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MSP #3: TELEPHONE AND IN-PERSON SERVICE

Taxpayers Face Significant Challenges Reaching IRS Representatives Due to Longstanding Deficiencies and Pandemic Complications

TAS Recommendations and IRS Responses

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1.

TAS RECOMMENDATION #3-1

Implement and increase callback technology capacity across all taxpayer-facing telephone lines.

IRS RESPONSE TO RECOMMENDATION: ​In 2022, IRS increased the number of lines Customer Callback (CCB) is offered on from 16 to 31, adding 15 more telephone lines or applications. This includes the IRS’s most popular 1040 toll-free line as well as additional Spanish applications. Last year, we served over 7 million taxpayers with CCB and saved them 3 million hours of hold time. We will upgrade the platform for CCB, with the first iteration planned for December 2022, starting with the set of 31 toll-free applications currently offering a callback. The upgrade deployment process will include a review of what has changed in the call center regarding different telephone applications since we base-lined this service in 2019. The review will include all business units that have phone operations. Future releases of the callback system throughout 2023 and 2024 will continue to add toll-free applications from these business units to reach the goal of offering a CCB option to 95% of viable assistor services demand by 2024. With the 2022 deployment of the 15 additional applications, we reached 70% of the 95% goal.

CORRECTIVE ACTION: We will upgrade the platform for CCB, with the first iteration planned for December 2022, starting with the set of 31 toll-free applications currently offering a callback. The upgrade deployment process will include a review of what has changed in the call center regarding different telephone applications since we base-lined this service in 2019. The review will include all business units that have phone operations. Future releases of the callback system throughout 2023 and 2024 will continue to add toll-free applications from these business units to reach the goal of offering a CCB option to 95% of viable assistor services demand by 2024. With the 2022 deployment of the 15 additional applications, we reached 70% of the 95% goal.

TAS RESPONSE: TAS commends the IRS for its progress in expanding the availability of CCB on many of its highly utilized phone lines. Likewise, we appreciate the IRS’s goal of expanding CCB coverage to 95% of viable assistor services demand by 2024. This comprehensive coverage will greatly assist taxpayers in obtaining the telephone support from the IRS that taxpayers need to resolve account inquiries and facilitate tax compliance. Although this 95% target falls slightly short of “all taxpayer-facing telephone lines,” as recommended by TAS, it represents the substantial equivalent of full implementation.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Open

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

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2.

TAS RECOMMENDATION #3-2

Prioritize the rollout of a comprehensive ECM system, which is a prerequisite for meeting the IRS’s goal of a robust concierge support system.

IRS RESPONSE TO RECOMMENDATION: ​Per the recommendation, Enterprise Case Management’s (ECM’s) work is already prioritized through a well-defined and transparent governance process led by the ECM Executive Steering Committee (ESC) and other subordinate governance boards. In providing its sequencing guidance, the ESC has considered ECM’s current capacity to migrate legacy processes and address the related technology enablers. The ECM Roadmap envisions capacity to support Accounts Management processes in the future; however, because IRS Toll-Free Level of Service is influenced by a variety of factors, it is difficult to project the effect of ECM on future levels of service. ECM is proud to be at the forefront of developing technology that when fully delivered will improve the taxpayer experience.

This recommendation has already been implemented.

CORRECTIVE ACTION: N/A

TAS RESPONSE: TAS agrees that a comprehensive ECM system will not be a panacea for all of the phone service challenges experienced by taxpayers. It will, however, help increase the quality of services provided by phone assistors, decrease taxpayer wait time to reach those assistors, and more efficiently allocate IRS resources. Accordingly, TAS is gratified that the IRS is making development of ECM a significant priority.

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 #3-3

Implement flexible hiring and training strategies for CSRs to reach and maintain a telephone LOS of at least 85 percent.

IRS RESPONSE TO RECOMMENDATION: ​The IRS partially agrees with the TAS recommendation to implement flexible hiring and training strategies for Customer Service Representatives (CSRs) but is unable to agree to maintain a telephone Level of Service (LOS) of at least 85 percent because the LOS is dependent on funding.

The IRS has a long and successful history of applying flexible hiring and training strategies for our CSR workforce. The IRS is committed to servicing as many customers as supported by the budget and resources available and set hiring targets that align with projected customer demand to the extent possible. To make the best use of our resources, training is tailored to specific work assignments and focuses on the required skill sets.

The IRS is unable to agree with the recommendation to maintain a telephone LOS of at least 85 percent because our LOS is dependent on Congressional appropriations. The main component of the LOS calculation is the budget allocation, reduced by costs associated with hiring and training. The IRS must also balance resources allocated to telephone and inventory workloads. In addition to challenges with the varying budget allocation and resource balancing, several potential and often unknown variables, such as new legislation, Federal Emergency Management Agency support, and hiring challenges beyond our control, influence the LOS. Historical data shows planning for an LOS over 80 percent results in increased assistors waiting to receive calls during periods of lower telephone demand, while during peak periods the customer demand far exceeds staffing levels and other dedicated resources.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The IRS and TAS appear to agree that taxpayers should be accorded higher-quality phone service than that demonstrated by the 23% LOS provided during the recently concluded 2022 filing season. TAS acknowledges that “staffing up” will lead to inefficient utilization during slack periods and may still not enable ideal coverage during peak periods. Nevertheless, the IRS can double or even triple LOS before the question of fine-tuning even arises. Importantly, though, the IRS does embrace the idea of adequately servicing taxpayers and hiring the requisite staff to do so. Taxpayers are entitled to a significant improvement in the quality of phone service, but this will require a long-term funding increase from Congress, and we urge Congress to act accordingly.

