Tax Administration: IRS Faces Challenges in Reorganizing for Customer
Service (Letter Report, 10/10/95, GAO/GGD-96-3).
GAO reviewed the Internal Revenue Service's (IRS) progress in realizing
its plan for improving its customer service, focusing on: (1) IRS
customer service goals and its plans to meet these goals; (2) the
difficulty IRS has in meeting these goals; (3) current management
concerns; and (4) important challenges IRS faces.
GAO found that: (1) IRS customer service goals are to provide better
service to taxpayers, utilize its resources more efficiently, and
improve taxpayers compliance with tax laws; (2) IRS expects to improve
its efficiency by having fewer work locations and automated workload
management, giving customer service representatives better computer
resources and access to taxpayer accounts, and improving taxpayers
accessibility to telephone service; (3) IRS has made some progress
toward its vision by initiating limited operations in new customer
service centers; (4) current IRS management concerns include the lack of
ownership for customer service, the absence of owner's involvement
during project development, and inadequate quality measures to evaluate
interactive telephone systems performance; (5) these management issues
have not had serious adverse effects on IRS goals because implementation
of the customer service vision is still in the beginning stages; and (6)
to achieve its customer service goals, IRS will have to overcome
challenges including how to manage the transition to a different
organization while maintaining ongoing workloads and developing and
using new information technology.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: GGD-96-3
TITLE: Tax Administration: IRS Faces Challenges in Reorganizing
for Customer Service
DATE: 10/10/95
SUBJECT: Taxpayers
Tax administration systems
Computerized information systems
Telephone communications operations
Human resources utilization
Information dissemination operations
Productivity
Tax law
Systems conversions
Compliance
IDENTIFIER: TSM
IRS Tax System Modernization Program
IRS Strategic Business Plan
IRS Tele-Tax System
IRS Integrated Case Processing System
IRS Document Processing System
IRS Workload Management System
IRS Business Master Plan
IRS Future Concept of Operations
IRS Integrated Transition Plan for Customer Service
IRS Electronic Filing System
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Cover
================================================================ COVER
Report to Congressional Committees
October 1995
TAX ADMINISTRATION - IRS FACES
CHALLENGES IN REORGANIZING FOR
CUSTOMER SERVICE
GAO/GGD-96-3
Customer Service
(268663)
Abbreviations
=============================================================== ABBREV
ACS - automated collection service
ICP - Integrated Case Processing project
IRS - Internal Revenue Service
NTEU - National Treasury Employees Union
TRIS - Telephone Routing and Interactive System
TPS - taxpayer services
TSM - Tax Systems Modernization
VBD - Voice Balance Due
WMS - Workload Management System
Letter
=============================================================== LETTER
B-261038
October 10, 1995
The Honorable Orrin G. Hatch
Chairman
The Honorable Bill Bradley
Ranking Minority Member
Subcommittee on Taxation and IRS Oversight
Committee on Finance
United States Senate
The Honorable Richard C. Shelby
Chairman
The Honorable J. Robert Kerrey
Ranking Minority Member
Subcommittee on Treasury, Postal Service,
and General Government
Committee on Appropriations
United States Senate
The Honorable Nancy L. Johnson
Chairman
The Honorable Robert T. Matsui
Ranking Minority Member
Subcommittee on Oversight
Committee on Ways and Means
House of Representatives
The Honorable Jim Lightfoot
Chairman
The Honorable Steny H. Hoyer
Ranking Minority Member
Subcommittee on Treasury, Postal Service,
and General Government
Committee on Appropriations
House of Representatives
The Internal Revenue Service (IRS) is undergoing a major effort to
modernize its information systems and restructure its organization.
This effort includes several components, one of which IRS calls its
"customer service vision." The vision is a plan for improving IRS'
interactions with taxpayers and includes combining several parts of
IRS' field organization into 23 customer service centers. These
centers would primarily work by telephone to provide taxpayer
service, distribute forms, collect unpaid taxes, and adjust taxpayer
accounts. They would absorb current IRS telephone operations and
attempt to convert much of IRS' written correspondence work to the
telephone.
We reviewed the progress IRS has made toward its customer service
vision because of the magnitude of the changes being undertaken, the
potential for improved performance, and the complexity of the
challenges IRS must overcome to make its vision a reality. This
report was not prepared at the request of the Committees, but as part
of our continuing efforts to provide information and analysis to
improve tax administration. The report discusses (1) IRS' goals for
customer service and its plans to achieve them, (2) the gap between
current performance and these goals, (3) its progress to date, (4)
current management concerns, and (5) several important challenges IRS
faces. We believe the report will be useful as a baseline for
assessing IRS' progress over the next few years.
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
IRS' goals for its customer service vision are to (1) provide better
service to taxpayers, (2) use its staff and facilities more
efficiently, and (3) raise the level of compliance with the tax laws.
IRS plans to better serve taxpayers by improving their accessibility
to telephone service and resolving most problems with a single
contact. IRS expects to improve its efficiency by (1) having fewer
work locations and automated workload management, (2) giving customer
service representatives better computer resources and nationwide
access to taxpayer accounts, and (3) moving work currently done by
correspondence to the telephone. IRS expects to improve compliance
by answering more taxpayer inquiries and having more timely data to
follow up on compliance problems.
The gap between IRS' current operations and its customer service
vision is very great. For example, IRS plans to improve telephone
accessibility by greatly reducing busy signals on its new customer
service telephone system. In contrast, taxpayers who called IRS'
Taxpayer Services toll-free sites in fiscal year 1994 got busy
signals 73 percent of the time.
IRS has made some progress toward its customer service vision,
including selecting sites for the new centers, experimenting with two
prototype sites, and beginning operations at five more customer
service centers. However, implementation still has far to go. For
example, as of June 30, 1995, only 925 of an eventual 22,240 staff
had been reassigned to customer service centers. The new computer
and telephone systems planned to support customer service were still
in an early stage of development and testing. IRS officials recently
acknowledged that the transition would last beyond the original goal
of full operation in 2001.
A lack of clarity in management responsibilities has, to some extent,
hampered IRS in implementing its customer service plans. This is
reflected both at the senior management level for achieving the
customer service vision and at lower management levels for specific
Tax Systems Modernization (TSM) projects crucial to the vision.
