interest earned in excess of $500 in accordance with 2 C.F.R. section 200.305(b).
Require the University of Cincinnati to remit $35,439 based on the TIP’s average rate of return, less no more than $320 ($500 minus the $180 already retained) for administrative expenses if applicable; and remit the actual amount of earned interest on any future advances of Federal funds, in accordance with 2 C.F.R. section 200.305(b)(9).
Require the University of Cincinnati to develop and implement written policies and procedures that incorporate the HEERF program’s reporting requirements and ensure that the expenditures in its quarterly HEERF Institutional expenditure reports are accurate and reported in the appropriate expenditure category.
Reporting on the Use of Coronavirus Response Funding Could Be Enhanced
The Chief Financial Officer should evaluate the feasibility of expanding the information captured in the IRS’s financial tracking system to include tracking budgeted and dedicated staffing by spend plan requirement area for future sources of supplemental funding.
American Rescue Plan Act: Accuracy of Advance Child Tax Credit Periodic Payments
As detailed previously, we provided the Director, Return Integrity and Compliance Services, Wage and Investment Division, with notifications and files detailing erroneous payments we identified and recommended that the IRS evaluate the discrepancies to identify why the payments were made to prevent additional periodic payments to ineligible taxpayers. In addition, we recommended that the IRS add a stop payment
transaction code to taxpayer accounts to prevent them from receiving additional improper advance Child Tax Credit payments.
On August 9, 2021, we notified the Director, Return Integrity and Compliance Services, Wage and Investment Division, of our concerns related to
eligible taxpayers who did not receive their advance Child Tax Credit payments. We recommended that the IRS evaluate the discrepancies to identify why periodic payments were not made to eligible taxpayers.
On June 29, 2021, we notified the Director, Return Integrity and Compliance Services, Wage and Investment Division, that the messaging provided on the IRS’s eligibility assistant tool and the presentation of information related to the advance Child Tax Credit payments on IRS.gov may be confusing to taxpayers. For example, the link to “Get Answers on the Advance Child Tax Credit” that is located on the IRS.gov main page takes taxpayers to the Advance Child Tax Credit Payments in 2021 web page; however, the links to get the questions and answers is at the bottom of the screen. We recommended that the IRS consider revising the messaging and presentation of information on its platforms to make it clear for taxpayers.
On January 28, 2022, we notified the Director, Return Integrity and Compliance Services, Wage and Investment Division, that we identified 2.2 million taxpayers who had their direct deposit information updated by the IRS between August 23 and October 5, 2021. We recommended that the IRS conduct an outreach effort to inform taxpayers of the possibility that their advance payments may have been sent to payroll allotment accounts. This outreach effort could include sending a separate letter to the impacted taxpayers.
The Director, Return Integrity and Compliance Services, Wage and Investment Division, should develop and implement processes and procedures to include data validation on incoming files from third-party sources prior to their use.
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.