IRS RESPONSE TO RECOMMENDATION: The CAF Unit does not provide direct contact channels for taxpayers or representatives, and establishing a separate communication channel dedicated to CAF inquiries would require the development of new systems, processes, and staffing models. At this time, the resources necessary to implement and sustain such a capability are not available.

Tax professionals currently have access to assistance through existing service channels, including the Practitioner Priority Service (PPS), which is designed to address a broad range of account-related and authorization inquiries. The IRS will continue to evaluate opportunities to improve service within existing channels, including enhancements to training and internal processes related to CAF operations.

CORRECTIVE ACTION: N/A

TAS RESPONSE: In conversations with a wide range of tax professionals, it was clear that they have been unable to obtain timely assistance from the CAF Unit. And calls to the Practitioner Priority Service (PPS) provided limited resolution to representatives calling about authorization inquiries, as customer service representatives (CSRs) often lack the authority or information needed to address CAF issues. PPS representatives are trained as generalists in account management rather than in the complexities of the CAF system. Consequently, they are frequently unable to resolve complicated CAF processing errors, mismatches, or unexplained delays. Flooding the PPS line with either routine or urgent CAF status questions slows down resolution times for standard account inquiries. To address these challenges, TAS recommended implementing a pilot chat feature within the existing Tax Pro Account to optimize limited resources. TAS further suggested that the IRS should consider an alternative solution involving expanding the authority of PPS line CSRs, empowering them to address and resolve a broad spectrum of CAF issues instead of transferring the call to another line for assistance.

While TAS appreciates the IRS evaluating opportunities to improve service within existing channels, TAS believes the IRS needs to commit to doing more to resolve this issue and to uphold the rights to quality service and to a fair and just tax system. Allowing for quicker resolution of CAF-related issues will lead to reduced processing delays, prevent repeated resubmission of forms, and result in a more efficient tax administration system.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

DUE DATE FOR ACTION (if left open): N/A

IRS RESPONSE TO RECOMMENDATION: The CAF function has collaborated with the Robotic Process Automation (RPA) team to automate aspects of CAF processing through Taxpayer Digital Communication (TDC) submissions, thereby reducing reliance on manual transcription. A soft launch of the RPA bot for Form 8821 was implemented on February 13, 2025. A broader deployment on March 28, 2025, expanded automation to include Form 2848 and incorporated enhancements to Form 8821 processing. The IRS continues to work with the RPA team to increase the volume of submissions processed through automation within TDC.

CORRECTIVE ACTION: The CAF function has collaborated with the Robotic Process Automation (RPA) team to automate aspects of CAF processing through Taxpayer Digital Communication (TDC) submissions, thereby reducing reliance on manual transcription. A soft launch of the RPA bot for Form 8821 was implemented on February 13, 2025. A broader deployment on March 28, 2025, expanded automation to include Form 2848 and incorporated enhancements to Form 8821 processing. The IRS continues to work with the RPA team to increase the volume of submissions processed through automation within TDC.

TAS RESPONSE: TAS appreciates IRS efforts using Robotic Process Automation (RPA) to automate aspects of CAF processing. We were aware of these two improvements in early 2025; however, based on conversations with tax practitioners after the deployment of RPA, they reported continued issues. The IRS’s action focuses on TDC submissions, but our recommendation extends further, advocating for technology solutions that facilitate the digitization of paper submissions and minimize human transcription throughout the CAF process. The IRS response does not clarify how the IRS will reduce manual entry for authorizations received by mail, fax, eFax, in-person, hand delivery, or forms routed to CAF by other IRS functions. Nor does it identify expected volumes, processing-time goals, accuracy targets, reject-rate reductions, or taxpayer-centered measures showing that automation will help taxpayers obtain representation sooner. TAS supports the IRS’s use of automation, but the IRS needs to do more to ensure the initiative produces meaningful taxpayer outcomes. Partial automation of TDC submissions is welcome, but it does not yet address the broader challenges posed by the manual, error-prone CAF processing system. Perhaps, the IRS can also expand RPA technology to be used with eGain in the TDC process. TAS also suggested the IRS could improve its Enterprise File Storage system. TAS urges the IRS to further prioritize operational efficiency and service within the CAF program, including shortening authorization processing times, reducing errors, and improving service delivery.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): Ongoing

IRS RESPONSE TO RECOMMENDATION: The IRS does not agree to implement the TAS recommendation.

