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State/Local Agency
State (State and Local Reports)
Fraud Type
Agency Reviewed
Related Organizations
Management Challenges
Any Recommendations
Any Open Recommendations
Reports
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.
FDIC Examinations of Government-Guaranteed Loans
Develop and implement guidance to examination staff on the credit, operational (including fraud), liquidity, and compliance risks related to Government-guaranteed loans to ensure staff adequately plans and conducts examinations to identify and address emerging risks.
Develop and implement a training plan to ensure examination staff are trained on the requirements and risks of Government-guaranteed loan programs.
Update, develop, and distribute to FDIC examination personnel a list of FDIC examiners who have significant experience examining banks that specialize in Government-guaranteed loan programs to regional offices.
Develop and implement a process to obtain improved data regarding Government-guaranteed lending activities of FDIC-supervised financial
institutions.
Update the [redacted] MOU to include the sharing of loan portfolio information such as historical loan performance, status of guaranty, and loan-level risk characteristics.
Establish arrangements with other Federal agencies that administer Government-guaranteed loan programs to facilitate information sharing and
proactive identification of risk.
Develop and implement processes and procedures for the routine sharing, receipt, and storage of confidential information with Federal agencies that administer Government-guaranteed loan programs.
Develop and implement guidance to provide instruction to FDIC bank examination staff requiring communication and information sharing with Federal agencies that administer Government-guaranteed loan programs to ensure FDIC staff and the Federal agencies are aware of any emerging risks.
Determine whether other Federal agencies that administer Government-guaranteed loan programs have a list of FDIC-supervised banks with high risk factors associated with such programs and develop protocols to share information with relevant FDIC personnel, including examiners.
Develop and implement guidance to ensure relevant risk information exchanged with Federal Government agencies that administer Government-guaranteed loan programs is shared internally within the FDIC on an ongoing basis with the appropriate FDIC employees.
Develop and implement updated FDIC examination guidance to establish an appropriate timeframe for uploading complete supervisory business records to RADD.
Develop and implement guidance to examination staff to ensure the staff consistently evaluate Government-guaranteed loans in their review of loan classification, assessment of off-balance sheet risk, concentration risk, and ongoing monitoring.
Update and implement the Examination Profile Script to include additional questions on financial institution participation in Government-guaranteed loan programs in order to identify and address emerging risk.
Develop and implement additional items to the Safety and Soundness Request List to identify Government-guaranteed loans, the performance of those loans, and status of the guaranty.
Issue and implement guidance to require that examination staff conduct a fraud risk assessment on future Government-guaranteed loan programs involving FDIC-insured and FDIC-supervised financial institutions to inform policy decisions.
Ensure guidance on future Government-guaranteed loan programs includes all risks associated with such programs and has instructions to allow for consistency in supervisory activities.
Issue and implement guidance for examiners clarifying the FDIC supervisory expectations for reviewing bank PPP activities, including the level of PPP loan volume triggering a heightened review, how examiners should assess the PPP activities of banks that have existing BSA/AML weaknesses, and protocols for examination staff to communicate observed weaknesses.
Revise and implement FDIC guidance and practices for assessing concentrations and loan classification to ensure uniform application with the other Federal bank regulators of supervisory approaches to banks
Coordinate with the other Federal bank regulators to ensure uniform application of supervisory approaches to banks regarding concentrations and loan classification.
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.
The Bureau of Indian Affairs Great Plains Region Did Not Oversee CARES Act Funds Appropriately
We recommend that the BIA Great Plains Region develop and implement a process to acquire the delinquent CARES Act Federal Financial Reports and Annual Narrative Reports identified in the Attachment of this management advisory.
We recommend that the BIA Great Plains Region develop a process to identify and address any other delinquent CARES Act Federal Financial Reports and Annual Narrative Reports.
We recommend that the BIA Great Plains Region develop and implement written policies and procedures that describe the roles and responsibilities of BIA officials and the review processes for Federal Financial Reports and Annual Narrative Reports to ensure submitted reports are complete, accurate, and address areas of concern.
We recommend that the BIA Great Plains Region in accordance with developed and implemented written policies and procedures, provide and track annual training for BIA officials responsible for reviewing Federal Financial Reports and Annual Narrative Reports.
The Omaha Tribe Did Not Account for CARES Act Funds Appropriately
We recommend that the BIA resolve the unreasonable hazard pay costs of $29,574 by requiring the Omaha Tribe to perform an analysis of the costs incurred to applicable criteria and document its determination of reasonableness.
