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MSP #6: ONLINE ACCOUNTS

IRS Online Accounts Do Not Have Sufficient Functionality and Integration With Existing Tools to Meet the Needs of Taxpayers and Practitioners.

TAS Recommendations and IRS Responses

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1.

TAS RECOMMENDATION #6-1

Prioritize Tax Pro Account updates to enable practitioners to upload documents and request transcripts on behalf of clients.

IRS RESPONSE TO RECOMMENDATION: ​A Single Sign On (SSO) link from Tax Pro Account to the Transcript Delivery System has been prioritized for FY 2023 delivery. Enabling practitioners to upload documents from within the Tax Pro Account is currently on the Tax Pro Account 5-year roadmap but is not yet funded or prioritized for development. This item is dependent on the IRS completing the Tax Pro Account MVP Release 3 which includes the delivery of the foundational capabilities such as Claim a CAF and Enable Tax Professionals to View their Clients list and info. Implementation of these foundational capabilities will enable us to expand Tax Pro Account functionality to offer authorized representatives additional features like integration with messaging and documents upload.

CORRECTIVE ACTION: ​A Single Sign On (SSO) link from Tax Pro Account to the Transcript Delivery System has been prioritized for FY 2023 delivery. Enabling practitioners to upload documents from within the Tax Pro Account is currently on the Tax Pro Account 5-year roadmap but is not yet funded or prioritized for development. This item is dependent on the IRS completing the Tax Pro Account MVP Release 3 which includes the delivery of the foundational capabilities such as Claim a CAF and Enable Tax Professionals to View their Clients list and info. Implementation of these foundational capabilities will enable us to expand Tax Pro Account functionality to offer authorized representatives additional features like integration with messaging and documents upload.

SSO link from Tax Pro Account to TDS TBD for enabling practitioners to upload documents using Tax Pro Account to be implemented in FY 2023.

TAS RESPONSE: The National Taxpayer Advocate is pleased that the IRS has made it more convenient for practitioners to access the Transcript Delivery System from within Tax Pro Account. Allowing tax professionals more capabilities within Tax Pro Account, such as uploading documents on behalf of clients, is essential to improving the adoption rate of Tax Pro Account among practitioners. The National Taxpayer Advocate encourages the IRS to prioritize the funding of Tax Pro Account Release 3 and other updates to expand the functionality of Tax Pro Account. We will consider this recommendation as partially addressed and keep it open until these expanded capabilities are implemented.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 9/30/2023

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2.

TAS RECOMMENDATION #6-2

Prioritize and expedite efforts to deliver BOLA to business taxpayers by the end of FY 2023.

IRS RESPONSE TO RECOMMENDATION: ​IRS agrees to implement this recommendation in part. The IRS has prioritized business online account (BOLA) development by the end of FY23. However, this development is now entirely dependent on the organization’s ability to secure appropriate funding and IT development resources in FY22. The IRS is very dedicated to developing an online account for business taxpayers. Over the past year, the Office of Online Services (OLS) has conducted extensive customer research with over 2,000 small business owners and tax professionals via online surveys, in-person interviews and focus groups and concept design workshops. Our objective is to understand business taxpayer challenges and develop customer facing digital products/solutions that enable these taxpayers to ‘self-serve’ in managing their federal tax obligations.

Assuming funding and IT resources are available, OLS is committed to developing BOLA with an initial set of product features that will allow business taxpayers to make, schedule, cancel and view tax payments online.

CORRECTIVE ACTION: N/A

TAS RESPONSE: Congress allocated increased funding to the IRS for FYs 2022 and 2023, but the fact that the investment in BOLA is still contingent on the allocation of funding and IT resources belies that the IRS has “prioritized” BOLA development. The National Taxpayer Advocate would like IRS senior leadership to make a firm commitment to rolling out BOLA by the end of FY 2023.

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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3.

TAS RECOMMENDATION #6-3

Expand IRS2Go mobile app functionality, such as displaying account payment information and IRS notices.

IRS RESPONSE TO RECOMMENDATION: ​IRS agrees with TAS recommendation but cannot implement it currently due to funding limitations. Due to funding limitations, work to expand digital services is currently focused on building transactional online experiences on the web that are mobile friendly (e.g., responsive design), which will allow us to better support all taxpayers regardless of device. Mobile-friendly web applications are optimized to be just as functional as an app and can be accessed from any mobile, tablet, or desktop device without needing app downloads, installations, or updates.

Enhancing services on the web provides more value to all taxpayers than simply placing existing features into a mobile app. When specific problems are later identified where a mobile app can provide a unique solution or benefit to taxpayers, we will review a mobile app-based approach for prioritization at that time.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate understands the reality that the IRS has to make choices on how to stretch its IT budget. If the IRS makes a business decision to not prioritize optimizing the IRS2Go app (which had 11.9 million active users as of April 2022), then it should at least make sure its mobile-friendly web applications are able to deliver what taxpayers need. For example, taxpayers should be able to log on to Online Account (OLA) through IRS2Go and view recently filed tax returns, view notices, upload documents, make payments, and have access to all OLA features and capabilities on mobile devices.

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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4.

TAS RECOMMENDATION #6-4

Add links to relevant IRS.gov content and videos where appropriate to allow taxpayers easy access to self-help information and personalized guidance based on their usage of their Online Account.