We appreciate the NTA’s commitment to improving efficiency and eliminating confusion in the submission process for Forms 2848 and 8821. Regrettably, and after review and careful consideration, we have determined that this recommendation cannot be adopted.

Forms 2848 and 8821 can be submitted to the IRS through: mail; traditional fax; electronic fax (eFax); in-person; hand-delivery; the Submit Forms 2848 and 8821 Online Taxpayer Digital Communication (TDC) submission portal (https://www.irs.gov/tax-professionals/submit-forms-2848-and-8821-online); and Tax Pro Account (https://www.irs.gov/tax-professionals/tax-pro-account). Ultimately, the IRS plans to fully standardize electronic signatures across the TDC and Tax Pro Account platforms, while maintaining the availability of handwritten, wet ink signatures for the traditional submission methods of mail, fax, and in-person delivery.

Regarding the electronic submission of Forms 2848 and 8821 via the TDC submission portal and Tax Pro Account, they relate to section 2302 of the Taxpayer First Act of 2019. Section 2302 requires the IRS to publish guidance to establish uniform standards and procedures for the acceptance of taxpayers’ electronic signatures on “any request for disclosure [under IRC 6103(c)] of a taxpayer’s return or return information to a practitioner” and on “any power of attorney granted by a taxpayer to a practitioner,” including Forms 2848 and 8821. In response to section 2302, the IRS implemented the TDC submission portal and accelerated implementation of Tax Pro Account to meet the statute’s requirements. Further, in connection with the mandate to establish “uniform standards and procedures,” the IRS published, in December 2019, new IRM 10.10.1, IRS Electronic Signature (e-Signature) Program, (revised in 2023 and 2024). It sets forth the IRS’s e-Signature policy, which is specifically designed for electronic transactions, such as Tax Pro Account.

The IRS continues to develop Tax Pro Account, which is fully compliant with IRS e-Signature policy, by adding new features and functionalities to meet the needs of taxpayers and tax professionals. While Tax Pro Account was in its initial development and prior to its first release, the IRS created the TDC submission portal as both an interim solution and a long-term alternative to faxing and mailing of the forms. To accommodate this new method (given the forms are not signed in electronic transactions with the IRS), the IRS adopted certain security measures: placing the portal within e-Services and specifically limiting its use to individuals with Secure Access accounts, who must first log into their accounts to use the portal and also attest that they have authenticated the taxpayer’s identity if the taxpayer electronically signs Form 2848 or 8821 in a remote transaction.

Any electronic signatures on forms submitted in-person or by mail, fax, or eFax do not comply with the IRS approved e-Signature policy because the signatures do not occur in electronic transactions with the IRS, with the ability to ensure a secure and non-repudiable event. The data elements that are captured and stored within an electronic transaction do not exist in a signed form that is not submitted electronically.

CORRECTIVE ACTION: N/A

TAS RESPONSE: TAS acknowledges the IRS’s focus on safeguarding taxpayer information and appreciates its efforts to ensure that Forms 2848 and 8821 are authenticated through secure and reliable methods. However, the IRS’s response does not address the core problem identified in this Most Serious Problem. TAS recommended the IRS standardize the acceptance of electronic signatures on Forms 2848 and 8821 across IRS channels and methods of submission. The IRS’s response instead preserves a bifurcated system in which an electronic signature may be accepted in one IRS channel but rejected when the same authorization is submitted by mail, fax, eFax, in-person, or hand delivery. This distinction perpetuates the confusion and inconsistent treatment the recommendation intended to eliminate.

