oversight

IRS Management: IRS Faces Challenges as it Restructures the Office of the Taxpayer Advocate

Published by the Government Accountability Office on 1999-07-15.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United States General Accounting Office

GAO              Report to the Chairman, Committee on
                 Ways and Means, House of
                 Representatives


July 1999
                 IRS MANAGEMENT
                 IRS Faces Challenges
                 as it Restructures the
                 Office of the Taxpayer
                 Advocate




GAO/GGD-99-124
GAO                United States
                   General Accounting Office
                   Washington, D.C. 20548



                   General Government Division



                   B-279035

                   July 15, 1999

                   The Honorable Bill Archer
                   Chairman, Committee on Ways and Means
                   House of Representatives

                   Dear Mr. Chairman:

                   Witnesses at the Senate Finance Committee hearings in September 1997
                   included taxpayers who described difficulties they had experienced in
                   trying to get help from the Internal Revenue Service (IRS) in resolving
                   ongoing problems. As a result of their experiences, specific concerns were
                   raised about the operations of IRS’ Office of the National Taxpayer
                   Advocate (Advocate’s Office) that had been created, in part, to help such
                   taxpayers.

                   You requested that we review operations of the Advocate’s Office and the
                   Problem Resolution Program (PRP) administered by that office. In
                   response to that request, this report discusses (1) challenges the National
                   Taxpayer Advocate (Advocate) faces in managing program resources, (2)
                   the potential effects of workload fluctuations on program operations, (3)
                   information available to help the Advocate determine the causes of
                   taxpayer problems and prevent their recurrence, and (4) the adequacy of
                   performance measures IRS uses to gauge program effectiveness.

                   As part of an agencywide effort to align IRS processes with taxpayer
                   needs, IRS is designing a new structure for the Advocate’s Office. With the
                   permission of your office, we briefed the Advocate and the IRS team
                   responsible for redesigning the Advocate’s Office several times during the
                   course of our review. During these briefings, we discussed various issues
                   that we had identified during our review and provided feedback on
                   proposed redesigns of the structure and operations of the Advocate’s
                   Office. Additionally, we testified on the results of our work at hearings
                                                                                 1
                   held by your Oversight Subcommittee on February 10, 1999.

                   We identified various management and operational challenges facing IRS,
Results in Brief   the Advocate’s Office, and PRP. How these challenges are addressed could
                   affect how efficiently and effectively taxpayers are helped by PRP.

                   1
                    IRS Management: Challenges Facing the National Taxpayer Advocate (GAO/T-GGD-99-28, Feb. 10,
                   1999).




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First, the Advocate’s Office faced resource management challenges
because it lacked direct control over most PRP resources. Specifically, (1)
the Advocate’s Office did not know how many staff were working in PRP
or the costs associated with that staffing; (2) the Advocate’s Office had to
rely on resources provided by IRS’ operating functions, such as Customer
Service, Collections, and Examination; (3) some Advocate Office and PRP
staff reported that they lacked training that Advocate Office officials
considered necessary; and (4) the Advocate’s Office faced obstacles, such
as limited advancement opportunities, in acquiring and keeping qualified
staff. Planned changes to the Advocate’s Office and PRP, such as placing
PRP resources under the control of the Advocate’s Office, could mitigate
some of these issues. However, it is too early to evaluate the impact of
these changes.

Second, IRS faces challenges as it restructures the Advocate’s Office to
better handle variations in PRP’s workload. According to Advocate Office
officials, in the past, because PRP operations depended on IRS functional
units for resources, any fluctuations in PRP’s workload were handled by
adjusting the number of functional staff assigned to work PRP cases.
However, the Advocate’s Office is moving away from a structure that relies
on other IRS units for staffing, which may make it more difficult for the
Advocate’s Office to handle workload fluctuations, especially workload
increases. The Advocate told us that he was committed to helping any
taxpayer who contacts the office. While it is understandable why the
Advocate’s Office might not want to turn away anyone seeking help,
accepting cases that could be handled elsewhere in IRS could overburden
PRP.

Third, the demands on the Advocate’s Office to resolve individual taxpayer
problems has left little time for staff to spend identifying the causes of
recurring taxpayer problems and recommending solutions. Also,
limitations in the kind of information available provided little assurance
that the time being spent was being used most effectively. These efforts on
recurring problems, called advocacy, are key to the success of the
Advocate’s Office because the improvements they generate can reduce the
number of taxpayers who ultimately require help from PRP.

Finally, IRS lacked adequate measures of the effectiveness of the
Advocate’s Office and PRP. Measures of effectiveness should cover the full
range of Advocate Office operations so they can be used to improve
program performance, increase accountability, and support
decisionmaking. The set of measures used by the Advocate’s Office during
our review focused on descriptive program events instead of program



Page 2                                  GAO/GGD-99-124 Taxpayer Advocate Office
             B-279035




             outcomes; did not provide complete data; or were not based on consistent
             data collection.

             The Advocate’s Office is identifying and implementing changes aimed at
             addressing some of the issues identified in this report; however, it is too
             soon to tell the efficacy of these efforts. Additionally, some of the changes
             might require more extensive efforts than are currently planned to
             alleviate the problem cited.

             IRS founded PRP in 1976 to provide an independent means of helping
Background   taxpayers solve problems that they encountered in dealing with IRS.
             Initially, PRP units were established in IRS district offices. In 1979, IRS
             expanded PRP to its service centers and created the position of Taxpayer
             Ombudsman to head PRP. The Ombudsman was appointed by and
             reported to the Commissioner of Internal Revenue. Congress has since
             renamed the Ombudsman the “National Taxpayer Advocate” and shifted
                                                                        2
             appointment authority to the Secretary of the Treasury. However, the
             Advocate continues to report to the Commissioner. To promote the
             independence of the Advocate, Congress required that the individual not
             be an IRS employee for 2 years preceding his or her appointment and that
             the individual not accept a position elsewhere in IRS for 5 years following
                                                3
             his or her tenure as the Advocate. The current Advocate was appointed in
             August 1998, in accordance with these provisions. Additionally, to enhance
             independence, the Advocate is required to submit annual reports directly
             to Congress on the objectives and activities of the Advocate’s Office. These
             reports are to be developed by the Advocate’s Office and are to be
             submitted directly to Congress without any prior review or comment from
             the Commissioner of Internal Revenue, the Secretary of the Treasury, or
             any other officer or employee of the Department of the Treasury.

             The Advocate manages an organization (i.e., the Advocate’s Office) that
                                                                                         4
             has advocates in each of IRS’ 4 regions, 33 districts, 30 former districts,
             and 10 service centers and in the Executive Office for Service Center
                                  5
             Operations (EOSCO) in Cincinnati, OH, and the Office of the Assistant

             2
                 IRS Restructuring and Reform Act of 1998, P.L. 105-206 (July 22, 1998).
             3
              Service as an officer or employee of the Advocate’s Office is not taken into account for purposes of
             the 2-year and 5-year rules.
             4
              In fiscal year 1996, IRS consolidated its field operations and reduced the number of districts from 63 to
             33. The former 30 districts continue to have staff and operations, including a local advocate’s office.
             5
              Before the establishment of EOSCO, the regions were responsible for service centers within their
             geographic boundaries. Organizationally, EOSCO is on a par with the regions.




             Page 3                                                   GAO/GGD-99-124 Taxpayer Advocate Office
B-279035




                                                                        6
Commissioner (International) in Washington, D.C. The regional and
EOSCO advocates are responsible for providing program oversight and
support to advocates in the district, former district, and service center
offices (hereafter referred to as “local advocates”), who manage PRP
operations at the local level. This program oversight and support is to
include reviewing PRP casework, ensuring the training of PRP staff and
staff in the Advocate’s Office, dealing with sensitive individual cases,
pursuing advocacy initiatives, and handling potential hardship cases.

Formerly, the regional and local advocates were selected by and reported
to the director of the regional office, district office, or service center where
they worked. However, the IRS Restructuring and Reform Act of 1998
changed that relationship. Now, regional advocates are to be selected by
and report to the National Taxpayer Advocate, and local advocates are to
be selected by and report to regional advocates.

At the time we completed our review in May 1999, most PRP casework
was being done by district office and service center staff, called
caseworkers, who were employees of IRS’ operating functions, such as
Customer Service, Collection, and Examination. In addition, each function
doing PRP work had a coordinator to ensure that all PRP cases within the
function were assigned to caseworkers and placed under PRP control and
to provide coordination between the function and the local advocates. PRP
caseworkers and coordinators were funded by the operating functions, not
the Advocate’s Office.

Also, each district office and service center had its own PRP structure,
which reflected differences in office size and composition and in the way
PRP caseworkers were managed. In the past, PRP caseworkers were
generally assigned to functional units and reported to functional managers.
In recent years, some local offices centralized their PRP casework in PRP
units staffed by functional employees who reported directly to the local
advocate.

The goals of the Advocate’s Office are consistent with IRS’ mission of
providing quality service to taxpayers by helping them meet their tax
responsibilities and by applying the tax laws fairly. The Advocate’s goals
are to



6
 The Office of International District Operations serves essentially as a district office for taxpayers
living outside the United States.




Page 4                                                  GAO/GGD-99-124 Taxpayer Advocate Office
                       B-279035




                     • assist taxpayers who cannot get their problems resolved through normal
                       IRS channels or those who are suffering significant hardships. For
                       example, local advocate offices can expedite tax refunds or stop
                       enforcement actions for taxpayers experiencing significant hardships. This
                       assistance is provided through PRP. During fiscal year 1998, PRP closed
                       more than 300,000 cases, of which about 10 percent involved potential
                       hardships;
                     • determine the causes of taxpayer problems so that systemic causes can be
                       identified and corrected and to propose legislative changes that might help
                       alleviate taxpayer problems. IRS commonly refers to this process as
                       advocacy; and
                     • represent taxpayers’ interests in the formulation of IRS policies and
                       procedures.
                       Our objectives were to (1) identify challenges the Advocate faces in
Objectives, Scope,     managing program resources, (2) identify potential effects of workload
and Methodology        fluctuations on program operations, (3) determine what information was
                       available for advocacy efforts, and (4) assess the adequacy of performance
                       measures IRS used to gauge program effectiveness. For all of our
                       objectives, we interviewed Advocate Office officials at IRS’ National
                       Office, all 4 IRS regional offices, and EOSCO, and we interviewed local
                       advocates, PRP coordinators, and caseworkers in 17 of IRS’ 73 local
                       offices—including 9 district offices, 4 former district offices, and 4 service
                       centers.

                       For the first objective, we also surveyed Advocate Office and PRP staff,
                       including PRP caseworkers, at IRS locations where Advocate’s Office and
                       PRP work was being done.

                       Additionally, for the third and fourth objectives, we reviewed program
                       documents on the Advocate’s Office and PRP, including guidance on
                       advocacy efforts, and program management information, including goals
                       and measures for the program.

                       For a more detailed account of our scope and methodology, including IRS
                       offices visited and limitations of our surveys, see appendix I.

                       We did our work from December 1997 to May 1999 in accordance with
                       generally accepted government auditing standards. We requested
                       comments on a draft of this report from the Commissioner of Internal
                       Revenue. His written comments are discussed near the end of this report
                       and are reprinted in appendix VII.




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                          We identified several resource management issues within the Advocate’s
Resource Management       Office and PRP that could affect how efficiently and effectively taxpayers
Issues Present            are helped by PRP. Specifically, (1) the Advocate’s Office did not know
Challenges for the        how many staff were working in PRP or the costs associated with that
                          staffing; (2) the Advocate’s Office had to rely on resources provided by
Advocate                  IRS’ operating functions, such as Customer Service, Collections, and
                          Examination; (3) some Advocate Office and PRP staff reported that they
                          lacked training that Advocate Office officials considered necessary; and
                          (4) the Advocate’s Office faced obstacles, such as limited advancement
                          opportunities, in acquiring and keeping qualified staff. Addressing such
                          issues presented a particular challenge to the Advocate’s Office because it
                          has not had direct control over most PRP resources.

                          IRS has begun to address some of the resource management issues we
                          identified. Other changes to the Advocate’s Office and PRP are being
                          considered in conjunction with a major effort that IRS has begun to
                          substantively revise its organizational structure. However, it is too soon to
                          tell how these changes will affect program operations.

The Advocate’s Office     The Advocate’s Office did not know the total number, time, and thus, cost
                          of staff devoted to PRP because IRS did not have a standard system to
Lacked Information on                                             7
                          track functional staff doing PRP work. The absence of this basic staffing
Functional PRP Staffing   information yields an incomplete picture of program operations, places
                          limitations on decisionmaking, and hinders the identification of matters
                          requiring management attention. For example, without complete staffing
                          information, IRS does not know the total cost of the program; and it
                          cannot project the potential cost, for planning purposes, of any
                          prospective changes or enhancements to the program.

