United States General Accounting Office

GAO Report to the Chairman of the

Committee on Ways and Means and the

Chairman of the Subcommittee on

Oversight, House of Representatives

November 1998 IRS PERSONNEL

ADMINISTRATION

Use of Enforcement

Statistics in Employee

Evaluations

GAO/GGD-99-11

GAO United States

General Accounting Office

Washington, D.C. 20548

General Government Division

B-279232 

November 30, 1998

The Honorable Bill Archer

Chairman, Committee on Ways and Means

House of Representatives

The Honorable Nancy L. Johnson

Chairman, Subcommittee on Oversight

Committee on Ways and Means

House of Representatives

Both the law and Internal Revenue Service (IRS) policy prohibit IRS

managers from using records of tax enforcement results, such as dollars

collected and taxes assessed, to evaluate employee performance or

establish production goals. The underlying reason for these prohibitions is

that employees may try to achieve statistical benchmarks through

inappropriate or abusive enforcement actions, such as unwarranted

seizures or unreasonable tax assessments, instead of acting strictly on the

merits of the case.

This report responds to your request for information on IRS managers’

compliance with legislative and policy prohibitions and the requirement

that managers certify each quarter whether violations had occurred.

Accordingly, this report discusses our evaluation of (1) the extent to

which IRS’ certification process identified violations of law and policy,

(2) IRS employees’ perceptions of the use of tax enforcement results in

their annual performance evaluations, (3) supervisors’ use of tax

enforcement results in written employee performance evaluations, and

(4) IRS’ efforts to revise the certification process.

Background Since 1973, IRS Policy Statement P-1-20 has prohibited using records of tax

enforcement results to evaluate enforcement officers or to impose or

suggest production goals or quotas. An enforcement officer is an employee

who exercises judgment with regard to determining tax liability or the

ability to pay. Enforcement officers include employees directly involved in

collection, examination, or criminal investigation functions as well as

appeals officers and reviewers. Each function has its own set of tax

enforcement results. For example, for the examination function, tax

enforcement results include data such as the number of hours spent per

return, amount of dollars proposed per return, and number of cases

closed. For the collection function, tax enforcement results include the

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number of liens, levies, and seizures; amount of dollars collected; and

number of cases closed.

As a general rule, the policy prohibited managers from using any statistic

that measures quantity, time per case, type of disposition, or dollar value.

Instead, employees are to be evaluated on the basis of the quality of the

work, including the use of enforcement tools, timeliness of action, and

application of tax law. However, the policy statement permitted IRS

officials to use statistics on tax enforcement results when carrying out

certain management activities, such as preparing long-range and financial

plans, allocating resources, and evaluating program effectiveness. In

addition, managers were permitted to use tax enforcement results when

evaluating employee performance during a case review, for example by

noting whether a revenue officer appropriately levied a bank account

given the facts of the specific case. Managers were also permitted to

discuss with employees the number of cases processed, the amount of

time spent on cases, and the kind of results obtained, as long as the

discussion was based on a review of the results that were appropriate for

specific cases processed by the employees and goals and quotas were not

involved.

In 1988, along with other changes, the Taxpayer Bill of Rights1

 also

prohibited the use of records of tax enforcement results to evaluate

employees, but the prohibition only applied to employees directly involved

in collection activities and their immediate supervisors. The law specified

that IRS would be in compliance with the legislative requirements as long

as IRS followed its policy statement. To help ensure compliance, the law

also required each district director to certify each quarter whether

violations had occurred and the corrective action taken, if needed.

Because IRS service centers also have collection responsibilities, IRS

imposed the same certification requirement on its service center directors.

Generally, the self-certification process requires managers to submit

certifications to the next higher level for review. Quarterly, group

managers are to submit certifications to their branch chiefs, branch chiefs

are to submit certifications to their division chiefs, and division chiefs are

to submit certifications to their directors. Directors, relying on lower-level

managers’ certifications, are to submit their certifications to the

Commissioner of Internal Revenue through the Assistant Commissioner

(Collection).

1

Taxpayer Bill of Rights, Public Law 100-647, Nov. 10, 1988.

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During hearings held by the Senate Committee on Finance in September

1997, witnesses alleged that IRS’ focus on enforcement statistics was

encouraging enforcement officers to take unnecessary and illegal

enforcement actions against taxpayers. Prompted by these hearings, IRS’

Internal Audit reviewed the use of enforcement statistics by collection

personnel in 12 districts, as well as at national and regional offices, and

found an atmosphere largely driven by statistical measures. Internal Audit

also found similar conditions in its July 1998 report on the use of

enforcement results by the examination functions in 12 district offices.

The IRS Restructuring and Reform Act of 1998 (Public Law 105-206, July 22,

1998) repealed the Taxpayer Bill of Rights prohibitions, which only

covered collection employees, and instead expanded the prohibitions to

cover all employees. The act also expanded the quarterly certifications to

cover each appropriate supervisor.

Results in Brief For fiscal years 1996 and 1997, district and service center directors

submitted 368 quarterly certifications that reported 11 potential violations,

of which 4 were subsequently determined by IRS to be actual violations.

However, we identified several systemic weaknesses that affected the

reliability of the certifications. Specifically, we found (1) some confusion

among IRS officials about what constituted a violation, (2) inadequate

guidance about specific actions directors should take to identify

violations, (3) a failure to integrate performance evaluations and the

certification process, and (4) unclear guidance on sanctions that could be

applied against managers for misusing tax enforcement results or

submitting false certifications.

While the quarterly certifications showed few violations, our survey of a

statistically representative sample of examination and collection

employees showed a widespread perception that managers considered

enforcement results when preparing annual performance evaluations. We

estimated that 75 percent of front-line employees (revenue agents, tax

auditors, and revenue officers) and 81 percent of group managers

perceived that tax enforcement results affected their most recent

performance evaluation. When asked about various potential bases for

their perception, about 70 percent of front-line employees, who indicated

that tax enforcement results affected their evaluations, said they based

their perception in part on information communicated to them verbally in

staff meetings or performance feedback sessions with their managers. And

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about 36 percent of front-line employees indicated tax enforcement results

were used in their written performance evaluations.

On the basis of our review of the two most recent performance evaluations

for a statistically representative sample of front-line employees, we

estimated that 9 percent of employees received a written evaluation that,

according to our application of IRS’ revised guidelines, contained a tax

enforcement result. Although this incidence rate is low relative to our

employee survey results, we also found that an estimated 69 percent of the

evaluations in our sample contained narrative that employees could have

interpreted as inappropriate references to tax enforcement results but

which did not violate IRS guidance. For example, an estimated 50 percent

of the evaluations in our sample included either general or case-specific

references to enforcement-related activities, such as employees’ overall

use of collection tools or auditing techniques, that IRS does not consider

violations. In addition, we estimated that about 41 percent of the

evaluations in our sample mentioned process measures dealing with the

age of the cases in the employee’s workload inventory and the number of

cases worked within guidelines established for closing cases, which could

be interpreted by employees as a surrogate for prohibited measures, such

as the “number of cases closed.”

As a result of IRS’ Internal Audit reviews, IRS has undertaken several steps

to strengthen the certification process, such as (1) expanding the number

of employees covered by certifications, (2) revising its guidance on the

proper use of tax enforcement results, (3) requiring an annual independent

review to verify the accuracy of the certifications, and (4) requiring the

preparer and reviewer to attest that the tax enforcement results were not

improperly used in the evaluation. Although these actions address some of

the weaknesses of the current system, IRS’ revised guidance has few

examples of the appropriate and inappropriate use of tax enforcement

results in written evaluations. In addition, the certification form includes

only a general statement of compliance rather than a statement

specifically detailing what managers are certifying. Furthermore, the

revised guidance does not clearly inform managers about potential

sanctions for inappropriate use of tax enforcement results. In addition to

these potential sources of confusion, IRS’ new independent review process

is geared toward identifying written violations and not violations

communicated verbally, which our employee survey indicates is the most

common way tax enforcement results are communicated.

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Scope and

Methodology

To determine the extent to which IRS’ current certification process

identified violations, we reviewed fiscal year 1996 and 1997 quarterly

certifications filed by district and service center directors—a total of 288

for the district offices and 80 for the service centers. We also obtained

summary information on the potential violations for the first quarter of

fiscal year 1998. To obtain information on IRS’ quarterly certification policy

and procedures, we interviewed officials from IRS’ National Office; the

Western Regional Office; the Georgia, Kansas/Missouri, and Northern

California District Offices; and the Atlanta and Fresno Service Centers. We

visited these offices because of their close proximity to our offices. We

also surveyed officials in all districts and service centers on the quarterly

certification process they had in place as of the last quarter of calendar

year 1997. Appendix I contains a summary of the violations reported in the

quarterly certifications we reviewed.

To determine IRS employees’ perceptions of the use of tax enforcement

results, we surveyed a statistically representative sample of 1,104 of 20,974

IRS front-line employees and group managers in the collection and

examination functions. The survey included questions on whether

employees perceived that tax enforcement results influenced their

evaluations, the basis for those perceptions, and the use of tax

enforcement results to establish group goals. We also analyzed the

comments provided voluntarily by IRS employees on the survey.