Furthermore, Section 2302 of the TFA explicitly directs the IRS to establish “uniform standards and procedures” for accepting electronic signatures on authorizations like Forms 2848 and 8821. By definition, “uniform” means that the standard should be identical, consistent, and unvarying. Maintaining different signature rules based solely on the method of delivery (e.g., rejecting an e-signed document simply because it was sent via fax or mail) is not uniformity. By restricting e-signature acceptance exclusively to the Taxpayer Digital Communication (TDC) portal and Tax Pro Account, the IRS creates an inequitable system. This policy penalizes taxpayers lacking reliable, high-speed internet access, or those who face barriers with online portals. This artificial restriction contributes to high rejection rates for authorizations, delaying taxpayer representation, increasing the backlog of paper correspondence, and wasting valuable IRS customer service resources on repetitive processing tasks.

To truly fulfill the mandate of TFA Section 2302 and reduce taxpayer burden, the IRS must adopt a technology-neutral policy so that if an electronic signature meets secure, established standards, it must be accepted across all entry points, including mail and fax. TAS continues to recommend that the IRS develop and publish uniform e-signature standards for Forms 2848 and 8821, update the IRM and public guidance, train employees across all intake points and Business Operating Divisions, and monitor rejection data to ensure consistent application. While protecting taxpayer information is crucial, modern security controls and taxpayer access to representation does not have to be treated as mutually exclusive.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

DUE DATE FOR ACTION (if left open): N/A

IRS RESPONSE TO RECOMMENDATION: IRS agrees to engage in a Lean Six Sigma Opportunity (LSSO) Assessment to identify improvement opportunities in the process.

The volume of these cases is relatively limited, which may not support significant process changes. Any additional measures will be considered based on operational feasibility, resource considerations, and the need to maintain program integrity.

CORRECTIVE ACTION: IRS agrees to engage in a Lean Six Sigma Opportunity (LSSO) Assessment to identify improvement opportunities in the process.

The volume of these cases is relatively limited, which may not support significant process changes. Any additional measures will be considered based on operational feasibility, resource considerations, and the need to maintain program integrity.

TAS RESPONSE: TAS welcomes the IRS’s agreement to engage in a Lean Six Sigma Opportunity (LSSO) Assessment. However, the IRS’s justification for minimizing future action, claiming that limited case volume may not warrant significant process changes, fails to recognize the severe, compounding damage these delays inflict on taxpayers and their representatives. Program integrity should not be maintained at the expense of due process. The IRS’s focus on the “relatively limited” volume of Centralized Authorization File (CAF) suspensions ignores the catastrophic impact on the affected taxpayers. When a practitioner’s CAF number is placed in “pending review” suspension, it triggers an immediate, absolute halt on their ability to represent all of their clients. A single suspension does not impact just one case; it paralyzes a practitioner’s entire tax practice and deserves an urgent response. An unmitigated CAF suspension violates the taxpayers’ rights to retain representation and to a fair and just tax system. TAS recognizes that not every case will permit the same interim relief but urges the IRS to make this issue a priority and design a framework that balances fraud prevention with continuity of representation.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 05/01/2027

IRS RESPONSE TO RECOMMENDATION: Due to the need to protect personally identifiable information (PII) and prevent unauthorized disclosures, the IRS is limited in its ability to provide detailed notifications or direct contact with tax professionals while a CAF review is ongoing. These safeguards are necessary to ensure the integrity and security of the authorization process.

The IRS will enhance publicly available guidance on IRS.gov to better explain the CAF pending review process, including general expectations and steps tax professionals may take to facilitate resolution.

CORRECTIVE ACTION: The IRS will enhance publicly available guidance on IRS.gov to better explain the CAF pending review process, including general expectations and steps tax professionals may take to facilitate resolution.

