IRS RESPONSE TO RECOMMENDATION: IRS does not agree to implement the TAS recommendation.

The Inflation Reduction Act (IRA) provided $79.4 billion to the IRS for a 10-year period. This funding is intended for critically needed transformations at the IRS, including taxpayer service improvements directed to IRS.gov, online accounts and other digital and technology transformations. Since passage of the IRA, the IRS has worked quickly to build out a Strategic Operating Plan and stand up a Transformation & Strategy Office.

The IRS notionally agrees that a centralized hub is one way, of many, that the IRS could approach increasing accessibility and usability of our authenticated and unauthenticated taxpayer-facing platforms and that moving away from siloed platforms based on IRS operating divisions is consistent with taxpayer expectations. However, at this stage of IRA implementation it would be premature to commit to any one framework for improving access and usability on IRS.gov in favor of any of the other frameworks available. As part of IRA implementation, the IRS will conduct robust user experience research, leveraging both our own behavioral data and best practices from industry to ensure that IRS.gov and the online applications available to taxpayers are user friendly while accommodating taxpayers who desire both authenticated and unauthenticated online services.

CORRECTIVE ACTION: N/A

TAS RESPONSE: We support the IRS’s plans to conduct robust user experience research and apply internal behavioral data and best practices from industry to improve online services. However, robust research may not be needed to determine that taxpayers would prefer an option of having IRS online tools available in a central hub with one-click access. The IRS concedes that our recommendation would be consistent with taxpayer expectations but does not agree to implement the recommendation. We request the IRS reconsider this recommendation as it continues to implement the IRA.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Closed

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

IRS RESPONSE TO RECOMMENDATION: ​IRS agrees to implement the TAS recommendation in part.

The breadth of IRS employees that are “taxpayer-facing” is tremendous and includes a diversity of roles that includes Customer Service Representatives, Internal Revenue Agents, Taxpayer Assistance Center employees, Special Agents in the Criminal Investigations Division, Appeals Officers and other Independent Office of Appeals staff, and attorneys within the Office of Chief Counsel. Not all taxpayer-facing employees work in positions where it is appropriate to educate taxpayers on Online Account and other digital communication tools.

Since 2019, IRS has promoted the awareness of online account with employees via Digital Day, which is a monthly, virtual product demo and Q&A event. Digital Day has proven to be successful, with employee polling indicating that significantly more employees are aware of online account in 2022 than in 2019. IRS plans to continue monthly product demo events promoting online account and the Deputy Commissioner of Services & Enforcement (DCSE) will direct each DCSE business unit to evaluate which position types within their unit should be directed to attend a Digital Day event on a mandatory basis.

The IRS will consider the employee’s view of taxpayer account as part of our overall process of evaluating and implementing the forthcoming IRS Inflation Reduction Act Strategic Operating plan as more fully discussed in the IRS’ responses to MSPs #5-5 and #6-2.

CORRECTIVE ACTION: The IRS will consider the employee’s view of taxpayer account as part of our overall process of evaluating and implementing the forthcoming IRS Inflation Reduction Act Strategic Operating plan as more fully discussed in the IRS’ responses to MSPs #5-5 and #6-2.

Update: On September 19, 2023, the appropriate function within each Business Operating Division were alerted about the NTA’s ARC Recommendation and directing them to evaluate which position types should be required to attend a Digital Day event. They were also encouraged to publicize the Digital Day educational opportunity, even to employees that would not be required to attend on a mandatory basis.

TAS RESPONSE: While the IRS did not agree to make training on Online Account and digital communication tools mandatory for any taxpayer-facing IRS employees, the DCSE agreed to direct each DCSE business unit to evaluate which position types within their unit should be directed to attend a Digital Day event on a mandatory basis. The IRS also agreed to consider the employee’s view of the taxpayer account as part of its overall process of evaluating and implementing the forthcoming IRS Inflation Reduction Act Strategic Operating Plan, which would improve employees’ ability to assist taxpayers with questions about navigating their Online Account.

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: IRS agrees to implement the TAS recommendation in part.

IRS is committed to delivering a robust Business Online Account (BOLA) product in FY23. However, the BOLA launch in FY23 is subject to several contingencies including, vendor procurement, the development of technical requirements, and the prioritization of other competing IRS projects.

BOLA product features will be prioritized based on business customer needs, approved funding, development resources and technical constraints. The notional set of BOLA product capabilities at launch will likely include business authorization, make/view payments, view balance due, and a customer profile page.

Additionally, as part of the longer-term process of implementing the IRS Inflation Reduction Act Strategic Operating Plan, the IRS intends to broadly explore opportunities to leverage technology improvements to expand the features available in BOLA.

CORRECTIVE ACTION: BOLA product features will be prioritized based on business customer needs, approved funding, development resources and technical constraints. The notional set of BOLA product capabilities at launch will likely include business authorization, make/view payments, view balance due, and a customer profile page.

Additionally, as part of the longer-term process of implementing the IRS Inflation Reduction Act Strategic Operating Plan, the IRS intends to broadly explore opportunities to leverage technology improvements to expand the features available in BOLA.

