Recommendations for Executive Action

1. Status: Closed - Implemented

   Priority recommendation

   Comments: As of January 2020, IRS had estimated the resources required for the foundational initiatives and supporting activities in its Identity Assurance Strategy and Roadmap (Roadmap), as GAO recommended in June 2018. IRS documentation states that as a first step in updating the original Roadmap, the Identity Assurance office worked with stakeholders to verify the progress made and current status of its 14 foundational initiatives. In addition, the Identity Assurance office collected existing information on high-level financial and human resource estimates for the 14 foundational initiatives and supporting activities that are currently underway or planned. Further, IRS documentation shows that it has completed five of the 14 foundational initiatives in its Roadmap; the remaining nine foundational initiatives are shown as "in progress" or "near complete." IRS stated that it intends to update its Roadmap annually to reflect changes in IRS priorities. IRS's continued monitoring of its foundational initiatives-and the resources required to complete them-will help ensure continued progress on its authentication efforts.

   Recommendation: The Commissioner of Internal Revenue should direct the Identity Assurance Office, in collaboration with other IRS business partners, to estimate the resources (i.e., financial and human) required for the foundational initiatives and supporting activities identified in its Identity Assurance Strategy and Roadmap. (Recommendation 1)

   Agency Affected: Department of the Treasury: Internal Revenue Service

2. Status: Open

   Priority recommendation

   Comments: As of January 2020, the Internal Revenue Service (IRS) had taken preliminary steps to prioritize its foundational initiatives in its Identity Assurance Strategy and Roadmap (Roadmap), as GAO recommended in June 2018. For example, IRS documentation stated that initial efforts to update the original Roadmap included collecting implementation documents for the 14 foundational initiatives. IRS stated that this information and progress that IRS has made on the initiatives shows that the initiatives are a priority for IRS leadership. However, IRS has not used this information to clearly prioritize in-progress initiatives or supporting activities going forward. IRS stated that it intends to update its Roadmap annually, including prioritizing new and existing authentication initiatives and capabilities. IRS's continued attention to this action will help ensure that in-progress authentication initiatives are prioritized and completed.

   Recommendation: Based on the estimates developed in Recommendation 1, the Commissioner of Internal Revenue should direct the Identity Assurance Office to prioritize foundational initiatives in its Identity Assurance Strategy and Roadmap. (Recommendation 2)

   Agency Affected: Department of the Treasury: Internal Revenue Service

3. Status: Open

   Comments: As of November 2019, IRS officials had developed a draft policy for conducting risk assessments for telephone, in-person, and correspondence channels for authentication, as we recommended. IRS officials stated that once this policy is approved, it will be used to develop a plan to perform risk assessments for these authentication channels. IRS's continued attention to this recommendation will help ensure that it is aware of emerging threats to the tax environment.

   Recommendation: The Commissioner of Internal Revenue should establish a policy for conducting risk assessments for telephone, in-person, and correspondence channels for authentication. This policy should include, for example, the frequency of assessments to be performed and timeframes for addressing deficiencies. (Recommendation 3)

   Agency Affected: Department of the Treasury: Internal Revenue Service

4. Status: Open

   Comments: As of November 2019, IRS officials stated that they will develop a plan for performing risk assessments for telephone, in-person, and correspondence channels for authentication by May 2020. Until IRS develops and implements this plan, these authentication channels may be more vulnerable to fraudulent activity, including unauthorized attempts to access taxpayer information.

   Recommendation: Consistent with the policy developed in Recommendation 3, the Commissioner of Internal Revenue should direct the Identity Assurance Office and IRS business owners to develop a plan for performing risk assessments for telephone, in-person, and correspondence channels for authentication. (Recommendation 4)

   Agency Affected: Department of the Treasury: Internal Revenue Service

5. Status: Open

   Comments: As of November 2019, IRS officials stated that the agency intends to implement this recommendation by spring 2020. Officials noted that developing a systemic solution for collecting data on all authentication outcomes is complex and involves multiple IRS business divisions. Until IRS fully addresses this recommendation, it will have limited insight into the number of taxpayers who fail authentication and the reason for failure.

   Recommendation: The Commissioner of Internal Revenue should establish a mechanism to collect data on outcomes for telephone, in-person, and correspondence authentication, consistent with federal standards for internal control. (Recommendation 5)

   Agency Affected: Department of the Treasury: Internal Revenue Service

6. Status: Open

   Comments: As of November 2019, IRS stated that it has planned enhancements to its authentication data collection procedures in AMS. Officials stated that by June 2020, they intend to implement improvements for ensuring data quality of authentication outcomes. Until IRS fully implements our recommendation, it will be limited in conducting systematic data analysis on taxpayer authentication outcomes.

