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Management Challenges
Any Recommendations
Any Open Recommendations
Reports
Delays Continue to Result in Businesses Not Receiving Pandemic Relief Benefits
On November 22, 2021, we notified the Director, Customer Account Services, Wage and Investment Division, that IRS employees were erroneously suspending Forms 941-X when the amended employment tax return did not include an adjustment to the amount of deferred Social Security tax. We recommended that the Accounts Management function immediately review the Forms 941-X that are identified in the suspense inventory as an adjustment to the amount of deferred Social Security tax to ensure that they are categorized properly.
The Commissioner, Wage and Investment Division, should evaluate the current inventory of backlogged claims related to pandemic relief and develop specific plans to prioritize claims and develop timelines to process backlogged claims.
The Commissioner, Wage and Investment Division, should review the 928 business entities identified that do not appear to qualify as an RSB and take actions needed to recover the ERCs that are determined to be erroneous.
The Commissioner, Small Business/Self-Employed Division, should identify all fourth quarter Tax Year 2021 paper-filed Forms 941 processed prior to when the programming was implemented and identify amended employment tax returns receiving the ERC for which there was no indication that the business was an RSB and take actions needed to recover the ERCs that are determined to be erroneous.
On May 13, 2021, we notified the Director, Examination, Small Business/Self-Employed Division, about the inconsistent referral criteria and recommended that the IRS update referral criteria to include Forms 941-X with refundable credits.
On November 23, 2021, we alerted the Director, Customer Account Services, Wage and Investment Division, that Forms 941-X were not being referred to Examination as required and recommended that the Accounts Management function provide additional guidance to its employees to reinforce established CAT-A referral criteria.
The Commissioner, Wage and Investment Division, should review the 41 Form 941-X claims identified with a nonrefundable COVID-19 related employer credit that meet CAT-A referral criteria and take actions needed to recover credits that are determined to be erroneous.
Provide additional training to employees as it relates to referring Forms 941-X to Examination for review.
Submit a request for the development of a systemic process to identify Form 941-X claims that meet referral criteria and alert the Accounts Management employee when processing these claims of the need to refer the return to Examination.
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.
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
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 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.
American Rescue Plan Act: Implementation of Advance Recovery Rebate Credit Payments
The Commissioner, Large Business and International Division, should coordinate with the territories to share information that will enable the territories to recover duplicate payments that the territories have issued, to the extent permitted under the relevant territory’s domestic law.
If Congress enacts additional stimulus payments, the Commissioner, Wage and Investment Division, should consider additional programming changes to prevent ineligible individuals from receiving advance payments, including individuals claimed as dependents or dependents claimed on multiple returns, nonresident individuals, individuals who had a filing status or filing partner change, deceased individuals, and individuals affected by the mentioned related programming errors.
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.
American Rescue Plan Act: Assessment of Processes to Identify and Address Improper Child and Dependent Care Credit Claims
The Commissioner, Wage and Investment Division, should update processes to *****2***** from Form 2441 the care provider’s **2********************2*******************, and the amount paid to the care provider.
The Commissioner, Wage and Investment Division, should update paper verification processes to generate errors in the Error Resolution System when the ****************2****************, or amounts paid to the care provider are missing
The Commissioner, Wage and Investment Division, should revise Form 2441 to include checkboxes to note whether dependent care expenses are for a spouse or dependent who is physically or mentally incapable of caring for themselves or if special deemed earned income rules apply.
The Commissioner, Wage and Investment Division, should develop a process to identify tax returns with adult **********2********** **************************2*****************************. These tax returns should be considered for selection for post-refund compliance reviews.
The Commissioner, Wage and Investment Division, should work with the Department of the Treasury, Office of Tax Policy, to obtain the legal authority to disallow the Child and Dependent Care Credit (CDCC) when the primary or secondary taxpayer is identified by an ***2*** Individual Taxpayer Identification Number (ITIN) on Form 2441
The Commissioner, Wage and Investment Division, should develop a process to identify tax returns with ***2*** Individual Taxpayer Identification Numbers (ITINs) used to identify the care provider. These tax returns should be considered for selection for post-refund compliance review.
The Commissioner, Wage and Investment Division, should revise Form 2441 instructions and Publication 503, using examples, so taxpayers may better understand the requirements for qualifying care and expenses
The Commissioner, Wage and Investment Division, should develop a process to identify tax returns with care provider ****************************************************2******************************. These tax returns should be selected for post-refund compliance review.
The Commissioner, Wage and Investment Division, should coordinate with the Small Business/Self-Employed Division to develop a compliance plan for post-refund treatment of cases involving **********************2********************************************** ****************************************************2********************************************** ****************************************************2**************************************************2***