                          IRS’ operating functions (e.g., Customer Service, Collection, and
                          Examination), which provided most of the staff working in PRP, had
                          systems to track the amount of time employees devoted to PRP, but each
                          function tracked time spent differently. The procedures varied, from
                          having employees charge all time spent to resolve a case to PRP, to having
                          them charge only a minimal amount of time to PRP.

                          Because of the situation just described, IRS was unable to tell us how
                          many functional staff were working on PRP activities and how much time
                          those staff were devoting to PRP work. To get information on the number
                          of functional staff, with the help of the Advocate’s Office, we sent out

                          7
                           IRS was able to track staff in the Advocate’s Office because these staff are funded by the Advocate’s
                          Office, not the functions.




                          Page 6                                                GAO/GGD-99-124 Taxpayer Advocate Office
                           B-279035




                           surveys that solicited staffing information from all locations where
                           Advocate Office and PRP work was being done. Summaries of the
                           responses to our surveys are presented in appendixes II and III.

                           Our surveys showed that on June 1, 1998, there were 508 staff working in
                           the Advocate’s Office and another 1,532 functional employees doing PRP
                           casework. Selected survey results for those 1,532 PRP caseworkers are
                           presented in appendix IV. As shown in that appendix, the 1,532 PRP
                           caseworkers included 726 district office employees and 806 service center
                           employees.

Reliance on Functional     The Advocate’s Office had to rely on other management officials within
                           IRS to provide most of the resources—including staff, space, and
Resources Contributed to   equipment—needed to do PRP casework. Because there was no direct
Staffing Issues            funding for PRP, however, functional managers had to carve out resources
                           for PRP from their operating budgets. This arrangement required district
                           and service center directors to shift employees and other resources into or
                           out of PRP as workload demands changed. When functional needs
                           conflicted with PRP needs, there were no assurances that PRP needs
                           would be met. This arrangement also meant that functional managers, not
                           local advocates, determined which employees would do PRP casework—
                           leaving the local advocates with little, if any, control over the quality of the
                           caseworkers. Local advocates told us that good communication and
                           working relationships with other managers within IRS was imperative to
                           receive the support needed to meet PRP goals.

                           Another result of the relationship just described is that local advocates
                           were not responsible for preparing official performance evaluations for
                           most PRP caseworkers. In that regard, our surveys showed that about 80
                           percent of the PRP caseworkers reported to and were evaluated by
                           functional management. Such a situation could have affected the ability of
                           caseworkers to resolve taxpayers’ problems impartially, because those
                           problems could involve disputes between the taxpayer and the function
                           responsible for evaluating the caseworker. Also, this situation could have
                           led to a perception that PRP was not an independent program.
                           Independence—actual and apparent—is important because, among other
                           things, it helps promote taxpayer confidence in PRP.

                           Because the Advocate’s Office did not have direct control over functional
                           employees, PRP caseworkers could sometimes be pulled from PRP duties
                           to do other work. For example, IRS officials said that PRP caseworkers
                           were often required to help the customer service function answer taxpayer




                           Page 7                                    GAO/GGD-99-124 Taxpayer Advocate Office
                               B-279035




                               telephone calls during the filing season. While caseworkers were helping
                               customer service, they were still responsible for their PRP work.

                               Since PRP did not have a direct budget, IRS officials said that it was easy
                               for PRP “to fall through the cracks” in terms of getting other resources,
                               such as equipment and space, for PRP work. When PRP caseworkers told
                               us of their equipment needs, they generally mentioned

                                     •   computers for word processing,
                                     •
                                                                                                           8
                                         ready access to Integrated Data Retrieval System (IDRS) terminals,
                                     •   telephone lines and voice mail,
                                     •   fax machines, and
                                     •   basic office supplies.

                               Given the nature of PRP work, caseworker access to IDRS and the
                               availability of such things as word processing equipment, voice mail, and
                               telephone lines would seem essential. For example, we observed that
                               caseworkers often prepared handwritten correspondence to taxpayers that
                               was not as professional looking as correspondence prepared on word-
                               processing equipment.

Some Advocate Office and       According to our survey, some Advocate Office staff and PRP caseworkers
                               had not received training that Advocate Office officials considered
PRP Staff Had Not Received     necessary. Our surveys of IRS staff who were doing Advocate Office work
Training Considered            as of June 1, 1998, indicated the following:
Necessary
                             • Only 35 percent of the staff in the Advocate’s Office had attended an
                               Advocate’s Office training course for their current position. These
                               positions included advocate, analyst, and PRP specialist.
                             • Fewer than half of the caseworkers had attended a PRP caseworker
                               training course.
                             • Almost 78 percent of the caseworkers had received PRP quality standards
                               training. This training is designed to ensure that caseworkers are aware of
                               the standards for acceptable PRP casework.

                               Although our survey indicated that caseworkers often had not completed a
                               formal PRP caseworker training course, the survey also indicated that
                               about 85 percent of the caseworkers had received on-the-job training.
                               While on-the-job training can be an effective means of teaching, it opens up
                               the possibility of inconsistencies in the way the program operates.

                               8
                                   IDRS is the primary system used by IRS employees to research and adjust taxpayer accounts.




                               Page 8                                                 GAO/GGD-99-124 Taxpayer Advocate Office
                                  B-279035




                                  In addition to being trained in PRP matters, Advocate Office officials said
                                  that caseworkers should continue to receive training in functional matters.
                                  Functional training, such as training in tax law changes, is important
                                  because resolving taxpayer problems requires that caseworkers
                                  understand the tax laws affecting a particular case. Our surveys indicated,
                                  however, that about half of the PRP caseworkers had not received such
                                  functional training.

                                  Both Advocate Office and PRP staff who we talked to said that there was
                                  no established training schedule, so they did not always know what
                                  training was being offered. When they did hear about training, it was
                                  sometimes too late to sign up. Some staff said that it had been several
                                  years since they had received any formal PRP training. Both Advocate
                                  Office staff and PRP caseworkers told us that, in addition to the basic
                                  training needed to do PRP work, they would like training in other areas,
                                  especially tax law changes. Also, many caseworkers wanted cross-
                                  functional training so that they could work cases across functional lines.
                                  IRS officials said that cross-functional training would broaden caseworker
                                  skills and might lead to faster and more accurate service to taxpayers.
                                  Additionally, they said that by broadening caseworkers’ skills and thus
                                  expanding the types of cases that they could work, cross-functional
                                  training could help the Advocate’s Office manage workload fluctuations.

Obstacles Existed to              Obstacles existed that could adversely affect the ability of the Advocate’s
                                  Office to acquire and keep qualified staff. Those obstacles included (1) the
Acquiring and Keeping             absence of standard position descriptions for PRP caseworkers that could
Qualified Staff                   be used to help ensure that qualified staff were assigned to PRP work and
                                  (2) limited opportunities for advancement within the Advocate’s Office and
                                  PRP.

Obstacle to Acquiring Qualified   There were no standard position descriptions for PRP caseworkers.
Staff                             Instead, PRP caseworkers worked under the position descriptions for
                                  employees in their functional organizations. This situation permitted
                                  functional managers to fill PRP caseworker positions through a
                                  noncompetitive process. IRS officials said that management usually asked
                                  for volunteers to work in PRP; if no volunteers came forward, management
                                  usually assigned staff to PRP, based on reverse seniority (i.e., staff with the
                                  least seniority would be assigned to PRP if not enough volunteers were
                                                 9
                                  forthcoming). Without competition, less qualified staff could be assigned

                                  9
                                   Many of the caseworkers we talked with enjoyed working in PRP more than doing functional work. In
                                  the customer service function, PRP work was viewed as being especially desirable because most
                                  customer service staff spent their time answering telephone calls from IRS’ toll-free lines and PRP
                                  work offered a respite from the telephone activity. However, some caseworkers said that they did not




                                  Page 9                                              GAO/GGD-99-124 Taxpayer Advocate Office
                            B-279035




                            to PRP. IRS officials said that if there were standard PRP caseworker
                            position descriptions, staff from the operating functions would have to
                            meet a set of qualifications and then compete for caseworker positions. As
                            in any organization, when staff compete for a position, management is
                            afforded an opportunity to select from among the best-qualified staff for
                            the duties prescribed for that position.

Obstacle to Keeping Staff   IRS officials said that the grade structure and size of the Advocate’s Office
                            and PRP limited opportunities for staff to advance within these
                            organizations. There were gaps in the Advocate’s Office and PRP grade
                                      10
                            structure. These gaps meant that, at some point, staff who wanted to
                            advance their careers would have to leave the Advocate’s Office or PRP to
                            get a promotion elsewhere in IRS—generally in an operating function. In
                            addition, the small size of the Advocate’s Office and PRP (in terms of
                            number of positions) meant that there were fewer numbers of promotions
                            available than in the larger operating functions.

                            Advocate Office and PRP staff who we talked to had mixed views on
                            whether they would have promotion opportunities within the functions.
                            Because the Advocate’s Office was “off line” from the operating functions,
                            many of the Advocate Office staff said that they would not have the
                            background necessary to compete for a promotion in an operating
                            function. Instead, they said that the only way for them to leave the
                            Advocate’s Office would be through a lateral transfer. Many caseworkers
                            told us, however, that the knowledge and skills they acquired in PRP could
                            potentially enhance their opportunities in their functional organizations.

IRS Has Begun to Address    IRS has taken some actions and has others planned that are related to the
                            resource management issues previously discussed; however, it is too soon
the Resource Management     to tell if these actions will fully address these issues.
Issues Facing the
Advocate’s Office           Many of the actions were being developed as part of IRS’ effort to redesign
                            the agency and are scheduled to be completed by the end of fiscal year
                            1999. IRS is planning substantive changes to the agency’s organizational
                            structure and work processes. Among other things, those plans would
                            eliminate or substantially modify IRS’ existing organization and establish



                            want to continue working in PRP because increased workloads and higher program visibility made the
                            job too stressful.
                            10
                               In some local advocate offices, for example, the associate advocate was a General Schedule (GS)-12
                            and the advocate was a GS-14. There was no GS-13 position in the office. Because of that gap, an
                            associate advocate would have to go elsewhere in IRS to get a promotion to GS-13.




                            Page 10                                               GAO/GGD-99-124 Taxpayer Advocate Office
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organizational units serving particular groups of taxpayers, such as wage
earners and small businesses.

In commenting on a draft of this report, IRS said that, beginning in October
1999, it will have the ability to track Advocate Office resources accurately.

Resource management changes include realigning the PRP staffing so that
all caseworkers report to local advocates, not functional management.
This should give the Advocate’s Office more control over PRP resources.
In October 1998, IRS announced that those caseworkers who were already
reporting to local advocates—about 20 percent—would officially be part of
the Advocate’s Office. In addition, at the time we completed our audit
work, IRS was developing an implementation plan to have the remaining
80 percent of the caseworker positions assigned to local advocate offices
during fiscal year 1999. To complement the shift to direct reporting of
caseworkers and further strengthen the independence of the Advocate’s
Office, IRS established for fiscal year 1999 a separate, centralized financial
structure for managing all Advocate Office resources. This structure
covers the resources allocated to the Advocate’s Office and includes PRP
caseworkers who have been transferred from the functions to the
Advocate’s Office. Having a separate, centralized structure gives the
Advocate’s Office control over its resource and should prevent Advocate
Office funds from being redirected to other IRS programs.

As of May 1999, IRS was also developing and updating the training for
Advocate Office staff and PRP caseworkers. The training is to reflect the
new operating structure and procedures for the Advocate’s Office as part
of the agencywide redesign effort. Training needs for all Advocate Office
and PRP staff are to be identified by the end of fiscal year 1999.

Other actions could make it easier for the Advocate’s Office and PRP to
acquire and keep qualified staff. In that regard, IRS has developed position
descriptions for all staff working in the Advocate’s Office and PRP. The
Advocate said that all positions within the Advocate’s Office and PRP will
be filled competitively using the new position description. This includes
having all existing Advocate Office and PRP staff reapply for their current
positions. IRS has reevaluated the PRP caseworker duties and, in many
cases, the new caseworker positions are higher-graded than the current
caseworker positions. According to the Advocate, the competition for the
positions should help ensure that the best staff are selected for the
Advocate’s Office and PRP.




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                       Additionally, in an effort to attract and keep qualified staff, the IRS
                       Restructuring and Reform Act of 1998 required that the Advocate develop
                       a career path for local advocates who choose to make a career in the
                       Advocate’s Office. In response to this requirement, the Advocate, at the
                       time we completed our audit work, had a plan that would not only provide
                       a career path within the Advocate’s Office and PRP, but would also enable
                       Advocate Office and PRP staff to compete for jobs in the operating
                       functions.