First, because the work units and related resources that are to make
up the new customer service organization currently belong to two
separate IRS organizations, Managing Accounts and Ensuring
Compliance, there is no "owner" in terms of a single individual
responsible for the success of all the work activities and resources
that are to be transferred to customer service. IRS officials are
aware of the potential for problems related to the lack of ownership
for customer service and plan to resolve the issue of a single owner
for customer service within the next few months.
Second, at lower management levels, we found instances in which
"products" were being developed for use in the customer service sites
that had no clearly designated process owners. Process owners are
responsible for making sure new products are successfully integrated
into the organizations that are to use the products. To illustrate,
an IRS project office is charged with developing numerous interactive
telephone systems to allow taxpayers to resolve many issues without
speaking with an IRS customer service representative. Although these
interactive telephone systems are crucial to IRS' customer service
vision, one of the systems was developed without a clearly designated
owner. However, near the end of the pilot test for the one system,
an owner was designated. This was over 2 years after the project
office began the design and development of the system.
The absence of an owner's involvement during project development
could result in products that do not meet the owners' operational
needs. It also puts the project office in the position of either
making decisions that should be made by those who will use the
products or stopping development. In this one case, the project
office continued with development, and IRS officials told us that no
adverse effects resulted.
Third, we identified two other instances in which IRS officials had
assumed ownership roles for interactive telephone systems, but had
not carried out their duties to establish the quality measures
critical to evaluating their performance. In these instances, the
owners did not provide timely input for quality measures. After
testing of the systems had begun, the owners called for additional
quality measures, resulting in a delay. IRS officials said they
wanted to be involved earlier, but ongoing workloads prevented them
from doing so.
The management issues we identified have not had serious adverse
effects because implementation of the customer service vision is
still in the early stages. However, IRS documents showed and IRS
officials confirmed that there was confusion about who should be
assigned as an owner for TSM projects that are to support customer
service operations and what those owners' responsibilities should be.
IRS' top management had not made clear the criteria and
responsibilities for ownership of the processes in situations that
include projects such as the interactive telephone systems to support
those processes.
To achieve its customer service goals, IRS will have to overcome
several important challenges including (1) how to manage the
transition to a different organization while maintaining ongoing
workload, (2) deciding how much to expect of individuals in the new
position of customer service representative, (3) developing and
effectively using new information technology, and (4) devising ways
to measure the work of the new customer service centers and balance
their competing workloads.
BACKGROUND
------------------------------------------------------------ Letter :2
In 1986, IRS began to modernize its technology for processing tax
returns, enforcing the tax laws, and assisting taxpayers. IRS was
several years into its system modernization efforts before it began
to study the implications for its organization and work processes.
In response to suggestions from us and others, IRS decided that it
should take this opportunity to redesign its organization and
processes for administering the tax laws. Hence, TSM has become part
of IRS' business vision for both technological and organizational
change.
IRS' business vision includes the following basic organizational
components: (1) submission processing centers to receive paper
returns, correspondence, and other tax documents; (2) customer
service centers to interact with taxpayers mainly by telephone; (3)
district offices to use face-to-face contacts to assist taxpayers and
enforce the tax laws; and (4) computer centers to maintain taxpayer
accounts, process electronically filed returns, and receive
electronic fund transfers.
IRS' customer service vision is a plan for changing the way IRS
interacts with taxpayers. IRS does this in a number of ways, such as
answering inquiries, clarifying and correcting tax returns, and
collecting unpaid taxes. The agency has decided that these
interactions are too fragmentary in its current organization and that
taxpayers who contact IRS are too often told to call or write to
other offices. It thus developed a plan to consolidate, in 23
customer service centers, work that has been done in at least 70
organizational units in 44 locations, including much work currently
done by correspondence.
As shown in figure 1, this consolidation of functions involves a
major restructuring of IRS operations, including a reduction in the
number of staff doing customer service work in 1994 from about 29,000
to an estimated 22,240 in 2001. Customer service centers would
absorb the functions of toll-free taxpayer assistance sites, which
answer calls about tax law and procedures, taxpayer accounts, and
notices that taxpayers receive from IRS. In addition, customer
service centers would attempt to convert to the telephone some work
now done by correspondence in the collection, adjustment, taxpayer
relations, and underreporter branches of service centers. Customer
service centers would also absorb the workload of the current
automated collection call sites, which contact taxpayers to secure
payments and answer calls from taxpayers who are the subjects of
collection actions. Finally, customer service centers would handle
requests for tax forms in lieu of the current forms distribution
centers.
Figure 1: Consolidation of IRS
Customer Service Functions and
Reduction of Staff
(See figure in printed
edition.)
Note: Staff numbers are approximate and include both full-time and
seasonal employees. Staff performing customer service work are to be
reduced from a 1994 level of about 29,000 to an IRS estimate of about
22,240 for 2001.
Source: IRS Business Master Plan and Customer Service Staffing
Projections.
OBJECTIVES, SCOPE, AND
METHODOLOGY
------------------------------------------------------------ Letter :3
We did this assignment because of the magnitude of the changes IRS
was planning for its customer service activities. Our objectives
were to describe IRS' goals for its customer service vision and its
plans for achieving them, determine the current status of
implementation, and identify major challenges facing IRS in moving
toward its vision. To gather information on these objectives, we
reviewed numerous IRS studies, plans, IRS' National Office customer
service site visit reports, and training materials. The key
documents used as baselines for following the progress of
customer service were IRS' September 1993 Business Plan; April
1994 Business Master Plan; IRS Future Concept of Operations,
Volume V, Customer Service Center, August 1994; November 1994
Customer Service Implementation Information; and February 1995
draft Integrated Transition Plan for Customer Service;
interviewed IRS' National Office officials responsible for customer
service and related technology projects;
reviewed IRS' customer service workload model that was used for
forecasting staff needs and the model used for selection of
customer service sites, and discussed the latter model with
officials of IRS' Office of Cost Analysis;
interviewed the Assistant Director of Negotiations at the National
Treasury Employees Union (NTEU) who represents IRS' bargaining
unit employees;
visited three of the seven customer service centers that had begun
operations as of June 30, 1995: Nashville, TN; Fresno, CA; and
Cincinnati, OH; and
reviewed related reports done by us, IRS' Internal Audit, and the
National Research Council.
We requested comments on a draft of this report from the Commissioner
of Internal Revenue or her designee. On August 21, 1995, we met with
IRS officials to obtain their comments on the draft. IRS
representatives at that meeting included the Assistant Commissioner
for Taxpayer Services; the Customer Service Site Executive; the
Director, Taxpayer Service Design and Review; and the Director,
Collection Customer Services. Their comments are summarized on pages
24 and 25 and incorporated elsewhere in the report where appropriate.