IRS RESPONSE TO RECOMMENDATION: ​In December 2021, the IRS updated the individual Online Account to include a “Help” link in the header so that users can access relevant Frequently Asked Questions (FAQs) from anywhere within the application. We iteratively update those FAQs based on user feedback and add or update links to relevant IRS.gov content from within the application to enable easy access to self-help information. We’re unable to personalize IRS.gov content based on usage of Online Account since outside of the applications users of the website are not authenticated, and we don’t store their personally identifiable information. We do, however, provide links from different pages within Online Account to relevant content based on what they were viewing there.

This recommendation has already been implemented.

CORRECTIVE ACTION: N/A

TAS RESPONSE: Taxpayers have different preferences on how to navigate IRS.gov. Some prefer to go directly to the IRS.gov site, while others may prefer to log on to Online Account first and then navigate to a particular page on IRS.gov. Regardless of taxpayer preference, it is critical that the IRS post relevant FAQs and links so that taxpayers can access those without having to take any extra steps. Taxpayers are entitled to this level of convenience, and it should not be cost-prohibitive for the IRS to ensure relevant content is available to taxpayers both within and outside of Online Account.

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 #6-5

Prioritize the development and deployment of more personalized status updates for Where’s My Refund? and Where’s My Amended Return? online tools.

IRS RESPONSE TO RECOMMENDATION: ​Future implementation will be contingent upon the availability of funding/resources and prioritization with other programming needs.
On January 3, 2022, the IRS implemented changes to improve WMR messaging for taxpayers whose refunds are held or delayed and provide improved messaging on returns in processing for extended periods. The IRS is currently working to implement WMR Multiple Tax Year Functionality, allowing most taxpayers to access refund information for the last two tax years.

Pending approval of funding requests, the IRS plans to incorporate more detailed status messaging to meet taxpayer needs to add capabilities in WMR to include: extracting Error Resolution System (ERS) data; providing more specific messages based on the ERS status code; extracting data for certain Taxpayer Protection Program (TPP) delays; and allowing direct deposit recipients or married filing joint taxpayers to self-initiate a refund trace.
The IRS is conducting a research effort in 2022 to further review specific taxpayer needs and expectations regarding online updates of refund status. We will use the outcomes of this research to help inform updates to WMR and the Where’s My Amended Return application.

On January 3, 2022 WMR messaging was added for refund delays. Additional features will be deployed as funding permits.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate is encouraged that the IRS has made incremental improvements to the WMR tool, including the June 2022 change to Where’s My Refund? that expanded refund information to cover the 2021, 2020, and 2019 tax years. Recognizing that the more useful taxpayers find WMR, the fewer calls the IRS needs to answer, it is imperative that the IRS prioritize funding of the additional improvements mentioned in the IRS response.

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 #6-6

Work with the Department of Treasury to issue guidance specifically applying the provisions of IRC §§ 6713 and 7216 to unauthorized access to the online account system. In addition, the IRS should work with Treasury to revise Circular 230 sanctions to include sanctions for preparers who conduct, or attempt to conduct, unauthorized transactions on the online account system.

IRS RESPONSE TO RECOMMENDATION: NTA Recommendation Not Adopted as Written, but IRS Actions Taken to Address Issues Raised by NTA. The cross-functional team, including members of the TAS, will work on specific components, capabilities and business requirements. The IRS recognizes it must protect taxpayer information by ensuring that taxpayers authorize an approved representative, identify the data to be shared with the representative and determine the length of time the representative has access to the data. Upon completion of the study and analysis of findings, the IRS will take this recommendation under consideration.

Update: A determination has been made that access for third parties will be worked parallel with Online Account for individuals. Access for third parties is contingent upon the successful completion of eA3 Solutions that are under development. Access for third parties will adhere to governing regulations, policy, and law.

Update: Prior to revising Circular 230, we must ensure access for the online system adheres to governing regulations, policy and law. W&I is working with IT to develop the Tax Professional Account which includes the ability to submit authorizations online, view, manage (withdraw/revoke) and modify. This capability was included in the IRS Integrated Modernization Business Plan under Phase 1 (FY 2019 – FY 2021). Because authorizations have a technical dependency on electronic signatures, the first capability to be delivered will be the e-Signature capability. Once developed developmental work regarding design and requirements can begin. The final timeline for delivery has not been determined yet, as with all Web Apps products, the first release will be the Minimal Viable Product and each subsequent release will have enhancements and improvements.

CORRECTIVE ACTION: The cross-functional team, including members of the TAS, will work on specific components, capabilities and business requirements. The IRS recognizes it must protect taxpayer information by ensuring that taxpayers authorize an approved representative, identify the data to be shared with the representative and determine the length of time the representative has access to the data. Upon completion of the study and analysis of findings, the IRS will take this recommendation under consideration.

Update: A cross-functional IRS team, including members from the TAS, is currently working on analysis and policy planning. 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.

TAS RESPONSE: TAS appreciates the IRS considering this very important matter, however, it is unclear why the IRS does not agree with general principal stated in this recommendation, which should form the foundation for any review by the cross-functional team. Due to the evolving technology in tax administration since the drafting of both disclosure Code provisions, we believe guidance is a necessary reminder to both internal and external stakeholders of the consequences of using and disclosing taxpayer data accessed through the online account.

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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