IRS MANAGEMENT

IRS Faces Challenges

as it Restructures the

Office of the Taxpayer

Advocate

United States General Accounting Office

GAO Report to the Chairman, Committee on

Ways and Means, House of

Representatives

July 1999

GAO/GGD-99-124

United States

General Accounting Office

Washington, D.C. 20548

General Government Division

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Page 1 GAO/GGD-99-124 Taxpayer Advocate Office

GAO

July 15, 1999

The Honorable Bill Archer

Chairman, Committee on Ways and Means

House of Representatives

Dear Mr. Chairman:

Witnesses at the Senate Finance Committee hearings in September 1997

included taxpayers who described difficulties they had experienced in

trying to get help from the Internal Revenue Service (IRS) in resolving

ongoing problems. As a result of their experiences, specific concerns were

raised about the operations of IRS’ Office of the National Taxpayer

Advocate (Advocate’s Office) that had been created, in part, to help such

taxpayers.

You requested that we review operations of the Advocate’s Office and the

Problem Resolution Program (PRP) administered by that office. In

response to that request, this report discusses (1) challenges the National

Taxpayer Advocate (Advocate) faces in managing program resources, (2)

the potential effects of workload fluctuations on program operations, (3)

information available to help the Advocate determine the causes of

taxpayer problems and prevent their recurrence, and (4) the adequacy of

performance measures IRS uses to gauge program effectiveness.

As part of an agencywide effort to align IRS processes with taxpayer

needs, IRS is designing a new structure for the Advocate’s Office. With the

permission of your office, we briefed the Advocate and the IRS team

responsible for redesigning the Advocate’s Office several times during the

course of our review. During these briefings, we discussed various issues

that we had identified during our review and provided feedback on

proposed redesigns of the structure and operations of the Advocate’s

Office. Additionally, we testified on the results of our work at hearings

held by your Oversight Subcommittee on February 10, 1999.1

We identified various management and operational challenges facing IRS,

the Advocate’s Office, and PRP. How these challenges are addressed could

affect how efficiently and effectively taxpayers are helped by PRP.

 

1

IRS Management: Challenges Facing the National Taxpayer Advocate (GAO/T-GGD-99-28, Feb. 10,

1999).

Results in Brief
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First, the Advocate’s Office faced resource management challenges

because it lacked direct control over most PRP resources. Specifically, (1)

the Advocate’s Office did not know how many staff were working in PRP

or the costs associated with that staffing; (2) the Advocate’s Office had to

rely on resources provided by IRS’ operating functions, such as Customer

Service, Collections, and Examination; (3) some Advocate Office and PRP

staff reported that they lacked training that Advocate Office officials

considered necessary; and (4) the Advocate’s Office faced obstacles, such

as limited advancement opportunities, in acquiring and keeping qualified

staff. Planned changes to the Advocate’s Office and PRP, such as placing

PRP resources under the control of the Advocate’s Office, could mitigate

some of these issues. However, it is too early to evaluate the impact of

these changes.

Second, IRS faces challenges as it restructures the Advocate’s Office to

better handle variations in PRP’s workload. According to Advocate Office

officials, in the past, because PRP operations depended on IRS functional

units for resources, any fluctuations in PRP’s workload were handled by

adjusting the number of functional staff assigned to work PRP cases.

However, the Advocate’s Office is moving away from a structure that relies

on other IRS units for staffing, which may make it more difficult for the

Advocate’s Office to handle workload fluctuations, especially workload

increases. The Advocate told us that he was committed to helping any

taxpayer who contacts the office. While it is understandable why the

Advocate’s Office might not want to turn away anyone seeking help,

accepting cases that could be handled elsewhere in IRS could overburden

PRP.

Third, the demands on the Advocate’s Office to resolve individual taxpayer

problems has left little time for staff to spend identifying the causes of

recurring taxpayer problems and recommending solutions. Also,

limitations in the kind of information available provided little assurance

that the time being spent was being used most effectively. These efforts on

recurring problems, called advocacy, are key to the success of the

Advocate’s Office because the improvements they generate can reduce the

number of taxpayers who ultimately require help from PRP.

Finally, IRS lacked adequate measures of the effectiveness of the

Advocate’s Office and PRP. Measures of effectiveness should cover the full

range of Advocate Office operations so they can be used to improve

program performance, increase accountability, and support

decisionmaking. The set of measures used by the Advocate’s Office during

our review focused on descriptive program events instead of program
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outcomes; did not provide complete data; or were not based on consistent

data collection.

The Advocate’s Office is identifying and implementing changes aimed at

addressing some of the issues identified in this report; however, it is too

soon to tell the efficacy of these efforts. Additionally, some of the changes

might require more extensive efforts than are currently planned to

alleviate the problem cited.

IRS founded PRP in 1976 to provide an independent means of helping

taxpayers solve problems that they encountered in dealing with IRS.

Initially, PRP units were established in IRS district offices. In 1979, IRS

expanded PRP to its service centers and created the position of Taxpayer

Ombudsman to head PRP. The Ombudsman was appointed by and

reported to the Commissioner of Internal Revenue. Congress has since

renamed the Ombudsman the “National Taxpayer Advocate” and shifted

appointment authority to the Secretary of the Treasury.2

 However, the

Advocate continues to report to the Commissioner. To promote the

independence of the Advocate, Congress required that the individual not

be an IRS employee for 2 years preceding his or her appointment and that

the individual not accept a position elsewhere in IRS for 5 years following

his or her tenure as the Advocate.3

 The current Advocate was appointed in

August 1998, in accordance with these provisions. Additionally, to enhance

independence, the Advocate is required to submit annual reports directly

to Congress on the objectives and activities of the Advocate’s Office. These

reports are to be developed by the Advocate’s Office and are to be

submitted directly to Congress without any prior review or comment from

the Commissioner of Internal Revenue, the Secretary of the Treasury, or

any other officer or employee of the Department of the Treasury.