Appendixes II through VI contain our sampling methodology and survey

results. All results are reported at the 95-percent confidence level.

Sampling errors for all of our estimates are less than plus or minus

10 percentage points unless otherwise reported.

To determine how tax enforcement results were used in written employee

evaluations, we reviewed the 2 most recent evaluations for a statistically

representative sample of 300 of 18,292 examination and collection

front-line employees. We reviewed the evaluations to determine whether

tax enforcement results were used to rate the employee in violation of IRS

guidance. We discussed potential violations with IRS officials and

considered their opinions on whether they were violations. We also

reviewed the evaluations to determine whether the narratives used tax

enforcement results to generally characterize employee performance or to

discuss specific case examples. Appendix II contains our sampling

methodology and appendix VII contains the results of our review of

employee evaluations. All results are reported at the 95-percent

confidence level and, unless noted otherwise, the data have sampling

errors of no more than 8 percent.

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To evaluate IRS’ efforts to revise the certification process, we discussed IRS

proposals with senior-level officials who were involved in developing the

new process. We reviewed the existing and proposed guidance provided to

managers and identified the differences between the existing and

proposed certification processes. We also met with National Treasury

Employees Union (NTEU) officials to obtain their perspective on the

existing and proposed processes. We compared the proposed changes

with the results of our review of the current process to determine if the

limitations we noted were being addressed.

There were some limitations to our analysis. We did not verify employees’

responses to our survey. However, we discussed these responses with

senior IRS officials. We also did not verify IRS’ personnel database from

which we drew our sample.

We did our work between December 1997 and August 1998 in accordance

with generally accepted government auditing standards.

We requested comments on a draft of this report from the Commissioner

of Internal Revenue. The comments we received are in appendix VIII and

are evaluated at the end of this letter.

IRS’ Certification

Process Identified

Few Violations but

Had Systemic

Weaknesses

Our review of quarterly certifications for fiscal years 1996 and 1997 found

that directors reported 11 potential violations in 368 quarterly

certifications (see app. I). IRS determined that four of the incidents were

actual violations, two were unfounded allegations, and five were reported

because the directors believed the actions could be misconstrued as

violations. However, there are some indications that the certification

process may not have identified all violations. For example, for the first

quarter of fiscal year 1998, directors reported 28 potential enforcement

results violations, more than double the total reported for the prior 8

quarters. According to IRS officials, the increase in reported potential

violations occurred as a result of the September 1997 Senate hearings on

IRS abuses, which made managers more aware of their responsibilities for

reporting potential violations. IRS had not completed its investigation of

these potential violations at the time we completed our audit work.

Also, we identified several systemic weaknesses that affected the

reliability of the certification process. First, our analysis of the potential

violations that were reported indicated that there was confusion among IRS

officials about what constituted a violation. For example, one certification

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noted that a district director had asked the National Office official, who

was responsible for providing guidance on the use of tax enforcement

results, whether a group could establish a team goal to increase dollars

collected by 10 percent as part of an organizational pilot project. Although

the National Office official agreed that this was acceptable because neither

awards nor individual evaluations would be based on achieving the goal,

IRS’ Chief Counsel subsequently determined that the group goal was a

production quota or goal and, as such, a violation.

Second, IRS guidance did not specify how the certifications were to be

supported. For example, IRS policy did not mandate what action directors

should take to support their certifications, such as reviewing a sample of

evaluations or indicating on the certification the number and type of

documents reviewed. As a result, National Office officials may not have

been in a position to determine whether directors performed enough

oversight to validate their certifications. We found that officials at all

levels with certification responsibility said that they reviewed some

documents to determine whether managers complied with the tax

enforcement results policy. However, the nature and scope of their review

varied widely. For example, some officials reviewed all performance

evaluations and supporting documents for violations while other officials

reviewed a random sample or reviewed a small, judgmental sample.

Third, IRS did not integrate the employee performance evaluation and

certification processes. For example, although IRS procedures require

managers to submit an evaluation to a higher level of management for

review and approval before the evaluation is given to the employee, they

do not require the reviewer to assess the evaluation for potential tax

enforcement results violations. Although the preparers’ and reviewers’

signatures on the evaluation form signified that the evaluation complied

with procedures for conducting evaluations, the procedures did not

specifically refer to the tax enforcement results policy or the certification

process. Such a requirement could heighten managerial awareness of

policy and legal prohibitions at the time the evaluation is prepared.

Fourth, IRS guidance did not clearly inform managers that they could be

subject to sanctions or the kinds of sanctions that could be imposed if they

either misused tax enforcement results or signed a false or misleading

certification. Neither the policy guidance nor the certification included an

acknowledgement that managers could be subject to disciplinary action

for the improper use of tax enforcement records, so managers might not

have known the importance or potential consequences of their actions.

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Furthermore, the lack of clear guidance could lead to inconsistent

disciplinary actions. The Guide for Penalty Determinations listed in IRS’

Interim Handbook of Employee Conduct and Ethical Behavior did not

specify the types of disciplinary actions that could be imposed on

managers who violate tax enforcement results policy. According to an IRS

official, the guide is not intended to be an exhaustive listing of all offenses,

and one general category can be used for penalty determinations in

matters not otherwise covered. The penalties for this general category

ranged from a reprimand, to a 14-day suspension, to a removal.

Disciplinary action for the four violations IRS identified in the fiscal year

1996 and 1997 certifications ranged from counseling to removing the

manager from his/her position.

Employees Perceive

That Tax Enforcement

Results Affect

Evaluations

Our employee survey showed a widespread perception on the part of

collection and examination front-line employees that tax enforcement

results are considered by managers when preparing performance

evaluations. We estimated that, overall, about 75 percent of front-line

employees (i.e., revenue agents and tax auditors in the examination

function and revenue officers in the collection function) and 81 percent of

examination and collection group managers believe that one or more

enforcement measures were considered to some extent by their managers

when preparing their most recent performance evaluation.

For those revenue officers who indicated that tax enforcement results

affected their evaluation, an estimated 58 percent of them cited “number

of cases closed”—a measure of productivity—as a tax enforcement result

influencing their evaluations. Revenue agents and tax auditors who

indicated that tax enforcement results affected their evaluations cited

measures of revenue production more frequently as factors that influenced

their evaluations than did revenue officers. At least an estimated

61 percent of revenue agents and tax auditors said that “additional dollars

proposed per return” influenced their evaluations, while an estimated

29 percent of revenue officers said that “average dollars collected per

return” influenced their evaluations. Appendix III shows the

point-estimates intervals for each type of enforcement result by type of

employee and manager.

An estimated 77 percent of collection group managers who indicated that

tax enforcement results affected their evaluations believed that the

number of cases closed affected their evaluations, compared with an

estimated 39 percent who believed that the average dollars collected per

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return affected their evaluations. Examination group managers who

indicated that tax enforcement results affected their evaluations cited

workload measures about as frequently as revenue production measures.

About 74 percent of examination group managers identified tax

enforcement results dealing with the average hours per return and about

76 percent identified additional dollars proposed per return as affecting

their evaluations.

IRS’ quarterly certification process focused on the use of enforcement

results in formal written performance evaluations. However, our survey

results indicated that although many employees had multiple bases for

their perceptions on the use of tax enforcement statistics, most based their

perception on verbal information received from their managers. We

estimated that about 70 percent of front-line employees, who believed that

tax enforcement results affected their evaluations, based their perceptions

on verbal communication with their managers during group meetings and

performance feedback sessions. An estimated 36 percent based their

perception on written information contained in their evaluations.

Likewise, managers who believed that tax enforcement results affected

their evaluations had multiple bases for their perceptions. An estimated

83 percent based their perception on verbal communication with their

branch and division chiefs, while an estimated 51 percent based their

perception on written communications. Appendix IV contains detailed

information on the basis for front-line employee and group manager

perceptions.

IRS’ managers are prohibited from using tax enforcement results to

establish group production quotas or goals because of the possibility that

group goals will be interpreted as individual goals or expectations. About

one-half of front-line employees and group managers indicated that

performance goals were established for their groups. Where group goals

were established, at least two-thirds of the front-line employees and

managers indicated that the goals included one or more enforcement

results. Appendix V provides more detailed information on which

enforcement results were included in group goals.

In voluntary written comments to our questionnaires, front-line employees

and managers included additional reasons why they believe enforcement

results influenced their performance evaluations. The comments generally

centered on the following scenarios: (1) supervisors or managers implied

that an employee’s performance evaluation was influenced by tax

enforcement results; (2) the general culture or atmosphere of IRS implied

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that enforcement results affected performance evaluations;

(3) higher-level managers pressured group managers to increase

production or revenue yield; and (4) IRS’ business plan, reports, and other

documents emphasized enforcement results as goals. Front-line employees

and managers also made positive and negative comments about using

enforcement and workload measures to establish group goals or in

performance evaluations. Generally, the number of negative comments

made by front-line employees and managers exceeded the number of

positive comments. Appendix VI contains examples of voluntary

comments received from front-line employees and managers.

