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MSP #4: DIGITAL COMMUNICATIONS

Limited Digital Communications With the IRS Make Problem Resolution Unnecessarily Difficult for Taxpayers

TAS Recommendations and IRS Responses

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1.

TAS RECOMMENDATION #4-1

Maintain a robust omnichannel service environment at the same time that it enhances its digital offerings.

IRS RESPONSE TO RECOMMENDATION: The Taxpayer First Act Report to Congress includes a vision for a seamless experience that helps taxpayers solve problems and comply with their tax obligations. Under this strategy, we will integrate digital tools with other service channels (e.g., toll-free telephone assistance and walk-in assistance) to resolve issues efficiently and further improve the taxpayer experience. Taxpayers expect and routinely encounter similar “omni-channel” approaches with services like online banking and shopping. Using our omni-channel model, taxpayers will have the flexibility to communicate with the IRS via their preferred method and transition seamlessly to another resource or channel most suited to resolving their issue. We will deploy an omni-channel model to facilitate a 360 degree view of taxpayer records (e.g., real time tax filings, interaction history, appointment schedule, etc.) as well as launch a virtual face-to-face video chat option with IRS employees to simulate an in-person appointment for those that require a human touch point but are unable to or prefer not to meet in person. In addition, the Taxpayer First Act Report to Congress outlines opportunities to enhance digital services as a result of the proposed Organizational Redesign Strategy for the IRS.

CORRECTIVE ACTION: We will deploy an omni-channel model to facilitate a 360 degree view of taxpayer records (e.g., real time tax filings, interaction history, appointment schedule, etc.) as well as launch a virtual face-to-face video chat option with IRS employees to simulate an in-person appointment for those that require a human touch point but are unable to or prefer not to meet in person. In addition, the Taxpayer First Act Report to Congress outlines opportunities to enhance digital services as a result of the proposed Organizational Redesign Strategy for the IRS.

TAS RESPONSE: The IRS’s vision for a seamless taxpayer experience as set forth in the Taxpayer First Act Report to Congress is a promising development. Taxpayers have a right to quality service, and being able to communicate with the IRS via their preferred service channel, with the ability to transition seamlessly to another service channel, will ensure that this taxpayer right is realized to a greater extent. In addition, the IRS deployment of a 360-degree view of taxpayer records in the omnichannel model will likely significantly reduce burden as taxpayers navigate the IRS to resolve their tax issues. We eagerly await its development.

Update: In the 2021 ARC Digital Communications MSP recommendation 4-1 IRS stated: The IRS is targeting deployment in December 2023 for a modernized “agent desktop” to all contact center agents to provide a foundational framework for multi-channel capabilities and to allow for a seamless transition of services to taxpayers (e.g., live chat, click to voice call with a live agent) into a converged single agent desktop solution with voice, text, and other omnichannel technologies.

TAS is monitoring 2021 4-1 in conjunction with this recommendation.

ADOPTED, PARTIALLY ADOPTED Or NOT ADOPTED: Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 12/31/2023

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2.

TAS RECOMMENDATION #4-2

Accept electronic signatures on all documents that require a signature, once the IRS assesses, identifies, and eliminates any data security vulnerabilities, if applicable.

IRS RESPONSE TO RECOMMENDATION: Providing an electronic signature option for all documents is a long-term goal for the IRS. To reach this goal, the IRS developed a framework to assess IRS forms and prioritize them for e-Signature digitization and integration based on risk, policy considerations, federal mandates, and legal requirements. The IRS will use this analysis to identify opportunities to expedite form digitization and enable digital signatures to further enhance the taxpayer experience.

CORRECTIVE ACTION: Providing an electronic signature option for all documents is a long-term goal for the IRS. To reach this goal, the IRS developed a framework to assess IRS forms and prioritize them for e-Signature digitization and integration based on risk, policy considerations, federal mandates, and legal requirements. The IRS will use this analysis to identify opportunities to expedite form digitization and enable digital signatures to further enhance the taxpayer experience.

TAS RESPONSE: The IRS’s development of a framework to assess and prioritize forms for e-signature is the necessary first step in the process to digitalize forms. Both taxpayers and the IRS will benefit as the IRS makes progress on its long-term goal of enabling electronic signatures on all documents.

AGREED (FULL or PARTIAL) or NOT AGREED: Yes

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 12/31/2024

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3.

TAS RECOMMENDATION #4-3

Make permanent the use of a secured messaging system with taxpayers and their representatives.

