IRS' Year 2000 Efforts: Actions Are Underway to Help Ensure That
Contingency Plans Are Complete and Consistent (Letter Report, 09/14/1999,
GAO/GGD-99-176).
GAO reviewed two Internal Revenue Service (IRS) year 2000 business
continuity and contingency plans for their consistency and completeness
on the basis of IRS' guidance for such plans.
GAO noted that: (1) two IRS business continuity and contingency
plans--one for processing paper tax returns that result in a refund
(refund plan) and the other for receiving paper submissions (paper
submissions plan)--were inconsistent and incomplete in two key areas
included in IRS' guidance: (a) performance goals; and (b) mitigating
actions; (2) these weaknesses raise questions about whether these two
plans provide sufficient assurance that IRS has taken all the necessary
steps to reduce the impact of a potential year 2000 failure; (3) IRS'
guidance requires that plans specify a desirable performance goal; (4)
the performance goal for the refund plan was inconsistent with the
plan's contingency actions; (5) this inconsistency raises questions
about the goal that IRS is trying to achieve with the refund plan; (6)
the paper submissions plan did not include a performance goal; (7)
without appropriate performance goals, IRS has little assurance that the
contingency actions specified in the plan are appropriate for reducing
the impact of a potential year 2000 failure; (8) in addition, neither
plan specified the completion dates for the mitigating actions, which
IRS' guidance defines as the steps that are to be completed in advance
of a potential year 2000-related failure, to help reduce its impact; (9)
moreover, neither plan specified which individuals were to be
responsible for completing the mitigating actions; (10) IRS' guidance
requires that the plans include mitigating actions and completion dates,
but does not require that responsible individuals be identified for
completing mitigating actions; (11) however, without assigning actions
to specific individuals and identifying completion dates, IRS has little
assurance that these actions will be completed before a potential year
2000 failure; (12) in June 1999, GAO informed IRS officials of its
concerns regarding these two plans; (13) GAO also told them that its
concerns raise questions about the extent to which other plans may have
similar weaknesses; (14) in response to GAO's concerns, IRS officials
agreed to make changes to improve the completeness and consistency of
these two plans; (15) they also said they have designated an individual
that is to determine the extent to which other plans may have similar
weaknesses and revise the plans as needed; and (16) in addition, IRS
assigned one of its year 2000 contractors to set up a mechanism by which
IRS could track the implementation of business continuity and
contingency plan actions.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: GGD-99-176
TITLE: IRS' Year 2000 Efforts: Actions Are Underway to Help
Ensure That Contingency Plans Are Complete and Consistent
DATE: 09/14/1999
SUBJECT: Computer software verification and validation
Computer software
Systems conversions
Strategic information systems planning
Data integrity
Information resources management
Y2K
Tax returns
Tax administration systems
Performance measures
IDENTIFIER: Y2K
IRS Service Center Automated Mail Processing System
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United States General Accounting Office GAO Report
to the Commissioner of Internal Revenue September 1999 IRS'
YEAR 2000 EFFORTS Actions Are Under Way to Help Ensure That
Contingency Plans Are Complete and Consistent GAO/GGD-99-176
United States General Accounting Office
General Government Division Washington, D.C. 20548 B-283400
September 14, 1999 The Honorable Charles O. Rossotti Commissioner
of Internal Revenue Dear Mr. Rossotti: The Internal Revenue
Service (IRS) agreed with recommendations we made in June 1998 to
broaden its Year 2000-related contingency planning approach by
developing a comprehensive, business-based set of business
continuity and contingency plans.1 Because adequate plans are
necessary for mitigating the impact of any Year 2000-related
system failure, we followed up on our June 1998 report by
reviewing two plans that address critical IRS business processes.