We did our work from January 1994 to June 1995 in accordance with
generally accepted government auditing standards.
ACHIEVING CUSTOMER SERVICE
GOALS IS EXPECTED TO BENEFIT
BOTH TAXPAYERS AND IRS
------------------------------------------------------------ Letter :4
IRS' customer service goals are to greatly improve both its service
to taxpayers and its efficiency in using resources. IRS also expects
these improvements to contribute to a higher level of compliance with
the tax laws. IRS intends to achieve these goals by consolidating
several taxpayer interaction functions in customer service centers,
giving customer service representatives broad training and
responsibility, and using better technology. IRS' customer service
vision, if achieved, would represent a substantial change from
current capabilities and performance.
INTENDED BENEFITS TO
TAXPAYERS ARE FEWER CONTACTS
WITH IRS AND IMPROVED
TELEPHONE ACCESSIBILITY
---------------------------------------------------------- Letter :4.1
One goal of the customer service vision is to resolve 95 percent of
taxpayer inquiries after one contact, which IRS refers to as initial
contact resolution. In its 1993 Business Plan, which describes IRS'
business vision, IRS stated that its interactions with taxpayers were
fragmented among too many organizational units. One of IRS' reasons
for consolidating taxpayer interaction functions is its perception
that taxpayers are often referred from one office to another or told
to write a letter to resolve their inquiries.
The difficulty of achieving this goal and of measuring its
achievement is illustrated by one of IRS' first experiences with
initial contact resolution in 1991. By giving telephone assistors
additional computer terminals with access to taxpayer accounts and
more authority to resolve issues, IRS tried to reduce the contacts
taxpayers had to make to resolve questions about their accounts.
However, we reported that IRS was not reliably measuring its
performance in this area.\1 For fiscal year 1993, IRS reported
achieving 96-percent initial contact resolution for these types of
calls, but we found that about 80 percent of a small sample of these
callers had to make additional contacts to resolve their account
concerns. IRS acknowledged that its methodology for measuring
initial contact resolution was flawed and agreed to develop a more
accurate way to measure initial contact resolution for all types of
calls.
IRS intends to reach its initial contact resolution goal by bringing
functions together in customer service centers, giving its
representatives broader responsibility and authority, and giving them
better technological tools with easy access to the needed data.
Another IRS goal is to improve telephone accessibility. Currently,
many taxpayers find it difficult to reach IRS by telephone. In
fiscal year 1994, 73 percent of all call attempts received busy
signals. IRS' Tele-Tax, an automated system in which taxpayers can
listen to selected topic tapes and get refund status information did
better, recording busy signals only 13 percent of the time.
IRS' business vision for customer service centers calls for greatly
reducing busy signals. Callers would be satisfied by an automated
response program, reach a representative immediately, be put on hold,
or leave a message to be called back. IRS' plans call for having
automated response programs resolve up to 45 percent of inquiries
without intervention by a representative. IRS has an automated
system that should allow it to route calls around the nation to
balance peak and slack times in different areas. However,
considering the shortcomings of current telephone accessibility to
IRS, achievement of full accessibility is an ambitious goal.
--------------------
\1 Tax Administration: Better Measures Needed to Assess Progress of
IRS' One-Stop Service (GAO/GGD-94-131, Aug. 29, 1994).
INTENDED BENEFIT TO IRS IS
GREATER EFFICIENCY IN USING
RESOURCES
---------------------------------------------------------- Letter :4.2
In addition to providing improved service to taxpayers, IRS plans to
achieve efficiencies of personnel and facilities use by combining
functions, providing better data and technology to customer service
representatives, and moving most of the correspondence work to the
telephone.
WORK TO BE COMBINED AT
FEWER LOCATIONS AND
WORKLOAD DISTRIBUTED
NATIONALLY
-------------------------------------------------------- Letter :4.2.1
The 23 customer service centers are expected to assume the workload
currently done at 32 taxpayer services toll-free sites, 23 automated
collection call sites, 3 toll-free forms distribution sites, and
several branches in the 10 IRS service centers, such as adjustments
and collection. In many locations, existing operations are to be
consolidated to form the customer service centers, but operations
would be closed at 21 locations that currently house 14 taxpayer
services sites, 9 collection sites, and 2 forms distribution sites.
(See app. I.)
Existing IRS operations have drawn their workloads from
geographically defined service areas; until 1995, employees had
limited access to taxpayer data outside their service areas. When
dealing with a taxpayer from another area, they had to request data
from the IRS service center responsible for that area and recontact
the taxpayer. In early 1995, IRS implemented a networking procedure
among the 10 service center computers so that customer service
representatives could have on-line access to some taxpayer account
data nationwide, rather than only within their service areas. IRS
plans to give its customer service representatives additional on-line
access to taxpayer data nationwide. IRS also has an automated system
that routes calls nationwide when one area is overloaded, and plans
for the system to route specific calls and assign compliance cases on
a nationwide basis to those customer service representatives that
have the appropriate level of expertise to resolve the taxpayer's
concern. Its goal is to even the workload as much as possible and
use personnel efficiently.
IRS has projected that taxpayer interaction work now done by about
29,000 people will be done by about 22,240 at customer service
centers. Under a redeployment understanding with the NTEU, IRS
intends to gradually reassign employees to customer service centers
from current positions that are being eliminated. IRS expects the
planned reduction to occur through attrition.
CUSTOMER SERVICE CENTERS
TO HAVE IMPROVED
TECHNOLOGY AND ACCESS TO
DATA
-------------------------------------------------------- Letter :4.2.2
IRS employees interacting with taxpayers have often lacked easy
access to information needed to resolve cases. This has not been
just a geographic limitation, but also a result of fragmentation of
taxpayer data into stand-alone systems that currently store different
taxpayer data. Also, the current systems are not very user friendly
because they require extensive knowledge of procedures and command
codes.
IRS intends to provide its customer service representatives with
on-line access to a national database encompassing all the taxpayer's
account data and reference information needed to resolve most
taxpayer accounts. In addition, new case processing software should
help representatives work through cases more efficiently. Using a
taxpayer's social security number to obtain case history information,
the software should automatically assemble the relevant information
on screen, provide questions and prompts for the representative, and
perform calculations for updating the account. IRS is moving toward
this goal by first developing an Integrated Case Processing (ICP)
project that links together existing information systems and helps
representatives use them.