TAS RESPONSE: Although it may not be able to bring a robust set of features to BOLA by the end of FY 2024, the IRS is making progress toward launching an initial product in FY 2023 and appears on track to include basic features such as the ability to enter a business authorization, make and view payments, view balance due, and view customer profile page. The IRS should understand based on its experience launching individual Online Account that features and utility are critical for attracting users.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): TBD

IRS RESPONSE TO RECOMMENDATION: ​IRS agrees to implement the TAS recommendation in full.

The IRS’s modernized digital identity platform aligns with the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-63-3, Digital Identity Guidelines and leverages the use of Credential Service Providers (CSPs) to provide identity verification and credential management for access to IRS online services. The CSP may choose to allow the use of trusted referees for in-person identity proofing and enrollment as outlined in NIST 800-63A.

The IRS is coordinating with our current CSPs to assess their in-person proofing capabilities to ensure compliance with NIST and IRS requirements. Concurrently, the IRS is developing a small-scale in-person proofing test for taxpayers who are unable to authenticate their identity online, tentatively planned for late Spring 2023.

Based on the data analysis of the in-person proofing test, the IRS will work to expand in-person authentication alternatives by means of a limited release pending available resources and evaluation of CSP capabilities which the IRS anticipates will occur in Fall 2023.

More broadly, as part of implementing the IRS Inflation Reduction Act Strategic Operating Plan, the IRS will include as a focus, continuing to evaluate the expansion/refinement of identity proofing options that meet the unique needs of different taxpayer groups.

CORRECTIVE ACTION: The IRS is coordinating with our current CSPs to assess their in-person proofing capabilities to ensure compliance with NIST and IRS requirements. Concurrently, the IRS is developing a small-scale in-person proofing test for taxpayers who are unable to authenticate their identity online, tentatively planned for late Spring 2023.

Based on the data analysis of the in-person proofing test, the IRS will work to expand in-person authentication alternatives by means of a limited release pending available resources and evaluation of CSP capabilities which the IRS anticipates will occur in Fall 2023.

More broadly, as part of implementing the IRS Inflation Reduction Act Strategic Operating Plan, the IRS will include as a focus, continuing to evaluate the expansion/refinement of identity proofing options that meet the unique needs of different taxpayer groups.

IRS Response from 2023 Recommendation 7-9: The IRS is very interested in expanding identity proofing options, including increasing the number of Credential Service Providers (CSPs) and expanding in-person identity assistance to taxpayers. The IRS tested in-person identity proofing assistance and is evaluating the results, which will inform the expansion of identity proofing options that align with IRS Strategic Operating Plans to deliver seamless service. While the IRS is ready to partner with additional CSPs, it is the CSPs who are not yet equipped to authenticate at the level taxpayer data requires and provide the number of transactions per second the IRS needs to meet taxpayer demands. IRS Cybersecurity continues to revisit the marketplace for new and emerging CSPs that have developed a mature solution that aligns with NIST 800-63-3 and other industry certifications. The implementation of additional CSPs will depend on the readiness of the CSPs, not the readiness of the IRS.

TAS RESPONSE: It’s a positive development that the IRS is coordinating with our current CSPs to assess their in-person proofing capabilities to ensure compliance with NIST and IRS requirements and conducting its own tests. Ensuring that taxpayers who are unable to complete online identity-proofing have an in-person option is essential to protecting taxpayer’s right to quality service.

Update – This recommendation is repeated in the 2023 ARC Online Accounts MSP (2023 Rec. 7-9). TAS will review IRS’s response to the 2023 recommendation (expected May 1, 2024) and update this accordingly.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 12/31/2025

IRS RESPONSE TO RECOMMENDATION: ​IRS agrees to implement the TAS recommendation in part.

The IRS agrees with the TAS recommendation to add increased capabilities and functionality to Tax Pro Account, with the goal to allow authorized representatives seamless access to some of the same information their clients have in their Online account(s) (OLA) through Tax Pro Account.
We prioritized Tax Pro Account functionality for our August 2023 release to allow authorized individuals the ability to link their CAF number, view their list of authorizations and the authorization details and to manage their authorizations. These additions will bring increased functionality to Tax Pro Account.

Additionally, as part of implementing the IRS Inflation Reduction Act Strategic Operating Plan, the IRS will further prioritize expanding Online TaxPro Accounts to include a comprehensive suite of services including the ability to manage client authorizations online; view clients’ balances, payment histories, and notices; and act on their behalf to make payments, set up payment plans, and complete other account updates as authorized. This extensive expansion of TaxPro Account is a long-term project that is not expected to be completed within the implementation timeframe listed below.

CORRECTIVE ACTION: As part of implementing the IRS Inflation Reduction Act Strategic Operating Plan, the IRS will further prioritize expanding Online TaxPro Accounts to include a comprehensive suite of services including the ability to manage client authorizations online; view clients’ balances, payment histories, and notices; and act on their behalf to make payments, set up payment plans, and complete other account updates as authorized. This extensive expansion of TaxPro Account is a long-term project that is not expected to be completed within the implementation timeframe listed below.

TAS RESPONSE: Though it’s a long-term project, it is encouraging the IRS is willing to prioritize adding increased functionality to Tax Pro Account, such as viewing notices and letters and uploading requested documents to provide authorized representatives seamless access to their clients’ Online Accounts through Tax Pro Account. Adding useful features to Tax Pro Account will help the IRS attract users.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 12/31/2024