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Any Recommendations
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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.
Alaska Experienced Challenges in Meeting Federal and State Foster Care Program Requirements During the COVID-19 Pandemic
We recommend that the Office of Children's Services ensure that staff are adequately trained on policies and procedures to ensure that required background checks are completed before placing children in foster homes under emergency conditions.
We recommend that the Office of Children's Services continue to identify ways to address the challenges related to meeting the requirements for conducting monthly caseworker visits and home inspections, including consulting with ACF.
We recommend that the Office of Children's Services complete home inspections in accordance with requirements for the two foster homes identified by our audit as lacking completed inspections and for the five foster homes requiring in-person inspections.
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.
Seventeen of Thirty Selected Health Centers Did Not Use or May Not Have Used Their HRSA COVID-19 Supplemental Grant Funding in Accordance With Federal Requirements
We recommend that the Health Resources and Services Administration require the 10 health centers identified in our report as having charged unallowable COVID-19 supplemental grant funding costs to refund $787,152 (less any amounts health centers voluntarily refunded as a result of our audit) to the Federal Government.
We recommend that the Health Resources and Services Administration work with the 13 health centers identified in our report that may not have properly allocated COVID-19 supplemental grant funding costs to determine what portion of the $15,056,835 is allocable to their COVID-19 supplemental grant funding and require the health centers to refund the improperly allocated funds to the Federal Government.
We recommend that the Health Resources and Services Administration assist the 17 health centers identified in our report as having charged unallowable costs or potentially improperly allocated costs to implement HRSA's guidance for developing and maintaining financial management systems and internal controls that ensure that only allowable, allocable, and documented costs are charged to their HRSA supplemental grant funding.
Montana Generally Complied With Requirements for Telehealth Services During the COVID-19 Pandemic
We recommend that the Montana Department of Public Health and Human Services develop and implement edits in its claim payment system so that the State agency pays only telehealth claims whose HCPCS codes denote the associated services as eligible to be performed via telehealth.
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.