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MSP #7: ONLINE ACCOUNTS

Research into Taxpayer and Practitioner Needs and Preferences Is Critical As the IRS Develops an Online Taxpayer Account System

TAS Recommendations and IRS Responses

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1.

TAS RECOMMENDATION #7-1

By mid-2017, make available at least 24 months of payment history, rather than only 18 months, on the online account in order to provide information necessary for refund claims.

IRS RESPONSE TO RECOMMENDATION: IRS actions to be adopted/addressed if resources and budget allow. During the initial development of a payment module, the 18-month window was chosen to provide taxpayers with a full year’s worth of payment history, including up through the filing extension deadline. This was the parameter set for the minimum viable product for payment information. Follow up payment work will extend the payment history window through 7 years of historical payments.

Initial payment information was made available to taxpayers through Online Account on March 5, 2017. Additional years of history are estimated to be available in Fall 2017, however the timing of when this functionality can be delivered is dependent on resources and other competing priorities (e.g., tax law changes, etc.).

Update: Extending the length of time the payment history is available to users from 18 months to 24 months was deployed in the August 2018 online account update. Future enhancement includes displaying up to 60 months of payments but has not yet been planned for development due to reprioritization of additional functionality and resource constraints. Our longer-term vision includes programming that would make it easier for customers who have a large volume of payments to view a list of payments in a format that would be easy to use on most devices. Currently customers can access their full payment history and other account activity while they’re logged into the Online Account application by selecting the Get Transcript feature.  They can view, print, or download this information for multiple years.

CORRECTIVE ACTION: Initial payment information was made available to taxpayers through Online Account on March 5, 2017. Additional years of history are estimated to be available in Fall 2017, however the timing of when this functionality can be delivered is dependent on resources and other competing priorities (e.g., tax law changes, etc.).

Update: Extending the length of time the payment history is available to users has been identified as a priority.  This enhancement includes displaying up to 60 months of payments but has not yet been planned for development due to reprioritization of additional functionality and resource constraints. Our longer-term vision includes programming that would make it easier for customers who have a large volume of payments to view a list of payments in a format that would be easy to use on most devices. Currently customers can access their full payment history and other account activity while they’re logged into the Online Account application by selecting the Get Transcript feature.  They can view, print, or download this information for multiple years.

TAS RESPONSE: The National Taxpayer Advocate is encouraged by the IRS’s commitment to expand the payment history provided on the online account. We understand that IRS resources are scarce, but we firmly believe that taxpayers have the right to be informed of at least two years of payment history in order to file accurate refund claims. By not providing such information, the IRS is also jeopardizing the taxpayer’s right to pay no more than the correct amount of tax. Accordingly, we believe the IRS should prioritize this feature because it should have already been included in the minimum viable product.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Closed

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

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2.

TAS RECOMMENDATION #7-2

By mid-2017, provide a link on the payments page of the online account to give the taxpayer an option, other than paying the tax, to dispute the balance due shown. The IRS should provide a button on the payment page indicating “I don’t think I owe this amount.” Once the taxpayer selects this option, the IRS should provide links for different options, including: amending a return, audit reconsideration, refund claims, penalty abatement, innocent spouse, injured spouse, identity theft, return preparer fraud, and doubt as to liability offer in compromise.

IRS RESPONSE TO RECOMMENDATION: NTA recommendation not adopted as written, but IRS actions taken to address issues raised by the NTA. The IRS is in the process of user testing recommendations and alternate design options provided by the NTA to determine an implementation that will help taxpayers find the information they are looking for when they believe they do not owe the amount showing as their balance due. The results of the user tests will drive the ultimate design decision however, we expect this to be an ongoing and iterative process, so we will continue to monitor the information provided to determine usage and understanding once it is in production.

Update: Dispute button – the online account teams developed a balance assistance FAQ that enables users to better understand factors that may have impacted their balance.  We confirmed the design for this feature through multiple rounds of user testing.  The Program Increment 11 release added a link in the cumulative balance module to find out more information, taking users to additional details and links.  The content was developed with TAS input and finalized by W&I.  The designs were shared with executives (including TAS representatives) on September 19, 2017 and the executive demo (including TAS) was held on October 10, 2017.  This feature was deployed with the Program Increment 11 release 10/29/17.

CORRECTIVE ACTION: The IRS is in the process of user testing recommendations and alternate design options provided by the NTA to determine an implementation that will help taxpayers find the information they are looking for when they believe they do not owe the amount showing as their balance due. The results of the user tests will drive the ultimate design decision however, we expect this to be an ongoing and iterative process, so we will continue to monitor the information provided to determine usage and understanding once it is in production.

TAS RESPONSE: TAS appreciates the IRS’s willingness to include us in the design decision-making process. While the recommended button did not test well, we appreciate the IRS’s continuing initiatives to address this void in the current state of the account. If the goal of the online account is to reduce phone calls, it is in the IRS’s best interest to develop something to address those taxpayers who do not agree with the balance due shown. If not, taxpayers will continue to call the IRS to understand their options. Furthermore, the absence of this information on the online account application jeopardizes the taxpayer’s rights to be informed, to quality service, and to pay no more than the correct amount of tax.

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 #7-3

Work collaboratively with the National Taxpayer Advocate to review the recommendations of participants in the 2016 National Taxpayer Advocate Public Forums, the 2016 IRS Nationwide Tax Forum TAS Focus Groups, as well as the findings of TAS and third party research, and address the public’s recommendations in the plans for the online account.

IRS RESPONSE TO RECOMMENDATION: The IRS is working collaboratively with the NTA to prioritize, collect, and synthesize Taxpayer Experience research. As an active member of this group, TAS is invited to share the recommendations and outcomes of the 2016 NTA Public Forums with a broad group of IRS research directors. We have also worked with TAS to identify the research that has been conducted and to locate the transcripts and narratives that could best inform features and development for individual Account and Tax Pro Account applications.