                       According to local advocates, dealing with workload fluctuations—
Handling Workload      especially increased workloads—poses a challenge for them as Advocate’s
Fluctuations Poses a   Office and PRP operations are restructured. (See app. V for factors that
Challenge as the       have increased and could increase PRP’s workload.) IRS uses “cases
                       closed” as its indicator of PRP workload. As figure 1 shows, the number of
Advocate’s Office      PRP cases closed in fiscal years 1993 through 1998 varied from year to
Restructures           year.

                       Figure 1: PRP Cases Closed (Fiscal Years 1993–1998)

                       Cases in thousands

                                          500


                                          400
                           Cases closed




                                          300


                                          200


                                          100


                                            0
                                                  1993        1994   1995      1996         1997       1998
                                                Fiscal year


                       Note: PRP cases that were opened and closed on the same day are not included in the totals
                       because they were not included in the IRS database from which this information was obtained.
                       Source: IRS Office of the National Taxpayer Advocate.


                       Historically, because PRP was staffed by the functions, the Advocate’s
                       Office relied on the functions to provide additional staff to cover workload
                       increases. However, as discussed previously, this reporting structure could



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                           have led to the perception that PRP lacked independence. In an attempt to
                           alleviate this possible perception, and as part of the restructuring effort, all
                           caseworkers are to be placed in the Advocate’s Office.

Workload Increases Could   Workload increases may make it necessary for the Advocate’s Office to
                           decide which cases to address with PRP resources. PRP was designed to
Affect PRP Services        help taxpayers who were unable to get their problems resolved elsewhere
                           in IRS. However, the Advocate told us that he was committed to helping
                           any taxpayer who contacts the office. We understand why the Advocate’s
                           Office might not want to turn away any taxpayers seeking help. However,
                           if the Advocate’s Office accepts cases that could be handled elsewhere in
                           IRS, PRP could be overburdened, potentially reducing its ability to help
                           taxpayers who have nowhere else to go to resolve their problems. As one
                           local advocate said, “if everything is a priority, then nothing is a priority.”
                           Overburdening PRP could also result in less staff time available for the
                           Advocate’s Office to devote to advocacy. We discuss that issue in more
                           detail in the next section.

                           In its plan to redesign the Advocate’s Office, IRS has acknowledged the
                           need to handle workload fluctuations. In the event of workload increases,
                           the Advocate’s Office needs to be able to either decrease the number of
                           cases entering the program, increase the number of staff working on cases,
                           or some combination of both. The Advocate said that for workload
                           increases, IRS plans to detail additional staff from the functions, as
                           necessary.

                           In his written comments on a draft of this report, the Commissioner of
                           Internal Revenue stated that IRS had recently modified the PRP criteria to
                           create a “taxpayer focused balance between cases handled by the
                           Taxpayer Advocate and other functions.” We did not have time to evaluate
                           the potential impact that the modified criteria might have on PRP
                           workload. (See app. V for a list of the PRP criteria.)

                           Through advocacy, the Advocate’s Office is to identify the underlying
Better Information         causes of recurring taxpayer problems and recommend changes in the tax
Could Help Ensure the      law or in IRS’ systems or procedures. Advocacy is key to the success of the
Best Use of Resources      Advocate’s Office because the improvements it generates could reduce the
                           number of taxpayers who ultimately require help from PRP. However, the
for Advocacy Efforts       advocates we talked with indicated that the demands on Advocate Office
                           staff and PRP caseworkers to resolve individual taxpayers’ problems left
                           little time to spend on advocacy. In addition, because of limitations in the
                           kind of information available to and compiled by the Advocate’s Office,
                           there was little assurance that the time being spent on advocacy was being



                           Page 13                                   GAO/GGD-99-124 Taxpayer Advocate Office
                           B-279035




                           used most effectively. As of May 1999, the Advocate was considering
                           various ideas for improving the advocacy process.

Time Spent Working on      As discussed more fully below, the advocacy process involves all levels of
                           the Advocate’s Office, from the Advocate to local caseworkers.
Individual Taxpayer        Nevertheless, most of the advocates we talked with said that the need to
Problems Has Limited the   work on individual taxpayer problems limited the amount of time that
Time Available for         advocate staff and PRP caseworkers could spend on advocacy. In that
Advocacy                   regard, our surveys indicated that, as of June 1, 1998, advocates and their
                           staffs were spending about 60 percent of their time on problems of
                                                11                                                12
                           individual taxpayers and about 10 percent of their time on advocacy.
                           PRP caseworkers were spending almost all of their PRP time on problems
                           of individual taxpayers.

The Advocacy Process       The advocacy process within the Advocate’s Office involves all levels of
                           the organization, from the Advocate to local caseworkers. The Advocate’s
                           Office is responsible for (1) assisting, supporting, and guiding advocacy
                           efforts at all levels; (2) identifying issues with nationwide implications and
                           assigning responsibility for conducting research on these issues to regional
                           advocates; and (3) compiling information on the status of ongoing and
                           completed advocacy projects. Advocacy projects are intended to develop
                           recommendations for improving IRS processes and procedures that can be
                           forwarded to the function responsible for the processes or procedures.
                           Advocate staff are to monitor the implementation of the recommendation
                           and, in instances in which no action is taken by the function, the Advocate
                           can compel the function to implement the recommendation by issuing a
                           Taxpayer Advocate Directive. The Advocate was delegated this authority
                           in March 1998, and on December 7, 1998, he issued the first directive
                           requiring that IRS operations abate penalties on some “innocent spouse”
                                 13
                           cases. As of April 1999, there had been no other directives issued.

                           Each region and EOSCO has an advocacy council comprised of Advocate
                           Office staff and functional executives and staff. These councils are

                           11
                              Advocates and their staffs generally deal with sensitive cases, such as congressional inquiries, and
                           cases in which a taxpayer has applied for relief due to hardship.
                           12
                            The remainder of their time was spent on other types of Advocate Office work, such as program
                           management and support.
                           13
                              To qualify for innocent spouse relief, a person must have filed a joint return with an understatement
                           of taxes owed; the understatement must result from erroneous items of the spouse; and the person
                           applying for innocent spouse relief must not have known about the errors caused by the other spouse.
                           Prior to the IRS Restructuring and Reform Act of 1998, the understatement must have exceeded the
                           greater of 500 dollars or a specified percentage of the innocent spouse's adjusted gross income for the
                           most recent year.




                           Page 14                                                 GAO/GGD-99-124 Taxpayer Advocate Office
                                B-279035




                                responsible for promoting advocacy and serve as clearinghouses for
                                advocacy efforts by evaluating the merits of recommendations proposed at
                                the regional and local office levels and by assigning projects to local
                                advocates for further research. In evaluating the merits of local and
                                regional advocacy recommendations, the councils are to either (1) endorse
                                a recommendation and forward it to the National Office, (2) decide that a
                                recommendation has merit but that more work needs to be done to
                                support it, or (3) decide that the recommendation does not have merit. The
                                councils are also responsible for providing guidance to local offices on
                                advocacy projects and for ensuring that local offices receive feedback on
                                advocacy projects.

                                Local advocates receive ideas for advocacy efforts from a variety of
                                sources, such as PRP’s case inventory system, PRP caseworkers,
                                functional staff, and tax practitioners. In some cases, immediate action can
                                be taken by local managers to improve local procedures and prevent local
                                administrative problems. In other cases, the idea may be studied at the
                                local office and recommendations for improvement can be forwarded to
                                the responsible advocacy council for agencywide consideration.

                                Advocacy recommendations also come from the Equity Task Force, which
                                was chartered to make recommendations to the Advocate. The task force
                                is comprised of a cross-section of IRS functional executives, functional
                                staff, and Advocate Office staff. Recommendations from the task force are
                                designed to further the interests of fairness in tax administration.

Inadequate Information          We understand the need for the Advocate’s Office to give priority to
                                individual taxpayer problems (i.e., casework) over advocacy when there is
Available to Ensure the         not enough time to do both. If the PRP workload were to increase, it could
Most Effective Use of Time      become even more difficult for the Advocate’s Office to find time to spend
Spent on Advocacy               on advocacy. The Advocate’s Office must, therefore, make the best
                                possible use of the time available for advocacy. However, at the time of
                                our review, the Advocate’s Office did not have the kind of information
                                needed to (1) make sound decisions on which projects to undertake and
                                (2) protect against wasteful duplication of effort.

Information On Which Projects   The Advocate’s Office did not systematically gather the information
To Work Was Limited             needed to identify and prioritize advocacy projects. For the most part,
                                advocacy projects were identified by analyzing the codes used to
                                categorize taxpayer problems for the Advocate’s case inventory system.
                                However, IRS officials said that analyzing these codes was not the best
                                means of identifying advocacy projects because the codes do not provide
                                enough information on the nature of the problems.



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                                  B-279035




                                  For example, one code indicates that the problem involved a lost or stolen
                                  refund. However, there is no way to tell from the code why the case ended
                                  up in PRP. There are normal procedures for taxpayers and IRS to follow in
                                  getting a lost or stolen refund replaced. The fact that such a case ended up
                                  in PRP does not indicate whether there was some procedural failure that
                                  resulted in IRS’ inability to produce a replacement refund for the taxpayer.
                                  This level of detail may be available on individual cases—in the case
                                  history section—however, there is no way to search the Advocate’s case
                                  inventory system for this information. As a result, the inventory system can
                                  only describe the frequency of taxpayer problems; it cannot describe why
                                  the problem ended up in PRP. In the absence of such information, the
                                  Advocate’s Office does not know which advocacy efforts have the greatest
                                  potential to resolve recurring taxpayer problems.

Comprehensive Information on      We found that the Advocate’s Office did not have a comprehensive source
Advocacy Projects Not Available   of information on all proposed, ongoing, and completed advocacy projects.
                                  Additionally, we found that field staff did not always have access to
                                  information on advocacy projects. Because advocacy projects can be
                                  started at any level in the Advocate’s Office, it is important that everyone
                                  have access to comprehensive information on advocacy projects. Among
                                  other things, such information should help enhance coordination and
                                  prevent unnecessary duplication of effort.

                                  Information on advocacy efforts is available from the (1) the Advocacy
                                  Project Tracking System, (2) an inventory of legislative recommendations,
                                  and (3) the Commissioner’s Tracking System. None of these three sources
                                  provides a comprehensive listing of advocacy projects.

                                  The Advocacy Project Tracking System is a document maintained by the
                                  Advocate’s Office that includes completed and ongoing advocacy projects
                                  from IRS’ four regional offices and EOSCO. The document is presented as
                                  a matrix with information on each project, such as the project title, a short
                                  description of the project, the project contact points, and the status of the
                                  project’s recommendations. The matrix was last updated as of September
                                  30, 1998, and there were 39 projects listed. The matrix does not, however,
                                  contain any information on what projects were ongoing or planned at the
                                  local offices.

                                  The inventory of legislative recommendations aimed at changing the
                                  current tax law is a document that presents potential legislative changes
                                  recommended by each region and EOSCO. The list is also presented in
                                  matrix format with information on each recommendation, such as whether
                                  there is an advocacy project related to the issue, what the proposed action



                                  Page 16                                 GAO/GGD-99-124 Taxpayer Advocate Office
B-279035




is, and the status of the recommendation. The list is tracked by fiscal year,
and those recommendations that the Advocate endorsed are to be included
in the Advocate’s Report to Congress. As of April 1999, there were seven
legislative recommendations on the list. This listing, however, is limited to
proposed changes to legislation and does not contain any information on
ongoing, proposed, or completed advocacy projects.

The Commissioner’s Tracking System is a document that is to contain
information on all advocacy memorandums that were sent to functional
management. Advocacy memorandums are to be sent from the Advocate
to a National Office function when the function resists or does not respond
to a recommendation that the Advocate feels will alleviate harm to
taxpayers or decrease taxpayer burden. Advocacy memorandums are to be
sent only after other inquiries or attempts to resolve the issue have proved
unsuccessful. The function is asked to respond in writing to the advocacy
memorandum. If the functional area does not provide a satisfactory reason
for not implementing a recommendation, the Advocate can compel the
function to implement the recommendation by issuing a Taxpayer
Advocate Directive, as explained previously. Information on the
Commissioner’s Tracking System and information from the directives are
to be included in the Advocate’s Annual Report to Congress. As of April
1999, the Advocate had written 12 advocacy memorandums. This
document only contains those advocacy recommendations that were not
willingly implemented by the functions and is not a complete source of
advocacy projects.

The lack of a comprehensive source of information on all advocacy
projects increases the risk of unnecessary duplication of effort. In that
regard, staff at several locations said that regional and local offices are
often studying similar problems. For example, an IRS regional official said
that two of IRS’ regions were studying projects on several similar issues,
including (1) the application of taxpayer overpayment credits and (2)
waiving the 10 percent additional tax penalty on withdrawals from
Individual Retirement Accounts in hardship cases. The official also said
that there was even less awareness of ongoing efforts at the district office
and service center levels than at the regional level described above.

