IRS RESPONSE TO RECOMMENDATION: NTA Recommendation Not Adopted as Written, but IRS Actions Taken to Address Issues Raised by NTA.  The IRS recognizes the importance of delivering a high level of service (LOS) to PPS customers. Congress approved $290 million in additional funding for the IRS for FY 2016, to improve service to taxpayers. We used approximately $178.4 million of this additional funding to add about 1,000 extra temporary employees to help improve service on our toll-free telephone lines, including PPS.  Improving the level of taxpayer service on the phones was a priority this filing season. Our levels of service on all telephone lines are a major improvement over 2015 levels.

This filing season, we delivered an 83% LOS on PPS. Additional resources were allocated during the 2016 filing season to improve PPS services. We issued only 20,500 disconnects, compared to a 45% LOS for the same time last year with 147,000 disconnects. PPS is consistently planned at a higher level of service than the overall LOS each fiscal year.  Level of service for future fiscal years will be dependent on budget and funding availability.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate is pleased with the improvement in the LOS provided by the IRS during the 2016 filing season.  The IRS needs to continue to fund the PPS at adequate levels to ensure high levels of service for practitioners who rely on the service to address account-related issues on behalf of their clients.  The National Taxpayer Advocate looks forward to seeing this trend of improvement continue throughout the remainder of the fiscal year.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Closed

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

IRS RESPONSE TO RECOMMENDATION: ​​The IRS established the PPS product line to provide a dedicated phone line where practitioners can obtain account-related assistance for their clients. Since the inception of this service, the scope has been account-related services, as the IRS is the only source for that information. By using this service, practitioners can resolve their client’s issues over the telephone with the assistor. Practitioners have access to tax law resources, as a part of their profession, and IRS.gov provides extensive tax law information for individuals, businesses, and practitioners.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate is disappointed the IRS will not answer tax law questions during the calls from practitioners on the PPS.  As stated in the MSP, the IRS is placing more and more of the burden on taxpayers and practitioners for correctly resolving tax issues.  In order to accurately comply with the tax obligations placed upon them, taxpayers and their practitioners should be able to receive answers to their tax law questions in addition to their account-related issues.  The National Taxpayer Advocate will continue to monitor this recommendation and will continue to suggest that practitioners be able to receive answers to their questions within the scope of the PPS’s services.

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: Guidelines in IRM 21.3.10.2.1(2) allow PPS telephone assistors to service up to five clients per call, provided the practitioner has the appropriate authorization on file or is able to fax the authorization information during the time of the call.

CORRECTIVE ACTION: N/A

TAS RESPONSE: It is true that IRM 21.3.10.2.1(2) specifies that PPS telephone assistors are able to service up to five clients per call but the National Taxpayer Advocate has heard from many practitioners that in practice this does not occur.  The National Taxpayer Advocate recommends that additional training and reminders be provided to the PPS telephone assistors to ensure that the IRM is being properly followed and practitioners who call are able to service up to five clients per call, if needed.

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 participates in multiple practitioner forums throughout the year and addresses practitioner questions and concerns on an ongoing basis through the Issue Management Resolution System and Stakeholder Liaison Office. We also conduct a Customer Satisfaction Survey for PPS. When feasible, the IRS will continue to consult and survey the practitioner community to find out their needs and preferences before making changes to the PPS product line.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate disagrees that this recommendation has been implemented by the IRS.  Hosting infrequent meetings once or twice a year at various functions does not equal a systematic survey of the needs and preferences of practitioners who utilize the PPS to resolve account-related issues.  Dialog between practitioners and the IRS is essential as the IRS prepares for the future state and without a statistically representative survey of tax practitioners to determine their needs, the IRS will weaken the value of the PPS.  The National Taxpayer Advocate encourages the IRS to work with TAS to develop the survey tools to accurately determine what the needs and preferences of the practitioner communities are regarding the PPS.

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 is committed to meeting practitioner service needs. We currently have no plans to eliminate service on the PPS toll-free line as online systems are developed. However, we anticipate a natural reduction in demand as online services become available. To support the agency’s move to digital services, Wage & Investment is working with partners and stakeholders to develop the Bridge to the Future State which will assist in determining the future service initiatives for taxpayers and practitioners. Providing digital services to practitioners is a continuous long term effort which is driven by analysis, requires input from internal and external stakeholders, and is dependent on funding availability.

Update: PPS remains an active and critical piece of IRS Service Delivery.  We recently completed an 18 month period during which PPS LOS exceeded 80% and our average speed of answer (wait time) was consistently less than 10 minutes. The Tax Pro account is still in very early planning stages, this will be a complicated multiyear process. A conceptual design of a Tax Pro Account was demonstrated at the 2017 Tax Forum  and feedback was solicited from tax pros that participated in the demo to be used in the development of future on line services for tax professionals.

Update: The IRS continues to provide PPS service and has no plans to eliminate it.

CORRECTIVE ACTION: The IRS is committed to meeting practitioner service needs. We currently have no plans to eliminate service on the PPS toll-free line as online systems are developed. However, we anticipate a natural reduction in demand as online services become available. To support the agency’s move to digital services, Wage & Investment is working with partners and stakeholders to develop the Bridge to the Future State which will assist in determining the future service initiatives for taxpayers and practitioners. Providing digital services to practitioners is a continuous long term effort which is driven by analysis, requires input from internal and external stakeholders, and is dependent on funding availability.

Update: PPS remains an active and critical piece of IRS Service Delivery.  We recently completed an 18 month period during which PPS LOS exceeded 80% and our average speed of answer (wait time) was consistently less than 10 minutes. The Tax Pro account is still in very early planning stages, this will be a complicated multiyear process. A conceptual design of a Tax Pro Account was demonstrated at the 2017 Tax Forum  and feedback was solicited from tax pros that participated in the demo to be used in the development of future on line services for tax professionals.

TAS RESPONSE: The National Taxpayer Advocate encourages the IRS to continue to conduct research on taxpayer preferences for various service channels, by type of transaction. However, it is the National Taxpayer Advocate’s belief that the PPS will continue to be a much needed resource for practitioners to consult for resolution of their clients’ account-related issues and thus should not be eliminated or reduced in functionality. Further, the National Taxpayer Advocate encourages the IRS to work with TAS in developing these studies and evaluating the results.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Closed

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