IRS RESPONSE TO RECOMMENDATION: ​​​An increase of “train the trainer” in-person trainings does not guarantee an increase in IRS’ ability to provide top-quality training to employees or top-quality service to taxpayers. Instead, the IRS
embraces a blended learning approach to training delivery that has proven to be effective and aligned with industry standards and recognizes that a one-size-fits-all approach to training is not an efficient use of government funds or an effective method of designing a training program. Our training evaluation data indicate that employees express the same high level of satisfaction
regardless of the training delivery method.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate is concerned the IRS has missed the point of the recommendation to increase “train the trainer” in-person trainings. The recommendation to increase stems from the utility of allowing for group collaboration and learning during training that having an in-person event run by a trainer permits. While the National Taxpayer Advocate appreciates and also utilizes a multi-faceted approach to training in TAS, a goal to increase in-person training through lower-cost methods like “train the trainer” events is something TAS is also striving to achieve.

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: ​​​​​To determine when additional training is needed, the IRS uses an annual training needs assessment that takes into account individual and organizational needs, employees’ level of expertise, legislative and procedural changes, and Service initiatives. For example, training hours were increased for certain mission critical series in SB/SE and W&I to implement the provisions of the Affordable Care Act. Indeed, mission critical employees receive technical and continuing professional education training annually to ensure that they provide top-quality service to taxpayers. This holistic approach ensures that employees receive just-in-time training, particularly in mission critical job series, and is more effective than a broad-brushed approach of simply increasing training hours per employee.

The IRS’ annual training needs assessment process identifies training gaps and provides flexibilities across the organization. In addition, employees may create an individual development plan, in coordination with their manager, that customizes training based on their personal needs and goals. Similarly, employees aspiring to a leadership position complete a Career Learning Plan that identifies training needed to develop competencies. To help employees achieve their goals, the IRS provides multiple training resources at no-cost, including Thomson Reuters Checkpoint Learning, Practicing Law Institute, and Learn and Lead 24×7.

In addition to formal training, employees receive informal instruction through group meetings and on-the-job training hours that may not be recorded in the Enterprise Learning Management System. Employees also may access the IRS Virtual Library for just-in-time instruction. These vehicles provide opportunities that increase employee training hours as needed.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate appreciates and understands the need to deliver just-in-time training to meet the challenges of emerging issues, such as the Affordable Care Act in previous years and the Tax Cuts and Jobs Act this year. However, such an approach has clearly led to minimal training of certain job series as described in the Most Serious Problem, with some employees receiving as few as 14 hours of training in substantive topics in a fiscal year. The National Taxpayer Advocate strongly believes that providing such a limited amount of training per year to any employee cannot adequately address that employee’s training needs. It not only is inadequate to keep abreast of current developments in the law, but it is inadequate to reinforce basic tenets of the law and administrative practices, and to ensure adherence to the Taxpayer Bill of Rights, as required by Internal Revenue Code (IRC) § 7803(a).

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 a long history of leveraging outside training to address technical training needs not offered internally. Employees are encouraged to complete outside courses and training events, when appropriate, to expand their knowledge base by exposing them to industry practices, outside perspectives, and trends.

Opportunities to participate in external training result from individual and organizational needs assessments. For example, through the IRS annual training needs assessment process, employees in Appeals, Large Business and International (LB&I), Tax Exempt & Government Entities (TE/GE), and SB/SE have identified and attended external conferences and seminars to enhance their expertise, including conferences sponsored by Parker Fielder, George Washington University, the American Bar Association, and New York University.

Similarly, the IRS promotes continuous development, beginning with employees creating their customized Individual Development Plans (IDPs), and supports attendance by providing 16 hours of administrative time annually to complete the training. The IDP aligns employees’ training and development efforts with IRS mission and goals and identifies training offered internally and externally. The IDP creates an opportunity for employees to take personal responsibility and accountability for their professional development.

The IRS also offers the Leadership Succession Review process for employees who are aspiring leaders, which includes the development of a Career Learning Plan (CLP) to address competency gaps. Similar to an IDP, employees creating a CLP may identify internal and external sources of training.

CORRECTIVE ACTION: N/A

TAS RESPONSE: While the National Taxpayer Advocate is pleased to learn that the IRS does encourage employees to leverage outside training events, she remains concerned about how this unfolds in practice. Anecdotally, TAS has heard from IRS employees who were denied permission to attend events and then went on to use their own annual leave to attend. The IRS should ensure that all employees and managers are aware of opportunities and encourage mangers to approve attendance during the work day.

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 recognizes the value that outside experts provide in enhancing taxpayer service by gaining insight from their knowledge and experience with taxpayers. For example, LB&I incorporates the perspectives of, and input from, outside experts and taxpayers into LB&I’s core revenue agent training programs. In addition, LB&I annually sponsors joint tax conferences with practitioners on emerging compliance issues and challenges. These efforts are considered a strategically important part of LB&I’s training plans and compliance strategies. They reflect recognition that tax administration benefits greatly when taxpayers, tax practitioners, and IRS tax professionals have common understandings about effective audit processes and applications of the Internal Revenue Code. LB&I actively pursues training updates on business acumen, tax law, and industry practices via a robust and well-funded out-service training strategy on an ongoing basis.

Similarly, Appeals employees attend external conferences and seminars to enhance their expertise, including conferences sponsored by Parker Fielder, George Washington University, and New York University. TE/GE routinely conducts outreach events with taxpayers; feedback from those events is evaluated and incorporated into training courses when applicable.

Conversely, W&I and SB/SE rely on internal experts with institutional knowledge and experience derived from taxpayer contact to develop and deliver their training materials. For example, in SB/SE, resident lead instructors are highly skilled and have extensive experience interacting and working with taxpayers and their representatives to resolve issues.

CORRECTIVE ACTION: N/A

TAS RESPONSE: Notwithstanding LB&I’s approach, which is commendable, the IRS has not taken steps to address the National Taxpayer Advocate’s concerns. The National Taxpayer Advocate finds it difficult to believe that no training of W&I or SB/SE employees, particularly since W&I is the largest operating division and most taxpayers who contact the IRS reach a W&I employee, could benefit from the knowledge and experience of an outside expert. Similarly, SB/SE employees interact with individual and small business taxpayers through its audit and collection functions. Practitioners can offer a unique perspective from the taxpayer point of view, particularly into the circumstances of taxpayers who face challenges interacting with the IRS, such as the low income or the elderly. TAS regularly invites Low Income Taxpayer Clinic practitioners to conduct internal training, providing real-world experience and knowledge about discrete issues and fact patterns pertinent to low income and elderly taxpayers.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Closed

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