The Advocate manages an organization (i.e., the Advocate’s Office) that

has advocates in each of IRS’ 4 regions, 33 districts, 30 former districts,4

and 10 service centers and in the Executive Office for Service Center

Operations (EOSCO)5

 in Cincinnati, OH, and the Office of the Assistant

 

2

IRS Restructuring and Reform Act of 1998, P.L. 105-206 (July 22, 1998).

3

Service as an officer or employee of the Advocate’s Office is not taken into account for purposes of

the 2-year and 5-year rules.

4

In fiscal year 1996, IRS consolidated its field operations and reduced the number of districts from 63 to

33. The former 30 districts continue to have staff and operations, including a local advocate’s office.

5

Before the establishment of EOSCO, the regions were responsible for service centers within their

geographic boundaries. Organizationally, EOSCO is on a par with the regions.

Background
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Commissioner (International) in Washington, D.C.6 The regional and

EOSCO advocates are responsible for providing program oversight and

support to advocates in the district, former district, and service center

offices (hereafter referred to as “local advocates”), who manage PRP

operations at the local level. This program oversight and support is to

include reviewing PRP casework, ensuring the training of PRP staff and

staff in the Advocate’s Office, dealing with sensitive individual cases,

pursuing advocacy initiatives, and handling potential hardship cases.

Formerly, the regional and local advocates were selected by and reported

to the director of the regional office, district office, or service center where

they worked. However, the IRS Restructuring and Reform Act of 1998

changed that relationship. Now, regional advocates are to be selected by

and report to the National Taxpayer Advocate, and local advocates are to

be selected by and report to regional advocates.

At the time we completed our review in May 1999, most PRP casework

was being done by district office and service center staff, called

caseworkers, who were employees of IRS’ operating functions, such as

Customer Service, Collection, and Examination. In addition, each function

doing PRP work had a coordinator to ensure that all PRP cases within the

function were assigned to caseworkers and placed under PRP control and

to provide coordination between the function and the local advocates. PRP

caseworkers and coordinators were funded by the operating functions, not

the Advocate’s Office.

Also, each district office and service center had its own PRP structure,

which reflected differences in office size and composition and in the way

PRP caseworkers were managed. In the past, PRP caseworkers were

generally assigned to functional units and reported to functional managers.

In recent years, some local offices centralized their PRP casework in PRP

units staffed by functional employees who reported directly to the local

advocate.

The goals of the Advocate’s Office are consistent with IRS’ mission of

providing quality service to taxpayers by helping them meet their tax

responsibilities and by applying the tax laws fairly. The Advocate’s goals

are to

 

6

The Office of International District Operations serves essentially as a district office for taxpayers

living outside the United States.
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Page 5 GAO/GGD-99-124 Taxpayer Advocate Office

• assist taxpayers who cannot get their problems resolved through normal

IRS channels or those who are suffering significant hardships. For

example, local advocate offices can expedite tax refunds or stop

enforcement actions for taxpayers experiencing significant hardships. This

assistance is provided through PRP. During fiscal year 1998, PRP closed

more than 300,000 cases, of which about 10 percent involved potential

hardships;

• determine the causes of taxpayer problems so that systemic causes can be

identified and corrected and to propose legislative changes that might help

alleviate taxpayer problems. IRS commonly refers to this process as

advocacy; and

• represent taxpayers’ interests in the formulation of IRS policies and

procedures.

Our objectives were to (1) identify challenges the Advocate faces in

managing program resources, (2) identify potential effects of workload

fluctuations on program operations, (3) determine what information was

available for advocacy efforts, and (4) assess the adequacy of performance

measures IRS used to gauge program effectiveness. For all of our

objectives, we interviewed Advocate Office officials at IRS’ National

Office, all 4 IRS regional offices, and EOSCO, and we interviewed local

advocates, PRP coordinators, and caseworkers in 17 of IRS’ 73 local

offices—including 9 district offices, 4 former district offices, and 4 service

centers.

For the first objective, we also surveyed Advocate Office and PRP staff,

including PRP caseworkers, at IRS locations where Advocate’s Office and

PRP work was being done.

Additionally, for the third and fourth objectives, we reviewed program

documents on the Advocate’s Office and PRP, including guidance on

advocacy efforts, and program management information, including goals

and measures for the program.

For a more detailed account of our scope and methodology, including IRS

offices visited and limitations of our surveys, see appendix I.

We did our work from December 1997 to May 1999 in accordance with

generally accepted government auditing standards. We requested

comments on a draft of this report from the Commissioner of Internal

Revenue. His written comments are discussed near the end of this report

and are reprinted in appendix VII.

Objectives, Scope,

and Methodology
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We identified several resource management issues within the Advocate’s

Office and PRP that could affect how efficiently and effectively taxpayers

are helped by PRP. Specifically, (1) the Advocate’s Office did not know

how many staff were working in PRP or the costs associated with that

staffing; (2) the Advocate’s Office had to rely on resources provided by

IRS’ operating functions, such as Customer Service, Collections, and

Examination; (3) some Advocate Office and PRP staff reported that they

lacked training that Advocate Office officials considered necessary; and

(4) the Advocate’s Office faced obstacles, such as limited advancement

opportunities, in acquiring and keeping qualified staff. Addressing such

issues presented a particular challenge to the Advocate’s Office because it

has not had direct control over most PRP resources.

IRS has begun to address some of the resource management issues we

identified. Other changes to the Advocate’s Office and PRP are being

considered in conjunction with a major effort that IRS has begun to

substantively revise its organizational structure. However, it is too soon to

tell how these changes will affect program operations.

The Advocate’s Office did not know the total number, time, and thus, cost

of staff devoted to PRP because IRS did not have a standard system to

track functional staff doing PRP work.7

 The absence of this basic staffing

information yields an incomplete picture of program operations, places

limitations on decisionmaking, and hinders the identification of matters

requiring management attention. For example, without complete staffing

information, IRS does not know the total cost of the program; and it

cannot project the potential cost, for planning purposes, of any

prospective changes or enhancements to the program.