We recognize that these plans are being revised to incorporate the
results of testing that was done in July 1999. At the time we
prepared this report, however, the testing reports were not
completed. Because of the time-critical nature of Year 2000
business continuity and contingency planning, we are reporting the
results of our work at this time, rather than waiting to review
testing reports and any revisions that may be made to the plans as
a result of that testing. Our objective was to evaluate two IRS
business continuity and contingency plans for their consistency
and completeness on the basis of IRS' guidance for such plans. We
focused on 2 of the 18 plans that IRS developed for its submission
processing core business process. These two plans address
processing paper tax returns that result in a refund and receiving
paper submissions (which include tax returns).2 We reviewed these
plans because they are designed to address failure scenarios that,
if they occur and are prolonged, could require IRS to revert to
manual operations for issuing refunds-something that could
potentially affect the majority of taxpayers that file individual
tax returns. For example, in calendar year 1998, IRS processed
about 91 million paper individual tax 1IRS' Year 2000 Efforts:
Business Continuity Planning Needed for Potential Year 2000 System
Failures (GAO/GGD-98-138, June 15, 1998). 2As discussed later in
this report, IRS identified five submission processing
subprocesses: (1) receive paper submissions; (2) receive
electronic submissions; (3) control and track tax and submissions;
(4) process, correct, and forward payment data; and (5) process,
correct, and forward tax information return data. Refund issuance
includes aspects of several of these subprocesses. Page 1
GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
returns3 and issued more than 82 million refunds totaling about
$112 billion. Two IRS business continuity and contingency plans-
one for processing Results in Brief paper tax returns that
result in a refund (hereafter referred to as the refund plan) and
the other for receiving paper submissions (hereafter referred to
as the paper submissions plan)-were inconsistent and incomplete in
two key areas included in IRS' guidance: performance goals4 and
mitigating actions. These weaknesses raise questions about whether
these two plans provide sufficient assurance that IRS has taken
all the necessary steps to reduce the impact of a potential Year
2000 failure. IRS' guidance requires that plans specify a
desirable performance goal. The performance goal for the refund
plan was inconsistent with the plan's contingency actions. This
inconsistency raises questions about the goal that IRS is trying
to achieve with the refund plan. The paper submissions plan did
not include a performance goal. Without appropriate performance
goals, IRS has little assurance that the contingency actions
specified in the plan are appropriate for reducing the impact of a
potential Year 2000 failure. In addition, neither plan specified
the completion dates for the mitigating actions, which IRS'
guidance defines as the steps that are to be completed in advance
of a potential Year 2000-related failure, to help reduce its
impact. Moreover, neither plan specified which individuals were to
be responsible for completing the mitigating actions. IRS'
guidance requires that the plans include mitigating actions and
completion dates, but does not require that responsible
individuals be identified for completing mitigating actions.
However, without assigning actions to specific individuals and
identifying completion dates, IRS has little assurance that these
actions will be completed before a potential Year 2000 failure. As
part of our effort to provide IRS with timely feedback on our
observations regarding its Year 2000 efforts, in June 1999, we
informed IRS officials of our concerns regarding these two plans.
We also told them that our concerns raise questions about the
extent to which other plans may have similar weaknesses. In
response to our concerns, IRS officials agreed to make changes to
improve the completeness and consistency of these 3In 1998, IRS
received more than 24 million tax returns by means other than
paper, either electronically or via the telephone. IRS prepared
separate business continuity and contingency plans for Year 2000
system failures that would affect receiving electronic returns.
