IRS Procurement:

Software Documentation Requirement Did Not Restrict Competition

IMTEC-92-30: Published: Mar 2, 1992. Publicly Released: Apr 6, 1992.

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Hazel E. Edwards
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Pursuant to a congressional request, GAO reviewed the Internal Revenue Service's (IRS) efforts to acquire the Check Handling Enhancements and Expert System (CHEXS), an automated system to process tax remittances, focusing on whether: (1) software documentation requirements were justified; and (2) those requirements improperly restricted competition.

GAO found that: (1) 1 month before the CHEXS bids were due, IRS amended the solicitation, in response to a vendor's question, to require that all application software for which IRS might assume maintenance responsibility be documented in accordance with Internal Revenue Manual (IRM) 2500; (2) IRS stated that all software and documentation developed specifically for IRS must be in conformance with IRM 2500; (3) IRM 2500 was in accordance with generally accepted system development methodologies; (4) the requirement to document all software developed specifically for CHEXS in accordance with IRM 2500 was justified and did not improperly restrict competition; (5) in the past, IRS has had problems in maintaining contractor-supplied software that was not documented in accordance with IRM 2500 and it is easier for IRS programmers to maintain software when the documentation meets prescribed, agencywide standards; (6) system documentation is necessary to help maintain and enhance CHEXS as IRS users' needs change; (7) none of the IRS solicitations, including those issued after the CHEXS solicitation, explicitly state the requirement that software be documented in conformance with IRM 2500; and (8) the lack of clarity regarding compliance with IRM 2500 could be a source of problems or protests in future procurements.

Recommendation for Executive Action

  1. Status: Closed - Implemented

    Comments: IRS agreed with the recommendation, and in February 1992, IRS amended the RFP for the Document Processing System as suggested by GAO. The agency issued guidelines in November 1993, Systems Information Bulletin Number 67, which clearly states IRS software documentation requirements for internally and externally developed software.

    Recommendation: The Commissioner of Internal Revenue should amend IRS contracting procedures to require that all future solicitations clearly indicate that the software documentation requirements apply to all software for which IRS expects to assume maintenance responsibility, including pre-existing and off-the-shelf software.

    Agency Affected: Department of the Treasury: Internal Revenue Service


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