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MSP #16: Field Collection

The IRS Field Collection Function Is Not Appropriately Staffed or Trained to Minimize Taxpayer Burden and Ensure Taxpayer Rights Are Protected.

TAS Recommendations and IRS Responses

1
1.

TAS RECOMMENDATION #16-1

Formally evaluate the impact on taxpayers of hoteling Revenue Officers—for example, is there any quantifiable harm to taxpayers due to the lag time in responding to taxpayer or practitioner calls or appointments, or in posting payments and tax returns, installment agreements, and OICs?

IRS RESPONSE TO RECOMMENDATION: Revenue Officers are available by appointment and can be reached by cell phone. Additionally, Revenue Officers have the ability to forward calls received on their business line to their laptop computer. Requirements for timely and courteous service are the same regardless of where the Revenue Officer is working on a given day.

CORRECTIVE ACTION: N/A

TAS RESPONSE: We do not question the value derived by the government in allowing its employees to participate in hoteling arrangements. However, the IRS needs to acknowledge that there are trade-offs in taxpayer service that accompany the decision to allow hoteling. In our discussion, we provided examples of when a taxpayer may be negatively impacted when a Revenue Officer is teleworking (e.g., reduced ability to accommodate walk-in or last-minute appointments). We are disappointed that the IRS will not agree to even assess the impact of such arrangements.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

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

2
2.

TAS RECOMMENDATION #16-2

Implement lessons from the “Fresh Inventory” pilot to modify its case selection and assignment methodologies for Revenue Officers to focus on early intervention that educate taxpayers on compliance, resolve cases timely, and promote future voluntary compliance.

IRS RESPONSE TO RECOMMENDATION: ​The Fresh Inventory Pilot was one of three case assignment studies undertaken simultaneously under the umbrella of the Field Inventory Process Improvement Team (FIPIT) project. The  hypothesis of the Fresh Inventory pilot was that early intervention and cases with more current modules would lead to improved cycle time and yield with no negative impact on quality or customer satisfaction. The other tests were the Virtual and Flex Inventory Pilots. The Virtual pilot tested whether Revenue Officers could, in some situations (disasters or inventory imbalances), work cases “virtually” in another geographic location without negatively impacting quality or business results. The Flex Inventory pilot hypothesized that Revenue Officers could resolve more cases if they had increased flexibility in inventory and casework management.

Because the Fresh Inventory Pilot Project limited the case assignment methodology to one simple factor, it is not compatible with the very complex assignment and delivery processes developed and implemented over a number of years in the Collection Operation. We are continuing to review the results and analysis of the FIPIT pilots to leverage the information in exploring diverse alternatives to assigning cases to Revenue Officers.

CORRECTIVE ACTION: N/A

TAS RESPONSE: From our perspective, the Fresh Inventory pilot was a resounding success—cases in this pilot generally had a higher number of full pay cases and a lower number of Currently Not Collectible closures. The pilot groups also closed substantially more cases per Revenue Officer. Yet, the IRS response seems to imply that Field Collection is satisfied with the status quo—that it does not  want to adopt changes to its case assignment methodology. The IRS should expand the FIPIT to cover the current case assignment process to make the results more relevant and use the existing results to inform its current work processes.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

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

3
3.

TAS RECOMMENDATION #16-3

Implement the Early Interaction Initiative to ensure business taxpayers are in compliance with and educated on the federal tax deposit requirements for employment taxes.

IRS RESPONSE TO RECOMMENDATION: We began implementing recommendations from the Early Interaction Initiative project in 2017, including expanded Federal Tax Deposit Alert treatment segments and expanded issuance of soft letters. We continue to collaborate with the IRS Information Technology (IT) function to find ways to incorporate learnings from the Early Interaction Initiative into systemic processes.

CORRECTIVE ACTION: We began implementing recommendations from the Early Interaction Initiative project in 2017, including expanded Federal Tax Deposit Alert treatment segments and expanded issuance of soft letters. We continue to collaborate with the IRS Information Technology (IT) function to find ways to incorporate learnings from the Early Interaction Initiative into systemic processes.

TAS RESPONSE: The National Taxpayer Advocate is pleased that Field Collection has begun implementing recommendations from the Early Interaction Initiative. We ask that the IRS not consider this recommendation as “implemented” until the recommendations are fully adopted, including working with IT to overcome any systems challenges.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Closed

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

4
4.