4IRS' guidance refers to a performance goal as the "event
/achievement indicating success." Page 2
GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
two plans. They also said they have designated an individual that
is to determine the extent to which other plans may have similar
weaknesses and revise the plans as needed. In addition, IRS
assigned one of its Year 2000 contractors to set up a mechanism by
which IRS could track the implementation of business continuity
and contingency plan actions. If properly implemented in a timely
fashion, these actions will give IRS a higher level of assurance
that its plans will help reduce the impact of a potential Year
2000-related system failure. In light of IRS' actions, we are not
making any recommendations at this time. Business continuity and
contingency plans should describe the steps an Background
organization would take to ensure the continuity of its core
business processes in the event of a system failure. In a June
1998 report, we made a series of recommendations5 aimed at
broadening IRS' Year 2000 contingency planning approach to
encompass a core business system focus as called for in our
business continuity and contingency plan guide.6 IRS agreed with
our recommendations and in July 1998 began to take action to
develop a more comprehensive, business-based approach to
contingency planning. IRS' Century Date Change Project Office7
hired a contractor to provide business continuity and contingency
planning expertise and training and assist the business areas in
developing and testing their plans. IRS established a working
group comprised of representatives from IRS' business areas to
identify IRS' core processes and associated subprocesses. For each
core business process, IRS established a working group to (1)
identify possible failure scenarios for subprocesses; (2)
determine the business impact of these failures; (3) determine
which failure scenarios should be addressed by business
contingency plans, based on a scoring system that included
business impact and risk; and (4) develop plans for those
scenarios. IRS determined that business continuity 5Specifically,
we recommended that IRS (1) solicit the input of business
functional area officials to identify IRS' core business processes
and prioritize those processes that must continue in the event of
Year 2000-induced failures, (2) map IRS' mission-critical systems
to those core business processes, (3) determine the impact of
information system failures on each core business process, (4)
assess any existing business continuity and contingency plans that
may have been developed for non-Year 2000 reasons to determine
whether they are applicable to Year 2000-induced failures, and (5)
develop and test contingency plans for core business processes if
existing plans are not appropriate. See IRS' Year 2000 Efforts:
Business Continuity Planning Needed for Potential Year 2000
Failures (GAO/GGD-98-138, June 15, 1998). 6Year 2000 Computing
Crisis: Business Continuity and Contingency Planning (GAO/AIMD-
10.1.19, Aug. 1998). 7The Century Date Change Project Office
within IRS' Information Systems organization is responsible for
coordinating IRS' Year 2000-related activities. Page 3
GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
and contingency plans should be prepared for all of the failure
scenarios for its five submission processing subprocesses (receive
paper submissions; receive electronic submissions; control and
track tax and submissions; process, correct, and forward payment
data; and process, correct, and forward tax information return
data), several of which involve issuing refunds. In November 1998,
IRS' Century Date Change Project Office issued its business
continuity and contingency plan guidance8 that describes the (1)
methodology to be used to develop business contingency plans (the
term IRS uses for plans prepared in accordance with this guidance)
and (2) types of information that should be included in the plans.
IRS' guidance states that IRS used our guide to help develop its
methodology for preparing business contingency plans. IRS' Chief
Operations Officer designated a Year 2000 business executive to
help coordinate the efforts of the working groups and oversee the
development of the plans. According to IRS officials, the groups
used IRS' guidance to develop the plans. These groups also
received technical guidance from the contractor. Each business
contingency plan was assigned to an executive-level official who
was responsible for approving the plan. In the event of a Year
2000 system-related failure, this executive is also to decide if
and when the trigger conditions have been met for implementing the
business contingency plan. The plans were to be tested to identify
any needed changes. The two plans that we reviewed were tested on
July 8 and 9, 1999, respectively.9 The refund plan and the paper
submissions plan were inconsistent and Plans Were
incomplete in two key areas of IRS' guidance. These areas were
Inconsistent and performance goals and mitigating actions.
These weaknesses raise questions about whether these two plans
provide sufficient assurance that Incomplete IRS has
taken all the necessary steps to reduce the impact of a potential
Year 2000 failure. IRS officials agreed to make changes to these
two plans to improve their consistency and completeness in these
areas. In addition, IRS officials said they have taken steps to
help ensure the consistency and completeness of other business
contingency plans and make changes to those plans if necessary.