Employee Evaluations

Contained Policy

Violations and Other

References to

Enforcement and

Productivity-Related

Activities

Using IRS guidance for determining whether an evaluation contained a

violation, we estimated that 9 percent of front-line employees received at

least one written performance evaluation containing a violation in the two

most recent annual evaluations. The potential effect of the violations on

future employee performance could vary, however, depending on how the

enforcement results were used in evaluations. Some violations could

influence employees to be more aggressive in their dealings with

taxpayers. For example, the following two comments taken from

evaluations could create an incentive for employees to more aggressively

pursue fraud cases, liens, and levies.

“You had one possible fraud case during this period. Keep trying for more fraud cases.”

“You do not hesitate to lien or levy and have demonstrated innovative ideas in your efforts

to comply with group goals. . . Your workload management produces a closure rate that

demonstrates your commitment to group goals.”

Both evaluations violations link a positive evaluation to achieving a higher

number of enforcement results, rather than focusing on the

appropriateness of the employees’ action.

In other cases, however, the potential impact of the violations on

employee performance was less clear. For example, many of the violations

mentioned closing cases when summarizing employees’ accomplishments,

as shown in the following two examples.

“The effectiveness of your planning and time utilization is demonstrated by the fact that

you closed 38 key cases during the year.”

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“You have selected the proper technique to detect unreported income and applied your

technique to detect and recognize indications of fraud. For example, [employee name],

during this fiscal year you have submitted and had accepted six civil fraud referrals.”

For most of the violations we identified, IRS officials said that the

comments would not have been considered violations under the guidance

in effect at the time the evaluations were prepared. However, the officials

agreed that the comments would be considered inappropriate under IRS’

revised guidance, which is discussed in the following section.

The incidence of violations was relatively low, given that 36 percent of

front-line employees who believed that tax enforcement results affected

their evaluations based their perception on their written evaluations. Our

analysis of employee evaluations found that an estimated 69 percent of the

evaluations contained two types of narrative that employees could have

interpreted as inappropriate references to tax enforcement results but

which did not violate IRS guidance. The first type of narrative involved the

use of general or case-specific references to enforcement-related

activities, such as the amounts of revenue collected or use of collection

tools. These references, which are not based on statistics such as group

goals, are not violations. We estimated that 50 percent of employees

received evaluations that contained this type of narrative. For example,

one evaluation included the statement “You had one case that the property

was in foreclosure and you were looking at seizing or redeeming the

property but would only get around $23,000. Through your working with a

third-party lending institution, you were able to secure $30,000. . . .”

Another included “[employee name] . . . have done a very good job in

locating assets even in unusual situations. An example of this would be the

research you completed on a large dollar tax protestor assigned to your

inventory.” Since the comments were based on specific cases reviewed,

they are not considered tax enforcement results violations under IRS’

guidelines. However, IRS guidance cautions managers that discussing a tax

deficiency or referencing a dollar amount collected may give the employee

an improper perception that only the size of the deficiency or the amount

collected was the basis for the employee’s evaluation.

The second type of narrative that could create misperceptions about the

use of tax enforcement results was the use of the terms “overage” (the age

of the cases in the employee’s workload inventory) and “cycle time” (the

number of cases worked within the established guidelines for closing

cases). IRS views these statistics as measures of process time and

responsiveness to taxpayers because they are indications of timely

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attention to taxpayer issues rather than measures of tax enforcement

results. We estimate that 41 percent of employees received evaluations

that included either general or case-specific references to overage cases

and cycle time. For example, one evaluation included the statement “You

are making excellent progress in closing out cases and specifically

targeting overage and high cycle time to minimize these problems.”

Another included the statement “You appear to be doing a better job of

meeting the time frames for initial contact and follow-up action on your

cases, but your high overage and potential overage rates still indicate a

need to improve in this area.” Although neither cycle time nor overage

cases are defined by IRS as enforcement results, IRS guidance cautions

managers in their use of such terms because of the potential for either of

the terms being interpreted as a prohibited statistic such as “hours per

case.” Also, during our discussions with NTEU officials, they raised

concerns about whether front-line employees and group managers clearly

understood the distinction between the inappropriate use of

productivity-related enforcement measures, such as hours per case, and

the appropriate use of overage and cycle-time data. Appendix VII provides

the detailed results for our review of employee evaluations.

IRS’ Proposed

Revisions to the

Certification Process

Address Some

Weaknesses

Because of Internal Audit reports, IRS has undertaken several steps to

strengthen the certification process, including expanding the number of

employees covered, instituting an independent review process of the

certifications, revising guidance, and training managers.

According to IRS officials, IRS has expanded the certification process to

include all appropriate enforcement supervisors, not just those working in

the collection function. Employees who are to be covered by the

certification include revenue agents, tax auditors, appeals officers, and

criminal investigators. The IRS Restructuring and Reform Act of 1998 also

mandates quarterly certification of all appropriate enforcement

supervisors. IRS is also instituting an annual independent review to verify

the accuracy of the certifications. The reviews are to be performed

annually by cross-functional management teams and must include a

review of Employee Performance Folders and employee evaluations,

which may include documentation related to the evaluation process—such

as award narratives and case reviews. The review team may also consider

other sources, such as local memos, minutes of meetings, and grievances

submitted by employees.

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IRS has also implemented a new employee evaluation process effective

September 1998 that includes a revised form to document a performance

evaluation. The guidance on the new form sent to IRS managers in

August 1998 states that by signing the form the rater and reviewer certify

that enforcement statistics were not used in preparing the appraisal.

In addition, IRS has revised the handbook that provides guidance on the

appropriate and inappropriate use of tax enforcement results. The

handbook provides guidance on which employees are considered

enforcement officers and examples of common scenarios involving the

proper and improper use of tax enforcement results for each job

classification. The handbook also includes a decision table that leads

managers through a series of four questions to help them determine

whether they are using tax enforcement results appropriately. This new

guidance may help clarify some of the confusion managers had on what

constitutes a tax enforcement result violation.

Furthermore, IRS trained managers on the new certification process and

handbook. After providing background on the prohibitions, the training

discussed the appropriate use of tax enforcement results and how the

prohibitions affect supervisory activities, such as setting expectations as

well as explaining the self-certification and independent review processes.

To signal its commitment to addressing issues involving the use of

enforcement statistics, IRS involved senior executives in the training. For

example, IRS directed that district and service center directors would teach

the section on self-certification and the independent review. IRS completed

the training before the new certification process became effective in the

last quarter of 1998.

These initiatives address existing weaknesses that we have identified by

clarifying which employees are covered and the steps directors should

take to independently validate certifications. However, managers may be

confused about how to apply the decision table contained in the revised

guidance to the preparation of written evaluations. The scenarios included

in the revised guidance focus primarily on the prohibited use of statistical

reports to imply group goals with relatively few examples relating to the

appropriate and inappropriate uses of tax enforcement results in written

evaluations. Providing such examples is particularly important because, as

noted earlier, IRS officials said that most of the violations we identified

would be considered violations under the revised guidance but not under

the guidance in effect before 1998. IRS officials agreed that expanding the

guidance to include additional examples could be beneficial, especially

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since managers raised many questions about the appropriate use of tax

enforcement results in written evaluations during the training on the

revised guidance.

Furthermore, IRS has revised its certification form to reflect that more

employees are covered by the certification process, but the form contains

only a vague statement of conformance. As shown in appendix IX, the

certification does not specifically state that first-level managers have not

personally misused records of tax enforcement results in written

performance evaluations they prepared or to set individual production

goals or quotas during their verbal communications with employees. In the

case of second-level managers, the certifications do not specifically

require that managers certify that tax enforcement results were not used

in written performance evaluations they prepared or reviewed or during

their verbal communications with employees. As a result, the form does

not clearly explain to managers what they are certifying to.

IRS has not informed managers about what specific sanctions can be

imposed for misusing tax enforcement results or submitting misleading

certifications. Neither the revised guidance nor the certification form

refers to potential sanctions.

In addition to these possible sources of confusion, IRS’ independent review

process is to focus on reviewing documents and records to identify written

violations. As a result, IRS does not have a mechanism, such as our

employee survey, for monitoring employee perceptions of how often tax

enforcement results are verbally communicated or whether their written

evaluations are influenced by records of tax enforcement results.

Consequently, without an employee survey, IRS cannot determine whether

further clarifications of the guidance or additional training is needed.

Conclusions IRS directors reported few violations through the quarterly certification

process in fiscal years 1996 and 1997, and we found an estimated 9 percent

of employees received evaluations that were in violation of IRS’ revised

guidance during our review of employee evaluation files. Nonetheless, our

survey of IRS employees indicated a widespread perception that managers

consider tax enforcement results when preparing performance

evaluations. Most of the employees indicated that the violations occurred

during verbal communications with their supervisors, such as staff

meetings or performance feedback sessions, rather than in their written

performance evaluations. Perceptions based on such verbal

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communications could encourage employees to focus on achieving

statistical benchmarks rather than acting solely on the merits of the case.

Furthermore, the use of overage and cycle-time data in evaluations may

further employee perceptions that tax enforcement results affect their

evaluations, because they may be misconstrued as an enforcement

statistic, such as hours per case.

Although IRS is taking steps to strengthen its reporting of violations,

weaknesses remain. IRS’ revised guidance has few examples of the

appropriate and inappropriate use of tax enforcement results in written

evaluations. Furthermore, the certification form does not specifically

require managers to certify that tax enforcement results were not used in

written evaluations or used inappropriately during verbal communications

with employees. IRS has not provided clear guidance on the sanctions for

misusing tax enforcement results or submitting misleading certifications.