   Recommendation: The Commissioner of Internal Revenue should revise or establish, as appropriate, procedures to ensure data quality in the Account Management Services (AMS) consistent with federal standards for internal control. (Recommendation 6)

   Agency Affected: Department of the Treasury: Internal Revenue Service

7. Status: Open

   Comments: As of November 2019, IRS officials told us that IRS has explored options that will allow the agency to more effectively record, track, and monitor authentication outcomes. IRS officials said that they are developing and testing a tool to document Taxpayer Protection Program interactions, outcomes of taxpayer authentication, and the reasons for authentication failures. Officials stated that IRS plans to have this tool implemented by spring 2020, one year later than originally planned. Officials stated that the delay is due to additional technical programming to fully develop the tool. We will follow up on IRS's actions to determine the extent to which they implement our recommendation.

   Recommendation: The Commissioner of Internal Revenue should ensure that IRS business units have access to complete AMS data to monitor authentication performance and identify potential issues. (Recommendation 7)

   Agency Affected: Department of the Treasury: Internal Revenue Service

8. Status: Open

   Priority recommendation

   Comments: As of January 2020, IRS has taken steps to implement this recommendation. Efforts include developing plans for a new authentication capability to authenticate taxpayer's identities online using external partners, consistent with National Institute of Standards and Technology (NIST) guidance. IRS officials told us that they plan to work with external partners to perform additional testing on its new authentication platform this year, including a usability study to understand user experience. IRS officials also stated that they are determining a schedule for fully implementing these NIST-compliant taxpayer authentication capabilities. IRS's timely implementation of NIST's guidance is critical to help the agency mitigate potential security weaknesses in its existing online authentication programs.

   Recommendation: The Commissioner of Internal Revenue should direct the Identity Assurance Office and other appropriate business partners to develop a plan--including a timeline, milestone dates, and resources needed--for implementing changes to its online authentication programs consistent with new NIST guidance. (Recommendation 8)

   Agency Affected: Department of the Treasury: Internal Revenue Service

9. Status: Open

   Priority recommendation

   Comments: As of January 2020, IRS has taken steps to develop plans for a new authentication capability to authenticate taxpayer's identities online using external partners, consistent with National Institute of Standards and Technology (NIST) guidance. IRS officials stated that they are determining a schedule for fully implementing these NIST-compliant taxpayer authentication capabilities. As noted in our report, IRS's timely implementation of NIST's new guidance is critical, as it can help the agency mitigate potential security weaknesses in its existing online authentication programs.

   Recommendation: In accordance with the plan developed in Recommendation 8, the Commissioner of Internal Revenue should implement improvements to IRS's systems to fully implement NIST's new guidance. (Recommendation 9)

   Agency Affected: Department of the Treasury: Internal Revenue Service

10. Status: Open

    Comments: As of January 2020, the Internal Revenue Service (IRS) had taken steps to develop a repeatable, comprehensive process to identify and evaluate alternative options for improving taxpayer authentication, as GAO recommended in June 2018. IRS stated that the draft process was being reviewed by the Chief Privacy Officer and it expects to finalize the process in spring 2020. IRS also stated that the Identity Assurance office will be ready to use the repeatable process once it is approved by IRS leadership. IRS's continued attention to this action will help ensure that it has a sound rationale for its investment decisions and the resources it needs to make authentication improvements in a timely manner.

    Recommendation: The Commissioner of Internal Revenue should develop a repeatable, comprehensive process to identify and evaluate alternative options for improving taxpayer authentication, including technologies in use by industry, states, or other trusted partners. (Recommendation 10)

    Agency Affected: Department of the Treasury: Internal Revenue Service

11. Status: Open

    Comments: As of January 2020, the Internal Revenue Service (IRS) had taken steps to develop a repeatable, comprehensive process to identify and evaluate alternative options for improving taxpayer authentication. However, IRS had not yet included and prioritized these options, as appropriate, in IRS's Identity Assurance Strategy and Roadmap (Roadmap), as GAO recommended in June 2018. IRS stated that it expects to finalize its process to evaluate alternative authentication options in spring 2020. IRS documentation states that it plans to update its Roadmap annually, but it has not articulated a timeline for doing so in 2020. IRS's continued attention to this action will help ensure that it has a sound rationale for its investment decisions and the resources it needs to make authentication improvements in a timely manner.

    Recommendation: Based on the approach developed in Recommendation 10, the Commissioner of Internal Revenue should include and prioritize these options, as appropriate, in IRS's Identity Assurance Strategy and Roadmap. (Recommendation 11)

    Agency Affected: Department of the Treasury: Internal Revenue Service

Explore the full database of GAO's Open Recommendations »