A more comprehensive source of information on advocacy projects might
also help provide staff with better feedback on project results. Although
each IRS region and EOSCO has an advocacy council that is responsible
for providing feedback to district and service center staffs, the local
advocates and council members with whom we talked said that there was
no formal mechanism for providing feedback. In particular, council



Page 17                                 GAO/GGD-99-124 Taxpayer Advocate Office
                         B-279035




                         members said that staff who had worked on projects were not receiving
                         status reports or even an acknowledgment that recommendations from
                         their projects were being considered for possible implementation, even
                         though the councils were responsible for providing this information. In one
                         district, for example, the local advocate said that he had forwarded the
                         same advocacy recommendations to the regional council over the course
                         of several years, but had not received feedback concerning what actions, if
                         any, were taken on these recommendations.

Proposed Changes for     In October 1998, the Advocate established a team to develop
                         recommendations to strengthen advocacy within IRS. The team’s goal was
Strengthening Advocacy   to develop and recommend a national advocacy plan, and the team made
Efforts Are Under        several recommendations to the Advocate for initiating and coordinating
Consideration            advocacy projects. For example, in its February 1999 report to the
                         Advocate, the team recommended that a national advocacy database be
                         developed to provide a single source of information on ongoing advocacy
                         projects. The national database would contain information on all advocacy
                         efforts, including those at the national, regional, and local levels. In
                         addition, the database would be accessible to all local advocates. As part
                         of the effort to redesign the Advocate’s Office, the Advocate said that he
                         plans to adopt the recommendations from the team. Also, the redesign
                         plan calls for establishing separate casework and advocacy units, each
                         with its own dedicated staff, thus reducing the possibility that advocacy
                         will suffer in times of high PRP caseloads.

                         IRS lacked adequate measures of the effectiveness of the Advocate’s Office
The Advocate’s Office    and PRP. The set of measures used by the Advocate’s Office during our
Lacked Adequate          review (1) provided descriptive information about program activities, such
Measures of              as the average amount of time it takes to close a PRP case, rather than
                         information needed to assess effectiveness; (2) did not provide complete
Effectiveness            data; or (3) were not based on consistent data collection. IRS has efforts
                         under way to improve program measures. Those efforts, at least as they
                         relate to the Advocate’s Office, may be hampered by existing information
                         systems.

                         While it is necessary for an organization to measure program activities,
                         such as average case processing time, the more important and more
                         difficult task is to develop measures of effectiveness that focus on the
                         impact of an agency’s programs on its customers. Measures of
                         effectiveness are important because they provide data to improve program
                         performance, increase accountability, and support decisionmaking. We
                         found that the Advocate’s Office had measures to gauge certain aspects of
                         PRP’s performance, but that these measures could not fully assess PRP’s



                         Page 18                                GAO/GGD-99-124 Taxpayer Advocate Office
                            B-279035




                            effectiveness. For example, the Advocate’s Office did not have a method
                            for measuring customer satisfaction, and there was no mechanism for
                            determining the effectiveness of advocacy efforts—both of these measures
                            would help the Advocate understand how effective the program is in
                            helping taxpayers.

Existing PRP Measures Are   During our review, the Advocate’s Office was using the following four
                            measures to gauge PRP’s performance: (1) average processing time to
Inadequate                  close PRP cases, (2) currency of PRP case inventory, (3) quality of
                            casework, and (4) case identification rate. Although those measures
                            provided some useful information, they did not provide all of the
                            information needed to assess PRP’s effectiveness. (See app. VI for more
                            information on these measures.)

                            The first two measures, average processing time and currency of case
                            inventory, provide descriptive information about program activities.
                            Although these measures are useful for some program management
                            decisions, such as the number of staff needed at a specific office, they do
                            not provide information on PRP’s effectiveness.

                            The third measure is designed to determine the quality of PRP casework.
                            Although this measure provides some data on program effectiveness, it
                            provides no information on customer satisfaction. In commenting on a
                            draft of this report, IRS said that it is developing ways to measure PRP
                            customer satisfaction and that it plans to test and refine the measure
                            beginning in October 1999. By helping taxpayers resolve problems that
                            were not resolved elsewhere in IRS, the Advocate’s Office plays a pivotal
                            role in delivering customer service to the taxpayers. Customer satisfaction
                            data from taxpayers who contacted PRP could provide the Advocate’s
                            Office with information on how taxpayers feel about the service they
                            received and whether taxpayers consider their problems solved. Without
                            this information, the Advocate’s Office is not in the best position to
                            improve program operations to better satisfy taxpayer needs.

                            The fourth measure, PRP case identification, attempts to determine if
                            service center employees are properly identifying potential PRP cases
                            from incoming correspondence. This measure is an important tool to help
                            the Advocate’s Office know whether PRP actually serves those taxpayers
                            who qualify for help from the program. However, the measure provides an
                            incomplete picture because it is designed for use only at service centers.
                            There is no similar measure to determine how well district offices and toll-
                            free telephone call sites are identifying and referring potential PRP cases.




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                            B-279035




                            Also, a recent review of the PRP case identification measure by IRS’ Office
                            of Internal Audit disclosed, among other things, that inconsistent data
                            collection could affect the integrity and reliability of the measure’s results.
                            For example, Internal Audit found that the test was not always performed
                            the required number of times per month at each service center and that the
                            mail sample was not based on the service center’s incoming mail
                            population. Additionally, when Internal Audit performed a parallel PRP
                            case identification sample—in accordance with national standards—its
                            rates for some service centers were significantly lower—in one case, over
                            55 percentage points lower—-than rates reported by the service center.

                            In addition to the shortcomings of these four measures, IRS lacked a
                            method for determining the effectiveness of its advocacy efforts. Advocacy
                            is a major responsibility of the Advocate’s Office and is aimed at ultimately
                            reducing the number of taxpayers needing help from PRP. Without
                            information on the effectiveness of these efforts, the Advocate’s Office
                            does not know, for example, which efforts provide the greatest benefit to
                            taxpayers.

Current Information         The Advocate is working to improve Advocate Office and PRP measures of
                            effectiveness. In January 1999, as part of its efforts to redesign the
Systems May Limit IRS’      Advocate’s Office, IRS established a task force to determine what
Ability to Develop Needed   measures are needed to assess program effectiveness. Specifically, the
Measures                    group is tasked to research, identify, and develop corporate level measures
                            for Advocate Office program results, customer satisfaction, and employee
                            satisfaction. Their ability to develop needed measures of effectiveness,
                            however, may be hampered by existing information systems. The Taxpayer
                            Advocate Management Information System is comprised of the Problem
                            Resolution Office Management Information System (PROMIS), the
                            Customer Feedback System, and the PRP Case Identification and Tracking
                            System. These systems do not provide the Advocate’s Office with the data
                            it needs to assess the effectiveness of PRP operations.

                            PROMIS is a computerized inventory control and report system that
                            includes information from individual PRP cases, such as the taxpayer’s
                            name, address, and Social Security number. PROMIS generates reports on
                            cumulative descriptive program data, such as the number of cases worked
                            in PRP and how quickly cases are closed. Although the system also
                            captures data on the types of problems taxpayers are experiencing—such
                            as the “lost or stolen refund” example mentioned earlier—there is no
                            mechanism to search for other data that might help advocacy efforts by
                            pointing to agencywide weaknesses. For instance, there is no way to
                            determine if cases were caused by problems with a particular IRS system



                            Page 20                                  GAO/GGD-99-124 Taxpayer Advocate Office
              B-279035




              because the cases are coded only by type of tax problem. In a case history
              section, PROMIS captures information on the nature of the taxpayer’s
              problem and what actions were taken to help the taxpayer. However, there
              is no mechanism to search multiple cases for trend data from the history
              section.

              The Customer Feedback System is designed to capture taxpayers’
              compliments and complaints about IRS employees. The system depends
              on taxpayers to take the initiative to voluntarily comment about the
              treatment they received from an IRS employee and on IRS managers to
              complete the customer feedback form. The voluntary nature of the system
              means that the data are not statistically representative of program
              participation, and fluctuations in the data cannot be attributed to changes
              in program operations. In addition, comments captured on the system
              could relate to any IRS function, not just PRP, and therefore, are of limited
              use in assessing PRP’s effectiveness.

              The PRP Case Identification and Tracking System is used to capture
              information on the PRP case identification measure discussed earlier. As
              such, it has the same limitations as that measure—it only has information
              on cases coming into IRS through correspondence at the service centers.
              Because this system contains no information on cases coming in through
              district offices and call sites, it provides incomplete data on whether
              taxpayers who qualify for PRP assistance are being properly identified and
              referred to PRP.

              In addition to the problems with the Taxpayer Advocate Management
              Information System, we mentioned earlier that the Advocate’s Office
              lacked a system to track resources dedicated to the program. Because PRP
              was implemented through IRS’ functions, the Advocate’s Office had no
              system to track the resources devoted to PRP. Without this basic program
              information, the Advocate’s Office had no means to determine what it
              invested in the program.

              The Advocate’s Office can provide a valuable service by helping (1)
Conclusions   taxpayers who have been unable to resolve their problems elsewhere in
              IRS and (2) taxpayers who are suffering significant hardships.

              We have identified challenges, obstacles, and deficiencies in Advocate
              Office and PRP operations that could affect how efficiently and effectively
              services are provided to taxpayers. The Advocate’s Office is in the midst of
              identifying and implementing changes designed to improve its operations.
              Many of the changes, such as restructuring Advocate Office operations and



              Page 21                                 GAO/GGD-99-124 Taxpayer Advocate Office
                      B-279035




                      creating career paths for local advocates, are due to requirements of the
                      IRS Restructuring and Reform Act of 1998; other changes, such as
                      developing position descriptions for PRP caseworkers, are the result of
                      Advocate Office initiatives. However, it is too soon to tell how effective
                      these changes will be in addressing the challenges cited in this report.

                      Two areas in which changes are being considered are advocacy and
                      performance measures. However, changes in both areas require the
                      development of better information systems than are currently available.
                      For example, without a system or systems that provide (1) information
                      needed to identify and prioritize advocacy projects and (2) comprehensive
                      information on all proposed, ongoing, and completed advocacy projects,
                      IRS has no assurance that the Advocate’s Office is most effectively using
                      the resources available for advocacy. Similarly, without a system or
                      systems that provide better data than are now available in the Taxpayer
                      Advocate Management Information System, IRS’ ability to develop
                      appropriate measures of PRP effectiveness may be hampered.

                      To better ensure that the Advocate’s Office effectively uses the resources
Recommendations to    available for advocacy and thus enhances its ability to prevent the
the Commissioner of   recurrence of taxpayer problems and ultimately reduce the number of
Internal Revenue      taxpayers who need help from PRP, we recommend that the
                      Commissioner of Internal Revenue direct appropriate officials to define
                      the requirements for and to develop a system that captures the kind of
                      information needed to identify and prioritize potential advocacy projects
                      and provide feedback to staff on ongoing and completed projects.

                      To better manage PRP resources and improve operations, we recommend
                      that the Commissioner of Internal Revenue direct appropriate officials to
                      design management information systems that can support outcome-
                      oriented performance measures.

                      The Commissioner of Internal Revenue commented on a draft of this
Agency Comments and   report by letter dated July 7, 1999, in which he generally agreed with our
Our Evaluation        findings and concurred with our recommendations. (See app. VII for a
                      copy of the letter.) We modified the report to ensure technical correctness
                      and include updated information where appropriate.

                      We are sending copies of this report to Representative Charles B. Rangel,
                      Ranking Minority Member, House Committee on Ways and Means;
                      Representative Amo Houghton, Chairman, and Representative William J.
                      Coyne, Ranking Minority Member, Subcommittee on Oversight, House
                      Committee on Ways and Means; and Senator William V. Roth, Jr.,



                      Page 22                                 GAO/GGD-99-124 Taxpayer Advocate Office
B-279035




Chairman, and Senator Daniel P. Moynihan, Ranking Minority Member,
Senate Committee on Finance. We are also sending copies to The
Honorable Lawrence H. Summers, Secretary of the Treasury; The
Honorable Charles O. Rossotti, Commissioner of Internal Revenue; The
Honorable Jacob J. Lew, Director, Office of Management and Budget; and
other interested parties. Copies of this report will be made available to
others upon request.

If you have any questions regarding this letter, please contact me or David
Attianese at (202) 512-9110. Key contributors to this assignment were
Kelsey Bright, Isidro Gomez, and Susan Malone.