CUSTOMER SERVICE CENTERS
WOULD ATTEMPT TO CONVERT
MOST CORRESPONDENCE WORK
TO THE TELEPHONE
-------------------------------------------------------- Letter :4.2.3
In fiscal year 1994, IRS service centers received over 21 million
pieces of correspondence from taxpayers. IRS has made progress in
recent years in handling its correspondence. However, we reported in
1994 that IRS still had problems with timeliness, inadequate
responses, and repeat correspondence on the same subject.\2
One important assumption in the customer service vision is that most
correspondence work from service centers can be converted to
telephone and that this conversion will increase the productivity of
IRS' staff. As of June 30, 1995, the Fresno, CA, Customer Service
Center had substantial experience in converting correspondence, and
the Cincinnati, OH, Customer Service Center had just begun. IRS has
calculated that the Fresno prototype Customer Service Center, working
by telephone, has been at least twice as productive as the service
center adjustments branch, working by correspondence. However, the
director of the study noted that the range of inquiries handled by
the customer service center may not have been as complicated as at
the adjustments branch. In addition, the study showed that the cost
to process inquiries was lower using the customer service approach;
however, telephone charges were not factored in the cost. Thus,
while converting work from written correspondence to the telephone
appears on the surface to be more efficient and less costly, the
extent of savings from this approach is still unknown.
Success in converting correspondence to the telephone may require
that IRS have authority to resolve more issues based on oral evidence
from taxpayers rather than signed statements. Presently, some oral
evidence is acceptable for such issues as penalty abatements up to a
certain dollar amount. An IRS official told us that IRS might need
legislation to remove some of the existing requirements for written
evidence to meet its workload conversion goal. Achieving this goal
would also depend on the willingness of taxpayers to resolve issues
by telephone, which in turn may depend on the accessibility of the
telephone service. If IRS does not succeed in converting a large
percentage of correspondence workload to the telephone, it will need
to retain more people than it is currently projecting to handle this
workload.
--------------------
\2 Tax Administration: More Improvement Needed in IRS Correspondence
(GAO/GGD-94-118, June 1, 1994).
INTENDED REVENUE BENEFIT IS
IMPROVED COMPLIANCE WITH TAX
LAWS
---------------------------------------------------------- Letter :4.3
IRS has stated that achievement of its customer service vision will
contribute to improved compliance with tax laws. IRS believes that
compliance will improve as a result of (1) improved service to
taxpayers and (2) earlier access to taxpayer data that will allow IRS
to follow up on unreported or underreported income and other problems
with returns. Earlier access would come from the improved technology
expected for processing returns and checking the returns against
information from employers and other reporting sources at the time
the return is filed. IRS estimates that through increased voluntary
compliance, to which customer service will contribute, and increased
enforcement efforts, overall compliance will increase from 86.4 to
87.2 percent by 1997. IRS estimates that the increase would generate
about $6.7 billion more tax revenue in 1997 than in 1994.
IRS HAS MADE PROGRESS TOWARD
ITS CUSTOMER SERVICE VISION,
BUT STILL HAS FAR TO GO
------------------------------------------------------------ Letter :5
IRS has described its customer service vision in various planning
documents associated with its modernization effort, such as its
Future Concept of Operations. It has also selected sites for its
customer service centers, experimented with prototype centers,
projected staffing needs, developed a schedule for start-up
operations, and formulated a plan for progressively expanding the
workload of new centers. As of June 30, 1995, the actual
implementation of the customer service vision was still in an early
stage.
IRS HAS SELECTED SITES,
EXPERIMENTED WITH
PROTOTYPES, AND INITIATED
LIMITED OPERATIONS
---------------------------------------------------------- Letter :5.1
In December 1993, IRS announced the locations of future customer
service centers. These included all 10 current service centers and
13 of the 35 locations where collection and/or taxpayer services were
conducted by telephone. The 23 locations chosen and the 21 locations
where telephone operations are to be discontinued are listed in
appendix I.
In January 1994, IRS initiated the Fresno Service Center as the
prototype site for experimenting with customer service operations at
a service center, and the Nashville district as the prototype for
creating a customer service center out of existing taxpayer services
(TPS) and automated collection service (ACS) operations. According
to IRS' implementation plan, these two types of centers would follow
different paths of development, but would eventually come to perform
most of the same functions. In late 1994, IRS began customer service
operations on a small scale at the Cincinnati, OH, and Brookhaven,
NY, Service Centers, and in early 1995, at the Kansas City, MO;
Andover, MA; and Philadelphia, PA; Service Centers.
TRANSITION TO CUSTOMER
SERVICE HAS JUST BEGUN
---------------------------------------------------------- Letter :5.2
IRS' transition to the customer service vision is proceeding more
slowly than originally foreseen. The 1993 Business Plan estimated
that 10,000 of the eventual 22,240 customer service employees would
be on site by the end of fiscal year 1996, with centers fully
operational in 2001. While IRS still plans to begin operations at
all 23 locations by the end of 1996, the scope of their work will be
limited, and current plans call for about 5,000 staff in place. IRS
now expects full transition to occur some time after 2001.
Several indicators of IRS' progress in reorganizing for customer
service are summarized as follows:
IRS intends to set up 23 customer service centers, with staffs
varying from 186 to 2,609. Each center requires site
preparation, acquisition of furniture and equipment,
installation of software and telecommunications equipment, and
training of staff. As of June 30, 1995, 7 centers had begun
operations, 3 of which had fewer than 80 staff to perform very
limited workloads.
IRS intends to discontinue telephone operations at 21 locations,
which include 14 taxpayer services telephone sites, 9 collection
call sites, and 2 forms distribution sites. As of June 30,
1995, it had closed 6 locations. Figure 2 summarizes the
reorganization of IRS telephone operations foreseen in the
customer service plan.
Figure 2: IRS' Plans to
Consolidate Telephone
Operations
(See figure in printed
edition.)
Note: Conversions are those locations where one or more existing
telephone operations are being merged into a new customer service
center.
Source: IRS documents.
IRS intends to redeploy 22,240 staff to customer service centers.
As shown in figure 3, about 925 of these staff were in place on
June 30, 1995.
Figure 3: IRS' Plans to
Redeploy Staff to Customer
Service
(See figure in printed
edition.)
