IRS RESPONSE TO RECOMMENDATION: The IRS stays current with research best practices and considers all survey methods (phone, mail, internet, in person) when determining the best survey administration method based on the research question.  For example, the 2017 TES is scheduled to be administered utilizing the AmeriSpeak Panel. The AmeriSpeak Panel is operated by NORC at the University of Chicago. AmeriSpeak is a probability-based panel designed to be representative of the U.S. household population.  To address non-internet and internet adverse households, AmeriSpeak gives respondents a choice regarding their preferred mode of survey participation between online and phone surveys.  Other IRS surveys are administered by phone, mail, and in person depending on the best option for the research question to be answered or the population to be surveyed.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate welcomes the new feature of the Taxpayer Experience Survey that allows taxpayers to take the survey by phone. This may reduce some bias present in online panels generally. The IRS asserts that it chooses the best survey method depending on the research question to be answered or the population to be surveyed. Either way, the IRS is concerned about maximizing the number of taxpayers it reaches, not necessarily in reaching vulnerable taxpayers. Moreover, the IRS relies more heavily on data from studies conducted online, such as the conjoint study, in which the IRS decides which (non-exhaustive) options respondents may choose from. The IRS has not at all addressed the Pew finding that online panels are biased against African Americans and Hispanics. The fact remains that surveys conducted online cannot take into account the needs and preferences of those who do not have internet access or who are unwilling to take an online survey. The IRS should seek to serve all taxpayers, not just the easy to reach.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

DUE DATE FOR ACTION (if left open): N/A

IRS RESPONSE TO RECOMMENDATION: ​All three of the TAC Expectation Survey administrations have included taxpayers who do not receive service from the TAC.  During survey administration, every person who comes to the TAC seeking service is invited to participate in the survey.  Taxpayers who come to the TAC but do not receive service are requested to complete the applicable portions of the survey.

Additionally, the IRS will be implementing a customer satisfaction survey on the appointment line and an internet or phone follow up survey to better understand the customer experience. These surveys will include those who visited the TAC as well as those who called to make an appointment, whether they received service or not at the TAC.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The IRS response evidently uses the term “coming to the TAC” to mean arriving at the door of the TAC, which is where survey administrators were positioned, according to the IRS. Thus, taxpayers who stood in line waiting to arrive at the front door of the TAC were not surveyed. It is appropriate for the IRS to survey taxpayers who call to make an appointment, as well as though who visited TACs, whether or not they receive service at the TACs. However, because the contemplated survey will not be administered in person, the IRS will not be able to survey taxpayers who visit a TAC but leave without receiving service, because the IRS will not have contact information for those taxpayers.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

DUE DATE FOR ACTION (if left open): N/A

IRS RESPONSE TO RECOMMENDATION: 
Where applicable and methodically sound, the IRS includes “other” options on their survey questions.  For example, the TES has several questions with the other “please specify” as a response category including questions about tasks, what information source they used, service expectations and preferred source of general tax information.

Conjoint surveys are designed to gather qualified preference. Qualified preference is a respondent’s preference based on information the survey instrument provides to the respondent and is used to understand how respondents make choices and predict decisions for them based on that knowledge. Qualified preference is typically a better predictor of choice behavior when introducing new service options or including service options with low awareness. Unqualified preference, as measured in the TAS Service Priorities Survey, is a respondent’s stated preference without knowledge of how the respondent came to that decision and typically includes an “other” category where respondents can provide an alternative preference. Conjoint surveys do not include an “other” option. 

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate is pleased that the Taxpayer Experience Survey allows taxpayers to select a “please specify” option. Conjoint studies also provide options, but as the IRS notes,  the options themselves are limited to those the IRS provides, and assume the respondent is already familiar with those options. Moreover, the survey may ask taxpayers what their preferred service delivery method would be with respect to services they may not need or want in the first place. The most recent conjoint survey, for example, explores how taxpayers would like to make a payment, obtain a copy of a tax transcript, obtain tax account information, or have their identity authenticated for tax-related purposes. Nothing in the survey signals for the IRS that taxpayers are not actually familiar with the given options or that they may have very different preferences when, for example, they need to challenge the IRS’s proposed adjustment to their return or engage in other emotionally charged transactions. Additionally, taxpayers may have a much more intense preference for a given service delivery channel when they attempt to address complex, difficult, or time sensitive situations. As long as the IRS designs surveys that are not taxpayer-centric, but require taxpayers to choose among pre-set options the IRS has identified, the exclusion of an “other” category may lead the IRS to overlook important information about taxpayers’ needs and preferences.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

DUE DATE FOR ACTION (if left open): N/A

IRS RESPONSE TO RECOMMENDATION: The IRS has and does conduct focus groups, pre-testing, or cognitive testing of its surveys when resources and the budget allows.  For example, the TES regularly undergoes cognitive testing with real taxpayers to ensure the quality of the survey.  In addition, where resources and funding has allowed, focus groups have been part of the conjoint survey design process.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate is pleased that the IRS recognizes the need to vet surveys before they are administered. However, pre-testing and focus groups should be an integral part of every taxpayer survey rather than steps taken “when resources and the budget allow.” More importantly, the purpose of vetting should be to ensure not only that surveys are understandable to taxpayers, but that they capture taxpayer preferences the survey instrument would otherwise overlook. The extent to which the IRS does not vet a survey, especially a conjoint survey, should be taken into account in determining how much it should rely on the survey results.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Closed

DUE DATE FOR ACTION (if left open): N/A

IRS RESPONSE TO RECOMMENDATION: The IRS aims to deliver top quality service to America’s taxpayers and we continually look for new cost-effective ways to enhance the taxpayer experience.  In doing so, the IRS utilizes many factors to make an extensive assessment that includes taxpayer needs, preferences and behaviors as well as business considerations such as the budget.

CORRECTIVE ACTION: N/A

TAS RESPONSE: As the IRS notes, its commitment to deliver top quality service is qualified by the need to do so in a cost-effective way. The attention to cost containment has led it to emphasize digital service delivery with insufficient recognition that not all taxpayers prefer to interact with the IRS digitally for every service they need. While “going digital” may cost less than other service delivery channels, the focus on what best serves the IRS may impede taxpayers from engaging with it, with the attendant risk of future noncompliance.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Closed

DUE DATE FOR ACTION (if left open): N/A

IRS RESPONSE TO RECOMMENDATION: The IRS enthusiastically accepts the responsibility to deal with all 150 million taxpayers in whatever way they want to interact with us. We recognize there will always be taxpayers who do not have access to the digital economy, or who simply prefer not to interact with the IRS online. We remain committed to providing the services these taxpayers need. In fact, getting more people to use our online offerings will help us provide better and faster service to those who still want or need to call us or visit us in person.

CORRECTIVE ACTION: N/A

TAS RESPONSE: By stating “there will always be taxpayers” who do not have online access or prefer not to interact with the IRS online, the IRS attempts to minimize the population that is actually affected by its decision to force them to use online channels. Implicit in the IRS’s response is the admission that the IRS may attempt to force taxpayers to use online channels — “getting” them online. The refusal to adopt this recommendation is inconsistent with the IRS’s position that it accepts responsibility to deal with taxpayers “in whatever way they want to interact with us.”

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

DUE DATE FOR ACTION (if left open): N/A