Sincerely yours,




Cornelia M. Ashby
Associate Director, Tax Policy
  and Administration Issues




Page 23                                GAO/GGD-99-124 Taxpayer Advocate Office
Contents



Letter                                                                                        1


Appendix I                                                                                   26
                      Offices Visited                                                        26
Detailed Scope and    Program Information Reviewed                                           27
Methodology           Staffing Surveys                                                       27


Appendix II                                                                                  28
                      Survey Questions and Responses                                         28
Summary of
Responses to the
Taxpayer Advocate
Staffing Survey
Appendix III                                                                                 35
                      Survey Questions and Responses                                         35
Summary of
Responses to the
Functional PRP
Staffing Survey
Appendix IV                                                                                  43

Selected Survey
Results for PRP
Caseworkers
Appendix V                                                                                   46
                      Broad Interpretation of PRP Criteria                                   46
Factors That Have     IRS Initiatives Place Demands on Program Resources                     47
Increased and Could   Legislative Requirement May Increase Demands on PRP                    49

Increase PRP
Workload




                      Page 24                            GAO/GGD-99-124 Taxpayer Advocate Office
                      Contents




Appendix VI                                                                                      50
                      Performance Measures                                                       50
PRP Performance       Information Systems                                                        51
Measures and
Information Systems
Appendix VII                                                                                     53

Comments From the
Internal Revenue
Service




                      Abbreviations

                      EOSCO       Executive Office for Service Center Operations
                      GS          General Schedule
                      IDRS        Integrated Data Retrieval System
                      IRS         Internal Revenue Service
                      PROMIS      Problem Resolution Office Management Information System
                      PRP         Problem Resolution Program




                      Page 25                                GAO/GGD-99-124 Taxpayer Advocate Office
Appendix I

Detailed Scope and Methodology


                                        We interviewed agency officials at the Internal Revenue Service’s (IRS)
Offices Visited                         National Office, all 4 IRS regional offices, the Executive Office for Service
                                        Center Operations (EOSCO), and 17 local offices, including 9 district
                                                                           1
                                        offices, 4 former district offices, and 4 service centers (see table I.1 for a
                                        list of the regional and local offices we visited).

Table I.1: Regional and Local Offices
Visited                                 Regional Offices
                                         Midstates Region (Dallas, TX)
                                         Northeast Region (New York, NY)
                                         Southeast Region (Atlanta, GA)
                                         Western Region (San Francisco, CA)
                                        District Offices
                                         Delaware-Maryland (Baltimore, MD)
                                         Central California (San Jose, CA)
                                         Kentucky-Tennessee (Nashville, TN)
                                         Manhattan (New York, NY)
                                         Northern California (Oakland, CA)
                                         North Texas (Dallas TX)
                                         Pacific Northwest (Seattle, WA)
                                         Pennsylvania (Philadelphia, PA)
                                         Virginia-West Virginia (Richmond, VA)
                                        Former District Offices
                                         August, ME (part of the New England District)
                                         Pittsburgh, PA (part of the Pennsylvania District)
                                         Portland, OR (part of the Pacific Northwest District)
                                         Sacramento, CA (part of the Northern California District)
                                        Service Centers
                                         Atlanta, GA
                                         Brookhaven, NY
                                         Fresno, CA
                                         Philadelphia, PA



                                        We selected the 17 local offices on the basis of suggestions from Advocate
                                        Office staff; our stratification of offices to obtain a variety by size, type of
                                        work, and organization; and geographic convenience. At the National
                                        Office, we interviewed the National Taxpayer Advocate, his predecessor,
                                        and members of his staff. We interviewed the EOSCO advocate; and, at the
                                        regional and local offices, we interviewed the advocates and their staffs.
                                        Additionally, at the local offices, we interviewed Problem Resolution
                                        Program (PRP) coordinators and PRP caseworkers. We also attended two
                                        regional advocacy council meetings and discussed PRP operations with
                                        council members.


                                        1
                                         In fiscal year 1996, IRS consolidated its field operations and reduced the number of districts from 63
                                        to 33. The former 30 districts continue to have staff and operations, including a local advocate’s office.




                                        Page 26                                                 GAO/GGD-99-124 Taxpayer Advocate Office
                      Appendix I
                      Detailed Scope and Methodology




                      We reviewed documents, including sections of the Internal Revenue
Program Information   Manual pertaining to the Advocate’s Office and PRP; IRS Internal Audit
Reviewed              reports on the Advocate’s Office and PRP; and National Office, regional,
                      district, and service center program documents.

                      We reviewed program data on advocacy efforts at IRS. These data included
                      Internal Revenue Manual instructions on advocacy and databases on
                      ongoing and completed advocacy projects. We interviewed Advocate
                      Office staff responsible for advocacy and local advocates and their staffs
                      to determine how advocacy projects are identified and implemented. We
                      also attended two Regional Advocacy Council meetings to increase our
                      awareness of program operations. We did not assess IRS’ effectiveness in
                      implementing proposed advocacy projects because IRS Internal Audit had
                      an ongoing assignment with that specific objective.

                      We reviewed program management information for the Advocate’s Office
                      and PRP. This information included program goals and measures and the
                      systems by which these data are captured. Data for the Advocate’s Office
                      and PRP are captured on the Taxpayer Advocate Management Information
                      System, which includes three separate systems—the Problem Resolution
                      Office Management Information System, the PRP Case Identification and
                      Tracking System, and the Customer Feedback System.

                      Through our surveys and with the help of the Advocate’s Office, we
Staffing Surveys      obtained staffing information from all IRS locations where Advocate Office
                      and PRP work was being done. We attempted to get information for all IRS
                      staff doing Advocate Office or PRP work, including PRP caseworkers, as
                      of June 1, 1998. (See apps. II and III for summaries of the responses to our
                      surveys.) When necessary, we verified responses to the staffing surveys by
                      telephone. However, we did not verify that we received responses for all
                      staff doing Advocate Office or PRP work. The results of our surveys were
                      limited to a specific time (June 1, 1998), and responses may vary based on
                      how staff interpreted our questions.




                      Page 27                                GAO/GGD-99-124 Taxpayer Advocate Office
Appendix II

Summary of Responses to the Taxpayer
Advocate Staffing Survey

                       This appendix contains a summary of responses to the survey we sent to
                       the National Taxpayer Advocate, the four regional advocates, the
                       advocates at EOSCO and the Office of the Assistant Commissioner
                       (International), and the 43 local advocates. In that survey, we asked for
                       information on each person on their staffs as of June 1, 1998, including the
                       advocate or associate advocate, where appropriate. We received responses
                       for 508 staff, including staff detailed to advocate offices by the operating
                       functions.

                       1. Series? (Provide the position series number.)
Survey Questions and
Responses

                                                                                                  Number        Percentage
                                a                  b
                       Series        Occupation                                                    of staff         of staff
                       301           Miscellaneous administration & program                             66             13.0
                       303           Miscellaneous clerk & assistant                                    32               6.3
                       313           Work unit supervising                                               1              0.2
                       318           Secretary                                                          36              7.1
                       322           Clerk-typist                                                        1              0.2
                       326           Office automation clerical & assistance                             6              1.2
                       340           Program management                                                 34              6.7
                       343           Management & program analysis                                     201             39.6
                       344           Management & program clerical & assistance                         20              3.9
                       345           Not listed                                                          1              0.2
                       356           Data transcriber                                                    1              0.2
                       392           General telecommunications                                          1              0.2
                       503           Financial clerical & assistance                                     2              0.4
                       511           Auditing                                                            1              0.2
                       512           Internal revenue agent                                              4              0.8
                       526           Tax technician                                                     39              7.7
                       592           Tax examining                                                      35              6.9
                       962           Contact representative                                              5              1.0
                       987           Tax law specialist                                                  1              0.2
                       1169          Internal revenue officer                                            8              1.6
                       None          No response                                                        13              2.6
                       Total                                                                           508            100.2
                       Note: Percentages do not equal 100 due to rounding.
                       a
                        "Series" means a number identifying a recognized occupation in the federal service that includes all
                       jobs at the various skill levels in a particular kind of work.
                       b
                       "Occupation" means an occupational series listed in the Handbook of Occupational Groups and
                       Families developed by the U.S. Office of Personnel Management to aid federal agencies in classifying
                       positions under the Classification Act of 1949 and P.L. 92-392.




                       2. Grade? (Provide the person’s current grade level.)



                       Page 28                                               GAO/GGD-99-124 Taxpayer Advocate Office
Appendix II
Summary of Responses to the Taxpayer Advocate Staffing Survey




       a
Grade                                             Number of staff               Percentage of staff
General Schedule-4                                            27                               5.3
General Schedule-5                                            26                               5.1
General Schedule-6                                            38                               7.5
General Schedule-7                                            42                               8.3
General Schedule-8                                            10                               2.0
General Schedule-9                                            93                              18.3
General Schedule-10                                            1                               0.2
General Schedule-11                                           95                              18.7
General Schedule-12                                           77                              15.2
General Schedule-13                                           45                               8.9
General Schedule-14                                           42                               8.3
General Schedule-15                                           11                               2.2
Executive Schedule-5                                           1                               0.2
Total                                                        508                             100.2
Note: Percentages do not equal 100 due to rounding.
a
 "Grade" means the level of classification an employee has under a position classification system (i.e.,
referring to the duties, tasks, and functions he or she performs).




3. Permanent or detailed? (Indicate whether the person is assigned to the
Taxpayer Advocate’s Office on a permanent or detailed basis.)


Assignment basis                                  Number of staff               Percentage of staff
Permanent                                                    436                              85.8
Detailed                                                      63                              12.4
      a
Other                                                          7                               1.4
No response                                                    2                               0.4
Total                                                        508                             100.0
a
"Other" includes interim and temporary assignments.




4. Full-time or part-time? (Indicate whether the person is a full-time or
part-time IRS employee.)


IRS employment basis                              Number of staff               Percentage of staff
Full-time                                                    495                              97.4
Part-time                                                      8                               1.6
No response                                                    5                               1.0
Total                                                        508                             100.0




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Appendix II
Summary of Responses to the Taxpayer Advocate Staffing Survey




5. Percent of time spent on Advocate Office work? (Estimate the
percentage of time the person does work related to the Advocate’s Office,
including Problem Solving Day cases. Response should be 100 percent,
unless the person also does work for another office or function.)


Percentage of time spent
                        a
on Advocate Office work                        Number of staff            Percentage of staff
1-24                                                        1                            0.2
25-49                                                       0                            0.0
50-74                                                       0                            0.0
75-99                                                       2                            0.4
100                                                       505                           99.4
Total                                                     508                          100.0
a
"Advocate Office work" includes work related to PRP.




6. Years at IRS? (Provide the number of years the person has worked at
IRS. Do not include other government experience.)


Years at IRS                                   Number of staff            Percentage of staff
Less than 1                                                 2                            0.4
1-5                                                         7                            1.4
6-10                                                       68                           13.4
11-15                                                     123                           24.2
16-20                                                     108                           21.3
More than 20                                              186                           36.6
No response                                                14                            2.8
Total                                                     508                          100.1
Note: Percentages do not equal 100 due to rounding.




7. Years in PRP? (Provide the number of years the person has done PRP
work.)


Years in PRP                                   Number of staff            Percentage of staff
Less than 1                                               102                           20.1
1-5                                                       141                           27.8
6-10                                                      152                           29.9
11-15                                                      67                           13.2
16-20                                                      26                            5.1
More than 20                                                4                            0.8
No response                                                16                            3.1
Total                                                     508                          100.0




Page 30                                               GAO/GGD-99-124 Taxpayer Advocate Office
Appendix II
Summary of Responses to the Taxpayer Advocate Staffing Survey




8. Prior IRS function(s)? (Check all that apply.) (Indicate the IRS
operating function(s) where the person worked before coming to the
Taxpayer Advocate’s Office.)


Prior IRS function(s)                              Number of staff           Percentage of staff
Collection                                                    181                          35.6
Customer Service
 Automated Collection System                                      37                            7.3
 Taxpayer Service                                                224                           44.1
Examination                                                      164                           32.3
      a
Other                                                            221                           43.5
None                                                              11                            2.2
No response                                                        6                            1.2
Note: Percentages are based on a total of 508 Advocate Office staff. Percentages total more than
100, because some respondents checked more than one response to this question.
a
"Other" includes IRS functions not in the categories above, such as Information Systems, Resources
Management, and Submission Processing.


9. How acquired by the Advocate’s Office? (Check one.) (Indicate how
the person obtained a position in the Advocate’s Office.)


How position obtained                              Number of staff           Percentage of staff
Competed                                                      304                          59.8
Volunteered                                                    28                           5.5
Assigned                                                       64                          12.6
Detailed                                                       60                          11.8
      a
Other                                                          43                           8.5
No response                                                     9                           1.8
Total                                                         508                         100.0
a
 "Other" includes methods not in the categories above, such as reassignments resulting from IRS’
reorganization and hardship transfers.




