IRS Management: IRS Faces Challenges as it Restructures the Office of the
Taxpayer Advocate (Letter Report, 07/15/1999, GAO/GGD-99-124).
Taxpayers testified before Congress in 1997 about the difficulties they
had had in trying to get help from the Internal Reserve Service (IRS) in
resolving ongoing problems. Specifically, concerns were raised about
IRS' Office of the National Taxpayer Advocate, which was set up to help
taxpayers who (1) have been unable to resolve their problems elsewhere
in IRS or (2) are suffering significant hardships. GAO identified
shortcomings in the Office and in the Problem Resolution Program that
could affect how efficiently and effectively services are provided to
taxpayers. For example, the Office lacked control over resources for its
Problem Resolution Program. It did not know how many employees were
working in the program or the costs associated with that staffing. Some
staff said that they lacked the necessary training, and limited
advancement opportunities make it difficult for the Office to hire and
retain qualified employees. Also, demands on the Office to resolve
individual taxpayer problems left little time for staff to identify the
causes of recurring taxpayer problems and recommend solutions. The
Office is in the midst of improving its operations. Many of these
changes, such as restructuring Office operations and creating career
paths for local advocates, are outgrowths of the requirements of the IRS
Restructuring and Reform Act of 1998. Other changes, such as developing
position descriptions for Problems Resolution Program caseworkers, are
the result of Office initiatives. It is too soon to tell, however, how
effective these changes will be in overcoming the problems GAO cited.
Two areas in which changes are being considered are advocacy and
performance measures. But changes in both areas require better
information systems than are now available.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: GGD-99-124
TITLE: IRS Management: IRS Faces Challenges as it Restructures
the Office of the Taxpayer Advocate
DATE: 07/15/1999
SUBJECT: Taxpayers
Human resources utilization
Internal controls
Customer service
Performance measures
Federal agency reorganization
IDENTIFIER: IRS Problem Resolution Program
IRS Advocacy Project Tracking System
IRS Problem Resolution Office Management Information
System
IRS Taxpayer Advocate Management Information System
IRS Customer Feedback System
IRS PRP Case Identification and Tracking System
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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 United States General Accounting Office GAO
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 held by your Oversight Subcommittee on
February 10, 1999.1 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. 1IRS Management: Challenges Facing the National Taxpayer
Advocate (GAO/T-GGD-99-28, Feb. 10, 1999). Page 1
GAO/GGD-99-124 Taxpayer Advocate Office B-279035 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 appointment
authority to the Secretary of the Treasury.2 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 his or her tenure as the
Advocate.3 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 has advocates in each of IRS' 4 regions, 33 districts, 30
former districts,4 and 10 service centers and in the Executive
Office for Service Center Operations (EOSCO)5 in Cincinnati, OH,
and the Office of the Assistant 2IRS Restructuring and Reform Act
of 1998, P.L. 105-206 (July 22, 1998). 3Service 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. 4In 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. 5Before
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 Commissioner
(International) in Washington, D.C.6 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 6The 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. Page 5
GAO/GGD-99-124 Taxpayer Advocate Office B-279035 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 how
many staff were working in PRP or the costs associated with that
Challenges for the 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 did not know the total number,
time, and thus, cost The Advocate's Office of staff
devoted to PRP because IRS did not have a standard system to
Lacked Information on track functional staff doing PRP
work.7 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. The Advocate's Office had to rely on
other management officials within Reliance on Functional 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, * ready access to Integrated Data
Retrieval System (IDRS) terminals,8 * 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. According to our survey,
some Advocate Office staff and PRP caseworkers Some Advocate
Office and 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. 8IDRS 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
that could adversely affect the ability of the Advocate's
Obstacles Existed to 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 forthcoming).9 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
structure.10 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 taken some actions and has
others planned that are related to the IRS Has Begun to Address
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. 10In 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 B-279035 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. Page 11
GAO/GGD-99-124 Taxpayer Advocate Office B-279035 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 have
increased and could increase PRP's workload.) IRS uses "cases
Challenge as the 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 19931998) Cases in thousands 500 400 300 200 Cases closed
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 Page 12
GAO/GGD-99-124 Taxpayer Advocate Office B-279035 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 may make it necessary for
the Advocate's Office to Workload Increases Could 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 Advocate's Office because the
improvements it generates could reduce the Best Use of Resources
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. As discussed more fully
below, the advocacy process involves all levels of Time Spent
Working on 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 regard, our
surveys indicated that, as of June 1, 1998, advocates and their
Advocacy staffs were spending about 60 percent
of their time on problems of individual taxpayers11 and about 10
percent of their time on advocacy.12 PRP caseworkers were spending
almost all of their PRP time on problems of individual taxpayers.