Additionally, IRS does not have a mechanism for monitoring how often

violations result from verbal communications or employee perceptions of

whether records of tax enforcement results are influencing their

evaluations.

Recommendations to

the Commissioner of

Internal Revenue

To better ensure managerial accountability for the proper use of tax

enforcement results, we recommend that the Commissioner

• expand the guidance to include additional examples of the appropriate

and inappropriate use of records of tax enforcement results in written

evaluations,

• revise the quarterly certification form to specifically state that tax

enforcement results were not used in any written employee evaluation

prepared or reviewed, including appraisals, awards, or promotion

justifications, and that the manager did not verbally communicate to

employees that tax enforcement results affected their evaluations or were

used to set individual production goals or quotas,

• revise the penalty guide to specifically list the disciplinary actions that can

be taken for violations, and

• survey employees periodically to determine whether they perceive that tax

enforcement results were used in written evaluations or verbally

communicated by their supervisors and use the results to assess whether

IRS needs to further clarify the guidance, provide additional training, or

take any other appropriate action.

Page 15 GAO/GGD-99-11 IRS Personnel Administration
B-279232 

Also, to avoid the potential inappropriate use of overage and cycle-time

data, the IRS Commissioner should either designate overage and cycle-time

data as prohibited tax enforcement results or emphasize in official policies

or procedures to front-line employees and managers how overage and

cycle-time data may be used appropriately.

Agency Comments

and Our Evaluation

We obtained written comments on a draft of this report from the

Commissioner of Internal Revenue. The Commissioner agreed with all of

our recommendations and described the actions IRS plans to take in

response to our recommendations. Regarding our recommendation that

IRS should either designate overage and cycle-time data as prohibited tax

enforcement results or emphasize in official policies or procedures to

front-line employees and managers how overage and cycle-time data may

be used appropriately, the Commissioner said that IRS would revise the

Internal Revenue Manual to include examples of the appropriate use of

these data. If effectively implemented, the actions described should help to

resolve the problems we identified.

In addition, the Commissioner pointed out that IRS has undertaken a

number of initiatives to address the use of tax enforcement results in

employee performance evaluations. These initiatives included (1) revising

the Internal Revenue Manual provisions concerning the use of

enforcement statistics; (2) providing training to all managers on the use of

enforcement statistics, which included numerous examples of appropriate

and inappropriate language for discussing tax enforcement results in

evaluations; (3) providing an orientation course on the proper use of

statistics for all IRS employees; (4) establishing a Support Panel to answer

questions from managers or employees on the proper use of enforcement

statistics; (5) establishing independent review teams that are obliged to

review documentation in Employee Performance Files and Employee

Evaluations and may, at the director’s discretion, look to other sources of

information to ensure potential violations are uncovered, including group

discussions, union comments or reports, grievances, and minutes of

managers’ meetings; and (6) developing a balanced performance measure

system to include measures of customer satisfaction, employee

satisfaction, and business results. The business results measure is to focus

on the quality and quantity of work done. The quantity measures are to

consist exclusively of outcome-neutral production data, such as cases

closed and time per closing.

Page 16 GAO/GGD-99-11 IRS Personnel Administration
B-279232 

We are sending copies of this report to the Ranking Minority Member of

the House Ways and Means Committee; the Ranking Minority Member of

the Subcommittee on Oversight, Committee on Ways and Means; various

other congressional committees; the Secretary of the Treasury; the

Commissioner of Internal Revenue; and other interested parties. We will

also make copies available to others on request.

Please contact me at (202) 512-9110 if you or your staff have any questions.

Major contributors to this report are listed in appendix X.

James R. White

Director, Tax Policy

and Administration

Page 17 GAO/GGD-99-11 IRS Personnel Administration
Contents

Letter 1

Appendix I 

Potential Violations

Reported on Fiscal

Years 1996 and 1997

Certifications

22

Appendix II 

GAO Sampling

Methodology

25

Sample Designs 25

Sample Disposition 26

Calculation of Sample Estimates 27

Sampling Error 27

Nonsampling Error 27

Appendix III 

Survey Results on

Employee Perceptions

of the Effect of Tax

Enforcement Results

on Evaluations

28

Appendix IV 

Survey Results on the

Basis for Employee

Perceptions That

Enforcement Results

Affect Evaluations

34

Page 18 GAO/GGD-99-11 IRS Personnel Administration
Contents

Appendix V 

Survey Results on

Inclusion of

Enforcement Results

in Group Goals

37

Appendix VI 

Examples of

Voluntary Employee

Comments Included

on Surveys of IRS

Employees

39

Comments Indicating That Supervisors or Managers Implied That

an Employee’s Performance Evaluation Was Influenced by

Enforcement Results

39

Comments Indicating That the General Culture or Atmosphere of

IRS Implied That Enforcement Results Affected Performance

Evaluations

40

Comments Indicating That Higher Level Managers Pressured

Group Managers to Increase Production or Yield

40

Comments Indicating That IRS’ Business Plan, Reports, and

Other Documents Emphasized Enforcement Results

40

Positive Comments on the Use of Enforcement Results 41

Negative Comments on the Use of Enforcement Results 41

Appendix VII 

Results of Review of

Employee Evaluations

43

Appendix VIII 

Comments From the

Internal Revenue

Service

44

Appendix IX 

Examples of

Certification Forms

50

Page 19 GAO/GGD-99-11 IRS Personnel Administration
Contents

Appendix X 

Major Contributors to

This Report

52

Tables Table II.1: Disposition of Sample Cases for Our Survey of the

Extent to Which Employees Perceived Their Ratings Were Based

on Enforcement Results

26

Table II.2: Disposition of Sample Cases for Our Review of the

Extent to Which Enforcement Results Were Discussed in

Employees’ Evaluations

26

Table III.1: Estimated Percent of Front-Line Employees and

Managers Who Perceived That Tax Enforcement Results Were

Considered by Their Supervisor or Manager In Preparing Their

Most Recent Performance Evaluation

28

Table III.2: Estimated Percent of Revenue Agents Who Perceived

Tax Enforcement Results Were Considered by Their Supervisor

or Manager In Preparing Their Most Recent Performance

Evaluation

29

Table III.3: Estimated Percent of Tax Auditors Who Perceived

Tax Enforcement Results Were Considered by Their Supervisor

or Manager In Preparing Their Most Recent Performance

Evaluation

30

Table III.4: Estimated Percent of Revenue Officers Who

Perceived Tax Enforcement Results Were Considered by Their

Supervisor or Manager in Preparing Their Most Recent

Performance Evaluation

31

Table III.5: Estimated Percent of Examination Division Group

Managers Who Perceived Tax Enforcement Results Were

Considered by Their Supervisor or Manager In Preparing Their

Most Recent Performance Evaluation

32

Table III.6: Estimated Percent of Collection Division Group

Managers Who Perceived Tax Enforcement Results Were

Considered by Their Supervisor or Manager in Preparing Their

Most Recent Performance Evaluation

33

Table IV.1: Estimated Percent of Front-Line Employees and

Managers Whose Perception Was Based on Verbal and/or Written

Communication

34

Table IV.2: Estimated Percent of Front-Line Employees and

Managers Who Had Various Bases for Their Perception That Tax

Enforcement Results Influenced Their Evaluation

35

Page 20 GAO/GGD-99-11 IRS Personnel Administration
Contents

Table IV.3: Estimated Percent of Revenue Agents, Tax Auditors,

and Revenue Officers Who Had Various Bases for Their

Perception That Tax Enforcement Results Influenced Their

Evaluation

35

Table IV.4: Estimated Percent of Examination and Collection

Division Group Managers Who Had Various Bases for Their

Perception That Tax Enforcement Results Influenced Their

Evaluation

36

Table V.1: Estimated Percent of Front-Line Employees and

Managers Who Had Performance Goals Established for Their

Group in Calendar Year 1997

37

Table V.2 Estimated Percent of Revenue Agents, Tax Auditors,

and Examination Group Managers Who Had Performance Goals

Established for Their Group That Included at Least One Tax

Enforcement Result

38

Table V.3: Estimated Percent of Revenue Officers and Collection

Group Managers Who Had Performance Goals Established for

Their Group That Included at Least One Tax Enforcement Result

38

Table VII.1: Estimated Percent of Employees Whose Performance

Evaluations Contained References to Tax Enforcement Results

43

Abbreviations

IRS Internal Revenue Service

NTEU National Treasury Employees Union

Page 21 GAO/GGD-99-11 IRS Personnel Administration
Appendix I 

Potential Violations Reported on Fiscal

Years 1996 and 1997 Certifications

This appendix is a summary list of all potential violations that were

reported on quarterly certifications for fiscal years 1996 and 1997. No

violations were reported in the quarters ending June 30, 1996,

September 30, 1996, and December 31, 1996. The Internal Revenue Service

(IRS) determined that the reported incidents numbered 1, 2, 5, and 11 were

actual violations.