Page 31                                             GAO/GGD-99-124 Taxpayer Advocate Office
Appendix II
Summary of Responses to the Taxpayer Advocate Staffing Survey




10. Grade when entered PRP? (Provide the person’s grade level when he
or she entered PRP.)

          a
Grade                                                Number of staff            Percentage of staff
General Schedule-3                                                5                            1.0
General Schedule-4                                               38                            7.5
General Schedule-5                                               43                            8.5
General Schedule-6                                               36                            7.1
General Schedule-7                                               77                           15.2
General Schedule-8                                               13                            2.6
General Schedule-9                                               99                           19.5
General Schedule-10                                               2                            0.4
General Schedule-11                                              70                           13.8
General Schedule-12                                              54                           10.6
General Schedule-13                                              47                            9.3
General Schedule-14                                              11                            2.2
General Schedule-15                                               6                            1.2
Executive Schedule-4                                              1                            0.2
No response                                                       6                            1.2
Total                                                           508                          100.3
Note: Percentages do not equal 100 due to rounding.
a
 "Grade" means the level of classification an employee has under a position classification system (i.e.,
referring to the duties, tasks, and functions he or she performs).




11. Report to? (Provide the title and home function of the individual to
whom the person reports.)


Employee reports to                                  Number of staff            Percentage of staff
                 a
IRS management                                                   53                           10.4
                          b
Advocate Office management                                      440                           86.6
                      c
Functional management                                             8                            1.6
No response                                                       7                            1.4
Total                                                           508                          100.0
a
    "IRS management" means the head of an IRS office or his or her designee.
b
    "Advocate Office management" means the head of an Advocate office or his or her designee.
c
"Functional management" means the head of an IRS division, function, or functional unit, or his or her
designee.




Page 32                                               GAO/GGD-99-124 Taxpayer Advocate Office
Appendix II
Summary of Responses to the Taxpayer Advocate Staffing Survey




12. Evaluated by? (Provide the title and home function of the individual
who evaluates the person’s performance.)


Employee evaluated by                                Number of staff           Percentage of staff
                 a
IRS management                                                   53                          10.4
                          b
Advocate Office management                                      423                          83.3
                      c
Functional management                                            25                           4.9
No response                                                       7                           1.4
Total                                                           508                         100.0
a
    "IRS management" means the head of an IRS office or his or her designee.
b
    "Advocate Office management" means the head of an Advocate office or his or her designee.
c
"Functional management" means the head of an IRS division, function, or functional unit, or his or her
designee.




13. Percent of time currently spent on? (Estimate the percentage of time
the person currently spends on each type of work listed. Note: Total
should equal 100 percent.)


Type of work                                                 Average percentage of time spent
Advocacy                                                                                 10.4
Applications for Taxpayer Assistance
        a
Orders                                                                                           18.8
Congressional inquiries                                                                          10.0
PRP cases                                                                                        19.0
Problem Solving Day cases                                                                         9.4
                                 b
Senate Finance Committee cases                                                                    4.7
      c
Other                                                                                            27.8
Total                                                                                           100.1
Note: Average percentages are based on a total of 494 Advocate Office staff. We received no
response to this question for 14 Advocate Office staff. Percentages do not equal 100 due to rounding.
a
    Requests for relief from hardship.
b
    Cases sent to IRS by the Senate Finance Committee.
c
"Other" includes types of work not in the categories above, such as program management and
program support.




Page 33                                               GAO/GGD-99-124 Taxpayer Advocate Office
Appendix II
Summary of Responses to the Taxpayer Advocate Staffing Survey




14. Training completed? (Check all that apply.) (Indicate the type of
training that the person has completed for his or her current position.)


Type of training                                      Number of staff           Percentage of staff
                                a
PRP course for current position                                  179                          35.2
                      b
PRP quality standards                                            226                          44.5
             c
PRP updates                                                      211                          41.5
                          d
PROMIS/Intelligent Query                                         246                          48.4
Continuing professional education
provided by IRS functions                                           218                           42.9
On the job                                                          413                           81.3
No response                                                          47                            9.3
Note: Percentages are based on a total of 508 Advocate Office staff. Percentages total more than
100, because some respondents checked more than one response to this question.
a
 "PRP course for current position" includes training for the positions of advocate, analyst, and PRP
specialist.
b
    Standards for doing PRP casework.
c
Annual training to update Advocate Office and PRP staff on current issues and new laws affecting
PRP.
d
"Intelligent Query" is a software package for generating specialized reports using the PROMIS
database.




Page 34                                               GAO/GGD-99-124 Taxpayer Advocate Office
Appendix III

Summary of Responses to the Functional PRP
Staffing Survey

                       This appendix contains a summary of responses to the survey we sent to
                       the 43 local advocates and the advocate at the Office of the Assistant
                       Commissioner (International). In that survey, we asked for information on
                       each district office and service center employee assigned to functional
                       PRP work as of June 1, 1998. We received responses for 2,215 staff—1,018
                       district office staff and 1,197 service center staff.

                       1. PRP role(s): (Check all that apply.) (Indicate each person’s role(s) in
Survey Questions and   PRP.)
Responses

                                                            District office staff              Service center staff
                       PRP role                              Number           Percent           Number          Percent
                       PRP manager                                 69              6.8                71             5.9
                       PRP coordinator                             74              7.3               152            12.7
                       PRP caseworker                             726             71.3               806            67.3
                             a
                       Other                                      175             17.2               188            15.7
                       No response                                 14              1.4                25             2.1
                       Note: Percentages are based on totals of 1,018 for district office staff and 1,197 for service center
                       staff. Percentages total more than 100, because some respondents checked more than one response
                       to this question.
                       a
                       "Other" includes PRP roles not in the categories above, such as clerical support.




                       Page 35                                              GAO/GGD-99-124 Taxpayer Advocate Office
Appendix III
Summary of Responses to the Functional PRP Staffing Survey




2. Series? (Provide the position series number.)


                                                 District office     Service center
                                                      staff               staff
      a              b
Series Occupation                               Number Percent Number Percent
301     Miscellaneous administration & program       15          1.5       1       0.1
303     Miscellaneous clerk & assistant              11          1.1     55       4.6
304     Information receptionist                       0         0.0       1      0.1
305     Mail & file                                    0         0.0       8       0.7
318     Secretary                                    27          2.7       1       0.1
322     Clerk-typist                                   1         0.1       0       0.0
326     Office automation clerical & assistance        0         0.0       7       0.6
334     Computer specialist                            1         0.1       1       0.1
340     Program management                             4         0.4       1       0.1
343     Management & program analysis                  8         0.8     13        1.1
356     Data transcriber                               2         0.2       1       0.1
501     Financial administration & program             2         0.2     12        1.0
503     Financial clerical & assistance                9         0.9    111       9.3
512     Internal revenue agent                      130        12.8      17       1.4
525     Accounting technician                          0         0.0       9       0.8
526     Tax technician                              314        30.8      11       0.9
529     Not listed                                     3         0.3       1       0.1
530     Cash processing                                1         0.1       0      0.0
579     Not listed                                     1         0.1       0       0.0
582     Not listed                                     5         0.5       0       0.0
592     Tax examining                               203        19.9     937      78.3
905     General attorney                               2         0.2       2      0.2
930     Hearing & appeals                              9         0.9       0      0.0
962     Contact representative                      105        10.3        0       0.0
963     Legal instruments examining                    0         0.0       1       0.1
987     Tax law specialist                             2         0.2       0      0.0
1101 General business & industry                       2         0.2       0      0.0
1169 Internal revenue officer                       123        12.1        1      0.1
3012 Not listed                                        1         0.1       0      0.0
None No response                                     37          3.6       6       0.5
Total                                             1,018       100.1   1,197     100.3
Note: Percentages do not equal 100 due to rounding.
a
 "Series" means a number identifying a recognized occupation in the federal service that includes all
jobs at the various skill levels in a particular kind of work.
b
"Occupation" means an occupational series listed in the Handbook of Occupational Groups and
Families developed by the U.S. Office of Personnel Management to aid federal agencies in classifying
positions under the Classification Act of 1949 and P.L. 92-392.




Page 36                                               GAO/GGD-99-124 Taxpayer Advocate Office
Appendix III
Summary of Responses to the Functional PRP Staffing Survey




3. Grade? (Provide the person’s current grade level.)


                                   District office staff                Service center staff
       a
Grade                               Number            Percent            Number           Percent
General Schedule-3                          0             0.0                   1              0.1
General Schedule-4                        16              1.6                  69              5.8
General Schedule-5                        32              3.1                  11              0.9
General Schedule-6                          6             0.6                  76              6.3
General Schedule-7                       199             19.6                 645             53.9
General Schedule-8                       102             10.0                 207             17.3
General Schedule-9                       353             34.7                  78              6.5
General Schedule-10                         7             0.7                  69              5.8
General Schedule-11                      158             15.5                   8              0.7
General Schedule-12                       94              9.2                  20              1.7
General Schedule-13                       41              4.0                   5              0.4
General Schedule-14                         5             0.5                   1              0.1
General Schedule-15                         5             0.5                   0              0.0
No response                                 0             0.0                   7              0.6
Total                                  1,018             99.9               1,197            100.1
Note: Percentages do not equal 100 due to rounding.
a
 "Grade" means the level of classification an employee has under a position classification system (i.e.,
referring to the duties, tasks, and functions he or she performs).




4. Permanent or detailed? (Indicate whether the person is assigned to
PRP work on a permanent or detailed basis.)


                                   District office staff                Service center staff
Assignment basis                    Number            Percent            Number           Percent
Permanent                                695              68.3               1120             93.6
Detailed                                 296              29.1                 58              4.8
      a
Other                                       1              0.1                  2              0.2
No response                               26               2.6                 17              1.4
Total                                  1,018             100.1              1,197            100.0
Note: Percentages do not equal 100 due to rounding.
a
"Other" includes temporary and seasonal assignments.




Page 37                                               GAO/GGD-99-124 Taxpayer Advocate Office
Appendix III
Summary of Responses to the Functional PRP Staffing Survey




5. Full-time or part-time? (Indicate whether the person is a full-time or
part-time IRS employee.)


                                 District office staff              Service center staff
IRS employment basis              Number            Percent          Number          Percent
Full-time                              952             93.5             1,150             96.1
Part-time                               37              3.6                25              2.1
No response                             29              2.8                22              1.8
Total                                1,018             99.9             1,197            100.0
Note: Percentages do not equal 100 due to rounding.




6. Percent of time on PRP work? (Estimate the percentage of time the
person does work related to PRP, including Problem Solving Day cases.
Response should be 100 percent, unless the person also works outside of
PRP.)


Percentage of time               District office staff              Service center staff
spent on PRP work                 Number            Percent          Number          Percent
1-24                                   106             10.4               417            34.8
25-49                                   44              4.3               199            16.6
50-74                                   45              4.4                78             6.5
75-99                                   94              9.2                98             8.2
100                                    718             70.5               383            32.0
No response                             11              1.1                22             1.8
Total                                1,018             99.9             1,197            99.9
Note: Percentages do not equal 100 due to rounding.




7. Years at IRS? (Provide the number of years the person has worked at
IRS. Do not include other government experience.)


                                 District office staff              Service center staff
Years at IRS                      Number            Percent          Number          Percent
Less than 1                               3             0.3                 2              0.2
1-5                                     44              4.3                11              0.9
6-10                                   263             25.8               219             18.3
11-15                                  314             30.8               405             33.8
16-20                                  210             20.6               216             18.0
More than 20                           157             15.4               323             27.0
No response                             27              2.7                21              1.8
Total                                1,018             99.9             1,197            100.0
Note: Percentages do not equal 100 due to rounding.




Page 38                                               GAO/GGD-99-124 Taxpayer Advocate Office
Appendix III
Summary of Responses to the Functional PRP Staffing Survey




8. Years in PRP? (Provide the number of years the person has done PRP
work.)


                                          District office staff            Service center staff
Years in PRP                               Number          Percent          Number         Percent
Less than 1                                     375             36.8             166           13.9
1-5                                             304             29.9             556           46.4
6-10                                            205             20.1             312           26.1
11-15                                            81              8.0              75            6.3
16-20                                            10              1.0              17            1.4
More than 20                                       2             0.2               0            0.0
No response                                      41              4.0              71            5.9
Total                                         1,018           100.0            1,197         100.0




9. Position funded by? (Check one.) (Indicate the function that funds the
person’s position.)


                                         District office staff             Service center staff
Position funded by                       Number           Percent           Number         Percent
Appeals                                         16              1.6                0             0.0
Collection                                     383             37.6              161            13.5
Customer Service
 Automated Collection System                    34               3.3               12               1.0
 Taxpayer Service                              183              18.0              422              35.3
Employee Plans and Exempt
Organizations                                   37               3.6                1              0.1
Examination                                    317              31.1              244             20.4
Advocate Office                                 12               1.2                0              0.0
      a
Other                                           21               2.1              346             28.9
No response                                     15               1.5               11              0.9
Total                                        1,018             100.0            1,197            100.1
Note: Percentages do not equal 100 due to rounding.
a
 "Other" includes IRS functions not in the categories above. It also includes functions found only in
service centers, such as Accounting, Taxpayer Relations, Adjustments, and Returns Processing.