Source: IRS' Customer Service Implementation Information, Nov.
1994.
IRS has not yet estimated the volume of correspondence it expects
to convert to telephone work. Only Fresno had attempted any
conversion at the time of our review, and IRS had conducted a
study to assess the effect of Fresno's initial efforts. The
study concluded that these efforts may have reduced the service
center's correspondence receipts related to selected notices by
about 91,000, from 600,000 to 509,000. According to an IRS
study, the Fresno adjustments branch recorded a 15-percent
decline in incoming correspondence after IRS began including the
customer service center's telephone number on outgoing notices.
Fresno planned to expand its conversion efforts in 1995, and
initial efforts were also planned at some new customer service
centers.
As a transitional approach to case processing, IRS is developing
the ICP project. ICP is being developed in four increments.
The first increment has been tested at Nashville, and the
development and testing of the next two increments are scheduled
through 1997. Scheduling for increment four has not yet been
determined. The system is to be modified for use with a planned
new comprehensive database of taxpayer information.
MANAGEMENT RESPONSIBILITIES FOR
CUSTOMER SERVICE ARE NOT CLEAR
------------------------------------------------------------ Letter :6
IRS has been hampered to some extent in implementing its customer
service plans by a lack of clarity in management responsibilities.
This is reflected both at the senior management level for achieving
the customer service vision and at lower management levels for
specific TSM projects crucial to the vision. The lack of clarity at
both management levels can be traced to IRS' current organizational
structure, which does not fully conform to the plans for the customer
service vision, but uncertainty about how to implement IRS' new core
business systems management approach has also contributed to the
confusion.\3
IRS' officials have a plan that, if timely and thoroughly
implemented, should clearly identify responsibilities at the senior
management level.
An integral part of IRS' core business system approach is its
requirement for designation of "owners" of each core business system
and the underlying subsystems and processes. IRS has defined an
owner as an individual assigned to be responsible and accountable for
all the activities associated with a core business system, subsystem,
or process. This responsibility often includes establishing business
requirements, setting quality measures, and overseeing the
development of new products and services intended to enhance the
performance of the core business system in meeting taxpayers' needs.
IRS has designated owners for the six core business systems and for
most of the subsystems and processes that comprise the majority of
IRS' activities. Two of these core business systems, Managing
Accounts and Ensuring Compliance, include the subsystems and
processes that are to be transferred to customer service.\4
Thus, the subsystems and processes that are to make up customer
service are divided between two current IRS core business systems.
(As the boundaries of the two functional organizations involved,
Taxpayer Services and Compliance, are identical to the core business
system boundaries, customer service responsibilities are split
between the functional organizations also.)
Because IRS' current organizational structure does not match the
structure planned for customer service, no owner for the emerging
customer service organization has yet been designated. The result is
that responsibility for carrying out the many projects and tasks
necessary to work toward the goals of the customer service vision is
divided between two IRS organizations, which are headed by two
different senior managers called chiefs, who are also responsible for
directing current returns processing, taxpayer services, examination,
and collection activities.
The divided ownership of the components of the customer service
vision also raises the question of how the new customer service
organization that will emerge as more sites are rolled out will be
managed. Traditionally, IRS offices that carried out the service
activities being combined at customer service sites have been part of
a district and/or regional office, with the National Office providing
policy guidance and oversight. However, significant changes have
recently been made in both the number and responsibilities of IRS'
District and Regional offices. And, in some instances, components of
IRS' National Office have been structured in such a way that they
have greater control over field operations than has traditionally
been the case. IRS' top leaders will have to decide which office
will have responsibility for the emerging customer service
organization and who is to lead it.
IRS officials are aware of the potential problems associated with the
divided ownership of the components planned for customer service and
plan to address them soon. The Customer Service Site Executive told
us that a group of executives had been selected to study the issue
and make recommendations on how to deal with it.
The issue we identified at management levels below the chiefs deals
with IRS assigning process owners responsibility for seeing that
specific products and services needed to further the customer service
goals are successfully carried out and making sure process owners who
have been assigned effectively carry out their responsibilities.
Assigning process owners at the operational level has been difficult
because there was confusion about who they should be and what their
specific roles and responsibilities should be, especially in
activities involving more than one core business system.
IRS did not assign a process owner for its Voice Balance Due (VBD)
interactive telephone system until late in its development, thus
risking the need for changes late in the development process.\5 The
VBD system cuts across the Managing Accounts and Ensuring Compliance
core business systems. IRS officials told us that in cases where
core businesses overlap there has been confusion about who the owner
should be. In the case of the VBD system, Managing Accounts
personnel told us they owned it, but because the system includes
collection activities, the Customer Service Site Executive's Office
believed the system belonged to Ensuring Compliance. However, the
Director of Ensuring Compliance said that his office was not the
owner of the project, although it had been involved.
IRS officials in the Telephone Routing Interactive System (TRIS)
Project Office, the developer of the new telephone systems, told us
that they needed to have process owner input for the VBD quality
measures so that they could plan and collect the management data
needed to measure the system's performance. TRIS officials also told
us they did the best they could to determine the management data
needed for the pilot test.
Near the end of the pilot test, in June 1995, IRS assigned the
Assistant Commissioner for Taxpayer Services--a process
owner--responsibility for all the interactive systems, including the
VBD. This was over 2 years after the TRIS Project Office began the
design and development of the VBD. As a process owner, the Assistant
Commissioner for Taxpayer Services is responsible for coordinating
the requirements and overseeing the development for all interactive
telephone systems, including those that involve more than one core
business system. Although IRS officials told us the VBD system was
working well, they agreed that owners should be clearly designated
early in the design of systems to make sure they will meet the needs
of the customer service sites and the taxpayers who will use them.
In the case of two other interactive telephone systems, the Refund
and Location systems, officials in the Managing Accounts Core
Business System assumed the role of owner, but did not provide the
TRIS Project Office with timely input in developing quality measures.
Quality measures are important because IRS plans to use the measures
to determine the success of the new systems and whether to implement
them in the field. To avoid delays in development, the TRIS Project
Office established quality measures and began testing the systems
based on those measures. About 3 weeks into the 30-day test period,
the owners required that additional measures be tested, and the pilot
period was extended for at least 30 days. Managing Accounts
officials who worked on the quality measures said that they wanted to
be involved with TRIS earlier, but that their ongoing workload
prevented them from doing so.
