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MSP #6: ENTERPRISE CASE MANAGEMENT (ECM)

The IRS’s ECM Project Lacks Strategic Planning and Has Overlooked the Largely Completed Taxpayer Advocate Service Integrated System (TASIS) As a Quick Deliverable and Building Block for the Larger ECM Project.

TAS Recommendations and IRS Responses

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1.

TAS RECOMMENDATION #6-1

Develop its ECM solution from the ground up by actively and comprehensively engaging all its employees and seeking their specific suggestions as to how to make processes and procedures more  efficient and maximize employee productivity in order to provide quality customer service to taxpayers.

IRS RESPONSE TO RECOMMENDATION: NTA recommendation not adopted as written, but IRS actions taken to address issues raised by the NTA. The IRS has taken efforts and is continuing to engage stakeholders and other federal partners in developing the ECM solution. The IRS agrees with the essence of the NTA’s recommendation to develop ECM solutions with users in mind, engaging employees throughout the process, and developing a solution to facilitate more efficient, standard business processes. Throughout the development of the ECM solution, the IRS is engaging employees in the process from participating in key governance forums to identifying requirements to creating an ECM communications plan that will provide channels for employees to share ideas and suggestions.

The IRS’s ECM Program is focused on developing standardized, common ECM solutions that will meet the diverse needs of the IRS this may involve using several platforms to accommodate the requirements of dozens of business units. Building on the precepts of the IRS Future State, the ECM Program engaged with IRS stakeholders to develop a program-specific vision and set of design principles that guides the development of solutions to enhance employee productivity and improve the taxpayer experience. It is also essential to create IT systems that are efficient, scalable, and maintainable over time. The ECM vision specifically highlights the importance of empowering employees to rapidly resolve cases, providing top quality service to taxpayers, and upholding the fair administration of tax law.

Collaborating with key stakeholders, the ECM Program will develop an Enterprise ECM Strategic Roadmap that will outline the desired end state capabilities. Through the development of this roadmap, impacted IT and business stakeholders including TAS will be engaged to provide inputs on their desired business capabilities and functions. The process of engaging IT and business stakeholders is still in development, but this process will be an integral part of developing the Enterprise ECM Strategic Roadmap, which will in turn drive the development of the ECM solution. For the development of ECM, IT intends to use a federated delivery team structure to guide the ECM solution this collaboration model includes the business customers, IT ECM program management office, and IT service delivery partners on an integrated team that works in partnership on a daily basis.

The ECM vision and design principles, the Enterprise ECM Strategic Roadmap, and the federated delivery team are three examples of how the IRS is committed to supporting an integrated, inclusive approach for the ECM solution and to improving IRS operations. Throughout the ECM Program, the IRS will continue to engage with employees as a more efficient ECM solution is developed to provide quality customer service to taxpayers.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate applauds the IRS for its inclusive ECM approach and for reaching out to federal agencies as part of the ECM development process. However, she believes the IRS should engage all of its front-line employees, unit by unit, and ask them, through town halls and working groups, what they specifically need to more effectively and efficiently do their jobs and serve taxpayers. The IRS can then identify tasks or capabilities that are general or common, and those that are specific to particular business functions. This is a critical step to building an ECM system that will maximize employee productivity and creating efficiencies that will benefit both the IRS and taxpayers.

The National Taxpayer Advocate is concerned because it appears the IRS may be exploring general ECM capabilities, and require business functions to adapt to those capabilities, rather than designing the ECM system around the business functions and the needs of its employees. The National Taxpayer Advocate believes that the IRS can both find out what is on the ECM product market (as products have identified general capabilities) and also determine the specific needs of its employees. The benefit of reaching out directly to all front-line employees and collating and tracking their responses, is that it will enable the IRS to identify deficiencies in its current business practices, and modify them appropriately, prior to moving forward with the programming of a new ECM system. It may be the case that some IRS business practices are driven by limited technology, in which case it can plan a change to business practices at the same time it implements new ECM technology. When TAS went through the TASIS design process, TAS learned about employee technology needs by holding dedicated town hall or workgroup meetings. TAS asked all its employees what they needed to perform their jobs efficiently, recorded their proposals and “wish lists” for capabilities, and then considered and tracked them in the development of the business requirements to see what, if anything, we could do to address them.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Closed

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

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2.