IRS’ operating functions (e.g., Customer Service, Collection, and

Examination), which provided most of the staff working in PRP, had

systems to track the amount of time employees devoted to PRP, but each

function tracked time spent differently. The procedures varied, from

having employees charge all time spent to resolve a case to PRP, to having

them charge only a minimal amount of time to PRP.

Because of the situation just described, IRS was unable to tell us how

many functional staff were working on PRP activities and how much time

those staff were devoting to PRP work. To get information on the number

of functional staff, with the help of the Advocate’s Office, we sent out

 

7

 IRS was able to track staff in the Advocate’s Office because these staff are funded by the Advocate’s

Office, not the functions.

Resource Management

Issues Present

Challenges for the

Advocate

The Advocate’s Office

Lacked Information on

Functional PRP Staffing
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surveys that solicited staffing information from all locations where

Advocate Office and PRP work was being done. Summaries of the

responses to our surveys are presented in appendixes II and III.

Our surveys showed that on June 1, 1998, there were 508 staff working in

the Advocate’s Office and another 1,532 functional employees doing PRP

casework. Selected survey results for those 1,532 PRP caseworkers are

presented in appendix IV. As shown in that appendix, the 1,532 PRP

caseworkers included 726 district office employees and 806 service center

employees.

The Advocate’s Office had to rely on other management officials within

IRS to provide most of the resources—including staff, space, and

equipment—needed to do PRP casework. Because there was no direct

funding for PRP, however, functional managers had to carve out resources

for PRP from their operating budgets. This arrangement required district

and service center directors to shift employees and other resources into or

out of PRP as workload demands changed. When functional needs

conflicted with PRP needs, there were no assurances that PRP needs

would be met. This arrangement also meant that functional managers, not

local advocates, determined which employees would do PRP casework—

leaving the local advocates with little, if any, control over the quality of the

caseworkers. Local advocates told us that good communication and

working relationships with other managers within IRS was imperative to

receive the support needed to meet PRP goals.

Another result of the relationship just described is that local advocates

were not responsible for preparing official performance evaluations for

most PRP caseworkers. In that regard, our surveys showed that about 80

percent of the PRP caseworkers reported to and were evaluated by

functional management. Such a situation could have affected the ability of

caseworkers to resolve taxpayers’ problems impartially, because those

problems could involve disputes between the taxpayer and the function

responsible for evaluating the caseworker. Also, this situation could have

led to a perception that PRP was not an independent program.

Independence—actual and apparent—is important because, among other

things, it helps promote taxpayer confidence in PRP.

Because the Advocate’s Office did not have direct control over functional

employees, PRP caseworkers could sometimes be pulled from PRP duties

to do other work. For example, IRS officials said that PRP caseworkers

were often required to help the customer service function answer taxpayer

Reliance on Functional

Resources Contributed to

Staffing Issues
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telephone calls during the filing season. While caseworkers were helping

customer service, they were still responsible for their PRP work.

Since PRP did not have a direct budget, IRS officials said that it was easy

for PRP “to fall through the cracks” in terms of getting other resources,

such as equipment and space, for PRP work. When PRP caseworkers told

us of their equipment needs, they generally mentioned

• computers for word processing,

• ready access to Integrated Data Retrieval System (IDRS) terminals,8

• telephone lines and voice mail,

• fax machines, and

• basic office supplies.

Given the nature of PRP work, caseworker access to IDRS and the

availability of such things as word processing equipment, voice mail, and

telephone lines would seem essential. For example, we observed that

caseworkers often prepared handwritten correspondence to taxpayers that

was not as professional looking as correspondence prepared on wordprocessing equipment.

According to our survey, some Advocate Office staff and PRP caseworkers

had not received training that Advocate Office officials considered

necessary. Our surveys of IRS staff who were doing Advocate Office work

as of June 1, 1998, indicated the following:

• Only 35 percent of the staff in the Advocate’s Office had attended an

Advocate’s Office training course for their current position. These

positions included advocate, analyst, and PRP specialist.

• Fewer than half of the caseworkers had attended a PRP caseworker

training course.

• Almost 78 percent of the caseworkers had received PRP quality standards

training. This training is designed to ensure that caseworkers are aware of

the standards for acceptable PRP casework.

Although our survey indicated that caseworkers often had not completed a

formal PRP caseworker training course, the survey also indicated that

about 85 percent of the caseworkers had received on-the-job training.

While on-the-job training can be an effective means of teaching, it opens up

the possibility of inconsistencies in the way the program operates.

 

8

IDRS is the primary system used by IRS employees to research and adjust taxpayer accounts.

Some Advocate Office and

PRP Staff Had Not Received

Training Considered

Necessary
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In addition to being trained in PRP matters, Advocate Office officials said

that caseworkers should continue to receive training in functional matters.

Functional training, such as training in tax law changes, is important

because resolving taxpayer problems requires that caseworkers

understand the tax laws affecting a particular case. Our surveys indicated,

however, that about half of the PRP caseworkers had not received such

functional training.

Both Advocate Office and PRP staff who we talked to said that there was

no established training schedule, so they did not always know what

training was being offered. When they did hear about training, it was

sometimes too late to sign up. Some staff said that it had been several

years since they had received any formal PRP training. Both Advocate

Office staff and PRP caseworkers told us that, in addition to the basic

training needed to do PRP work, they would like training in other areas,

especially tax law changes. Also, many caseworkers wanted crossfunctional training so that they could work cases across functional lines.

IRS officials said that cross-functional training would broaden caseworker

skills and might lead to faster and more accurate service to taxpayers.

Additionally, they said that by broadening caseworkers’ skills and thus

expanding the types of cases that they could work, cross-functional

training could help the Advocate’s Office manage workload fluctuations.

