IRS RESPONSE TO RECOMMENDATION: On July 13, 2015, the IRS will complete centralization of identity theft casework and policy in W&I Accounts Management (AM), providing AM leadership with full end-to-end responsibility for victim assistance, including identity theft policy in AM headquarters and a campus component comprised of  approximately 1,700 employees.  The next phase of our efforts will be an effort to re-engineer/improve the identity theft processes to begin in early October 2015.  We appreciate the suggestions in the TAS report, and will use them as a framework to begin analyzing our processes and will work in collaboration with TAS to assess our current global review process to identify process improvement opportunities.  Currently the IRS performs a global account review upon case receipt.  All employees working identity theft cases rely on IRM 10.5.3.1.2.3 guidance which directs employees to perform an initial case review to identify all taxpayer and account issues.  Employees assigned an identity theft case are directed to treat the identity theft victim’s account as a whole and expected to resolve all account issues prior to case closure.  There are taxpayer situations involving multiple account issues across functional lines requiring access to unique systems and specialized training.  The IRS ensures oversight of these cases through monitoring efforts by the Identity Protection Specialized Unit (IPSU).  The IPSU office performs a check to ensure that all taxpayer issues have been resolved prior to case closure.  We look forward to identifying and exploring efforts to improve our global report processes in our upcoming re-engineering efforts.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate is pleased the IRS is in the process of reengineering its IDT victim assistance procedures.  Improving IDT victim assistance procedures has been a priority for the National Taxpayer Advocate for many years, and we now have empirical evidence to support our recommendations.  We appreciate the commitment by the IRS to collaborate with TAS and use our research as a framework of analysis.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Closed

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

IRS RESPONSE TO RECOMMENDATION: As the IRS embarks on a re-engineering effort to create process improvements in the identity theft arena, we will analyze identity theft case resolution from beginning to end to improve the taxpayer experience.  We will assess feasibility of the recommendations in the TAS report, will use them as a framework to analyze our process and will work in collaboration with TAS to assess procedures in the Identity Protection Specialized Unit (IPSU).  Currently, IPSU provides taxpayers with a single point of contact at the IRS via a specialized toll-free telephone line.  This approach has allowed taxpayers to reach one of many trained employees and does not depend on the availability of a single IRS employee who may be away or assisting another taxpayer.  The IPSU customer service representatives input electronic case notes that provide the most up-to-date actions taken or advice provided to taxpayers.  The notes can then be utilized by any IRS employee who interacts with the taxpayer.  Guidance for IPSU employees is found in IRM 10.5.3.2.3, Defining Multiple Case Issues, and IRM 21.9.2.4.3, Case Monitoring.  There are taxpayer situations involving multiple account issues across functional lines requiring access to unique systems and specialized training.  The IRS ensures oversight of these cases through monitoring efforts by IPSU who perform a check to ensure that all taxpayer issues have been resolved prior to case closure.  We are looking forward to improving the taxpayer experience through our collaborative re-engineering efforts.

CORRECTIVE ACTION: N/A

TAS RESPONSE: Our research study empirically demonstrated that victims of such a traumatic and invasive crime would be best served by having the IRS assign a sole IRS contact within the IRS, regardless of how many related issues stem from the IDT.  Simply tasking the IPSU with “monitoring” the victim’s account has proven to be ineffective – because the victim must still deal with multiple assistors within the IPSU, leading to additional delay and frustration and because the IPSU does not have the authority to require other IDT functions handling the case to meet timeliness goals.  As our 2014 case study has shown, a significant number of IDT cases had extended periods of inactivity, particularly when multiple assistors handled an IDT case.  For the IRS to continue to equate a specialized phone line with a “single employee dedicated to the case” is akin to equating the NTA Toll Free line with TAS case advocates.  They are radically different; one screens calls and the other stays and works with the taxpayer from start to finish, until all related issues are resolved.  We will continue to push for the IRS to provide a sole contact person for IDT victims who have more than one issue or year to resolve, or must deal with more than one IRS unit.

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 Compliance identity theft caseworkers were recently centralized with Accounts Management employees in the Identity Theft Victim Assistance (IDTVA) organization.  The centralization offers an opportunity to evaluate the way Compliance cases are counted.  Before the centralization, the “Compliance bucket” ensured identity theft cases involving only compliance issues were worked by one Compliance function based upon the earliest IRS received date as directed by IRM 4.19.24.1.2.2.  This approach was used to reduce hand-offs between functions, improve case processing through streamlined, consistent procedures, and improve  communication.  Now that we have completed the centralization of Compliance employees in IDTVA, we will include the reporting of the Compliance casework in our re-engineering effort beginning in October 2015 and we will consider the recommendations in the TAS report in collaboration with TAS employees.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate is pleased that the IRS will consider this recommendation as part of its IDT re-engineering beginning in October 2015.  TAS looks forward to working in collaboration with W&I in this effort.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Closed

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

IRS RESPONSE TO RECOMMENDATION: Your suggestions will be assessed in re-engineering efforts slated to begin in October 2015.  During this process the organization will look for improved means to track the resolution of an identity theft case from beginning to end.  While current identity theft case cycle time reporting is consistent with the manner in which all case cycle time is calculated, from the received date of the case to the date of case resolution (the date the final corrective actions are input to the taxpayer’s account), we are committed to exploring feasible options that might improve taxpayer perceptions of the time it takes to receive resolution and the overall taxpayer experience.  We look forward to collaborating with TAS on our re-engineering effort

CORRECTIVE ACTION: N/A

TAS RESPONSE: It is imperative the IRS accurately determine its IDT case cycle time.  The IRS should calculate cycle time from the taxpayers’ perspective – i.e., from the date it receives the case until the date of case resolution, when it has taken actions to address all related issues.  For example, even if IRS has taken an action to release a taxpayer’s refund, it should keep the case open until it actually issues the refund to the taxpayer.  If the IRS closes a case prematurely, it distorts IDT cycle time and underrepresents the harm suffered by IDT victims.  Notwithstanding W&I’s quality review results, in our 2014 study, we found the IRS closed 22 percent of the cases before it had taken actions required to resolve all related issues.

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: Re-engineering efforts to begin in October 2015 will include analyzing suggestions from TAS to ensure identity theft caseworkers complete all account issues before the closing the case to improve the taxpayer experience.  Currently, while a case is still open,  Identity Protection Specialized Unit  (IPSU) employees conduct a monthly global review using an Integrated Automation Technologies (IAT) tool to review taxpayer accounts if an unresolved issue is found, the case is referred to the responsible function if IPSU does not have the authority, tools, or training to resolve the issue.  Prior to case closure, IPSU performs a final global account review to ensure that all taxpayer issues were resolved by the responsible functions.  This is additional layer of review was designed to help ensure the taxpayer has been made whole, and is defined in  IRM 21.9.2.6.  In addition, IRM 10.5.3.8 directs the employee to review both prior and subsequent tax years ensuring all issues are addressed including the release of taxpayer refunds.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The IRS states its current procedures call for a global account review upon case receipt and again prior to case closure.  However, our 2014 case study showed the global account review was ineffective, as IRS closed more than one-fifth of the IDT cases in our study before it had resolved all related issues.  We suggest IRS revamp the global account review procedures and provide employees doing the global review with better training (or both).  We expect the IRS will look at this as part of its IDT reengineering efforts.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Closed

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