TAS RECOMMENDATION #6-2

Use TASIS and its foundational work as part of the ECM effort, for example by using TASIS modules that are adaptable for ECM.

IRS RESPONSE TO RECOMMENDATION: NTA recommendation not adopted as written, but IRS actions taken to address issues raised by the NTA. TAS initiated development on the Taxpayer Advocate Service Integrated System (TASIS) in 2010 with IRS IT and contractor support. TASIS Release 1 development was halted in March 2014 due to funding constraints. Studies conducted in 2015 and 2016 by IRS IT found the code developed for TASIS Release 1 has very limited reusability.

IRS is using the documentation and lessons learned from TASIS to inform the conceptual design and enterprise case management approach for development and delivery. Subject matter experts who worked on TASIS are actively participating in these ECM planning efforts. The marketplace of case management solutions has significantly evolved since 2010, when IT identified the COTS product used for TASIS development. The capabilities sought by TAS that previously required custom development are now integrated into many product offerings. IRS has initiated several efforts to better inform ECM, including requesting information from the industry and studying internal and external experiences of transitioning from a legacy system to a modern case management system (including TASIS). These efforts will inform the selection of new product(s) or solution(s) to support ECM. The development work done on TASIS to date is not suitable for use as a foundation for ECM efforts. The TASIS solution, as developed, will not satisfy many non-functional (technical) requirements, including those related to cybersecurity, performance, scalability, testing, and 508 compliance. The work done on TASIS to date is not suitable for use as a foundation for ECM efforts. The current software carries substantial “technical debt” (substantial rework that would need to be done to implement as designed) and security issues.

Update: TASIS was developed using a now obsolete version of a COTS software product, and the source code does not follow current case management practices.  This product is not integrated with current development tools and processes (e.g. source code management, testing, and continuous integration).  Reliance on this old platform limits the ability to maintain and upgrade the software, as numerous components were custom built for TASIS and are now obsolete. The TASIS solution, as developed, will not satisfy many non-functional (technical) requirements, including those related to cybersecurity, performance, scalability, testing, and 508 compliance.  The work done on TASIS to date is not suitable for use as a foundation for ECM efforts. Only 10-20% of business artifacts could inform ECM development, and the current software carries substantial “technical debt” (substantial rework that would need to be done to implement as designed) and security issues. As a result, there are grave concerns about the ability to integrate this system into the complex IRS IT environment if it were completed as designed.

CORRECTIVE ACTION: The IRS and the ECM program are planning to implement a set of common services that will provide standard case management features and will simplify future development to meet TAS business requirements, using up-to-date software and standardized development tools and processes. These efforts will address many of the concerns enumerated above. These services will be developed and implemented as funding and staffing priorities allow.

TAS RESPONSE: The National Taxpayer Advocate is encouraged to hear the IRS is using the documentation and lessons learned from TASIS in the ECM design process. The National Taxpayer Advocate also commends the IRS for requesting ECM information from industry and studying the experiences (both internally and externally) of how to transition from legacy to modern case management systems. While the National Taxpayer Advocate understands that the programming or code on the platform that the IRS selected for TASIS is not reusable for the current ECM project, she maintains, as described above, that the TASIS design and business requirement development process can serve as a foundation for the current ECM project. Moreover, as stated earlier, the National Taxpayer Advocate is concerned that the IRS is not acknowledging its role in making TASIS programming obsolete. In order to move forward on ECM, the IRS needs to honestly assess its own mistakes so it can avoid them in the future. The IRS’s failure to do so with respect to TASIS is deeply concerning. Nevertheless, TAS looks forward to working with the IRS and lending is case management development expertise to the ECM development effort.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Closed

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

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3.