Obstacles existed that could adversely affect the ability of the Advocate’s

Office to acquire and keep qualified staff. Those obstacles included (1) the

absence of standard position descriptions for PRP caseworkers that could

be used to help ensure that qualified staff were assigned to PRP work and

(2) limited opportunities for advancement within the Advocate’s Office and

PRP.

There were no standard position descriptions for PRP caseworkers.

Instead, PRP caseworkers worked under the position descriptions for

employees in their functional organizations. This situation permitted

functional managers to fill PRP caseworker positions through a

noncompetitive process. IRS officials said that management usually asked

for volunteers to work in PRP; if no volunteers came forward, management

usually assigned staff to PRP, based on reverse seniority (i.e., staff with the

least seniority would be assigned to PRP if not enough volunteers were

forthcoming).9

 Without competition, less qualified staff could be assigned

 

9

 Many of the caseworkers we talked with enjoyed working in PRP more than doing functional work. In

the customer service function, PRP work was viewed as being especially desirable because most

customer service staff spent their time answering telephone calls from IRS’ toll-free lines and PRP

work offered a respite from the telephone activity. However, some caseworkers said that they did not

Obstacles Existed to

Acquiring and Keeping

Qualified Staff

Obstacle to Acquiring Qualified

Staff
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to PRP. IRS officials said that if there were standard PRP caseworker

position descriptions, staff from the operating functions would have to

meet a set of qualifications and then compete for caseworker positions. As

in any organization, when staff compete for a position, management is

afforded an opportunity to select from among the best-qualified staff for

the duties prescribed for that position.

IRS officials said that the grade structure and size of the Advocate’s Office

and PRP limited opportunities for staff to advance within these

organizations. There were gaps in the Advocate’s Office and PRP grade

structure.10 These gaps meant that, at some point, staff who wanted to

advance their careers would have to leave the Advocate’s Office or PRP to

get a promotion elsewhere in IRS—generally in an operating function. In

addition, the small size of the Advocate’s Office and PRP (in terms of

number of positions) meant that there were fewer numbers of promotions

available than in the larger operating functions.

Advocate Office and PRP staff who we talked to had mixed views on

whether they would have promotion opportunities within the functions.

Because the Advocate’s Office was “off line” from the operating functions,

many of the Advocate Office staff said that they would not have the

background necessary to compete for a promotion in an operating

function. Instead, they said that the only way for them to leave the

Advocate’s Office would be through a lateral transfer. Many caseworkers

told us, however, that the knowledge and skills they acquired in PRP could

potentially enhance their opportunities in their functional organizations.

IRS has taken some actions and has others planned that are related to the

resource management issues previously discussed; however, it is too soon

to tell if these actions will fully address these issues.

Many of the actions were being developed as part of IRS’ effort to redesign

the agency and are scheduled to be completed by the end of fiscal year

1999. IRS is planning substantive changes to the agency’s organizational

structure and work processes. Among other things, those plans would

eliminate or substantially modify IRS’ existing organization and establish

 want to continue working in PRP because increased workloads and higher program visibility made the

job too stressful.

10In some local advocate offices, for example, the associate advocate was a General Schedule (GS)-12

and the advocate was a GS-14. There was no GS-13 position in the office. Because of that gap, an

associate advocate would have to go elsewhere in IRS to get a promotion to GS-13.

Obstacle to Keeping Staff

IRS Has Begun to Address

the Resource Management

Issues Facing the

Advocate’s Office
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organizational units serving particular groups of taxpayers, such as wage

earners and small businesses.

In commenting on a draft of this report, IRS said that, beginning in October

1999, it will have the ability to track Advocate Office resources accurately.

Resource management changes include realigning the PRP staffing so that

all caseworkers report to local advocates, not functional management.

This should give the Advocate’s Office more control over PRP resources.

In October 1998, IRS announced that those caseworkers who were already

reporting to local advocates—about 20 percent—would officially be part of

the Advocate’s Office. In addition, at the time we completed our audit

work, IRS was developing an implementation plan to have the remaining

80 percent of the caseworker positions assigned to local advocate offices

during fiscal year 1999. To complement the shift to direct reporting of

caseworkers and further strengthen the independence of the Advocate’s

Office, IRS established for fiscal year 1999 a separate, centralized financial

structure for managing all Advocate Office resources. This structure

covers the resources allocated to the Advocate’s Office and includes PRP

caseworkers who have been transferred from the functions to the

Advocate’s Office. Having a separate, centralized structure gives the

Advocate’s Office control over its resource and should prevent Advocate

Office funds from being redirected to other IRS programs.

As of May 1999, IRS was also developing and updating the training for

Advocate Office staff and PRP caseworkers. The training is to reflect the

new operating structure and procedures for the Advocate’s Office as part

of the agencywide redesign effort. Training needs for all Advocate Office

and PRP staff are to be identified by the end of fiscal year 1999.

Other actions could make it easier for the Advocate’s Office and PRP to

acquire and keep qualified staff. In that regard, IRS has developed position

descriptions for all staff working in the Advocate’s Office and PRP. The

Advocate said that all positions within the Advocate’s Office and PRP will

be filled competitively using the new position description. This includes

having all existing Advocate Office and PRP staff reapply for their current

positions. IRS has reevaluated the PRP caseworker duties and, in many

cases, the new caseworker positions are higher-graded than the current

caseworker positions. According to the Advocate, the competition for the

positions should help ensure that the best staff are selected for the

Advocate’s Office and PRP.
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Additionally, in an effort to attract and keep qualified staff, the IRS

Restructuring and Reform Act of 1998 required that the Advocate develop

a career path for local advocates who choose to make a career in the

Advocate’s Office. In response to this requirement, the Advocate, at the

time we completed our audit work, had a plan that would not only provide

a career path within the Advocate’s Office and PRP, but would also enable

Advocate Office and PRP staff to compete for jobs in the operating

functions.

