Tax Debt Collection:

IRS Needs to Define Field Program Objectives and Assess Risks in Case Selection

GAO-16-787: Published: Sep 13, 2016. Publicly Released: Sep 13, 2016.

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What GAO Found

The Internal Revenue Service (IRS) uses automated processes to prioritize cases to be potentially selected for in-person contact to resolve a tax collection issue (see figure), but group managers in the Field Collection program manually select the cases to assign to revenue officers. For example, when reviewing cases, group managers consider characteristics of the revenue officer available—such as current workload—and case characteristics—such as potential collectability—when deciding whether to assign a case.

IRS Field Collection Case Prioritization

IRS Field Collection Case Prioritization

GAO found weaknesses in the Field Collection program's internal controls for case selection, including:

Program objectives are not clearly defined and communicated. IRS has not sufficiently developed and communicated specific and measurable program objectives, including fairness. GAO heard different interpretations of program objectives and the role of fairness from focus group participants. Without clearly defined and clearly understood objectives aligned to its mission, Field Collection management does not have reasonable assurance that case selection processes support achievement of that mission. Further, the lack of clearly articulated objectives undercuts the effectiveness of Field Collection management's efforts to measure performance and assess risks.

Documentation and assessment of case selection risks are inadequate. The Field Collection program's automated prioritization and decision support systems are control procedures that may guide staff to reduce risks. However, the Field Collection program does not have documented procedures for periodically reviewing automated aspects of case selection. Further, the Field Collection program lacks sufficient guidance for group managers to exercise judgment in case selection. These deficiencies limit the Field Collection management's ability to provide reasonable assurance that selection decisions effectively support achievement of IRS's mission.

Why GAO Did This Study

IRS's Field Collection program is where IRS revenue officers make in-person contact with noncompliant individuals and business officials to enforce tax return filing and payment requirements. Sound processes for selecting cases are critical to maintain taxpayer confidence in the tax system and use federal resources efficiently. GAO was asked to review the processes IRS uses to select collection cases for potential enforcement action.

This report (1) describes the Field Collection program's automated and manual processes for prioritizing and selecting cases and (2) assesses how well Field Collection case selection processes support the collection program's mission, including applying tax laws “with integrity and fairness to all.” To address these objectives, GAO reviewed IRS documents and conducted interviews with IRS officials knowledgeable about the case selection processes, including a series of focus groups with IRS Field Collection managers. GAO evaluated how well the processes adhere to relevant federal standards for internal control.

What GAO Recommends

GAO is making five recommendations, including that IRS: develop and document objectives in clear and measurable terms, including fairness; provide guidance for group managers' use of judgment in selecting cases; and develop procedures to assess automated and manual processes. IRS agreed with the recommendations and outlined planned steps to address them.

For more information, contact James McTigue at (202) 512-9110 or mctiguej@gao.gov.

Recommendations for Executive Action

  1. Status: Open

    Comments: IRS agreed with the recommendation and described actions it will take to address it, to include that the Small Business/Self-Employed Division (SB/SE) will develop fiscal year 2017 program objectives that align with the mission of SB/SE and that the Collection program will develop and document specific Field Collection and case selection activities that will support SB/SE objectives. However, it is not clear how these efforts will be fully responsive our recommendation to establish Field Collection (not division-level) program and case selection objectives sufficient for use in internal control. IRS said it planned to complete actions on this recommendation by July 2017. We will update the status of IRS's implementation of the recommendation after we complete review of any documents IRS provides on actions taken.

    Recommendation: To ensure that Field Collection program case selection processes support IRS's and the Collection program's mission, including applying tax laws with integrity and fairness to all, the Commissioner of Internal Revenue should develop, document, and communicate Field Collection program and case selection objectives, including the role of fairness, in clear and measurable terms sufficient for use in internal control.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  2. Status: Open

    Comments: IRS agreed with the recommendation and outlined planned actions to address it. However, since it is not clear that IRS's planned actions to implement our first recommendation will result in Field Collection program and case selection objectives sufficient for internal control purposes, IRS's ability to address the related recommendation to establish performance measures may be limited. IRS said it planned to complete actions on this recommendation by August 2017. We will update the status of IRS's implementation of the recommendation after we complete review of any documents IRS provides on actions taken.

    Recommendation: To ensure that Field Collection program case selection processes support IRS's and the Collection program's mission, including applying tax laws with integrity and fairness to all, the Commissioner of Internal Revenue should develop, document, and implement performance measures clearly linked to the Field Collection program and case selection objectives.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  3. Status: Open

    Comments: IRS agreed with the recommendation and outlined planned actions to address it. However, since it is not clear that IRS's planned actions to implement our first recommendation will result in Field Collection program and case selection objectives sufficient for internal control purposes, IRS's ability to address the related recommendation to assess program risks may be limited. IRS said it planned to complete actions on this recommendation by July 2017. We will update the status of IRS's implementation of the recommendation after we complete review of any documents IRS provides on actions taken.

    Recommendation: To ensure that Field Collection program case selection processes support IRS's and the Collection program's mission, including applying tax laws with integrity and fairness to all, the Commissioner of Internal Revenue should incorporate program and case selection objectives into existing risk management systems or use other approaches to identify and analyze potential risks to achieving those objectives so that Field Collection can establish risk tolerances and appropriate control procedures to address risks.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  4. Status: Open

    Comments: IRS agreed with the recommendation and described actions it will take to address it, to include review of current procedures and guidance and making changes, if necessary. IRS said it planned to complete actions on this recommendation by July 2017. We will update the status of IRS's implementation of the recommendation after we complete review of any documents IRS provides on actions taken.

    Recommendation: To ensure that Field Collection program case selection processes support IRS's and the Collection program's mission, including applying tax laws with integrity and fairness to all, the Commissioner of Internal Revenue should develop, document, and communicate control procedures guidance for group managers to exercise professional judgment in the Field Collection program case selection process to achieve fairness and other program and collection case selection objectives.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  5. Status: Open

    Comments: IRS agreed with the recommendation and outlined planned actions to address it. However, since it is not clear that IRS's planned actions to implement our first recommendation will result in Field Collection program and case selection objectives sufficient for internal control purposes, IRS's ability to address the related recommendation to monitor control procedures may be limited. IRS said it planned to complete actions on this recommendation by July 2017. We will update the status of implementation of the recommendation after we complete review of documents IRS provides on the actions taken.

    Recommendation: To ensure that Field Collection program case selection processes support IRS's and the Collection program's mission, including applying tax laws with integrity and fairness to all, the Commissioner of Internal Revenue should develop, document, and implement procedures to periodically monitor and assess the design and operational effectiveness of both automated and manual control procedures for collection case selection to assure their continued effectiveness in achieving program objectives.

    Agency Affected: Department of the Treasury: Internal Revenue Service

 

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