TAS RECOMMENDATION #6-3

Provide the funding necessary to complete TASIS Release 1.

IRS RESPONSE TO RECOMMENDATION: After very careful deliberation, the IRS decided to halt development of the Taxpayer Advocate Service Integrated System (TASIS) in March 2014 and re-prioritize funding and resources. The IRS, and specifically the IRS IT organization, is under extreme pressure in regard to funding, staffing, and resources. The delivery of Filing Season, response to cybersecurity threats, implementation of core customer service initiatives, and the delivery of congressionally mandated initiatives (such as the Foreign Account Tax Compliance Act) require prioritization within a resource-constrained environment. TASIS Release 1 development was halted in March 2014 due to funding constraints, and even if funding were provided for the completion of TASIS, the system could not serve as an enterprise solution for case management due to the constraints outlined in #6-2.  If the IRS implemented TASIS as developed, it would put an obsolete system into production.  The IRS continues to be under-resourced and is challenged with balancing new investments to keep pace with technology, taxpayer expectations, criminal activity related to stolen identity/refund fraud, and preventing cybercrime. Given what we now know about the COTS product and the current state of development of the TASIS solution, completing this is not a viable option due to security and maintainability issues already discussed in #6-2.

Update: The IRS and the ECM program are planning to implement a set of common services that will provide standard case management features and will simplify future development to meet business requirements using up-to-date software and standardized development tools and processes. These efforts will address many of the concerns enumerated above. These services will be developed and implemented across the IRS—including TAS—as funding and staffing priorities allow.  The IRS has no plans to complete TASIS Release 1.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate understands the IRS’s decision not to place an obsolete case management system into production as it pursues an ECM solution that will work across the agency. However, the National Taxpayer Advocate urges the IRS to take steps to address its aging legacy systems while it develops an ECM system, which could take several years. Many of these legacy systems, such as TAS’s Taxpayer Advocate Management Information System (TAMIS) desperately need upgrading to provide effective tax administration and quality service to taxpayers.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Closed

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

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4.

TAS RECOMMENDATION #6-4

Prioritize and fund the development of an electronic OAR process.

IRS RESPONSE TO RECOMMENDATION: NTA recommendation not adopted as written, but IRS actions taken to address issues raised by NTA. The solution for an electronic Operations Assistance Request (OAR) process is understandably a high priority. The ECM program and TAS worked together in 2016 to develop scope and requirements for an ECM-based OAR solution, using functionality already developed in the now-halted Taxpayer Advocate Service Integrated System (TASIS). Analysis indicated that the IT infrastructure at the time was not sufficient to support development for both OAR and the ECM Tracking systems. Therefore, the business customer in July 2016 decided to make Tracking applications a priority and defer work on OAR.

CORRECTIVE ACTION: The IRS and the ECM program are planning to implement a set of common services that will provide standard case management features and will simplify future development to meet business requirements. These services will be developed and implemented across the IRS—including TAS—as funding and staffing priorities allow. Prioritization decisions will be made by Business and TAS stakeholders.

TAS RESPONSE: The National Taxpayer Advocate is disappointed that the IRS did not implement an electronic OAR process in 2016 but appreciates the IRS’s acknowledgement that such a process is a high priority. TAS is committed to working with the IRS on the ECM project and is offering its assistance with testing new products as the IRS designs and programs the ECM system. The National Taxpayer Advocate believes electronic OARs should be one of the first products to be programmed in the ECM project as it would benefit taxpayers, TAS, and the IRS by reducing delays in case resolution in the most urgent of cases. It would also produce resource savings by eliminating many of the current costs, including shipping, time spent by employees manually inputting and tracking OARs, and time spent physically printing and scanning OARs into other IRS tracking systems. TAS, having been through the case management testing process with TASIS, is a business unit highly capable of initially testing and evaluating new ECM products.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Closed

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

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