We recommend that the BIA resolve the questioned hazard pay costs of $27,841 for Payment 1 by requiring the Omaha Tribe to provide detailed reconciliation of incurred costs to supporting documentation.
We recommend that the BIA resolve the questioned costs of $182,388 for Payment 2 by requiring the Omaha Tribe to provide detailed complete supporting documentation for the hazard pay and indirect costs.
We recommend that the BIA review the Omaha Tribe’s revised policy regarding the custody of checks and document that proper controls have been implemented.
We recommend that the BIA resolve the questioned costs of $42,067 by requiring the Omaha Tribe to provide a detailed list of the questioned transactions and voided checks to the BIA for its files to ensure these transactions are not claimed for reimbursement.
We recommend that the BIA resolve the questioned costs of $10,792 by requiring the Omaha Tribe to reallocate these costs to the appropriate funding source.
We recommend that the BIA require the Omaha Tribe to revise its policy to ensure a complete property record for CARES Act-funded assets in accordance with 2 C.F.R. § 200.313(d)(1).
Backlogs of Tax Returns and Other Account Work Will Continue Into the 2023 Filing Season
The Bureaus of Indian Affairs and Indian Education Have the Opportunity To Implement Additional Controls To Prevent or Detect Multi-dipping of Pandemic Response Funds
We recommend that the Bureaus of Indian Affairs and Indian Education develop and implement policies, procedures, or guidance designed to prevent or detect <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
We recommend that the Bureaus of Indian Affairs and Indian Education communicate the policies and procedures developed and train bureau personnel and Tribes on preventing and detecting <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
We recommend that the Bureaus of Indian Affairs and Indian Education develop and implement policies, procedures, or guidance designed to prevent or detect <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
We recommend that the Bureaus of Indian Affairs and Indian Education develop and implement policies, procedures, or guidance designed to prevent or detect <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
We recommend that the Bureaus of Indian Affairs and Indian Education develop and implement policies, procedures, or guidance designed to prevent or detect <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
We recommend that the Bureaus of Indian Affairs and Indian Education communicate the policies and procedures developed and train bureau personnel and Tribes on preventing and detecting <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
We recommend that the Bureaus of Indian Affairs and Indian Education communicate the policies and procedures developed and train bureau personnel and Tribes on preventing and detecting <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
We recommend that the Bureaus of Indian Affairs and Indian Education communicate the policies and procedures developed and train bureau personnel and Tribes on preventing and detecting <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
The Social Security Administration’s Enumeration Services During the COVID-19 Pandemic
Develop and periodically conduct comprehensive refresher training on topics including but not limited to:
- processing original Social Security Number (SSN) cards for individuals aged 12 or older and emphasize requirements and documentation of the in-person interview;
- acceptable forms of evidentiary documents, and
- processing new (different) and replacement SSN cards when adoption
Complete the privacy assessments for the WorkTrack application.
Update quality control reviews to include comparison of SSNAP inputs to an applicant-submitted Form SS-5 and evidentiary documents, and provide feedback to the technicians who made input errors (such as race and ethnicity) or did not use the appropriate evidentiary documents.
Revise enumeration policy to include clear instructions for when Form SSA-5002 is required and how to properly document the form.
Update Program Operations Manual System (POMS) to provide current instructions for enumeration notices and archive outdated policy.
Retain enumeration notices in the Online Retrieval System for individuals with assigned SSNs.
Create and implement automated tools to assist staff in navigating through enumeration evidentiary document requirements.
Take corrective action on all keying errors and cross-referencing errors we identified.
Require managers to verify that incident reports are submitted through the Personally Identifiable Information (PII) Loss Reporting Tool before they approve reimbursement to customers for replacing lost original documents.
Update the National Mail Handling Business Process to include standard Agency-wide mitigation steps for misdirected mail including original documents.
The Three Affiliated Tribes Did Not Account for CARES Act Funds Appropriately
We recommend that the BIA resolve the questioned costs of $237,270 by requiring the Three Affiliated Tribes to provide supporting documentation to ensure that the incurred costs are allowable, allocable, and reasonable.
We recommend that the BIA require the Three Affiliated Tribes to establish controls to ensure that it can determine the appropriate funding source for each CARES Act expense.
We recommend that the BIA resolve the questioned costs of $106,280 by creating and adjusting journal entries to reallocate the funds from the U.S. Department of the Interior to the U.S. Department of Health and Human Services.
We recommend that the BIA resolve the questioned costs of $89,623 by creating adjusted journal entries to reallocate the funds from the BIA CARES Act to the appropriate funding source.