IRS' top management has not made clear the criteria for selecting
owners and what their roles and responsibilities are to be. This is
particularly important in situations where TSM projects such as the
interactive telephone systems involve more than one core business
system.
--------------------
\3 A core business system, as IRS uses the term, refers to a closely
related set of business processes, defined in terms of a customer's
needs. For example, the Managing Accounts core business system
includes all the steps involved in collecting taxpayer account
information, maintaining it, and providing it to the taxpayer and IRS
employees who need it. A few of these steps are (1) answering
taxpayers' tax law questions, (2) processing taxpayers' returns, (3)
sending taxpayers notices when errors are made and more taxes are
due, and (4) answering taxpayers' questions about their accounts and
making changes to the accounts in IRS' records.
\4 IRS' traditional functional organization continues to exist along
with the structure resulting from the core business systems approach.
For example, the functional organization called Taxpayer Services is
synonymous with the Managing Accounts core business system and their
organizational boundaries are identical. Compliance, the other
functional organization involved in customer service, is synonymous
with the core business system called Ensuring Compliance and this
functional and core business system pair also have identical
boundaries.
\5 VBD is one of 30 interactive telephone systems being developed by
IRS. This system is intended to allow eligible taxpayers to
establish an installment agreement for taxes due without contacting
an IRS customer service representative.
CHALLENGES FACING IRS
------------------------------------------------------------ Letter :7
In reviewing IRS' early progress toward its customer service vision,
we identified four important challenges that IRS must cope with and
which we intend to monitor: (1) how to manage the transition to a
substantially different organization while meeting ongoing workload
demands, (2) how to define the responsibilities of customer service
representatives to achieve a successful balance of generalization and
specialization, (3) how to realize the expected benefits of new
technology, and (4) how to measure success and balance multiple
workload goals in the new centers.
MANAGING TRANSITION TO
CUSTOMER SERVICE CENTERS
WHILE MEETING ONGOING
WORKLOAD DEMANDS
---------------------------------------------------------- Letter :7.1
One of the challenges IRS faces will be managing the transition to
the customer service vision while continuing to meet the ongoing
workload demands of answering taxpayer inquiries, managing taxpayer
accounts, and collecting unpaid taxes. Each group of employees who
are redeployed as customer service representatives requires classroom
and on-the-job training before the group can assume its share of the
workload. Classroom training time for recent start-up operations has
varied from 5 to 9 weeks, depending on the prior experience of
employees. An IRS official responsible for customer service did not
know at the time of our review how much training would be needed for
the full scope of a customer service representative's
responsibilities.
IRS intends to gradually close telephone operations at 21 locations
through 1999, in the meantime keeping them adequately staffed to
handle their share of the ongoing workload. In the spring of 1995,
concerned about premature attrition at the sites scheduled for
closing, IRS responded by hiring temporary employees who do not have
redeployment rights.
DETERMINING THE SCOPE OF
CUSTOMER SERVICE
REPRESENTATIVES'
RESPONSIBILITIES
---------------------------------------------------------- Letter :7.2
The customer service representative position has potentially very
broad responsibilities, involving such things as (1) answering some
tax law questions, (2) soliciting information from taxpayers and
adjusting accounts, (3) helping taxpayers arrange payment plans, (4)
contacting taxpayers to obtain payments, and (5) answering calls from
taxpayers who have been subject to collection actions. Experience at
the two prototype centers demonstrated the pitfalls of expecting too
much too soon of the representatives.
Nashville, which has both taxpayer services and automated collection
call sites, tried to achieve maximum versatility of the customer
service representatives in its prototype by creating a position with
customer service expertise in collection work, taxpayer account work,
and tax law matters. This involved cross training or "blending" some
of the employees from the two call sites. After experiencing some
accuracy and productivity problems, Nashville adopted less ambitious
goals for blending functions, returning to a division of
responsibility among its customer service representatives.
Fresno's prototype, based at a service center, focused primarily on
responding to some of the service center's written inquiries by
telephone. It also tried to broaden its workload by accepting some
tax law inquiries from neighboring taxpayer services sites. However,
although the customer service representatives received some training
in tax law, they nevertheless experienced difficulties with the tax
law questions, and Fresno has since discontinued this workload.
While IRS intends that the case processing software it is developing
will provide guidance to customer service representatives, its
expectations of them will nevertheless be substantial. In training
and assigning work to them, IRS will have to find a balance between
generalization and specialization. Expecting each representative to
handle any issue that comes along could result in many mistakes. On
the other hand, too much division of responsibility could undermine
the flexibility needed for efficient operations and the goal of
providing one-stop service to taxpayers.
IRS' task is complicated by the redeployment understanding it reached
with NTEU. One of the considerations in filling customer service
positions is that preference must be given according to the seniority
of employees whose jobs will be adversely affected by reorganization.
While some of these employees work at the current taxpayer services
and collection call sites, more than half are in service center
positions that do not involve telephone interaction with taxpayers.
Much of the workload encountered will be new to these employees, as
well as the environment of working by telephone. IRS found that many
of the employees who exercised redeployment rights for the initial
customer service start-up operations lacked relevant experience and
needed considerable training.
SUCCESS IN CUSTOMER SERVICE
DEPENDS ON SUCCESS WITH
INFORMATION TECHNOLOGY
PROJECTS
---------------------------------------------------------- Letter :7.3
The potential effectiveness of customer service centers will depend
considerably on the successful application of information technology.
IRS' vision for customer service relies directly on two TSM projects,
TRIS and ICP, and indirectly on several others, such as Electronic
Filing and the Document Processing System.
TELEPHONE ROUTING
INTERACTIVE SYSTEMS
-------------------------------------------------------- Letter :7.3.1
IRS is installing new telephone equipment that greets callers with
recorded messages. Taxpayers are able to choose from menus to route
themselves to the appropriate source of assistance. This equipment
allows management to monitor call volumes on specific subjects and
adjust staffing to reduce waiting time. In addition, IRS is
developing interactive systems that should allow taxpayers to
accomplish various actions without speaking to a customer service
representative.
This equipment has been in use at some taxpayer services sites in
recent years. IRS experience has shown that a large majority of
callers do use the menus to route their calls, thus reducing the need
for a group of representatives known as "screeners" who would
identify the nature of a taxpayer's inquiry and transfer it to the
appropriate area for resolution. However, IRS studies have also
shown that the success of such programs is very sensitive to menu
design. In 1994, for example, some features of the menus increased
the amount of time callers spent listening to menu options and also
increased the percentage of callers who opted for a live receptionist
instead of routing themselves. IRS is attempting to refine its menus
to minimize these problems.