1. Quarter Ending 12/31/95. A branch chief discussed enforcement

statistics in a group manager’s evaluation. According to a district office

official, the violation, discovered during the next level review, was a

statement to the effect that “Your group led the branch in the number of

seizures.” Corrective action included assigning the individual to another

position outside the Collection Division, assigning an acting branch chief

until a permanent replacement could be brought in, and reviewing

guidelines.

2. Quarter Ending 03/31/96. A proposal to redesign the revenue officer

position under an IRS test project recommended that individual groups

negotiate their own production goals. One group established a goal to

increase the amount of dollars collected by 10 percent in the next year.

The National Office Coordinator certified that this goal was not a policy

violation because (1) it was established as a part of a test, and (2) awards

or individual evaluations would not be based on the achievement of the

goal. District officials were still uncertain about whether this goal was in

conflict with policy and requested an opinion from the Office of Assistant

Commissioner (Collection), who in turn requested legal advice from IRS’

Chief Counsel. The Chief Counsel ruled that the group’s goal was a

violation because it was a production quota or goal and corrective action

needed to be taken to be in compliance with policy. The Chief Counsel

also cautioned that IRS managers must have the authority to void goals

negotiated under the test project if the goals violated law or policy.

3. Quarter Ending 03/31/97. A local chapter of the National Treasury

Employees Union (NTEU) raised a concern about a branch chief who

discussed the number of seizures reflected on a monthly activity report

with his group managers. Although this instance was reported on the

quarterly certification, the incident was not considered a violation

because, under the policy, managers can discuss recorded statistics with

employees as long as they do not imply that goals or quotas are being

established. Because the comments were open to misinterpretation,

district management said they reinforced the policy guidelines.

Page 22 GAO/GGD-99-11 IRS Personnel Administration
Appendix I 

Potential Violations Reported on Fiscal

Years 1996 and 1997 Certifications

4. Quarter Ending 03/31/97. An Automated Call Site manager discussed the

low number of calls made during 1 week with his employees and

requested them to quadruple the number of calls. The manager also

commended the group on the number of closures they made and identified

the number of closures he was “going for.” Although this instance was

reported, it was not considered a violation because (1) Automated Call

Site calls were not considered an enforcement statistic and (2) individual

goals were not established. Nonetheless, the manager was counseled and

requested to immediately meet with his team again to emphasize that it

was the quality of the case work that resulted in the closures.

5. Quarter Ending 06/30/97. A group manager prepared a positive employee

evaluation that was based on the amount of dollars collected. According to

a district office official, this violation was discovered during a branch

manager’s quarterly policy review. The group manager was counseled and

the evaluation was revised.

6. Quarter Ending 09/30/97. A district reported a pending allegation in

which an employee claimed he was forced to make seizures. According to

a district official, based on subsequent district and regional offices’

investigations, the allegation was found to be unwarranted.

7. Quarter Ending 09/30/97. A district identified, during a division and

branch chiefs’ sample review of employees’ performance binders, a few

instances in which performance evaluations and documents contained

enforcement results that could easily be misconstrued as violations (e.g.,

“His collection actions resulted in both the generation of substantial

revenue and in the proper disposition of numerous cases”; “You have

processed a number of Offer In Compromise recommendations”; etc.).

Corrective actions included emphasizing the policy guidelines on the use

of tax enforcement results and requiring more thorough reviews to assess

adherence with policy and the law.

8. Quarter Ending 09/30/97. An acting branch manager distributed a

memorandum to group managers indicating dollars collected were low

and needed to be improved. Although not a violation, the acting branch

manager was advised by the division chief that his memorandum was

inappropriate and could be misconstrued. He was also instructed to

schedule a meeting with the group managers on the real intent of his

message to ensure they understood the focus was to identify reasons for

the current level of performance and find ways to improve it.

Page 23 GAO/GGD-99-11 IRS Personnel Administration
Appendix I 

Potential Violations Reported on Fiscal

Years 1996 and 1997 Certifications

9. Quarter Ending 09/30/97. According to the NTEU, a group manager shared

with his group a report containing revenue officers’ statistical

accomplishments, including a recap of the dollars collected over a 3-year

period. As a corrective action, managers were given instructions that this

information should not be shared at the group level and that branch

statistics, comparing groups within a branch, should not be shared below

the branch level. While this was not classified as a violation at that time,

district management officials said they would consider it a violation under

the new draft certification procedures.

10. Quarter Ending 09/30/97. The NTEU reported an allegation that, in the

presentation of a manager’s award, a group manager mentioned that the

revenue officer being honored had made the most seizures in the group.

The manager denied making that statement, and the incident was not

considered a violation. District officials said that, although not directly

related to this incident, several actions were taken, including holding

meetings and briefings to discuss the policy and the discontinuation of the

distribution of statistics.

11. Quarter Ending 09/30/97. The NTEU and an outside party reported that a

group manager placed a routing slip on employees’ desks indicating the

amount of dollars that needed to be collected by each revenue officer each

day, week, and month. The group manager was temporarily reassigned

until an investigation and administrative determination was completed.

Instructions were given to branch chiefs not to provide statistical

information below their branch level. As a general corrective action

applicable to these three incidents, a meeting was held to discuss the

importance of adhering to the policy and law, and guidance was

distributed to managers.

Page 24 GAO/GGD-99-11 IRS Personnel Administration
Appendix II 

GAO Sampling Methodology

This appendix discusses the sampling methodology we used to determine

IRS employees’ perceptions of the use of tax enforcement results and how

tax enforcement results were used in employee evaluations.

Sample Designs To determine IRS employees’ perceptions of the use of tax enforcement

results, we conducted statistically representative surveys of five groups of

IRS employees: (1) revenue agents assigned to district office Examination

Divisions and Employee Plans and Exempt Organizations Divisions,

(2) tax auditors assigned to Examination Divisions, (3) revenue officers

assigned to Collection Divisions, (4) group managers assigned to

Examination Divisions and Employee Plans and Exempt Organizations

Divisions, and (5) group managers assigned to Collection Divisions. To

determine how tax enforcement results were used in employee

evaluations, we reviewed performance evaluations for a separately drawn

sample of revenue agents assigned to district office Examination Divisions

and Employee Plans and Exempt Organizations Divisions, tax auditors

assigned to Examination Divisions, and revenue officers assigned to

Collection Divisions.

Both samples were drawn from IRS’ personnel database as of January 3,

1998. Because the questionnaires for the employee surveys were not

mailed until March 1998, the results do not include the opinions of any IRS

employees who were in the groups of interest as of January 3, 1998, but

were not in these groups at the time the questionnaire was sent. We

assumed that the opinions of these employees, if they would have been

included, would have been the same in the aggregate as those of

employees who were included in the surveys. We sampled a total of 1,104

IRS employees from the 5 employee groups of interest from the population

of 20,974 employees in the January 3, 1998, IRS personnel database. We

allocated proportionately more of our sample to Collection Division

revenue officers and managers, since they are directly engaged in

collection activities.

For the objective of determining how tax enforcement results were used in

employee evaluations, we reviewed the evaluations of a sample of 300 IRS

employees from the 3 employee groups of interest. By design, none of the

300 employees selected were the same as the 1,104 employees sampled for

the first objective. IRS managers are not required to write performance

narratives for every rating dimension for every employee each year. To

review more narratives, the two most recent ratings were requested from

IRS for each employee in the sample. The results presented in the report

Page 25 GAO/GGD-99-11 IRS Personnel Administration
Appendix II 

GAO Sampling Methodology

only reflect employees for whom two performance evaluations were

received.

Sample Disposition For our survey of employees’ perceptions of the use of tax enforcement

results, we received usable responses (those that indicated the employee

was a member of one of the five target groups at the time the

questionnaire was received and responded to at least some of the

questions) from 814 employees, for a response rate of approximately

74 percent. The disposition of the sampled cases for our employee survey

and review of performance evaluations is shown in table II.1 and table II.2,

respectively.

Table II.1: Disposition of Sample Cases for Our Survey of the Extent to Which Employees Perceived Their Ratings Were

Based on Enforcement Results

Initial selection Nonrespondents

Strata ID Definition of strata

Number in

universe

Number of

selections

Eligible

respondents

Known

ineligible

Unknown

eligibility

1 Examination group managers 1,335 125 100 3 22

2 Collection group managers 543 175 123 13 39

3 Tax auditors 1,867 125 84 6 35

4 Revenue agents 11,796 320 250 11 59

5 Revenue officers 5,433 359 257 8 94

Total 20,974 1,104 814 41 249

Source: IRS data and GAO sample.

Table II.2: Disposition of Sample Cases for Our Review of the Extent to Which Enforcement Results Were Discussed in

Employees’ Evaluations

Initial selection Nonrespondents

Strata ID Definition of strata

Number in

universe

Number of

selections

Eligible

respondents Eligible

Known

ineligible

Unknown

eligibility

1 Tax auditors 1,867 30 28 1 1

2 Revenue agents 11,796 135 127 2 6

3 Revenue officers 5,433 135 120 6 9

Total 19,096 300 275 9 16

Source: IRS data and GAO sample.