8Internal Revenue Service Century Date Change Business Continuity
and Contingency Plan, Nov. 24, 1998. 9At the time we were
finalizing this letter, the reports showing the testing results
were not completed. Page 4
GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
IRS does not have viable, alternative backup systems for the
various Refund Plan information systems used for processing tax
returns.10 Further, IRS' refund plan acknowledges that in the
event that one or more of these systems fail, IRS may experience
"a major work stoppage," depending on how long the failure
continues. Given the lack of automated alternatives, the refund
plan calls for (1) notifying the public and (2) reverting to
manual issuance of refunds-a process that IRS currently uses for
certain types of taxpayers (e.g., those receiving a refund of more
than $1 million or those with a specific hardship). Although this
business contingency plan includes a specific performance goal as
required by IRS' guidance, that goal is inconsistent with the
recommended contingency actions. Specifically, the plan's
performance goal calls for issuing 20 percent of the normal refund
volume, using a $5,000 minimum as the threshold for manual
issuance. However, the plan's contingency procedures call for
instituting a manual operation that would give priority to
processing refunds for 1040EZ returns. These returns are filed by
taxpayers with taxable incomes of less than $50,000. Consequently,
these returns may not generate a significant number of $5,000
refunds. The inconsistency between the performance goal and the
business contingency plan procedures raises questions about the
goal that IRS is trying to achieve with its contingency plan. For
example, if IRS is trying to reduce the potential for incurring
increased interest costs on late refunds, high-dollar refunds
should be targeted regardless of the type of return.11 However, if
IRS is trying to expedite tax refunds for those taxpayers who may
have the greatest financial need, a performance goal that focuses
on issuing refunds of $5,000 or more may not be appropriate. In
our June 1999 meeting with IRS officials, we pointed out this
inconsistency, and they agreed that they needed to change the
plan's performance goal. In our meeting, the executive that was
responsible for this plan said the plan's performance goal should
focus on issuing refunds to certain "hardship" taxpayers.
According to IRS, hardship taxpayers 10This plan addresses the
business processes that would be implemented if one or more of the
following systems fail: (1) Generalized Unpostable Framework, (2)
Service Center Control File, (3) Generalized Mainline Framework,
(4) Error Resolution System, and (5) Multiple Virtual Storage
Enterprise System Architecture (MVSEA). This plan does not address
business processes that fall under the purview of the Department
of the Treasury's Financial Management Service, which is
responsible for, among other things, receiving and processing
requests for issuance of IRS refund checks. 11As stated in section
6611(e) of the Internal Revenue Code, IRS has until 45 days from
the receipt of the tax return or the due date of the return,
whichever is later, to issue a refund. If IRS fails to meet that
time frame, the taxpayer is entitled to interest on his or her
refund amount. Page 5
GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
would be those that filed a return with (1) a Form 911,
Application for Taxpayer Assistance Order; (2) an earned income
tax credit, which is a refundable tax credit available to low-
income, working taxpayers; or (3) an adjusted gross income within
a certain dollar range that is to be determined if a Year 2000
failure actually occurs. With respect to mitigating actions, this
plan did not include dates for completing them before a potential
Year 2000 failure. Examples of the plan's mitigating actions
include (1) preparing a letter to the Department of the Treasury's
Financial Management Service outlining the process for
transferring refund documents and files, (2) planning for one
additional week of training on the manual refund issuance process,
(3) identifying additional secure storage space in each service
center, and (4) coordinating press release information with IRS'
Office of Public Affairs. Moreover, the plan did not specify which
individuals were to be responsible for completing the mitigating
actions. Although IRS' guidance does not require that the plan
identify specific individuals, without identifying responsible
individuals and dates for completing the mitigating actions, IRS
has little assurance that these actions will be completed before a
potential Year 2000 failure. In our June 1999 meeting, the
executive responsible for this plan acknowledged this omission and
agreed that the mitigating actions should identify responsible
individuals and completion dates. IRS receives paper submissions,
including tax returns, at each service Paper Submissions Plan
center loading dock. From the loading dock, the returns are taken
to the mailroom for sorting. IRS' Service Center Automated Mail
Processing System (SCAMPS) is a new automated system that IRS uses
to sort the mail. SCAMPS is to (1) open the envelopes to expedite
the extraction process, in which employees remove the tax return
information from the envelopes; (2) identify those tax returns
with checks; (3) read the bar- coded tax return envelopes and sort
them into one of 40 different categories; and (4) sort outgoing
mail. The paper submissions plan focuses on the contingency
actions to be implemented in the event that SCAMPS experiences a
Year 2000 system failure. Although IRS' guidance calls for plans
to contain a performance goal, the paper submissions plan did not
include one. According to the plan, "specific performance measures
for manual mail handling operations are not yet available."