According to local advocates, dealing with workload fluctuations—

especially increased workloads—poses a challenge for them as Advocate’s

Office and PRP operations are restructured. (See app. V for factors that

have increased and could increase PRP’s workload.) IRS uses “cases

closed” as its indicator of PRP workload. As figure 1 shows, the number of

PRP cases closed in fiscal years 1993 through 1998 varied from year to

year.

Figure 1: PRP Cases Closed (Fiscal Years 1993–1998)

Cases in thousands

1993 1994 1995 1996 1997 1998

0

100

200

300

400

500

Fiscal year

Cases closed

Note: PRP cases that were opened and closed on the same day are not included in the totals

because they were not included in the IRS database from which this information was obtained.

Source: IRS Office of the National Taxpayer Advocate.

Historically, because PRP was staffed by the functions, the Advocate’s

Office relied on the functions to provide additional staff to cover workload

increases. However, as discussed previously, this reporting structure could

Handling Workload

Fluctuations Poses a

Challenge as the

Advocate’s Office

Restructures
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Page 13 GAO/GGD-99-124 Taxpayer Advocate Office

have led to the perception that PRP lacked independence. In an attempt to

alleviate this possible perception, and as part of the restructuring effort, all

caseworkers are to be placed in the Advocate’s Office.

Workload increases may make it necessary for the Advocate’s Office to

decide which cases to address with PRP resources. PRP was designed to

help taxpayers who were unable to get their problems resolved elsewhere

in IRS. However, the Advocate told us that he was committed to helping

any taxpayer who contacts the office. We understand why the Advocate’s

Office might not want to turn away any taxpayers seeking help. However,

if the Advocate’s Office accepts cases that could be handled elsewhere in

IRS, PRP could be overburdened, potentially reducing its ability to help

taxpayers who have nowhere else to go to resolve their problems. As one

local advocate said, “if everything is a priority, then nothing is a priority.”

Overburdening PRP could also result in less staff time available for the

Advocate’s Office to devote to advocacy. We discuss that issue in more

detail in the next section.

In its plan to redesign the Advocate’s Office, IRS has acknowledged the

need to handle workload fluctuations. In the event of workload increases,

the Advocate’s Office needs to be able to either decrease the number of

cases entering the program, increase the number of staff working on cases,

or some combination of both. The Advocate said that for workload

increases, IRS plans to detail additional staff from the functions, as

necessary.

In his written comments on a draft of this report, the Commissioner of

Internal Revenue stated that IRS had recently modified the PRP criteria to

create a “taxpayer focused balance between cases handled by the

Taxpayer Advocate and other functions.” We did not have time to evaluate

the potential impact that the modified criteria might have on PRP

workload. (See app. V for a list of the PRP criteria.)

Through advocacy, the Advocate’s Office is to identify the underlying

causes of recurring taxpayer problems and recommend changes in the tax

law or in IRS’ systems or procedures. Advocacy is key to the success of the

Advocate’s Office because the improvements it generates could reduce the

number of taxpayers who ultimately require help from PRP. However, the

advocates we talked with indicated that the demands on Advocate Office

staff and PRP caseworkers to resolve individual taxpayers’ problems left

little time to spend on advocacy. In addition, because of limitations in the

kind of information available to and compiled by the Advocate’s Office,

there was little assurance that the time being spent on advocacy was being

Workload Increases Could

Affect PRP Services

Better Information

Could Help Ensure the

Best Use of Resources

for Advocacy Efforts
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Page 14 GAO/GGD-99-124 Taxpayer Advocate Office

used most effectively. As of May 1999, the Advocate was considering

various ideas for improving the advocacy process.

As discussed more fully below, the advocacy process involves all levels of

the Advocate’s Office, from the Advocate to local caseworkers.

Nevertheless, most of the advocates we talked with said that the need to

work on individual taxpayer problems limited the amount of time that

advocate staff and PRP caseworkers could spend on advocacy. In that

regard, our surveys indicated that, as of June 1, 1998, advocates and their

staffs were spending about 60 percent of their time on problems of

individual taxpayers11 and about 10 percent of their time on advocacy.12

PRP caseworkers were spending almost all of their PRP time on problems

of individual taxpayers.

The advocacy process within the Advocate’s Office involves all levels of

the organization, from the Advocate to local caseworkers. The Advocate’s

Office is responsible for (1) assisting, supporting, and guiding advocacy

efforts at all levels; (2) identifying issues with nationwide implications and

assigning responsibility for conducting research on these issues to regional

advocates; and (3) compiling information on the status of ongoing and

completed advocacy projects. Advocacy projects are intended to develop

recommendations for improving IRS processes and procedures that can be

forwarded to the function responsible for the processes or procedures.

Advocate staff are to monitor the implementation of the recommendation

and, in instances in which no action is taken by the function, the Advocate

can compel the function to implement the recommendation by issuing a

Taxpayer Advocate Directive. The Advocate was delegated this authority

in March 1998, and on December 7, 1998, he issued the first directive

requiring that IRS operations abate penalties on some “innocent spouse”

cases.13 As of April 1999, there had been no other directives issued.

Each region and EOSCO has an advocacy council comprised of Advocate

Office staff and functional executives and staff. These councils are

 

11Advocates and their staffs generally deal with sensitive cases, such as congressional inquiries, and

cases in which a taxpayer has applied for relief due to hardship.

12The remainder of their time was spent on other types of Advocate Office work, such as program

management and support.

13To qualify for innocent spouse relief, a person must have filed a joint return with an understatement

of taxes owed; the understatement must result from erroneous items of the spouse; and the person

applying for innocent spouse relief must not have known about the errors caused by the other spouse.

Prior to the IRS Restructuring and Reform Act of 1998, the understatement must have exceeded the

greater of 500 dollars or a specified percentage of the innocent spouse's adjusted gross income for the

most recent year.