IRS RESPONSE TO RECOMMENDATION: The IRS is committed to making secured messaging available for taxpayers and their representatives. As part of the Taxpayer First Act Taxpayer Experience Strategy, the IRS outlined plans for a digital portal for taxpayers to securely access their tax information, make changes to their personal information, and communicate with the IRS online. These plans include providing secure two-way messaging that will give taxpayers the ability to communicate with IRS employees through their online accounts. This feature comes with related increased costs for licenses and technology support and must be prioritized in the context of other initiatives within the agency’s taxpayer experience strategy and information technology modernization efforts.

CORRECTIVE ACTION: IRS Agrees with TAS Recommendation but Cannot Implement It Currently Due to Funding Limitations.

As part of the Taxpayer First Act Taxpayer Experience Strategy, the IRS outlined plans for a digital portal for taxpayers to securely access their tax information, make changes to their personal information, and communicate with the IRS online. These plans include providing secure two-way messaging that will give taxpayers the ability to communicate with IRS employees through their online accounts. This feature comes with related increased costs for licenses and technology support and must be prioritized in the context of other initiatives within the agency’s taxpayer experience strategy and information technology modernization efforts.

Update: IT is continuing to make efforts in this space. The Digital Flexibilities authorized during COVID were only extended through 10/31/2023 because IT felt strongly that a secured messaging system would be in place between IRS, taxpayers and their representatives by then. Extending the due date 10/31/2023 to align with IT’s modernization plans.

TAS RESPONSE: The IRS’s commitment to making secured messaging available to both taxpayers and representatives in the Taxpayer Experience Strategy is encouraging. We acknowledge that such plans are costly and, to address this issue, the National Taxpayer Advocate has made a legislative recommendation to provide sufficient funding to implement the digital services proposed in the Taxpayer First Act Report to Congress.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 10/31/2023, TAS is monitoring this recommendation.

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4.

TAS RECOMMENDATION #4-4

Make permanent and expand the list of documents the IRS will accept and transmit by email using an established secured messaging system, once the IRS assesses, identifies, and eliminates any data security vulnerabilities and file size limitation issues, if applicable.

IRS RESPONSE TO RECOMMENDATION: In January 2021, the IRS established a cross-functional team to evaluate the long-term viability, benefits, and risks of these flexibilities and develop recommendations as to whether these temporary policies should be extended, and the specific forms listed expanded. While these deviations may not be permanent, secured messaging will continue to be utilized as the IRS moves toward a fully digitalized state.

CORRECTIVE ACTION: In January 2021, the IRS established a cross-functional team to evaluate the long-term viability, benefits, and risks of these flexibilities and develop recommendations as to whether these temporary policies should be extended, and the specific forms listed expanded. While these deviations may not be permanent, secured messaging will continue to be utilized as the IRS moves toward a fully digitalized state.

Update: The memorandums extending the digital flexibilities have been signed by the DCSE and posted, and the User Guide is available on IRS.gov.

TAS RESPONSE: In its response, the IRS committed to continue secured messaging as it moves toward a fully digitized state. The cross-functional team’s evaluation of the long-term viability of the current temporary policies is necessary to ensure all data security vulnerabilities are adequately addressed.

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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5.

TAS RECOMMENDATION #4-5

Assess how the new SADI platform will impact different demographics and determine the feasibility of potentially increasing accessibility to digital applications as they are integrated with SADI, while also maintaining compliance with NIST guidelines.

IRS RESPONSE TO RECOMMENDATION: We recognize that underserved taxpayers face unique challenges with regard to authentication and identity assurance. Deploying the focused strategies for reaching underserved communities envisioned under the Taxpayer First Act Taxpayer Experience Strategy should address these unique challenges.

CORRECTIVE ACTION: Deploying the focused strategies for reaching underserved communities envisioned under the Taxpayer First Act Taxpayer Experience Strategy should address these unique challenges.

In accordance with the Taxpayer First Act, these strategies will be implemented over the next 1-2; 3-5 and 5-10 years as we continually conduct studies and deploy new solutions to better meet the needs of the underserved segments of our taxpayer population.

TAS RESPONSE: The Taxpayer Experience Strategy specifically references online account authentication for international taxpayers in its focused strategies to reach underserved communities. While this is certainly an important effort, we encourage the IRS to commit to expand efforts to increase the e-authentication verification rate for underserved communities.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 12/31/2022

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6.

TAS RECOMMENDATION #4-6

Expand the availability of TDC eGain Text Chat beyond ACS.

