TAS determined that the most effective course of action for this Systemic Advocacy Objective (SAO) was to elevate the issue to a Most Serious Problem (MSP) in the FY 2025 Annual Report to Congress. TAS has provided the IRS with the following recommendation to further address this issue, as outlined in MSP Centralized Authorization File, Recommendation:
Study ways to shorten and mitigate CAF “pending review” suspensions. Study and implement ways to shorten the duration of CAF investigations that place CAF numbers in “pending review” status. The IRS should also explore interim measures to minimize disruption to taxpayers and their representatives while reviews are ongoing, particularly when no confirmed compromise exists.
The IRS agreed to enhance publicly available guidance on IRS.gov to better explain the CAF pending review process and to conduct a Lean Six Sigma Opportunity (LSSO) Assessment to identify improvement opportunities in the process.
As a result of elevating this issue from an SAO to an MSP, TAS is closing the SAO and will instead track the IRS’s progress on implementing this recommendation through the Annual Report to Congress (ARC) Recommendations Tracker page.