TAS RESPONSE: TAS appreciates the IRS’s recognition that additional public guidance is needed. Clear, publicly available information can help practitioners understand the CAF pending review process and may reduce confusion. TAS also agrees that the IRS must protect personally identifiable information and prevent unauthorized disclosures while reviewing potential CAF compromise. However, the general guidance on IRS.gov is insufficient when attempting to deliver meaningful due process to a practitioner whose CAF number has been suspended or to the taxpayers who suddenly lose access to their chosen representative. The recommendation called for the adoption of standardized procedures, prompt and sufficiently detailed notices, clear instructions for resolving the issue, and access to a dedicated CAF contact. While public guidance can outline the process in broad terms, it cannot provide practitioners with the specific information needed to resolve their situation, such as what the IRS requires, the status of the review, applicable deadlines, or how quickly imminent taxpayer harm will be resolved.

The IRS can provide fair notice without disclosing protected taxpayer information, revealing sensitive investigative details, or compromising security controls. Standardized notices such as CP322 can be improved to identify a general reason category for the review, explain the specific verification steps required, identify the documents or attestations needed, provide realistic timelines, explain consequences of non-response, and provide a secure contact or escalation path. A notice can be useful and actionable while still protecting PII and safeguarding the integrity of the review. Due process in this context does not require disclosure of confidential information rather it requires transparent procedures, timely communication, and a meaningful path to resolution.

TAS remains committed to supporting safeguards that protect taxpayer data. But the IRS needs to do more to ensure those safeguards do not unnecessarily impair the taxpayer’s rights to retain representation or to quality service.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 10/01/2026

IRS RESPONSE TO RECOMMENDATION: The IRS understands the need for Tax Pro Account to provide tax professionals with a comprehensive, secure, and intuitive digital self-service they can rely on to manage their authorization relationships with taxpayers. It delivers efficient, real-time authorization management and reduced reliance on paper submission. The process for requesting and withdrawing authorizations is fast, secure, fully digital, and fully automated.

Critically, the digital authorizations submission process is secured through an end-to-end (Tax Pro Account to Individual Online Account) workflow, with user authentication and electronic signature required on each side – tax professional and taxpayer. This two-party authentication and consent model is a key safeguard that helps protect taxpayers and the IRS from unauthorized submissions and fraud. Eliminating the taxpayer’s review and approval of authorization using their online account will break the end-to-end secure process and materially weaken identity assurance and signature validation controls and is therefore not appropriate under current security requirements. Withdrawal of authorizations does not require taxpayer online account access.

CORRECTIVE ACTION: N/A

TAS RESPONSE: TAS appreciates the IRS’s commitment to a secure authorization process and agrees that taxpayer approval, authentication, and signature validation are critical safeguards. But the Tax Pro Account authorization process remains limited and continues to present usability challenges. Representatives must use other channels when clients do not have an individual online account, when the matter involves a business or other non-individual taxpayer, or when the practitioner needs functionality that Tax Pro Account does not yet provide. When representatives are forced back to TDC, mail, fax, or separate manual processes, taxpayers experience the same delays, avoidable rejections, and representation disruptions that modernization is supposed to prevent.

The IRS response largely defends the current design and explains why it does not intend to eliminate taxpayer online approval. It does not identify specific new functionality, milestones, or alternative secure pathways for taxpayers who cannot or do not access an IRS online account. An end-to-end electronic process is valuable, but it is not taxpayer-centric if many taxpayers cannot use it.

The phrase “without requiring taxpayer online account access” should not be read to mean “without taxpayer review or approval.” TAS’s recommendation is that the IRS develop additional secure consent pathways that do not depend exclusively on a taxpayer’s ability to access an IRS online account. The IRS should evaluate options such as allowing representatives to upload executed Forms 2848 and 8821 through Tax Pro Account, using electronic signature audit trails, creating time-limited taxpayer approval codes, offering secure assisted authentication, or using video-based or other real-time identity verification, where appropriate. These approaches could preserve taxpayer consent and identity assurance while reducing reliance on paper and manual processing.

TAS continues to recommend that the IRS expand Tax Pro Account with measurable milestones and taxpayer-centered alternatives that maintain security while removing unnecessary barriers. The IRS needs to do more to ensure Tax Pro Account becomes the reliable digital hub taxpayers and representatives need.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

DUE DATE FOR ACTION (if left open): N/A