CORRECTIVE ACTION:  N/A

TAS RESPONSE: We appreciate the IRS’s willingness to collaborate with TAS as it rolls out new online account features and capabilities. We look forward to a continued collaboration in the future. However, the National Taxpayer Advocate is concerned that, based on the IRS’s response, it is clear the IRS has not reviewed the transcripts from the National Taxpayer Advocate Public Forums or any TAS research studies on this topic.

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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TAS RECOMMENDATION #7-4

Conduct research, in consultation with the NTA, using a variety of methods (online, landline and cell phone) into taxpayer and practitioner service needs and preferences for the various existing and proposed service channels by type of transaction, with acknowledgement that the taxpayer may choose multiple service channels to resolve a single issue.

IRS RESPONSE TO RECOMMENDATION: ​The IRS conducts numerous research efforts using a variety of methodologies, approaches, and techniques to assess taxpayer and practitioner service needs and preferences using best practices from the research community. For example, we conduct an annual Taxpayer Experience Survey that uses a mix of multiple-choice and open-ended questions with a broad cross-section of the U.S. population (including via telephone and online). The IRS also uses conjoint studies to better understand tradeoffs between specific services, channels, and attributes, as described in the NTA Report to Congress. The cadre of research tools employed by the IRS is not limited to online, landline, and mobile methods. The IRS also uses (but is not limited to) qualitative and quantitative research methods that uncover taxpayer preferences, attitudes and behaviors, as well as historical and predictive analytics.  The IRS recognizes the diverse service channels that taxpayers and practitioners desire and choose to engage with the IRS and employs the best suited research methods to understand the taxpayer experience regardless of the channel used. The IRS will work with the NTA on the prioritization and design of upcoming research endeavors through participation in the RAAS Taxpayer Experience working group, and will share research results, as appropriate.

CORRECTIVE ACTION: N/A

TAS RESPONSE: As discussed in more detail in the Most Serious Problem, TAS does not support the research methodology of several IRS research studies on this topic. Therefore, we encourage the IRS to analyze the findings of TAS research on Taxpayers’ Varying Abilities and Attitudes Toward IRS Taxpayers Service: The Effect of IRS Service Delivery Choices on Different Demographic Groups. This nationwide survey of U.S. taxpayers was conducted entirely by telephone (landline and mobile). The results will help the IRS to track preferred service channel by service need or task.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

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

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5.

TAS RECOMMENDATION #7-5

Incorporate into the Future State vision realistic expectations for access to and use of the online account application given robust e-authentication measures.

IRS RESPONSE TO RECOMMENDATION: NTA recommendation not adopted. The IRS has already made many improvements that expand access to the authentication process, including the ability to receive a pin by mail, corrections to technical errors, and improved business rules that allow more users to verify their identity.

As plans for new features come about based on user research and input from the taxpayer community, these new features will be balanced with a mix of services provided by other channels, including the phone and walk-in services. The IRS deployed the initial Online Account platform with basic features.  These features provide account-based services that many customers would otherwise call, write, and visit IRS to resolve.  The intent of the Future State is not to drive all customers to the web, but to recognize where a digital delivery can alleviate the pressures put on these other channels and free them up to address more serious and complicated problems with in person or phone support.

It is important to recognize that the initial launch of Online Account laid the foundation for future online capabilities.  IRS recognizes that Online Account will be a key component in achieving the Future State and is looking to leverage the ongoing partnership with TAS to gain perspectives on customer service.

CORRECTIVE ACTION: N/A

TAS RESPONSE: We are encouraged by the IRS’s acknowledgement that the online account application will be just one of many service options available to taxpayers. If the intent of the application is to alleviate the pressures put on other service channels, the IRS must also acknowledge, when allocating resources among the various service channels, that an overwhelming majority of taxpayers will not be able to open accounts due to necessary e-authentication requirements by individuals attempting to create accounts.

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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6.

TAS RECOMMENDATION #7-6

Limit access to the online account to only those practitioners who are subject to Circular 230 oversight.

IRS RESPONSE TO RECOMMENDATION: ​NTA recommendation not adopted as written, but IRS actions taken to address issues raised by the NTA. A cross-functional IRS team, including members from the TAS, is currently working on analysis and policy planning for tax professional account features. As a result of the team’s findings, we will make determinations based on legal requirements, procedural guidelines, and business needs, to improve taxpayer services. Upon completion of the study and analysis of findings, the IRS will take this recommendation under consideration.

CORRECTIVE ACTION: A cross-functional IRS team, including members from the TAS, is currently working on analysis and policy planning for tax professional account features. As a result of the team’s findings, we will make determinations based on legal requirements, procedural guidelines, and business needs, to improve taxpayer services. Upon completion of the study and analysis of findings, the IRS will take this recommendation under consideration.

Update: IRS is continuing to work on functionality for a tax pro account, but has not made any policy decisions about which features will be available or what requirements users will have to comply with.

TAS RESPONSE: We appreciate the IRS’s willingness to include TAS representatives in the policy planning meetings for the tax professional account features. We are encouraged that such meetings provided several opportunities for TAS representatives to give presentations on this topic. However, until the IRS makes a final decision to limit access to Circular 230 practitioners, we will continue to strongly advocate for this taxpayer protection measure. Without such restriction on access, the IRS will expose taxpayers to potential harm due to preparer incompetence or misconduct. Further, when the National Taxpayer Advocate raised this recommended restriction on preparer access during the dozen National Taxpayer Advocate Publics Forums held around the country, the proposal received overwhelming support.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Closed

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

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