The advocacy process within the Advocate's Office involves all
levels of The Advocacy Process 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" cases.13 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 11Advocates 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. 12The remainder
of their time was spent on other types of Advocate Office work,
such as program management and support. 13To 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. We understand the
need for the Advocate's Office to give priority to Inadequate
Information 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. Page 15 GAO/GGD-99-124
Taxpayer Advocate Office 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. In October 1998, the Advocate established a team
to develop Proposed Changes for 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 as
the average amount of time it takes to close a PRP case, rather
than Measures of 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. During our review, the Advocate's
Office was using the following four Existing PRP Measures Are
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. Page 19 GAO/GGD-99-124
Taxpayer Advocate Office 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. The Advocate is working to improve Advocate Office and
PRP measures of Current Information 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 taxpayers who need help from PRP, we recommend that the
Internal Revenue 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 1 Letter 26 Appendix I
Offices Visited
26 Detailed Scope and Program Information Reviewed
27 Staffing Surveys
27 Methodology 28 Appendix II Survey Questions and
Responses 28 Summary
of Responses to the Taxpayer Advocate Staffing Survey 35 Appendix
III Survey Questions and Responses
35 Summary of Responses to the Functional PRP Staffing Survey 43
Appendix IV Selected Survey Results for PRP Caseworkers 46
Appendix V Broad Interpretation of PRP Criteria
46 Factors That Have IRS Initiatives Place Demands on Program
Resources 47 Legislative Requirement May
Increase Demands on PRP 49 Increased and
Could Increase PRP Workload Page 24
GAO/GGD-99-124 Taxpayer Advocate Office Contents 50 Appendix VI
Performance Measures
50 PRP Performance Information Systems
51 Measures and Information Systems 53 Appendix VII 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 offices, 4 former district offices,1 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
Regional Offices Visited
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 Seriesa Occupationb
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 Gradea
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 Othera
71 . 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 Page 29
GAO/GGD-99-124 Taxpayer Advocate Office 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 on Advocate Office worka
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 Othera
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 Othera
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.) Gradea
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 IRS managementa
53 10.4 Advocate Office managementb
440 86.6 Functional managementc
81 . 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 IRS managementa
53 10.4 Advocate Office managementb
423 83.3 Functional managementc
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 Ordersa
18.8 Congressional inquiries
10.0 PRP cases
19.0 Problem Solving Day cases
9.4 Senate Finance Committee casesb
4.7 Otherc
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. aRequests for relief from hardship. bCases 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 PRP course for
current positiona 179
35.2 PRP quality standardsb
226 44.5 PRP updatesc
211 41.5 PROMIS/Intelligent Queryd
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. bStandards for doing PRP casework. cAnnual 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 Othera
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 Seriesa Occupationb
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 Gradea 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 Othera
10 . 1 20 . 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 Othera
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 Othera
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
Gradea 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 Advocate Office
managementa 308 30.3
83 6.9 Functional managementb
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 Advocate
Office managementa 287 28.2
83 6.9 Functional managementb
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 Applications for Taxpayer
Assistance Ordersa 4.5
1.9 Congressional inquiries
11.7 3.5 PRP cases
45.9 40.4 Problem Solving Day cases
12.0 0.6 Senate Finance Committee casesb
3.0 0.3 Otherc
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. aRequests for relief
from hardship. bCases 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 PRP course for current
positiona 416 40.9 471
39.3 PRP quality standardsb 680
66.8 864 72.2 PRP updatesc
548 53.8 886 74.0
PROMIS/Intelligent Queryd 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. bStandards for doing PRP casework. cAnnual 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 Othera
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
Advocate Office managementa 234
32.2 62 7.7 296
19.3 Functional managementb 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
Advocate Office managementa 214
29.5 62 7.7 276
18.0 Functional managementb 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 PRP quality standardsa 550
75.8 644 79.9 1,194
77.9 PRP updatesb 436
60.1 637 79.0 1,073
70.0 PROMIS/Intelligent Queryc 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. aStandards for doing PRP
casework. bAnnual 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 Assistance Ordersa
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 Senate Finance Committee casesb
2.7 0.2
1.4 Otherc
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.
aRequests for relief from hardship. bCases 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 initiative and the recent start of two other IRS initiatives-
Citizen Resources 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.
In November 1997, IRS began holding a series of monthly Problem
Solving Problem Solving Days 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. In
addition to their other duties, some local advocates are
responsible for Citizen Advocacy Panels 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.
Local advocates said that the introduction of a toll-free
telephone number PRP Toll-free Telephone 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 number of local
advocates on statutory notices of deficiency sent to Increase
Demands on taxpayers.1 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. 1A
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 Performance measure
1996 1997 1998 Office of the Taxpayer
Advocate (Fiscal Average processing time (in days)
38.2 33.4 37.8 years 1996-1998)
Currency of case inventory (in days) n/aa
n/aa 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 aData 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 regarding the cases.1
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. 1The 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
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