IRS anticipates using interactive programs for about 30 different
purposes. As of June 30, 1995, two programs had been in use for some
time nationwide: interactive menus for self-routing of calls and
recorded tax law information/refund status (Tele-Tax). Testing was
completed on three additional programs in June 1995 at the Nashville
prototype and are now being evaluated. They include one to be used
by taxpayers who receive notices of taxes owed. IRS plans to offer
taxpayers who select this option a chance to arrange for an extension
of their payment due date or an installment payment plan.
IRS expects that these interactive programs will be able to handle
many routine taxpayer inquiries and transactions without assistance
from a customer service representative. This would give
representatives more time to handle more complicated inquiries and
work on compliance issues, such as unreported or underreported
income, improperly completed returns, and unpaid taxes. IRS has
projected that 45 percent of calls can be satisfied by interactive
programs. However, if programs are not well designed, or taxpayers
are simply reluctant to use them, representatives would need to field
many more calls than anticipated, and productivity gains could be
reduced.
INTEGRATED CASE
PROCESSING
-------------------------------------------------------- Letter :7.3.2
IRS eventually wants its customer service representatives to interact
with a consolidated database. In the meantime, IRS is developing ICP
to overcome the fragmentation of taxpayer data in its current
systems. ICP is being developed in four increments that will
progressively expand the capability of representatives to interact
with the databases for taxpayer accounts, collection, examinations,
and underreported income. ICP is to provide a series of questions
and prompts to help representatives work through various kinds of
taxpayer issues, as well as make queries and updates to account data
with assurance that the data will be reconciled among the different
databases. Under ICP, IRS also intends to develop a workload
management system that would allocate representatives' time to
various functions, create electronic case folders, and assign cases
to representatives who have been certified to handle the issues
involved.
As of June 30, 1995, the first increment of ICP had been piloted at
Nashville, allowing customer service representatives to access
existing databases from a single terminal. Through 1998, IRS plans
to develop, test, and install the remaining increments, as well as
train representatives in their use. ICP includes plans to transfer
IRS data from its existing separate databases to its eventual
consolidated database. Customer service productivity would be
reduced if ICP fails to deliver the data access and analytical
capabilities envisioned for customer service representatives.
SUBMISSION PROCESSING
PROJECTS ALSO WILL AFFECT
CUSTOMER SERVICE
-------------------------------------------------------- Letter :7.3.3
IRS' projections of customer service workload are dependent on
certain TSM projects not directly used by customer service centers,
such as electronic filing of returns and electronic scanning of paper
returns. Electronically filed returns contain few errors compared to
paper returns and thus should generate fewer problems to be resolved
by customer service representatives. Similarly, electronic scanning
through the Document Processing System is expected to reduce data
input errors in processing paper returns. IRS expects these two
projects to replace most of the manual processing of tax returns and
greatly reduce errors.
As of June 30, 1995, results of these projects were somewhat
disappointing. The number of electronically filed returns received
was running 17.8 percent below that of the same period in 1994 (11.1
million compared to 13.5 million in 1994). Attempts to use scanning
equipment to process the simplest tax returns were also not
succeeding as planned. The final outcome of these projects will not
be known for several years. To the extent that the projects fail to
achieve projected results, the follow-up workload generated for
customer service centers will be greater than anticipated. This
would mean that estimated savings in staffing and costs may not
accrue to the degree that IRS had envisioned. In response to our
attempt to learn how shortcomings with certain TSM projects could
affect customer service, IRS officials told us that a statement of
work has been written to contract out for a comprehensive analysis of
the costs and savings associated with customer service.
MEASURING SUCCESS AND
MANAGING COMPETING WORKLOAD
DEMANDS IN CUSTOMER SERVICE
CENTERS
---------------------------------------------------------- Letter :7.4
IRS has not determined all of the indicators by which success in
customer service centers will be measured, although it has committed
itself to goals of 95-percent initial contact resolution and near-100
percent accessibility.\6 The customer service centers are to combine
work that is currently done in several different organizational
components of IRS. IRS has recognized that simply transplanting the
workload priorities and performance measures of these components to
the new centers would be inappropriate. It intends to develop work
plans and performance measures relevant to the new organizations.
Without appropriate performance indicators in place, IRS has only
physical indicators, such as sites established, persons redeployed,
and technological programs installed to measure progress toward the
customer service vision. While useful, these indicators do not
measure the value of the reorganization and may not alert IRS to
developing problems. Developing meaningful indicators will not be
easy because IRS is attempting to achieve qualitative as well as
quantitative change.
Managing the workload of customer service centers will also be a
significant challenge. We believe that the new centers will likely
feel the tension of competing demands to answer inquiries, adjust
accounts, follow up on examinations, and collect unpaid taxes. If
taxpayers are dissatisfied with accessibility and waiting times,
pressure will build to answer more calls at the expense of compliance
and collection activities. IRS will no longer have organizational
walls to protect these different functions and will have to balance
them within a single organizational structure. IRS is counting on
technology to cope with such problems. Under ICP, IRS intends to
develop an automated Workload Management System (WMS) that will
provide the capabilities to create and manage cases, track and
control correspondence, and maintain employees' skills inventories.
ICP is in an early stage of development, however, and the
requirements for WMS are still being defined.
--------------------
\6 IRS' accessibility measure of 100 percent is defined as every
taxpayer who calls IRS will get through on the first telephone call,
and no taxpayer will get a busy signal except during limited peak
periods.
CONCLUSIONS
------------------------------------------------------------ Letter :8
IRS has undertaken an ambitious plan to reorganize and downsize its
operations that provide service to taxpayers, a plan it has just
begun to implement. IRS officials have recently acknowledged that
the transition will last beyond its planned goal of 2001. It is too
soon to conclude whether IRS will eventually accomplish its goals,
but the gap between current operations and its customer service
vision is very great.
A lack of clarity in management responsibilities has, to some extent,
hampered IRS in the early stages of implementing its customer service
vision. This lack of clarity exists both at the senior management
level and at the lower management levels for specific TSM projects
crucial to the vision. The reasons for this are in part related to
IRS' current organizational structure, but are also due to problems
in adjusting to a new management structure based on the core business
system approach. At the senior management level, IRS has not
designated an owner to be responsible and accountable for all the
work units that will be part of customer service and the many
projects that must be successfully completed to make the customer
service vision a reality. IRS officials plan to address the need for
an owner for customer service at the senior management level.