Time Spent Working on

Individual Taxpayer

Problems Has Limited the

Time Available for

Advocacy

The Advocacy Process
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Page 15 GAO/GGD-99-124 Taxpayer Advocate Office

responsible for promoting advocacy and serve as clearinghouses for

advocacy efforts by evaluating the merits of recommendations proposed at

the regional and local office levels and by assigning projects to local

advocates for further research. In evaluating the merits of local and

regional advocacy recommendations, the councils are to either (1) endorse

a recommendation and forward it to the National Office, (2) decide that a

recommendation has merit but that more work needs to be done to

support it, or (3) decide that the recommendation does not have merit. The

councils are also responsible for providing guidance to local offices on

advocacy projects and for ensuring that local offices receive feedback on

advocacy projects.

Local advocates receive ideas for advocacy efforts from a variety of

sources, such as PRP’s case inventory system, PRP caseworkers,

functional staff, and tax practitioners. In some cases, immediate action can

be taken by local managers to improve local procedures and prevent local

administrative problems. In other cases, the idea may be studied at the

local office and recommendations for improvement can be forwarded to

the responsible advocacy council for agencywide consideration.

Advocacy recommendations also come from the Equity Task Force, which

was chartered to make recommendations to the Advocate. The task force

is comprised of a cross-section of IRS functional executives, functional

staff, and Advocate Office staff. Recommendations from the task force are

designed to further the interests of fairness in tax administration.

We understand the need for the Advocate’s Office to give priority to

individual taxpayer problems (i.e., casework) over advocacy when there is

not enough time to do both. If the PRP workload were to increase, it could

become even more difficult for the Advocate’s Office to find time to spend

on advocacy. The Advocate’s Office must, therefore, make the best

possible use of the time available for advocacy. However, at the time of

our review, the Advocate’s Office did not have the kind of information

needed to (1) make sound decisions on which projects to undertake and

(2) protect against wasteful duplication of effort.

The Advocate’s Office did not systematically gather the information

needed to identify and prioritize advocacy projects. For the most part,

advocacy projects were identified by analyzing the codes used to

categorize taxpayer problems for the Advocate’s case inventory system.

However, IRS officials said that analyzing these codes was not the best

means of identifying advocacy projects because the codes do not provide

enough information on the nature of the problems.

Inadequate Information

Available to Ensure the

Most Effective Use of Time

Spent on Advocacy

Information On Which Projects

To Work Was Limited
B-279035

Page 16 GAO/GGD-99-124 Taxpayer Advocate Office

For example, one code indicates that the problem involved a lost or stolen

refund. However, there is no way to tell from the code why the case ended

up in PRP. There are normal procedures for taxpayers and IRS to follow in

getting a lost or stolen refund replaced. The fact that such a case ended up

in PRP does not indicate whether there was some procedural failure that

resulted in IRS’ inability to produce a replacement refund for the taxpayer.

This level of detail may be available on individual cases—in the case

history section—however, there is no way to search the Advocate’s case

inventory system for this information. As a result, the inventory system can

only describe the frequency of taxpayer problems; it cannot describe why

the problem ended up in PRP. In the absence of such information, the

Advocate’s Office does not know which advocacy efforts have the greatest

potential to resolve recurring taxpayer problems.

We found that the Advocate’s Office did not have a comprehensive source

of information on all proposed, ongoing, and completed advocacy projects.

Additionally, we found that field staff did not always have access to

information on advocacy projects. Because advocacy projects can be

started at any level in the Advocate’s Office, it is important that everyone

have access to comprehensive information on advocacy projects. Among

other things, such information should help enhance coordination and

prevent unnecessary duplication of effort.

Information on advocacy efforts is available from the (1) the Advocacy

Project Tracking System, (2) an inventory of legislative recommendations,

and (3) the Commissioner’s Tracking System. None of these three sources

provides a comprehensive listing of advocacy projects.

The Advocacy Project Tracking System is a document maintained by the

Advocate’s Office that includes completed and ongoing advocacy projects

from IRS’ four regional offices and EOSCO. The document is presented as

a matrix with information on each project, such as the project title, a short

description of the project, the project contact points, and the status of the

project’s recommendations. The matrix was last updated as of September

30, 1998, and there were 39 projects listed. The matrix does not, however,

contain any information on what projects were ongoing or planned at the

local offices.

The inventory of legislative recommendations aimed at changing the

current tax law is a document that presents potential legislative changes

recommended by each region and EOSCO. The list is also presented in

matrix format with information on each recommendation, such as whether

there is an advocacy project related to the issue, what the proposed action

Comprehensive Information on

Advocacy Projects Not Available
B-279035

Page 17 GAO/GGD-99-124 Taxpayer Advocate Office

is, and the status of the recommendation. The list is tracked by fiscal year,

and those recommendations that the Advocate endorsed are to be included

in the Advocate’s Report to Congress. As of April 1999, there were seven

legislative recommendations on the list. This listing, however, is limited to

proposed changes to legislation and does not contain any information on

ongoing, proposed, or completed advocacy projects.

The Commissioner’s Tracking System is a document that is to contain

information on all advocacy memorandums that were sent to functional

management. Advocacy memorandums are to be sent from the Advocate

to a National Office function when the function resists or does not respond

to a recommendation that the Advocate feels will alleviate harm to

taxpayers or decrease taxpayer burden. Advocacy memorandums are to be

sent only after other inquiries or attempts to resolve the issue have proved

unsuccessful. The function is asked to respond in writing to the advocacy

memorandum. If the functional area does not provide a satisfactory reason

for not implementing a recommendation, the Advocate can compel the

function to implement the recommendation by issuing a Taxpayer

Advocate Directive, as explained previously. Information on the

Commissioner’s Tracking System and information from the directives are

to be included in the Advocate’s Annual Report to Congress. As of April

1999, the Advocate had written 12 advocacy memorandums. This

document only contains those advocacy recommendations that were not

willingly implemented by the functions and is not a complete source of

advocacy projects.