Page 39                                               GAO/GGD-99-124 Taxpayer Advocate Office
Appendix III
Summary of Responses to the Functional PRP Staffing Survey




10. How acquired by PRP? (Check one.) (Indicate how the person
obtained a functional position in PRP.)


                                    District office staff                Service center staff
How position obtained                Number            Percent            Number          Percent
Competed                                  235              23.1                212             17.7
Volunteered                               195              19.2                204             17.0
Assigned                                  315              30.9                645             53.9
Detailed                                  221              21.7                 42              3.5
      a
Other                                      46               4.5                 51              4.3
No response                                  6              0.6                 43              3.6
Total                                   1,018             100.0              1,197            100.0
a
“Other” includes methods not in the categories above, such as redeployment and assigned “as
needed.”




11. Grade when entered PRP? (Provide the person’s grade level when he
or she entered PRP.)


                                    District office staff                Service center staff
       a
Grade                                Number            Percent            Number          Percent
General Service-3                            0              0.0                  5              0.4
General Service-4                          23               2.3                 63              5.3
General Service-5                          46               4.5                 37              3.1
General Service-6                          34               3.3                157             13.1
General Service-7                         303              29.8                592             49.5
General Service-8                          45               4.4                131             10.9
General Service-9                         266              26.1                 63              5.3
General Service-10                           5              0.5                 47              3.9
General Service-11                        141              13.9                  5              0.4
General Service-12                         77               7.6                 18              1.5
General Service-13                         33               3.2                  3              0.3
General Service-14                           6              0.6                  0              0.0
General Service-15                           2              0.2                  0              0.0
No response                                37               3.6                 76              6.3
Total                                   1,018             100.0              1,197            100.0
a
 "Grade" means the level of classification an employee has under a position classification system (i.e.,
referring to the duties, tasks, and functions he or she performs).




Page 40                                               GAO/GGD-99-124 Taxpayer Advocate Office
Appendix III
Summary of Responses to the Functional PRP Staffing Survey




12. Report to? (Provide the title and home function of the individual to
whom the person reports.)


                                          District office staff           Service center staff
Employee reports to                        Number          Percent         Number        Percent
                          a
Advocate Office management                      308             30.3             83            6.9
                      b
Functional management                           699             68.7          1,104          92.2
No response                                      11              1.1             10            0.8
Total                                         1,018          100.1            1,197          99.9
Note: Percentages do not equal 100 due to rounding.
a
"Advocate Office management" means the head of an Advocate office or his or her designee.
b
"Functional management" means the head of an IRS division, function, or functional unit, or his or her
designee.




13. Evaluated by? (Provide the title and home function of the individual
who evaluates the person’s performance.)


                                          District office staff           Service center staff
Employee evaluated by                      Number          Percent         Number        Percent
                          a
Advocate Office management                      287             28.2             83            6.9
                      b
Functional management                           712             69.9          1,103          92.1
No response                                      19              1.9             11            0.9
Total                                         1,018          100.0            1,197          99.9
Note: Percentages do not equal 100 due to rounding.
a
"Advocate Office management" means the head of an Advocate office or his or her designee.
b
"Functional management" means the head of an IRS division, function, or functional unit, or his or her
designee.




Page 41                                               GAO/GGD-99-124 Taxpayer Advocate Office
Appendix III
Summary of Responses to the Functional PRP Staffing Survey




14. Percent of time currently spent on? (Estimate the percentage of time
the person currently spends on each type of work listed. Note: Total
should equal 100 percent.)



                                                           Average percentage of time spent

Type of work                                             District office staff Service center staff
Advocacy                                                                  0.6                  0.5
                                            a
Applications for Taxpayer Assistance Orders                               4.5                  1.9
Congressional inquiries                                                  11.7                  3.5
PRP cases                                                                45.9                 40.4
Problem Solving Day cases                                                12.0                  0.6
                                 b
Senate Finance Committee cases                                            3.0                  0.3
      c
Other                                                                    22.4                 52.9
Total                                                                   100.1                100.1
Note: Average percentages are based on totals of 1,005 for district office staff and 1,174 for service
center staff. We received no response to this question for 13 district office staff and 23 service center
staff. Percentages do not equal 100 due to rounding.
a
    Requests for relief from hardship.
b
    Cases sent to IRS by the Senate Finance Committee.
c
"Other" includes types of work not in the categories above, such as functional work not related to
PRP activities.




15. Training completed? (Check all that apply.) (Indicate the type of
training that the person has completed for his or her current position.)


                                              District office staff          Service center staff
Type of training                               Number         Percent         Number        Percent
                                a
PRP course for current position                     416           40.9             471          39.3
                      b
PRP quality standards                               680           66.8             864          72.2
             c
PRP updates                                         548           53.8             886          74.0
                          d
PROMIS/Intelligent Query                            248           24.4             268          22.4
Continuing professional education
provided by IRS functions                            506            49.7            515             43.0
On the job                                           861            84.6            995             83.1
No response                                           36             3.5             52              4.3
Note: Percentages are based on totals of 1,018 for district office staff and 1,197 for service center
staff. Percentages total more than 100, because some respondents checked more than one response
to this question.
a
“PRP course for current position” includes training for the positions of PRP manager, coordinator,
and caseworker.
b
    Standards for doing PRP casework.
c
    Annual training to update PRP staff on current issues and new laws affecting PRP.
d
“Intelligent Query” is a software package for generating specialized reports using the PROMIS
database.




Page 42                                                GAO/GGD-99-124 Taxpayer Advocate Office
Appendix IV

Selected Survey Results for PRP Caseworkers


                                          Following are five tables with selected results from our survey of district
                                          office and service center functional employees assigned to PRP work as of
                                          June 1, 1998. The results in this appendix are for the 726 district office and
                                          806 service center staff who were identified as PRP caseworkers in the
                                          responses to our functional PRP staffing survey.


Table IV.1: Funding Source of Functional PRP Caseworkers
                                                 District office caseworkers                           Service center caseworkers
Position funded by                                     Number               Percent                          Number              Percent
Appeals                                                        4                0.6                                0                 0.0
Collection                                                  271                37.3                              130                16.1
Customer Service
 Automated Collection System                                  30                4.1                                   6                       0.7
 Taxpayer Service                                           145                20.0                                 265                      32.9
Employee Plans and Exempt Organizations                       32                4.4                                   1                       0.1
Examination                                                 209                28.8                                 189                      23.4
Advocate Office                                                8                1.1                                   0                       0.0
      a
Other                                                         14                1.9                                 208                      25.8
No response                                                   13                1.8                                   7                       0.9
Total                                                       726               100.0                                 806                      99.9
                                          Note: Percentages do not equal 100 due to rounding.
                                          a
                                           "Other" includes IRS functions not in the categories above. It also includes functions found only in
                                          service centers, such as Accounting, Taxpayer Relations, Adjustments, and Returns Processing.
                                          Source: GAO survey.




Table IV.2: Reporting Structure of Functional PRP Caseworkers
                                    District office caseworkers   Service center caseworkers                              Total
Employee reports to                       Number          Percent       Number        Percent                        Number              Percent
                            a
Advocate Office management                     234           32.2            62            7.7                           296                19.3
                       b
Functional management                          485           66.8           744           92.3                         1,229                80.2
Cannot determine                                  7           1.0             0            0.0                             7                 0.5
Total                                          726          100.0           806          100.0                         1,532               100.0
                                          a
                                           "Advocate Office management" means the head of an Advocate office or his or her designee.
                                          b
                                          "Functional management" means the head of an IRS division, function, or functional unit, or his or her
                                          designee.
                                          Source: GAO survey.




                                          Page 43                                                GAO/GGD-99-124 Taxpayer Advocate Office
                                          Appendix IV
                                          Selected Survey Results for PRP Caseworkers




Table IV.3: Evaluation of Functional PRP Caseworkers
                                    District office caseworkers   Service center caseworkers                            Total
Employee evaluated by                     Number          Percent       Number        Percent                      Number             Percent
                            a
Advocate Office management                     214           29.5            62            7.7                         276               18.0
                       b
Functional management                          499           68.7           744           92.3                       1,243               81.1
Cannot determine                                 13           1.8             0            0.0                          13                0.8
Total                                          726          100.0           806          100.0                       1,532               99.9
                                          Note: Percentages do not equal 100 due to rounding.
                                          a
                                              "Advocate Office management" means the head of an Advocate office or his or her designee.
                                          b
                                          "Functional management" means the head of an IRS division, function, or functional unit, or his or her
                                          designee.
                                          Source: GAO survey.




Table IV.4: Training Completed by Functional PRP Caseworkers
                                   District office caseworkers   Service center caseworkers                             Total
Type of training                         Number          Percent       Number        Percent                       Number             Percent
PRP caseworker course                         332           45.7           335           41.6                          667               43.5
                      a
PRP quality standards                         550           75.8           644           79.9                        1,194               77.9
             b
PRP updates                                   436           60.1           637           79.0                        1,073               70.0
                         c
PROMIS/Intelligent Query                      158           21.8           132           16.4                          290               18.9
Continuing professional education
 provided by IRS functions                    400           55.1           380           47.1                           780                50.9
On the job                                    613           84.4           696           86.4                         1,309                85.4
No response                                     20           2.8            22            2.7                            42                 2.7
                                          Note: Percentages are based on totals of 726 district office and 806 service center caseworkers.
                                          Percentages total more than 100, because some respondents checked more than one response to
                                          this question.
                                          a
                                              Standards for doing PRP casework.
                                          b
                                          Annual training to update Advocate Office and PRP staff on current issues and new laws affecting
                                          PRP.
                                          c
                                          "Intelligent Query" is a software package used to generate specialized reports from the PROMIS
                                          database.
                                          Source: GAO survey.




                                          Page 44                                               GAO/GGD-99-124 Taxpayer Advocate Office
                                         Appendix IV
                                         Selected Survey Results for PRP Caseworkers




Table IV.5: Average Percentage of Time Spent by Functional PRP Caseworkers on Specific Types of Work
                                                               Average percentage of time spent
Type of work                         District office caseworkers   Service center caseworkers                                             Total
Advocacy                                                     0.4                           0.1                                              0.2
Applications for Taxpayer
                   a
Assistance Orders                                            5.3                           2.2                                             3.7
Congressional inquiries                                     12.8                           2.9                                             7.6
PRP cases                                                   55.6                          46.1                                            50.6
Problem Solving Day cases                                   10.0                           0.6                                             5.1
                               b
Senate Finance Committee cases                               2.7                           0.2                                             1.4
      c
Other                                                       13.3                          47.8                                            31.5
Total                                                      100.1                          99.9                                           100.1
                                         Note: Average percentages are based on totals of 721 for district office caseworkers and 801 for
                                         service center caseworkers. We did not receive a response to this question for five district office
                                         caseworkers and five service center caseworkers. Percentages do not equal 100 due to rounding.
                                         a
                                             Requests for relief from hardship.
                                         b
                                             Cases sent to IRS by the Senate Finance Committee.
                                         c
                                         "Other" includes types of work not in the categories above, such as functional work not related to
                                         PRP activities.
                                         Source: GAO survey.




                                         Page 45                                               GAO/GGD-99-124 Taxpayer Advocate Office
Appendix V

Factors That Have Increased and Could
Increase PRP Workload

                            Factors that have increased and could increase PRP workload include PRP
                            criteria that can be and have been broadly interpreted to include any
                            situation; IRS initiatives, such as Problem Solving Days, Citizen Advocacy
                            Panels, and the introduction of a PRP toll-free telephone number; and a
                            legislative requirement designed to increase public awareness of advocate
                            operations.

                            PRP cases can be generated when a taxpayer contacts a local advocate
Broad Interpretation of     with a problem or when a front-line IRS employee, such as a customer
PRP Criteria                service representative, revenue officer, or revenue agent, determines that a
                            situation should be referred to the Advocate’s Office.

                            The Internal Revenue Manual contains the following criteria for
                            determining whether a situation qualifies as a PRP case:

                          • any contact on the same issue at least 30 days after an initial inquiry or
                            complaint;
                          • any contact that indicates the taxpayer has not received a response from
                            IRS by the date promised; and
                          • any contact that indicates regular methods have failed to resolve the
                            taxpayer’s problem, or when it is in the best interest of the taxpayer or IRS
                            that the case be worked in PRP.

                            Officials in the Advocate’s Office said that the way PRP criteria are
                            interpreted had increased PRP’s workload because the portion of the third
                            criterion that reads “in the best interest of the taxpayer or IRS that the
                            case be worked in PRP” can be interpreted so that any case qualifies as a
                            PRP case. In that regard, the National Taxpayer Advocate said that he was
                            committed to work any case for which a taxpayer was seeking help from
                            PRP. In commenting on our draft report, the Commissioner of Internal
                            Revenue stated that the PRP criteria had recently been modified. IRS has
                            added the following four criteria:

                          • The taxpayer is suffering or is about to suffer a significant hardship;
                          • the taxpayer is facing an immediate threat of adverse action;
                          • the taxpayer will incur significant costs if relief is not granted (including
                            fees for professional representation); and
                          • the taxpayer will suffer irreparable injury, or long-term adverse impact if
                            relief is not granted.