At lower management levels, the process owner was assigned late for
overseeing an interactive telephone system that involved both the
Managing Accounts and Ensuring Compliance core business systems.
Also, in two other instances owners for such systems had assumed
ownership roles, but had not adequately carried out their
responsibilities.
The problems we identified have not had a serious adverse effect to
date because IRS' implementation of the customer service vision is
still in the early stages. However, failure to deal with them as
soon as possible could delay the development and implementation of
new products and services needed for customer service.
Finally, to achieve its customer service goals, IRS will have to
overcome a number of challenges involving managing the transition to
a new organization while meeting ongoing workload demands, defining
customer service representatives' responsibilities, realizing the
benefits of new information technology, and developing effective ways
to measure performance in the new centers.
RECOMMENDATIONS
------------------------------------------------------------ Letter :9
We recommend that the Commissioner of Internal Revenue
clarify the criteria for assigning process owners responsibility
for TSM projects when they involve more than one core business
system;
define process owners' roles and responsibilities for TSM projects
involving more than one core business system; and
emphasize to those designated as process owners the need for them
to provide the business requirements necessary to develop, test,
and implement new customer service products and services.
AGENCY COMMENTS AND OUR
EVALUATION
----------------------------------------------------------- Letter :10
We obtained oral comments on a draft of this report from senior IRS
officials in a meeting on August 21, 1995. IRS officials present
included the Assistant Commissioner for Taxpayer Service; the
Customer Service Site Executive; the Director, Taxpayer Service
Design and Review; and the Director, Collection Customer Services.
These comments were supplemented by a memorandum clarifying remarks
made during our discussion. IRS officials said that the report was
an accurate assessment of the progress to date for achieving IRS'
customer service vision. IRS officials agreed with our
recommendations, but suggested wording changes in the recommendations
to clarify their intent. We have made the wording changes the IRS
officials suggested.
In their comments on a draft of this report, IRS officials pointed
out that a process owner--the Assistant Commissioner for Taxpayer
Services--had been assigned ownership responsibility for all of the
interactive telephone systems in June 1995. They said that the
Assistant Commissioner's responsibilities included coordinating
requirements and overseeing the development of interactive telephone
systems that involved more than one core business system. Assigning
a senior official ownership responsibility for all of the interactive
telephone systems should help to avoid the kinds of problems we
identified with those systems.
The IRS officials said that, to address our concerns on a broader
basis, the Modernization Executive--the official who has overall
responsibility for IRS' TSM efforts--has been charged with directing,
prioritizing, and coordinating any projects dealing with
modernization, including those that support Customer Service. The
IRS officials also said core business system owners have
responsibility for identifying process owners for processes within
their core business system. However, they emphasized that the
Modernization Executive is responsible for making sure that any
change efforts that involve more than one core business system,
including TSM projects, are not adversely affected by the overlap.
We believe that assigning the Modernization Executive responsibility
for ensuring that TSM projects involving more than one core business
system are not adversely affected by the overlap should, if properly
carried out, accomplish the intent of our recommendations.
--------------------------------------------------------- Letter :10.1
We are sending copies of this report to other interested
congressional committees, the Secretary of the Treasury, the
Commissioner of Internal Revenue, and other interested parties.
Copies will also be made available to others upon request.
Major contributors to this report are listed in appendix II. If you
or your staff have any questions concerning the report, please call
me on (202) 512-9110.
Lynda D. Willis
Associate Director, Tax Policy and
Administration Issues
IRS LOCATIONS AFFECTED BY THE
CUSTOMER SERVICE REORGANIZATION
=========================================================== Appendix I
Table I.1
Locations Chosen for Customer Service
Centers
Forms
Scheduled to Service Taxpayer Automated distribution
Location begin center service collection center
---------- ------------ ------------ ------------ ------------ ------------
Fresno, CA 1/94 x
Nashville, 1/94 x x
TN
Cincinnati 11/94 x x
, OH
Brookhaven 12/94 x
, NY
Kansas 3/95 x
City, MO
Andover, 4/95 x x x
MA
Philadelph 6/95 x x x
ia, PA
Austin, TX 7/95 x
Atlanta, 8/95 x x x
GA
Ogden, UT 9/95 x
Cleveland, 1/96 x x
OH
Denver, CO 1/96 x x
Indianapol 1/96 x x
is, IN
Pittsburgh 5/96 x
, PA
St. Louis, 5/96 x x
MO
Portland, 6/96 x
OR
Richmond, 6/96 x x
VA
Baltimore, 7/96 x x
MD
Jacksonvil 7/96 x x
le, FL
Memphis, 8/96 x
TN
Buffalo, TBD\a x x
NY
Dallas, TX TBD x x
Seattle, TBD x x
WA
--------------------------------------------------------------------------------
\a To be determined.
Table I.2
Locations Where Telephone Operations
Will Be Discontinued
Forms
Taxpayer Automated distributio
Location service collection n center
------------------------------- ----------- ----------- -----------
Chicago, IL x x
Detroit, MI x x
Houston, TX x x
Newark, NJ x x
Anchorage, AK x
Brooklyn, NY x
Des Moines, IA x
El Monte, CA x
Honolulu, HI x
Milwaukee, WI x
Oakland, CA x
Omaha, NE x
Phoenix, AZ x
St. Paul, MN x
Kearny Mesa, CA x
Laguna Niguel, CA x
New York, NY x
Oklahoma City, OK x
San Francisco, CA x
Bloomington, IL x
Sacramento, CA x
----------------------------------------------------------------------
Note: San Juan, PR, a present collocated ACS/TPS call site, is not
considered 1 of the 23 selected customer service sites nor will its
telephone operations be discontinued. It will be considered a
specialized call site working on international tax matters.
Source: IRS data.
MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II
GENERAL GOVERNMENT DIVISION,
WASHINGTON, D.C.
John M. Lovelady, Assistant Director, Tax Policy and
Administration Issues
Robert L. Giusti, Assignment Manager
Monika R. Gomez, Evaluator
CINCINNATI FIELD OFFICE
Kenneth R. Libbey, Evaluator-in-Charge
Robert I. Lidman, Core Group Manager
ATLANTA FIELD OFFICE
Lorelei H. Hill, Site Senior