The lack of a comprehensive source of information on all advocacy

projects increases the risk of unnecessary duplication of effort. In that

regard, staff at several locations said that regional and local offices are

often studying similar problems. For example, an IRS regional official said

that two of IRS’ regions were studying projects on several similar issues,

including (1) the application of taxpayer overpayment credits and (2)

waiving the 10 percent additional tax penalty on withdrawals from

Individual Retirement Accounts in hardship cases. The official also said

that there was even less awareness of ongoing efforts at the district office

and service center levels than at the regional level described above.

A more comprehensive source of information on advocacy projects might

also help provide staff with better feedback on project results. Although

each IRS region and EOSCO has an advocacy council that is responsible

for providing feedback to district and service center staffs, the local

advocates and council members with whom we talked said that there was

no formal mechanism for providing feedback. In particular, council
B-279035

Page 18 GAO/GGD-99-124 Taxpayer Advocate Office

members said that staff who had worked on projects were not receiving

status reports or even an acknowledgment that recommendations from

their projects were being considered for possible implementation, even

though the councils were responsible for providing this information. In one

district, for example, the local advocate said that he had forwarded the

same advocacy recommendations to the regional council over the course

of several years, but had not received feedback concerning what actions, if

any, were taken on these recommendations.

In October 1998, the Advocate established a team to develop

recommendations to strengthen advocacy within IRS. The team’s goal was

to develop and recommend a national advocacy plan, and the team made

several recommendations to the Advocate for initiating and coordinating

advocacy projects. For example, in its February 1999 report to the

Advocate, the team recommended that a national advocacy database be

developed to provide a single source of information on ongoing advocacy

projects. The national database would contain information on all advocacy

efforts, including those at the national, regional, and local levels. In

addition, the database would be accessible to all local advocates. As part

of the effort to redesign the Advocate’s Office, the Advocate said that he

plans to adopt the recommendations from the team. Also, the redesign

plan calls for establishing separate casework and advocacy units, each

with its own dedicated staff, thus reducing the possibility that advocacy

will suffer in times of high PRP caseloads.

IRS lacked adequate measures of the effectiveness of the Advocate’s Office

and PRP. The set of measures used by the Advocate’s Office during our

review (1) provided descriptive information about program activities, such

as the average amount of time it takes to close a PRP case, rather than

information needed to assess effectiveness; (2) did not provide complete

data; or (3) were not based on consistent data collection. IRS has efforts

under way to improve program measures. Those efforts, at least as they

relate to the Advocate’s Office, may be hampered by existing information

systems.

While it is necessary for an organization to measure program activities,

such as average case processing time, the more important and more

difficult task is to develop measures of effectiveness that focus on the

impact of an agency’s programs on its customers. Measures of

effectiveness are important because they provide data to improve program

performance, increase accountability, and support decisionmaking. We

found that the Advocate’s Office had measures to gauge certain aspects of

PRP’s performance, but that these measures could not fully assess PRP’s

Proposed Changes for

Strengthening Advocacy

Efforts Are Under

Consideration

The Advocate’s Office

Lacked Adequate

Measures of

Effectiveness
B-279035

Page 19 GAO/GGD-99-124 Taxpayer Advocate Office

effectiveness. For example, the Advocate’s Office did not have a method

for measuring customer satisfaction, and there was no mechanism for

determining the effectiveness of advocacy efforts—both of these measures

would help the Advocate understand how effective the program is in

helping taxpayers.

During our review, the Advocate’s Office was using the following four

measures to gauge PRP’s performance: (1) average processing time to

close PRP cases, (2) currency of PRP case inventory, (3) quality of

casework, and (4) case identification rate. Although those measures

provided some useful information, they did not provide all of the

information needed to assess PRP’s effectiveness. (See app. VI for more

information on these measures.)

The first two measures, average processing time and currency of case

inventory, provide descriptive information about program activities.

Although these measures are useful for some program management

decisions, such as the number of staff needed at a specific office, they do

not provide information on PRP’s effectiveness.

The third measure is designed to determine the quality of PRP casework.

Although this measure provides some data on program effectiveness, it

provides no information on customer satisfaction. In commenting on a

draft of this report, IRS said that it is developing ways to measure PRP

customer satisfaction and that it plans to test and refine the measure

beginning in October 1999. By helping taxpayers resolve problems that

were not resolved elsewhere in IRS, the Advocate’s Office plays a pivotal

role in delivering customer service to the taxpayers. Customer satisfaction

data from taxpayers who contacted PRP could provide the Advocate’s

Office with information on how taxpayers feel about the service they

received and whether taxpayers consider their problems solved. Without

this information, the Advocate’s Office is not in the best position to

improve program operations to better satisfy taxpayer needs.

The fourth measure, PRP case identification, attempts to determine if

service center employees are properly identifying potential PRP cases

from incoming correspondence. This measure is an important tool to help

the Advocate’s Office know whether PRP actually serves those taxpayers

who qualify for help from the program. However, the measure provides an

incomplete picture because it is designed for use only at service centers.

There is no similar measure to determine how well district offices and tollfree telephone call sites are identifying and referring potential PRP cases.

Existing PRP Measures Are

Inadequate
B-279035

Page 20 GAO/GGD-99-124 Taxpayer Advocate Office

Also, a recent review of the PRP case identification measure by IRS’ Office

of Internal Audit disclosed, among other things, that inconsistent data

collection could affect the integrity and reliability of the measure’s results.

For example, Internal Audit found that the test was not always performed

the required number of times per month at each service center and that the

mail sample was not based on the service center’s incoming mail

population. Additionally, when Internal Audit performed a parallel PRP

case identification sample—in accordance with national standards—its

rates for some service centers were significantly lower—in one case, over

55 percentage points lower—-than rates reported by the service center.