Page 26 GAO/GGD-99-11 IRS Personnel Administration
Appendix II 

GAO Sampling Methodology

Calculation of Sample

Estimates

After weighting the responses to the employee survey to account for

selection probabilities and nonresponse, we were able to estimate the

percentage of IRS employees who perceived that certain tax enforcement

results were or were not used in their evaluations. We also were able to

estimate the percentage of IRS employees for whom tax enforcement

results were used in at least one of their two most recent employee

evaluations.

Sampling Error Because we reviewed a statistical sample of employees, each estimate

developed from the samples had a measurable precision or sampling error.

The sampling error is the maximum amount by which the estimate

obtained from a statistical sample can be expected to differ from the true

population value being estimated. Sampling errors are stated at a certain

confidence level—in this case, 95 percent. This means that the chances are

19 out of 20 that, if we surveyed all IRS employees in the groups of interest,

the true value obtained for a question on these surveys would differ from

the estimate obtained from our sample by less than the sampling error for

that question.

The sampling errors for our survey of the extent to which employees

perceived that their ratings were based on enforcement results are less

than plus or minus 10 percentage points, unless otherwise reported. The

sampling errors for our sample of the extent to which enforcement results

were discussed on employee evaluations are no more than plus or minus

8 percentage points.

Nonsampling Error In addition to the reported sampling errors, the practical difficulties of

conducting any survey may introduce other types of “nonsampling”

errors. For example, differences in how a particular question is interpreted

or the types of individuals that do not respond can introduce unwanted

variability into the survey results.

Page 27 GAO/GGD-99-11 IRS Personnel Administration
Appendix III 

Survey Results on Employee Perceptions of

the Effect of Tax Enforcement Results on

Evaluations

Our survey asked a representative sample of IRS employees the question

“To what extent, if at all, do you perceive that each of the following factors

was considered by your supervisor or managers in preparing your most

recent performance evaluation?” The “factors” shown for this question

were the tax enforcement results associated with each employee category.

The responses are shown in tables III.1 through III.6.

To compare the perceptions of front-line employees and managers, we

consolidated the responses of front-line employees (revenue agents, tax

auditors, and revenue officers) and managers (Examination Division and

Collection Division group managers) as shown in table III.1.

Table III.1: Estimated Percent of

Front-Line Employees and Managers

Who Perceived That Tax Enforcement

Results Were Considered by Their

Supervisor or Manager in Preparing

Their Most Recent Performance

Evaluation

Percent

Employee group

One or more factors

considered

Factor not considered/

Do not know if

factor(s) considered

Front-line employees 75 25

Managers 81 19

Source: GAO analysis of employee survey results.

Page 28 GAO/GGD-99-11 IRS Personnel Administration
Appendix III 

Survey Results on Employee Perceptions of

the Effect of Tax Enforcement Results on

Evaluations

Table III.2: Estimated Percent of

Revenue Agents Who Perceived Tax

Enforcement Results Were Considered

by Their Supervisor or Manager in

Preparing Their Most Recent

Performance Evaluation

Percent

Tax Enforcement Result

To no extent/

do not knowa

To some/

moderate

extent

To great/

very great

extent

Average hours spent per return 27 30 43

Additional dollars proposed per

return

39 24 37

Additional dollars proposed per

hour

40 25 36

Number of criminal and civil fraud

referrals

57c 28 15

No-change rate for examined

returns

53 26 21

Number of work units closed 41 32 27

Number of first contact closuresb 80 12 8

Note: Percents may not add to 100 percent due to rounding.

aWe assumed the behavior of employees who responded “To no extent” to be the same as that of

employees who responded “Do not know” because neither category would be encouraged to

take inappropriate case action to receive a positive evaluation.

bThe category “Number of first contact closures” refers to the number of times the IRS employee

was able to close the case based on information provided during the first contact with the

taxpayer.

cSampling error is plus or minus 10.15 percent.

Source: GAO analysis of employee survey results.

Page 29 GAO/GGD-99-11 IRS Personnel Administration
Appendix III 

Survey Results on Employee Perceptions of

the Effect of Tax Enforcement Results on

Evaluations

Table III.3: Estimated Percent of Tax

Auditors Who Perceived Tax

Enforcement Results Were Considered

by Their Supervisor or Manager in

Preparing Their Most Recent

Performance Evaluation

Percent

Tax enforcement result

To no extent/

do not knowa

To some/

moderate

extent

To great/

very great

extent

Average hours spent per return 22 36d 42e

Additional dollars proposed per

return

38c 31 31

Additional dollars proposed per

hour

37c 25 38e

Number of criminal and civil fraud

referrals

33 42d 25

No-change rate for examined

returns

43c 38d 19

Number of work units closed 31 36d 33

Number of first contact closuresb 33 40d 26

Note: Percents may not add to 100 percent because not all respondents completed each tax

enforcement result category.

aWe assumed the behavior of employees who responded “To no extent” to be the same as that of

employees who responded “Do not know” because neither category would be encouraged to

take inappropriate case action to receive a positive evaluation.

bThe category “Number of first contact closures” refers to the number of times the IRS employee

was able to close the case based on information provided during the first contact with the

taxpayer.

cSampling errors range from plus or minus 10.15 percent to plus or minus 10.40 percent.

dSampling errors range from plus or minus 10.07 percent to plus or minus 10.37 percent.

eSampling errors range from plus or minus 10.21 percent to plus or minus 10.44 percent.

Source: GAO analysis of employee survey results.

Page 30 GAO/GGD-99-11 IRS Personnel Administration
Appendix III 

Survey Results on Employee Perceptions of

the Effect of Tax Enforcement Results on

Evaluations

Table III.4: Estimated Percent of

Revenue Officers Who Perceived Tax

Enforcement Results Were Considered

by Their Supervisor or Manager in

Preparing Their Most Recent

Performance Evaluation

Percent

Tax enforcement result

To no extent/

do not knowa

To some/

moderate

extent

To great/

very great

extent

Average dollars collected per return 71 18 11

Number or returns secured 67 23 10

Number of installment agreements

obtained

71 23 6

Number of installment agreements

defaulted

80 15 5

Number of levies filed 67 15 17

Number of liens filed 66 17 18

Number of seizures 60 16 24

Number of cases closed 41 21 37

Number of cases closed as

“currently not collectable”

64 30 6

Number of fraud referrals 74 18 8

Note: Percents may not add to 100 percent because not all respondents completed each tax

enforcement result category or due to rounding.

aWe assumed the behavior of employees who responded “To no extent” to be the same as that of

employees who responded “Do not know” because neither category would be encouraged to

take inappropriate case action to receive a positive evaluation.

Source: GAO analysis of employee survey results.

Page 31 GAO/GGD-99-11 IRS Personnel Administration
Appendix III 

Survey Results on Employee Perceptions of

the Effect of Tax Enforcement Results on

Evaluations

Table III.5: Estimated Percent of

Examination Division Group Managers

Who Perceived Tax Enforcement

Results Were Considered by Their

Supervisor or Manager in Preparing

Their Most Recent Performance

Evaluation

Percent

Tax enforcement result

To no extent/

do not knowa

To some/

moderate

extent

To great/

very great

extent

Average hours spent per return 26 33 41

Additional dollars proposed per

return

28 32 40

Additional dollars proposed per

hour

24 22 54

Number of criminal and civil fraud

referrals

37 37 26

No-change rate for examined

returns

38 43 19

Number of work units closed 42 30 28

Number of first contact closuresb 77 13 10

aWe assumed the behavior of employees who responded “To no extent” to be the same as that of

employees who responded “Do not know” because neither category would be encouraged to

take inappropriate case action to receive a positive evaluation.

bThe category “Number of first contact closures” refers to the number of times the IRS employee

was able to close the case based on information provided during the first contact with the

taxpayer.

Source: GAO analysis of employee survey results.

Page 32 GAO/GGD-99-11 IRS Personnel Administration
Appendix III 

Survey Results on Employee Perceptions of

the Effect of Tax Enforcement Results on

Evaluations

Table III.6: Estimated Percent of

Collection Division Group Managers

Who Perceived Tax Enforcement

Results Were Considered by Their

Supervisor or Manager in Preparing

Their Most Recent Performance

Evaluation

Percent

Tax enforcement result

To no extent/

do not knowa

To some/

moderate

extent

To great/

very great

extent

Average dollars collected per return 61 20 19

Number or returns secured 61 25 14

Number of installment agreements

obtained

61 32 7

Number of installment agreements

defaulted

84 11 5

Number of levies filed 71 18 11

Number of liens filed 76 17 7

Number of seizures 57 25 18

Number of cases closed 23 35 42

Number of cases closed as

“currently not collectable”

55 34 11

Number of fraud referrals 61 29 9

Note: Percents may not add to 100 percent because not all respondents completed each tax

enforcement result category.

aWe assumed the behavior of employees who responded “Do not know” to be the same as that of

employees who responded “To no extent.”

Source: GAO analysis of employee survey results.

Page 33 GAO/GGD-99-11 IRS Personnel Administration
Appendix IV 

Survey Results on the Basis for Employee

Perceptions That Enforcement Results

Affect Evaluations

For survey respondents who perceived that their supervisor or manager

considered one or more tax enforcement results in preparing their most

recent performance evaluation, we asked “Why do you believe that one or

more of the factors for which you checked box 2 through 5 [To some

extent, To a moderate extent, To a great extent, To a very great extent] in

[the prior question] influenced your rating?” They were asked to check all

the reasons that applied. The responses are shown in tables IV.1 through

IV.8.