IRS RESPONSE TO RECOMMENDATION: The IRS supports expanding the availability of the TDC Platform capabilities, including text chat, authenticated chat, chat deflection, and virtual assistant, to assistors Servicewide, subject to resource constraints and prioritization. The IRS considers utilization of all TDC capabilities regularly and executes a periodic prioritization process to expand TDC usage within resource constraints. Our next prioritization effort is planned for FY 2022, and we will seek for this recommendation to be prioritized and funded, in which case we will expand chat capabilities accordingly.

CORRECTIVE ACTION: IRS Agrees with TAS Recommendation but Cannot Implement It Currently Due to Funding Limitations.

The IRS considers utilization of all TDC capabilities regularly and executes a periodic prioritization process to expand TDC usage within resource constraints. Our next prioritization effort is planned for FY 2022, and we will seek for this recommendation to be prioritized and funded, in which case we will expand chat capabilities accordingly.

TAS RESPONSE: We acknowledge that current funding limitations restrict the IRS’s ability to expand TDC Platform capabilities, and we are encouraged that the IRS commits to consider such expansion during its FY 2022 prioritization effort. In addition, the National Taxpayer advocate has made a legislative recommendation that Congress adequately fund the IRS’s Taxpayer Experience Strategy, which includes widespread integration of chat capabilities.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 10/31/2023, TAS is monitoring this recommendation.

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7.

TAS RECOMMENDATION #4-7

Continue to develop digital service tools that are mobile-ready.

IRS RESPONSE TO RECOMMENDATION: Consistent with the 21st Century Integrated Digital Experience Act legislation, the IRS is already obligated to develop new tools and services into mobile-ready experiences subject to legislative timelines and funding or other resource constraints. While we are actively working toward this goal, this activity will be ongoing with no final implementation date.

CORRECTIVE ACTION: Consistent with the 21st Century Integrated Digital Experience Act legislation, the IRS is already obligated to develop new tools and services into mobile-ready experiences subject to legislative timelines and funding or other resource constraints. While we are actively working toward this goal, this activity will be ongoing with no final implementation date.

TAS is monitoring this recommendation.

TAS RESPONSE: The IRS’s response acknowledges funding and other resource constraints as it actively works toward meeting its legislative obligations to make tools and services mobile-ready. The National Taxpayer Advocate has made a legislative recommendation that Congress adequately fund the IRS’s Taxpayer Experience Strategy, which includes widespread integration of mobile services.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 10/31/2023, TAS is monitoring this recommendation.

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8.

TAS RECOMMENDATION #4-8

Expand the use of virtual face-to-face technology to taxpayer-facing functions as permitted, while ensuring proper authentication and authorization controls are in place.

IRS RESPONSE TO RECOMMENDATION: The IRS is deploying several virtual face-to-face technology processes within available resources and funding in order to increase virtual services long-term. As part of the assessment process, the IRS is updating policies to ensure proper authentication, authorization, monitoring, and data protection controls are in place. Because of the urgent need for virtual interactions, the IRS is expediting the roll-out by investigating and deploying multiple virtual technologies at the same time. Making these technologies widely available to front-line assistors, tax examiners, revenue officers, and revenue agents will require significant new investment in software, network infrastructure, and cybersecurity controls and must be prioritized in the context of other initiatives within the agency’s taxpayer experience strategy and information technology modernization efforts.

CORRECTIVE ACTION: The IRS is deploying several virtual face-to-face technology processes within available resources and funding in order to increase virtual services long-term. As part of the assessment process, the IRS is updating policies to ensure proper authentication, authorization, monitoring, and data protection controls are in place. Because of the urgent need for virtual interactions, the IRS is expediting the roll-out by investigating and deploying multiple virtual technologies at the same time. Making these technologies widely available to front-line assistors, tax examiners, revenue officers, and revenue agents will require significant new investment in software, network infrastructure, and cybersecurity controls and must be prioritized in the context of other initiatives within the agency’s taxpayer experience strategy and information technology modernization efforts.

TAS RESPONSE: The IRS’s response recognizes the urgent need to expand virtual services and mentions that the agency has already taken steps to expedite the deployment of several virtual technologies. In addition, the IRS is taking the critical initial steps to update policies for authentication, authorization, monitoring, and data protection controls to ensure successful deployment of such services. The IRS did not commit to roll out the technologies to all taxpayer-facing functions due to a need to prioritize initiatives given the agency’s limited resources. Accordingly, the National Taxpayer Advocate will continue to recommend that Congress adequately fund the IRS’s Taxpayer Experience Strategy, which includes plans to expand virtual services.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): Ongoing

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