However, without a performance goal, it is unclear how IRS
determined that it would be sufficient to "use available service
center personnel to handle incoming mail" as specified in the
plan. Page 6 GAO/GGD-99-176 IRS' Year 2000
Business Contingency Plans B-283400 While we recognize that IRS is
developing new performance measures that may not yet be available
for this business function, in our June 1999 meeting with IRS
officials, we identified information that could be used to develop
a performance goal for the plan. For example, the SCAMPS
processing rate could be used as a guide for developing an
acceptable (albeit reduced) level of service for a manual mail
sorting process. IRS could also use its productivity data on
employees that manually extract tax return information from
envelopes as a basis for developing a performance goal. The IRS
executive that was responsible for this plan agreed that a goal
should be included and that these two data sources could be used
to develop that goal. The plan's mitigating actions were also
incomplete. Like the refund plan, this plan did not include the
dates and the responsible individuals for completing the plan's
two mitigating actions. Also, we told IRS officials that we had
questions about the viability of one of the plan's mitigating
actions. That action calls for reverting back to a mail sorting
system that is currently not Year 2000 compliant. Even if IRS
could develop a workaround solution to make the older mail sorting
system Year 2000 compliant, IRS officials said that they had
planned to remove the equipment for the older system by the 2000
filing season. IRS officials told us that as a result of testing
this plan, this mitigating action would be deleted in the revised
plan. The executive responsible for this plan also agreed to add
responsible individuals and the dates for completing the other
mitigating action, which pertains to sorting outgoing mail. In
addition to agreeing to make changes to the two plans, IRS
officials said Actions Are Under Way to that actions are under
way to help ensure that other business contingency Help Ensure
Consistency plans are consistent and complete. According to
officials in IRS' Business and Completeness of All Systems
Requirements Office (BSRO),12 a staff member has been Plans
designated to review all of the business contingency plans for
consistency and completeness and for crosscutting issues among the
plans. Heretofore, BSRO did not view this as its function, in part
because according to BSRO officials, it had a limited number of
staff. IRS also has issued a work request for one of its Year 2000
contractors to develop a database that BSRO staff could use to
track the implementation of key elements of the business
contingency plan (e.g., triggers, mitigating actions, contingency
team actions). According to IRS, information from the business
contingency plans is to be added to the database by late September
1999, and reports are to be generated shortly thereafter. 12BSRO,
among other things, provides support to business functions for
contingency planning and helps ensure Year 2000 compliance for the
Chief Operations Officer organizations. Page 7
GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
If properly implemented in a timely fashion, these actions should
provide IRS with a higher level of assurance that its business
contingency plans will help reduce the impact in the event of a
Year 2000related system failure. Accordingly, we are not making
any recommendations at this time. To achieve our objective of
evaluating the consistency and completeness Scope and of
two of IRS' Year 2000 business contingency plans according to IRS'
Methodology guidance, we * reviewed the following business
continuity and contingency plan guidance: (1) Year 2000 Computing
Crisis: Business Continuity and Contingency Planning (GAO/AIMD-
10.1.19, Aug. 1998); (2) Internal Revenue Service Century Date
Change Contingency Management Plan, (Version 5.0, Mar. 1, 1999);
and (3) Internal Revenue Service Century Date Change Business
Continuity and Contingency Plan, (Version 1.0, Nov. 24, 1998); *
interviewed officials from the Century Date Change Project Office;
* interviewed members of the submission processing contingency
plan working group, the executive that was responsible for the two
plans we reviewed, the Business Year 2000 Executive, and other
BSRO staff; * toured the Atlanta Service Center to learn more
about how tax returns are processed through IRS' information
systems; and * reviewed 6 of the 10 sections of the two business
contingency plans to determine whether they were consistent with
IRS' guidance. We did not analyze four sections of the plans
(training and testing, post- event wrap-up, contingency actions
log sheet, and information recovery) for several reasons. In lieu
of including the testing procedures in the plan, IRS developed
separate test plans for each contingency plan. To provide timely
feedback to IRS so that they could begin corrective actions
promptly, we focused our efforts on the business contingency plans