To compare the perceptions of front-line employees and managers, we

consolidated the responses of front-line employees (revenue agents, tax

auditors, and revenue officers) and managers (Examination Division and

Collection Division group managers) as shown in table IV.1. To compare

the importance of verbal and written communications, we also

consolidated the responses indicating verbal communications (feedback

and meetings) and written communications (performance expectations,

performance evaluations, and award justifications). Two other

categories—promotion patterns and a general “other” category—are

reported separately.

Table IV.1: Estimated Percent of

Front-Line Employees and Managers

Whose Perception Was Based on

Verbal and/or Written Communication

Percent

Employee category

Verbal

communication

Written

communication

Front-line employees 70 49

Managers 83 51

Source: GAO analysis of employee survey results.

The responses of front-line employees and managers on the specific basis

for their perception that tax enforcement results affected their ratings are

given in tables IV.2 through IV.4.

Page 34 GAO/GGD-99-11 IRS Personnel Administration
Appendix IV 

Survey Results on the Basis for Employee

Perceptions That Enforcement Results

Affect Evaluations

Table IV.2: Estimated Percent of

Front-Line Employees and Managers

Who Had Various Bases for Their

Perception That Tax Enforcement

Results Influenced Their Evaluation

Basis for employees’ and managers’ perception

that tax enforcement results influenced evaluation

Front-line

employees

(percent)

Managers

(percent)

One or more factors were mentioned in my

performance expectations

29 27

One or more factors were mentioned in my

performance evaluation

36 41

One or more factors were mentioned in feedback I

received from my group/branch manager

52 69

One or more factors were mentioned by my

group/branch manager in group meetings

56 70

One or more factors were mentioned in an award

justification

13 18

One or more factors were mentioned in a promotion

justification

6 2

Promotion patterns suggest that management

considers one or more factors

37 19

Other - Please describea 30 31

aThe category “other” is discussed in greater detail in appendix VI.

Source: GAO analysis of employee survey results.

Table IV.3: Estimated Percent of

Revenue Agents, Tax Auditors, and

Revenue Officers Who Had Various

Bases for Their Perception That Tax

Enforcement Results Influenced Their

Evaluation

Basis for employees’ perception that tax

enforcement results influenced evaluation

Revenue

agents

(percent)

Tax auditor

(percent)

Revenue

officer

(percent)

One or more factors were mentioned in my

performance expectations

27 30b 34

One or more factors were mentioned in my

performance evaluation

35 29b 41

One or more factors were mentioned in

feedback I received from my group manager

50 48b 56

One or more factors were mentioned by my

group manager in group meetings

55 74 50

One or more factors were mentioned in an

award justification

13 14 11

One or more factors were mentioned in a

promotion justification

5 1 9

Promotion patterns suggest that

management considers one or more factors

36 23 43

Other - Please describea 29 23 35

aThe category “other” is discussed in greater detail in appendix VI.

bSampling errors range from plus or minus 10.21 percent to plus or minus 10.35 percent.

Source: GAO analysis of employee survey results.

Page 35 GAO/GGD-99-11 IRS Personnel Administration
Appendix IV 

Survey Results on the Basis for Employee

Perceptions That Enforcement Results

Affect Evaluations

Table IV.4: Estimated Percent of

Examination and Collection Division

Group Managers Who Had Various

Bases for Their Perception That Tax

Enforcement Results Influenced Their

Evaluation

Basis for managers’ perception that tax

enforcement results influenced evaluation

Examination

managers

(percent)

Collection

managers

(percent)

One or more factors were mentioned in my

performance plan (Form 9688)

29 23

One or more factors were mentioned in my

performance evaluation

44b 36

One or more factors were mentioned in

feedback I received from my branch chief

76 58

One or more factors were mentioned by my

division chief or branch chief in group meetings

71 68

One or more factors were mentioned in an

award justification

17 21

One or more factors were mentioned in a

promotion justification

3 2

Promotion patterns suggest that management

considers one or more factors

21 16

Other - Please describea 27 38

aThe category “other” is discussed in greater detail in appendix VI.

bSampling error is plus or minus 10.64 percent.

Source: GAO analysis of employee survey results.

Page 36 GAO/GGD-99-11 IRS Personnel Administration
Appendix V 

Survey Results on Inclusion of Enforcement

Results in Group Goals

Our survey asked a representative sample of IRS employees “To your

knowledge, were performance goals established for your group in

calendar year 1997?”

To compare the perceptions of front-line employees and managers, we

consolidated the responses of front-line employees (revenue agents, tax

auditors, and revenue officers) and managers (Examination Division and

Collection Division group managers) as shown in table V.1.

Table V.1: Estimated Percent of

Front-Line Employees and Managers

Who Had Performance Goals

Established for Their Group in

Calendar Year 1997

Employee category Percent

Front-line employees 44

Managers 49

Revenue agents 44

Tax auditors 46a

Revenue officers 46

Examination Division group managers 45

Collection Division group managers 54

aSampling error is plus or minus 10.54 percent.

Source: GAO analysis of employee survey results.

For those employees who had group performance goals, we asked “Did

the performance goals established for your group in calendar year 1997

include any reference to any of the following factors?” The point estimates

and confidence intervals for each employee group are shown in tables V.2

and V.3.

Page 37 GAO/GGD-99-11 IRS Personnel Administration
Appendix V 

Survey Results on Inclusion of Enforcement

Results in Group Goals

Table V.2 Estimated Percent of

Revenue Agents, Tax Auditors, and

Examination Group Managers Who

Had Performance Goals Established

for Their Group That Included at Least

One Tax Enforcement Result

Tax enforcement result

Revenue agent

(percent)

Tax auditor

(percent)

Examination

manager

(percent)

Average hours spent per return 77 89 60d

Additional dollars proposed per

return

54b 55c 53d

Additional dollars proposed per

hour

76 66c 70d

Number of criminal and civil fraud

referrals

38 59c 47d

No-change rate for examined

returns

50b 51c 23d

Number of units closed 49b 74c 28d

Number of first contact closuresa 11 57c 7

aThe category “number of first contact closures” refers to the number of times the IRS employee

was able to close the case based on information provided during the first contact with the

taxpayer.

bSampling errors range from plus or minus 10.35 percent to plus or minus 10.90 percent.

cSampling errors range from plus or minus 13.80 percent to plus or minus 15.90 percent.

dSampling errors range from plus or minus 12.21 percent to plus or minus 14.41 percent.

Source: GAO analysis of employee surveys.

Table V.3: Estimated Percent of

Revenue Officers and Collection

Group Managers Who Had

Performance Goals Established for

Their Group That Included at Least

One Tax Enforcement Result

Tax enforcement result

Revenue

officer

(percent)

Collection

manager

(percent)

Average dollars collected per return 40 43a

Number of returns secured 33 30a

Number of installment agreements obtained 11 11

Number of installment agreements defaulted 6 2

Number of levies filed 23 8

Number of liens filed 16 6

Number of seizures 32 15

Number of cases closed 70 70

Number of cases closed as “currently not collectable” 24 15

Number of fraud referrals 13 8

aSampling errors range from plus or minus 10.01 percent to plus or minus 10.63 percent.

Source: GAO analysis of employee survey results.

Page 38 GAO/GGD-99-11 IRS Personnel Administration
Appendix VI 

Examples of Voluntary Employee

Comments Included on Surveys of IRS

Employees

This appendix gives some examples of voluntary written comments by

front-line employees and group managers to our questionnaires on why

they believe enforcement results influenced their performance

evaluations.2

 The comments generally involved the following scenarios:

(1) supervisors or managers implied that an employee’s performance

evaluation was influenced by tax enforcement results; (2) the general

culture or atmosphere of IRS implied that enforcement results affected

performance evaluations; (3) higher level managers pressured group

managers to increase production or revenue yield; and (4) IRS’ business

plan, reports, and other documents emphasized enforcement results as

goals. Front-line employees and managers also wrote about positive and

negative effects of using enforcement and workload measures to establish

group goals or in performance evaluations. Generally, the number of

negative comments made by front-line employees and managers exceeded

the number of positive comments.

Comments Indicating

That Supervisors or

Managers Implied

That an Employee’s

Performance

Evaluation Was

Influenced by

Enforcement Results

• “The district office provided monthly statistics to each branch, rating

branches and groups based on ‘dollars per hour,’ ‘dollars per return,’

‘no-change rate,’ [and] ‘collections percent by exam division.’ . . . Even

though performance goals were not established formally based on ‘dollars

per return,’ etc., the statistics were mentioned at each group meeting and

pressure was felt by each agent to assess the most tax at the least amount

of time spent on the case. It was always felt that our evaluations were

based indirectly on the factors mentioned in Item 19 (productivity and

enforcement statistics).”

• “Our emphasis used to be on quality and customer service but when our

district went under Boston, the emphasis changed to ‘dollars per hour.’ At

each group meeting, we would hear about ‘stats’ and ‘dollars per hour.’

This kind of pressure does tend to carry over into the work product.”

• “Although numbers [were] never mentioned, [my] group manager

discussed closure of cases, fraud referrals, and defaulted installment

agreements in meetings and in appraisals so it gave the appearance that

[is] what he expected.”