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 #3-4

Engage with outside parties to conduct a study to identify private industry or government best practices and how they might improve IRS phone systems.

IRS RESPONSE TO RECOMMENDATION: ​The IRS has conducted various benchmark studies, the most recent in 2016. The conclusion of that study is that IRS is comparable with industry standards relating to measuring and monitoring telephone performance as well as implementing telephone assistance technology. As recently as 2019, the IRS reviewed telephone measures with the Treasury Inspector General for Tax Administration and determined the current measures used are the best indicator of assistor performance. The IRS has also shared best practices with other government agencies, including the Department of the Treasury, Social Security Administration, and the United States Postal Service. If the IRS sees the need to conduct a new benchmark study in the future, funding would be needed to complete the effort.

CORRECTIVE ACTION: N/A

TAS RESPONSE: Industry standards and best practices with respect to telephone assistance and customer service technology have evolved substantially since 2016. In particular, private industry and some government agencies were forced by the pandemic to develop and implement significant innovations as a matter of practical survival. By failing to adequately inform itself regarding this evolution, the IRS is turning away from insights that could benefit taxpayers through improved customer service. TAS urges the IRS to recognize the importance of updating its knowledge base by setting aside the funding for a new study and proceeding accordingly.

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 #3-5

Conduct a postmortem study to identify specific challenges faced during the last two filing seasons to improve the responsiveness and quality of information provided to taxpayers and practitioners calling its phone lines.

IRS RESPONSE TO RECOMMENDATION: ​The IRS agrees with the TAS recommendation to conduct a postmortem review to identify specific challenges faced during filing seasons to improve the responsiveness and quality of information provided to taxpayers and practitioners calling its phone lines.

The IRS continually assesses the services provided to taxpayers and tax practitioners to monitor the quality of information delivered through the telephone lines. Several tools have been implemented to help address issues in real time, which include the Customer Early Warning System (CEWS) and Contact Analytics.

The CEWS program allows front-line assistors to elevate customer concerns as they are encountered, such as the processing issues with Advance Child Tax Credit payments that were identified by this system in 2021. These concerns were rapidly brought to the attention of senior leadership and forwarded to compliance operations for investigation.Using Contact Analytics, call trends can be identified on multiple topics by searching key words or phrases contained within telephone interactions. Contact Analytics is also used to validate and/or determine the scope of a concern raised through the CEWS process. These processes are used to update internal guidance for telephone assistors.

The IRS conducts pre-filing season program planning and develops an extension plan to execute the filing season. This process is led by an executive steering committee and closely monitors implementation of planned actions to achieve a successful filing season.

In partnership with the Treasury Inspector General for Tax Administration and the Government Accountability Office, the IRS has participated in multiple in-depth reviews over the past two filing seasons. These reviews document both the views of the auditors and of the IRS about the results of the filing season and the improvements planned for the following filing season.

This recommendation has already been implemented.

CORRECTIVE ACTION: N/A

TAS RESPONSE: TAS applauds the IRS’s use of real-time filing season analytics, along with its participation in the Treasury Inspector General for Tax Administration (TIGTA) and Government Accountability Office (GAO) audits of past filing seasons. We hope that the IRS will pay particular attention to its own studies of the 2020 and 2021 filing seasons, as well as the feedback of TAS, TIGTA, and the GAO, to help ensure that in the future, taxpayers receive high quality phone service, even under anomalous circumstances.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Closed

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

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6.

TAS RECOMMENDATION #3-6

Conduct a pilot program for “pop-up” mobile Taxpayer Assistance Centers (TACs), with stakeholders and community partners, to travel to underserved communities and reach vulnerable taxpayers, to determine the viability and benefit of this program to taxpayers.

IRS RESPONSE TO RECOMMENDATION: ​The IRS agrees to implement the TAS recommendation in full, dependent upon current Centers for Disease Control and Prevention (CDC) and local health guidance updates.

​In 2020, the IRS planned to have face-to-face Community Assistance Visits (CAV) in six locations throughout the country to reach low-income and under-served taxpayers. During these events, the Taxpayer Assistance Center (TAC) employees would offer low-income and under-served taxpayers tax law and account assistance, Taxpayer Protection Program (TPP) verifications, and services for transcripts and forms. Holdrege, Nebraska was the location for the first event, which was planned for March 24 and 25, 2020. However, due to the COVID-19 pandemic, all six outreach events were cancelled. The IRS plans to continue with the initial plan to have six face-to-face CAV in the second quarter of FY 2023 if circumstances allow.

CORRECTIVE ACTION: The IRS plans to continue with the initial plan to have six face-to-face CAV in the second quarter of FY 2023 if circumstances allow.

Update: On 11/22/2022, received the Optimal Sites data and will begin the coordination to determine how many CAVs will be held and at which locations.

Update: In FY20 the IRS Community Assistance Visit (IRS CAV) project was delayed due to COVID-19 and restrictions on non-essential travel. Plans to relaunch the IRS CAV project in FY23 Qtr. 3 are underway. Field Assistance received the Optimal Sites data from RAAS that will help us determine the number of IRS CAV events and locations and implement the IRS CAV events.

TAS RESPONSE: TAS and the IRS agree regarding the benefits of mobile CAVs. TAS encourages the IRS to expand this initiative as public health and budgetary limitations allow.

Update: IRS has successfully help some mobile TACs.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Closed

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