themselves rather than the test plans. We did not analyze the
post-event wrap-up information or the contingency actions log
sheet because these sections are to be completed after the
business contingency plan has been implemented. Both plans
included little information about information recovery (i.e.,
regaining or retrieving data that may be lost or damaged as a
result of a system failure).13 13The refund plan stated that (1)
lost data could be recovered from original documents given that
returns are stored up to 6 months at the service centers, and (2)
recovery of damaged data was under the purview of IRS' Information
Systems contingency plans. We did not review these plans. The
paper submissions plan indicated that developing manual procedures
for recovering the types of management information data generated
by SCAMPS was not possible. Page 8
GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
We also did not review any existing business resumption plans that
IRS developed for other than Year 2000-induced failures, and we
did not examine the relationship between individual Year 2000
business contingency plans and IRS' "End Game" activities,14 which
IRS is currently developing. We conducted our review from May 1999
to July 1999 in accordance with generally accepted government
auditing standards. On August 27, 1999, we obtained written
comments on a draft of this Agency Comments and report from the
Commissioner of Internal Revenue. (See app. I for a copy Our
Evaluation of IRS' letter.) IRS said that it
generally agreed with the issues raised in our report and is
taking the necessary steps to correct them. IRS also amplified on
its business contingency plan testing process and clarified some
facts and provided updated information, which we included in the
report where appropriate. IRS said that it had envisioned that the
business contingency plans were "living documents" that would be
revised over time to reflect changes in technology, business
processes, and legislation. Furthermore, IRS said that the plans
were to be tested by subject matter experts, including field
staff, to ensure their viability, which would result in
modifications to the plans. We agree that the plans were to be
living documents and designed our methodology accordingly.
Recognizing that the plans were subject to change based on the
results of business contingency plan testing (as stated on p. 1 of
our draft report), we met with IRS in June 1999 to discuss our
initial findings. We scheduled this meeting, in part, so that IRS
would have the benefit of our feedback while the plans were still
subject to change, and possibly before they were to be tested. IRS
said that as a result of our findings on the weaknesses in the
plans and the results of testing two plans, it has begun work to
address our concerns. We are sending copies of this letter to
Representative Amo Houghton, Chairman, and Representative William
J. Coyne, Ranking Minority Member, Subcommittee on Oversight,
House Committee on Ways and Means; Senator Robert F. Bennett,
Chairman, and Senator Christopher J. Dodd, Vice-Chairman, Senate
Special Committee on the Year 2000 Technology Problem; and
Representative Stephen Horn, Chairman, and 14IRS has a three-part
"End Game" strategy that involves (1) preparing back-up data
during the New Year's weekend; (2) conducting validation checks of
its systems, telecommunications, and facilities during the New
Year's weekend to identify any issues before the first day of
business in 2000; and (3) proactively monitoring key events to
mitigate Year 2000-related problems that may interrupt national
tax processing. IRS' monitoring efforts are scheduled to continue
through March 2000. Page 9
GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
Representative Jim Turner, Ranking Minority Member, Subcommittee
on Government Management, Information and Technology, House
Committee on Government Reform. We are also sending copies to the
Honorable Lawrence H. Summers, Secretary of the Treasury, and the
Honorable Jacob J. Lew, Director of the Office of Management and
Budget. Copies will be made available to others on request. If you
have any questions about the information contained in this report,
please contact me or Sherrie Russ at (202) 512-9110. Key
contributors to this assignment were Jackie Nowicki, Joanna
Stamatiades, and Linda Standau. Sincerely yours, James R. White
Director, Tax Policy and Administration Issues Page 10
GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans Page 11
GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans Appendix
I Comments From the Internal Revenue Service Page 12 GAO/GGD-
99-176 IRS' Year 2000 Business Contingency Plans Appendix I
Comments From the Internal Revenue Service Page 13
GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans Appendix
I Comments From the Internal Revenue Service Page 14
GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans Page 15
GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans Page 16
GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans Ordering
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