• “We were told by management in group meetings and in town hall

meetings that goals in the form of yield (dollars per hour) would no longer

be set. Yet, at group meetings, our manager reads our yield from Table 37

[a management information report] and comments on whether it is good,

bad, or fair. Our yield is obviously still very important to management.”

2

Of the 814 surveys received, a total of 402 front-line employees and 151 group managers added

voluntary comments.

Page 39 GAO/GGD-99-11 IRS Personnel Administration
Appendix VI 

Examples of Voluntary Employee

Comments Included on Surveys of IRS

Employees

Comments Indicating

That the General

Culture or

Atmosphere of IRS

Implied That

Enforcement Results

Affected Performance

Evaluations

• “There is one important goal in any revenue agent’s life—dollars per hour.

From the day I started with the Service until the present, that has been the

only constant in the organization. Quality programs have come and gone,

emphasis on taxpayer service ebbs and flows, lip service to auditing

standards is periodically given. Through it all, any successful revenue

agent knows that low time and high dollars will result in recognition,

promotion, and awards.”

• “It is well known that these factors are considered by upper management

to be important, although not all are mentioned in evaluations.”

• “Management has never been specific relative to the connection between

promotion and enforcement. However, the perception is here that the

more enforcement minded a revenue officer is, the greater the chance of

promotion.”

• “You are expected (unsaid) to do a seizure every quarter.”

Comments Indicating

That Higher Level

Managers Pressured

Group Managers to

Increase Production

or Yield

• “. . . [My present manager] was required to post statistics on most of these

items on our library room wall up to just a few months ago. When

Congress started seriously making noises about statistics, they were taken

down. . . . [My manager] would make reference to these statistics in a

general way as pressure was put on him through his chain of command.

The pressure relative to improving these statistics came primarily by

passing word down from the chief of audit and his assistant chief that our

statistics were not measuring up. . . .”

• “The manager only works toward faster closures and higher yield because

it has been stressed by the district management.”

Comments Indicating

That IRS’ Business

Plan, Reports, and

Other Documents

Emphasized

Enforcement Results

• “Time and dollars per hour, although less so within the past few years, has

always been a major consideration in ‘informal’ discussions and meetings.

Tables 36 and 37 [management information reports] were always utilized

and disbursed to the group and discussed with agents, although seldom in

writing.”

• “Statistics on dollars collected, number of returns [secured], number of

levies and liens were reported by group on a monthly basis to the division

via the branch chief.”

• “Monthly statistics . . . were distributed regarding levies, dollars collected,

liens, seizures, fraud referrals, currently not collectible cases, and cases

closed.”

Page 40 GAO/GGD-99-11 IRS Personnel Administration
Appendix VI 

Examples of Voluntary Employee

Comments Included on Surveys of IRS

Employees

Positive Comments on

the Use of

Enforcement Results

• “If a revenue agent is doing a good job, these factors (adjustments, etc.)

are present. The revenue agent will have good adjustments that are

technically correct and will also have no-changes. That is part of the job.”

• “Both time spent on a return and deficiencies are indicators of

effectiveness and efficiency in the audit process. Excessive time may

indicate complexity of issues or inefficiency and floundering in the audit.

The deficiency amount will indicate effectiveness of audit as compared to

similar audits or, potentially, a lack of issue identification. When used as

indicators of efficiency or effectiveness, these can help direct employees

toward improvement. It’s not all bad.”

• “Our job is to collect (hence ‘collection’) dollars and returns. It is ludicrous

to think that a revenue officer who collected no dollars or returns would

get a good performance evaluation. After all—that is our job!”

• “I definitely feel pressure to be productive in terms of dollars per hour, but

realistically, that makes sense to me. We should spend time on issues

which will most likely produce revenue and work them as quickly as

possible.”

Negative Comments

on the Use of

Enforcement Results

• “Statistics regarding ‘dollars per hour’ are disseminated at group meetings.

Our group is compared to the branch and the district. . . . Ten years ago

these kinds of statistics were never discussed at the group level. Due to

the constant referring to these numbers, it is obvious that ‘dollars per

hour’ is the most important concept to management. Consequently, agents

will always strive to get the highest yield per case. This means that you

will disregard adjustments in the taxpayers favor so as not to reduce the

tax yield. Individual statistics have not been discussed. However, the

constant reminder of the yield causes agents to do anything they can to get

good yield on their cases.”

• “Even though it is made very clear in the . . . region that there are no

individual or group enforcement goals, statistics are kept and very well

known throughout the region. Specifically, our ‘mission’ is very goal

oriented and very driven by the goals of the Chief of Collections. Very

clearly those groups that have good statistics—specifically the number of

seizures, cases closed, fraud referrals, etc.—receive special recognition. In

some cases, managers receive performance rewards. The revenue officers

who specifically take enforcement action to resolve cases are rewarded

with promotion even though the enforcement action is not mentioned in

the performance evaluation. Those revenue officers who are most

aggressive using enforcement are those rewarded most quickly with

promotion.”

Page 41 GAO/GGD-99-11 IRS Personnel Administration
Appendix VI 

Examples of Voluntary Employee

Comments Included on Surveys of IRS

Employees

• “National and regional management have used dollar goals and quotas for

as long as I can remember. It is common knowledge among employees and

first-line managers that ‘increase voluntary compliance’ equals ‘dollars per

hour.’ You get what you measure.”

• “Within the last couple of years, ‘dollars collected’ was being conveyed

from the division to the group level. This caused group comparisons and

competition. While never conveyed to an individual within my group that

dollars needed to be increased, it certainly was implied. While this didn’t

change my case decisions, I cannot speak for everyone.”

Page 42 GAO/GGD-99-11 IRS Personnel Administration
Appendix VII 

Results of Review of Employee Evaluations

Table VII.1 provides the results of our review of employee evaluations in

terms of whether the evaluations contained law or policy violations and

case or general discussions of enforcement-related activity.

Table VII.1: Estimated Percent of

Employees Whose Performance

Evaluations Contained References to

Tax Enforcement Results

Percent of employees whose

evaluations included tax enforcement

results references

Types of tax enforcement results

references

Collection

employees

Examination

employees Total

Law or policy violations 1 12 9

Case-specific discussion of:

1. Overage cases 2 12 6

2. Cycle time 1 2 2

3. Overage cases or cycle time 2 9 7

4. Assessment/Collection measures 33 31 32

A. Amount of revenue collected 14 N/A N/A

B. Use of collection tools 33 N/A N/A

C. Amount of revenue assessed N/A 25 N/A

D. Amount of dollars collected on

agreed cases

N/A 12 N/A

Any specific discussion of the above 33 38 37

General discussion of:

1. Overage cases 31 33 32

2. Cycle time 9 29 16

3. Overage cases or cycle time 32 34 33

4. Assessment/collection measures 75 20 36

A. Amount of revenue collected 9 N/A N/A

B. Use of collection tools 74 N/A N/A

C. Amount of revenue assessed N/A 17 N/A

D. Amount of dollars collected on

agreed cases

N/A 5 N/A

Any general discussion of the above 78 54 61

Any discussion of overage cases or cycle

time

38 43 41

Any discussion of assessment/collection

measures

75 40 50

Any discussion of any factors above 78 65 69

Note: N/A means not applicable to this employee category.

Source: GAO analysis of IRS employees’ performance evaluations.

Page 43 GAO/GGD-99-11 IRS Personnel Administration
Appendix VIII 

Comments From the Internal Revenue

Service

Page 44 GAO/GGD-99-11 IRS Personnel Administration
Appendix VIII 

Comments From the Internal Revenue

Service

Page 45 GAO/GGD-99-11 IRS Personnel Administration
Appendix VIII 

Comments From the Internal Revenue

Service

Page 46 GAO/GGD-99-11 IRS Personnel Administration
Appendix VIII 

Comments From the Internal Revenue

Service

Page 47 GAO/GGD-99-11 IRS Personnel Administration
Appendix VIII 

Comments From the Internal Revenue

Service

Page 48 GAO/GGD-99-11 IRS Personnel Administration
Appendix VIII 

Comments From the Internal Revenue

Service

Page 49 GAO/GGD-99-11 IRS Personnel Administration
Appendix IX 

Examples of Certification Forms

Page 50 GAO/GGD-99-11 IRS Personnel Administration
Appendix IX 

Examples of Certification Forms

Page 51 GAO/GGD-99-11 IRS Personnel Administration
Appendix X 

Major Contributors to This Report

General Government

Division

James A. Bell, Senior Statistician

James M. Fields, Senior Statistician

Stuart M. Kaufman, Senior Social Science Analyst

San Francisco Office Ralph T. Block, Assistant Director

Jonda Van Pelt, Evaluator-in-Charge

Shari Caporale, Senior Evaluator

Suzy Foster, Senior Evaluator

Sam Scrutchins, Senior Evaluator

John N. Zugar, Senior Evaluator

Atlanta Office Robert V. Arcenia, Senior Evaluator

Ronald J. Heisterkamp, Evaluator

Kansas City Office Benjamin Douglas, Senior Evaluator

(268823) Page 52 GAO/GGD-99-11 IRS Personnel Administration
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