                            Additionally, IRS deleted the portion of the third criterion that read, “in the
                            best interest of the taxpayer or IRS that the case be worked in PRP.”
                            Because we received the information on the modified criteria as part of the



                            Page 46                                   GAO/GGD-99-124 Taxpayer Advocate Office
                          Appendix V
                          Factors That Have Increased and Could Increase PRP Workload




                          agency comment letter, we did not have time to evaluate the potential
                          impact that the modified criteria might have on the PRP workload.

                          IRS officials said that part of the PRP workload increase can be attributed
IRS Initiatives Place     to an IRS initiative known as Problem Solving Days, which is the
Demands on Program        responsibility of the National Taxpayer Advocate. Continuation of that
Resources                 initiative and the recent start of two other IRS initiatives—Citizen
                          Advocacy Panels and publication of a unique toll-free telephone number
                          for taxpayers to call the Advocate’s Office—could place increasing
                          demands on PRP resources.

Problem Solving Days      In November 1997, IRS began holding a series of monthly Problem Solving
                          Days in each of its 33 districts. The purpose of these days is to give
                          taxpayers with unresolved tax problems the opportunity to meet face to
                          face with IRS staff in an effort to resolve those problems. These days have
                          been advertised both locally and nationally through newspaper articles,
                          television and radio interviews with IRS officials, and public service
                          announcements. From November 1997 to November 1998, over 36,000 PRP
                          cases were closed as a result of IRS’ Problem Solving Days.

                          According to local advocates, Problem Solving Days have not only
                          provided taxpayers with in-person service but also allowed IRS staff to
                          meet with taxpayers and help solve problems. However, the local
                          advocates also said that the work involved with planning and executing
                          these days and the subsequent increase in casework was taking its toll on
                          Advocate and PRP staff.

Citizen Advocacy Panels   In addition to their other duties, some local advocates are responsible for
                          implementing Citizen Advocacy Panels within their districts. Collectively,
                          the panels are designed to serve as advisory bodies to the Secretary of the
                          Treasury and the Commissioner of Internal Revenue to improve IRS
                          service and responsiveness. The panels are chartered to (1) provide citizen
                          input into improving IRS customer service by identifying problems and
                          making recommendations for improving IRS systems and procedures, (2)
                          identify and elevate problems to appropriate IRS officials and monitor
                          progress to effect change, and (3) refer taxpayers to the appropriate IRS
                          office for assistance in resolving their tax problems. Membership on the
                          panels is to include the local advocate and 8 to 15 citizens from the district.

                          The South Florida District held the first public meeting of a Citizen
                          Advocacy Panel in November 1998. Three more districts—Brooklyn,
                          Midwest, and Pacific Northwest—have established panels and plan to hold
                          public meetings during fiscal year 1999. Initially, IRS had planned to



                          Page 47                                      GAO/GGD-99-124 Taxpayer Advocate Office
                          Appendix V
                          Factors That Have Increased and Could Increase PRP Workload




                          establish panels in each of its 33 districts. However, IRS is reevaluating
                          this need in light of the agency’s planned reorganization. According to
                          local advocates, the Citizen Advocacy Panels represent a significant time
                          commitment for them. Not only are the local advocates members of the
                          panels, but they are also responsible for the administrative duties
                          associated with the panels, such as securing space and equipment for
                          meetings. In addition to time commitments for the local advocates,
                          taxpayers may be referred to PRP for further assistance, which could
                          increase PRP’s workload.

PRP Toll-free Telephone   Local advocates said that the introduction of a toll-free telephone number
                          for taxpayers to call the Advocate’s Office could increase PRP workloads.
Number                    The number was operational as of November 1, 1998, and has been
                          advertised in IRS publications, such as the tax year 1998 Form 1040 tax
                          package. IRS has used customer service staff as PRP telephone assistors to
                          answer the calls, and the assistors have been equipped with computer
                          systems that allow them to help some taxpayers immediately. There were
                          241,228 calls placed on this line between November 1, 1998, and April 17,
                          1999; and, according to the Advocate, 85 percent of these calls were for
                          non-Advocate Office matters. The Advocate said that the procedure for the
                          PRP toll-free assistors is to help any caller if the assistor has the time and
                          ability; and if the assistor cannot help, the assistor should transfer the
                          caller to IRS’ general assistance phone lines.

                          There is no way of determining whether taxpayers who were referred to
                          local advocate offices through the toll-free line would have contacted IRS
                          anyway or whether it was the availability of the new toll-free line that
                          prompted them to contact PRP. Therefore, the actual increase in PRP
                          cases, if any, cannot accurately be determined. However, local advocates
                          were concerned that the toll-free line would dramatically increase PRP’s
                          future caseload. They were also concerned that this toll-free line would be
                          inundated with calls from taxpayers needing general assistance—calls that
                          would be better handled by another toll-free line that IRS has available for
                          that purpose.




                          Page 48                                      GAO/GGD-99-124 Taxpayer Advocate Office
                      Appendix V
                      Factors That Have Increased and Could Increase PRP Workload




                      A legislative requirement designed to increase public awareness of
Legislative           advocate operations may increase demands on PRP. The IRS Restructuring
Requirement May       and Reform Act of 1998 required IRS to include the address and telephone
Increase Demands on   number of local advocates on statutory notices of deficiency sent to
                                 1
                      taxpayers. IRS began sending taxpayers the revised notice in August 1998.
PRP                   The notices state that the taxpayers can contact their local advocate with
                      their tax problem for “proper and prompt handling” if the problem is not
                      resolved through normal IRS channels. IRS officials said that about 1
                      million statutory notices are sent out each year, and some portion of those
                      taxpayers will probably be contacting the advocates, which will cause a
                      corresponding increase in workloads. According to a local advocate, some
                      taxpayers may have a legitimate reason to contact their local advocates.
                      For example, a taxpayer may have repeatedly tried without success to
                      rectify the problem addressed in the notice. Other taxpayers may contact
                      their local advocates because the telephone number is made available.




                      1
                       A statutory notice of deficiency is a legal notice that a tax deficiency exists and gives taxpayers the
                      right to petition the Tax Court within 90 days (150 days for taxpayers outside the United States). If the
                      taxpayer does not respond to this notice within this time period, the deficiency is to be assessed.




                      Page 49                                                GAO/GGD-99-124 Taxpayer Advocate Office
Appendix VI

PRP Performance Measures and Information
Systems

                                          At the time of our review, the Advocate’s Office used four measures to
Performance Measures                      gauge PRP’s performance. They were the (1) average processing time to
                                          close PRP cases, (2) currency of PRP case inventory, (3) quality of
                                          casework, and (4) case identification and tracking rate. Table VI.I shows
                                          actual performance results for the four measures for fiscal years 1996
                                          through 1998.

Table VI.1: Performance Results for the
Office of the Taxpayer Advocate (Fiscal   Performance measure                                      1996            1997          1998
years 1996-1998)                          Average processing time (in days)                         38.2            33.4          37.8
                                                                                                       a                a
                                          Currency of case inventory (in days)                      n/a             n/a          91.35
                                          Quality of casework (percentage of
                                          standards met)                                            72.6            83.7           80.8
                                          PRP case identification (percentage
                                          of PRP-eligible cases that were
                                          identified as PRP cases in IRS
                                          service centers)                                          86.4            87.0           86.3
                                          a
                                          Data for this measure were not collected until fiscal year 1998.
                                          Source: Office of the National Taxpayer Advocate.


                                          The first indicator, average processing time, represents the average
                                          number of days it took to close a PRP case. The measure does not include
                                          those cases that were opened and closed on the same day because these
                                          cases are not included in PRP’s inventory control system. The measure
                                          also does not include those cases in which the Advocate’s Office made a
                                          determination of hardship, which represent about 10 percent of the total
                                          PRP cases closed during fiscal year 1998. Hardship cases are not included
                                          in this measure because IRS requires that these cases be closed in 2 days;
                                          including these cases might misrepresent the actual average closure times
                                          for PRP cases.

                                          The second indicator, currency of case inventory, is designed to measure
                                          the average number of days that cases have been in the open PRP
                                          inventory.

                                          The third measure, expressed as a percentage, is designed to determine the
                                          quality of PRP casework. This measure is to be based on a statistically
                                          valid sample of PRP cases and provides the National Taxpayer Advocate
                                          with data on timeliness and the technical accuracy of PRP cases. Each
                                          month, sampled cases are to be sent to two locations—one for district
                                          office cases and one for service center cases—for review. Reviewers at
                                          these locations are to check the cases against a list of 13 quality standards,
                                          broken into 3 categories—timeliness, communication, and accuracy. Each
                                          of the 13 standards is worth a certain number of points totaling 100. Cases
                                          are to be reviewed to determine if, among other things, the caseworker



                                          Page 50                                               GAO/GGD-99-124 Taxpayer Advocate Office
                      Appendix VI
                      PRP Performance Measures and Information Systems




                      contacted the taxpayer by a promised date, whether copies of any
                      correspondence with the taxpayer appeared to communicate issues
                      clearly, and whether the taxpayer’s problem appeared to be completely
                      resolved. The caseworkers and local advocate staff we talked with said
                      that the quality measure was helpful because the elements that are
                      reviewed provide a checklist for working PRP cases. According to staff,
                      this helps ensure that most cases are worked in a similar manner in
                      accordance with standard elements.

                      The fourth measure, PRP case identification, is used only at the service
                      centers and attempts to determine if service center employees are properly
                      identifying potential PRP cases from incoming correspondence. Service
                      center employees responsible for sorting the mail are also responsible for
                      identifying potential PRP cases. The measure is to be based on a sample of
                      mail coming into each service center. Analysts at the service centers are to
                      review each sampled piece of incoming mail, identify potential PRP cases,
                      and return the mail to the workflow. After the mail has been sorted and
                      sent to the various service center units for handling, the analysts are to
                      check to see what percentage of the sampled mail was correctly identified
                      for PRP.

                      The Taxpayer Advocate Management Information System is comprised of
Information Systems   the Problem Resolution Office Management Information System
                      (PROMIS), the Customer Feedback System, and the PRP Case
                      Identification and Tracking System. PROMIS is a computerized inventory
                      control and report system for PRP cases. Background information on PRP
                      cases, such as the taxpayer’s name, address, tax identification number, and
                      a code to identify the taxpayer’s problem are captured on the system.
                      Additionally, in a case history section, the system captures a detailed
                      description of the taxpayer’s problem, along with what actions were taken,
                      and when, to help the taxpayer. This system produces standard reports for
                      the Advocate’s Office and can be queried to produce other more specific
                      reports, including reports for counts of information on any of its data
                      fields, such as the number of cases opened or closed during a certain time
                      period or at a certain location. The case history section cannot be queried
                      as to what specific problems faced the taxpayers. All PRP cases, except
                      those opened and closed in the same day, are to be entered into PROMIS.

                      The Customer Feedback System was made necessary by the second
                      Taxpayer Bill of Rights and is designed to capture taxpayers’ compliments
                      and complaints about IRS employees and what actions, if any were taken




                      Page 51                                     GAO/GGD-99-124 Taxpayer Advocate Office
Appendix VI
PRP Performance Measures and Information Systems




                           1
regarding the cases. If a taxpayer calls or writes IRS concerning the
behavior of an employee, IRS managers are responsible for recording
information on a customer feedback form. Additionally, forms are to be
filled out if a manager receives a complaint of employee behavior from
another IRS employee. After the forms are filled out, the information is
compiled and reports can be generated. Reports include identifying what
characteristics are more frequently described in customer complaints—
such as the IRS employee using discourteous, unprofessional language.
The system also collects data on what, if any, disciplinary actions—such as
counseling or suspension—were taken against IRS employees.

The PRP Case Identification and Tracking System is the system used to
capture information on the PRP case identification measure.




1
The Taxpayer Bill of Rights 2, P.L. 104-168 (July 30, 1996), section 1211, requires the Department of the
Treasury to report annually to Congress on or before June 1, all instances of employee misconduct
during the preceding calendar year and the dispositions of any such instances during that same year.




Page 52                                                GAO/GGD-99-124 Taxpayer Advocate Office
Appendix VII

Comments From the Internal Revenue Service




               Page 53      GAO/GGD-99-124 Taxpayer Advocate Office
Appendix VII
Comments From the Internal Revenue Service




Page 54                                      GAO/GGD-99-124 Taxpayer Advocate Office
Appendix VII
Comments From the Internal Revenue Service




Page 55                                      GAO/GGD-99-124 Taxpayer Advocate Office
Page 56   GAO/GGD-99-124 Taxpayer Advocate Office
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