TAS RECOMMENDATION #16-4

Issue a policy for a “Revenue Officer of the day” in all field offices, except offices with only one Revenue Officer, so every taxpayer, wherever they are located in the country, receives the same quality service. Such a policy would help ensure that payments and tax returns are posted timely, correspondence and questions are responded to timely, and face-to-face meetings are available.

IRS RESPONSE TO RECOMMENDATION: ​Being treated with respect and avoiding needless delay is important in every customer interaction, and taxpayers have a right to have timely communications and access to their assigned Revenue Officer, whether contact is made in the field or through a scheduled appointment in the IRS office. Field Collection can appropriately serve taxpayers without requiring a policy of “Revenue Officer of the day” in every office. Revenue Officers are available by appointment and by cell phone. Revenue Officers and Group Managers coordinate daily to ensure payments and tax returns are posted timely.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The IRS seems to discount the value in allowing taxpayers the ability to walk in or make last-minute appointments to meet with a Revenue Officer. We propose that the value of designating a “Revenue Officer of the day” be included in the formal evaluation of the benefits and costs of hoteling that we urged the IRS to conduct in Recommendation 1.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

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

5
5.

TAS RECOMMENDATION #16-5

Promote taxpayers’ future compliance by Revenue Officers conducting and participating in outreach events that provide information on policy and procedures of Field Collection and the role of Revenue Officers in the collection of taxes and voluntary tax compliance.

IRS RESPONSE TO RECOMMENDATION: Field Collection leaders and experts regularly participate in outreach events, including National Tax Forums, practitioner events, and business industry conferences, to increase understanding of a comprehensive list of topics relating to the Collection process. We also provide educational talking points and other background to the IRS Communications and Liaison organization to leverage their resources.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate is pleased to learn that Field Collection leadership participate in National Tax Forums and other outreach events. In addition, we recommend that ALL Revenue Officers participate in outreach events. We believe the IRS will benefit from having Revenue Officers regularly interact with members of their local community.

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 #16-6

Establish a quality measurement system that measures (using a statistically valid sample) the future voluntary compliance impact of Field Collection actions, including if those actions resulted in undue harm or burden to taxpayers.

IRS RESPONSE TO RECOMMENDATION: Our current quality review process measures actions that  potentially could result in undue harm or burden to the taxpayer. Changes to a taxpayer’s compliance behavior in the years after a case was worked by Field Collection may be attributed to many external factors. We are continuing to study potential methods to accurately measure the impact of specific compliance efforts on reducing recidivism. For instance, the IRS Research, Applied Analytics, and Statistics (RAAS) organization is performing analysis on the impact of our Federal Tax Deposit Alerts. In FY 2019, RAAS is working with Field Collection to measure the impact of pairing Revenue Officers when performing certain specialized taxpayer interviews versus interviews by a single Revenue Officer.

CORRECTIVE ACTION: N/A

TAS RESPONSE: Establishing a perfect measurement of quality is an elusive goal for many organizations. The response above appears that Field Collection is open to improving its quality measures. We are pleased with Field Collection’s efforts to continually review and improve its quality measures.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Closed

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

7
7.

TAS RECOMMENDATION #16-7

Grant Revenue Officers the authority to work Offer in Compromise cases.

IRS RESPONSE TO RECOMMENDATION: IRS centralized the Offer-In-Compromise (OIC) process in 2001 to provide more control and consistency in processing OICs. The recent realignment of the Collection program within the Small Business/Self-Employed Division further centralized the offer program under one Executive. In contrast, decentralizing the process would significantly increase training costs, decrease the effectiveness of specialized training, increase the chance that a taxpayer’s offer is processed by an employee with limited exposure to the offer program, require revenue officers to reprioritize their work to ensure that offer decisions are made within the statutorily mandated 24-month period, and generally increase the risk that there will be inconsistencies in OIC processing.

CORRECTIVE ACTION: N/A

TAS RESPONSE: While we see some benefits of allowing Revenue Officers to work OIC cases instead of passing them along to OIC specialists who will not be well-versed in the taxpayers’ particular set of circumstances, we recognize there are some drawbacks as outlined by the IRS in its response.

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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