In addition to the shortcomings of these four measures, IRS lacked a

method for determining the effectiveness of its advocacy efforts. Advocacy

is a major responsibility of the Advocate’s Office and is aimed at ultimately

reducing the number of taxpayers needing help from PRP. Without

information on the effectiveness of these efforts, the Advocate’s Office

does not know, for example, which efforts provide the greatest benefit to

taxpayers.

The Advocate is working to improve Advocate Office and PRP measures of

effectiveness. In January 1999, as part of its efforts to redesign the

Advocate’s Office, IRS established a task force to determine what

measures are needed to assess program effectiveness. Specifically, the

group is tasked to research, identify, and develop corporate level measures

for Advocate Office program results, customer satisfaction, and employee

satisfaction. Their ability to develop needed measures of effectiveness,

however, may be hampered by existing information systems. The Taxpayer

Advocate Management Information System is comprised of the Problem

Resolution Office Management Information System (PROMIS), the

Customer Feedback System, and the PRP Case Identification and Tracking

System. These systems do not provide the Advocate’s Office with the data

it needs to assess the effectiveness of PRP operations.

PROMIS is a computerized inventory control and report system that

includes information from individual PRP cases, such as the taxpayer’s

name, address, and Social Security number. PROMIS generates reports on

cumulative descriptive program data, such as the number of cases worked

in PRP and how quickly cases are closed. Although the system also

captures data on the types of problems taxpayers are experiencing—such

as the “lost or stolen refund” example mentioned earlier—there is no

mechanism to search for other data that might help advocacy efforts by

pointing to agencywide weaknesses. For instance, there is no way to

determine if cases were caused by problems with a particular IRS system

Current Information

Systems May Limit IRS’

Ability to Develop Needed

Measures
B-279035

Page 21 GAO/GGD-99-124 Taxpayer Advocate Office

because the cases are coded only by type of tax problem. In a case history

section, PROMIS captures information on the nature of the taxpayer’s

problem and what actions were taken to help the taxpayer. However, there

is no mechanism to search multiple cases for trend data from the history

section.

The Customer Feedback System is designed to capture taxpayers’

compliments and complaints about IRS employees. The system depends

on taxpayers to take the initiative to voluntarily comment about the

treatment they received from an IRS employee and on IRS managers to

complete the customer feedback form. The voluntary nature of the system

means that the data are not statistically representative of program

participation, and fluctuations in the data cannot be attributed to changes

in program operations. In addition, comments captured on the system

could relate to any IRS function, not just PRP, and therefore, are of limited

use in assessing PRP’s effectiveness.

The PRP Case Identification and Tracking System is used to capture

information on the PRP case identification measure discussed earlier. As

such, it has the same limitations as that measure—it only has information

on cases coming into IRS through correspondence at the service centers.

Because this system contains no information on cases coming in through

district offices and call sites, it provides incomplete data on whether

taxpayers who qualify for PRP assistance are being properly identified and

referred to PRP.

In addition to the problems with the Taxpayer Advocate Management

Information System, we mentioned earlier that the Advocate’s Office

lacked a system to track resources dedicated to the program. Because PRP

was implemented through IRS’ functions, the Advocate’s Office had no

system to track the resources devoted to PRP. Without this basic program

information, the Advocate’s Office had no means to determine what it

invested in the program.

The Advocate’s Office can provide a valuable service by helping (1)

taxpayers who have been unable to resolve their problems elsewhere in

IRS and (2) taxpayers who are suffering significant hardships.

We have identified challenges, obstacles, and deficiencies in Advocate

Office and PRP operations that could affect how efficiently and effectively

services are provided to taxpayers. The Advocate’s Office is in the midst of

identifying and implementing changes designed to improve its operations.

Many of the changes, such as restructuring Advocate Office operations and

Conclusions
B-279035

Page 22 GAO/GGD-99-124 Taxpayer Advocate Office

creating career paths for local advocates, are due to requirements of the

IRS Restructuring and Reform Act of 1998; other changes, such as

developing position descriptions for PRP caseworkers, are the result of

Advocate Office initiatives. However, it is too soon to tell how effective

these changes will be in addressing the challenges cited in this report.

Two areas in which changes are being considered are advocacy and

performance measures. However, changes in both areas require the

development of better information systems than are currently available.

For example, without a system or systems that provide (1) information

needed to identify and prioritize advocacy projects and (2) comprehensive

information on all proposed, ongoing, and completed advocacy projects,

IRS has no assurance that the Advocate’s Office is most effectively using

the resources available for advocacy. Similarly, without a system or

systems that provide better data than are now available in the Taxpayer

Advocate Management Information System, IRS’ ability to develop

appropriate measures of PRP effectiveness may be hampered.

To better ensure that the Advocate’s Office effectively uses the resources

available for advocacy and thus enhances its ability to prevent the

recurrence of taxpayer problems and ultimately reduce the number of

taxpayers who need help from PRP, we recommend that the

Commissioner of Internal Revenue direct appropriate officials to define

the requirements for and to develop a system that captures the kind of

information needed to identify and prioritize potential advocacy projects

and provide feedback to staff on ongoing and completed projects.

To better manage PRP resources and improve operations, we recommend

that the Commissioner of Internal Revenue direct appropriate officials to

design management information systems that can support outcomeoriented performance measures.

The Commissioner of Internal Revenue commented on a draft of this

report by letter dated July 7, 1999, in which he generally agreed with our

findings and concurred with our recommendations. (See app. VII for a

copy of the letter.) We modified the report to ensure technical correctness

and include updated information where appropriate.

We are sending copies of this report to Representative Charles B. Rangel,

Ranking Minority Member, House Committee on Ways and Means;

Representative Amo Houghton, Chairman, and Representative William J.

Coyne, Ranking Minority Member, Subcommittee on Oversight, House

Committee on Ways and Means; and Senator William V. Roth, Jr.,

Recommendations to

the Commissioner of

Internal Revenue

Agency Comments and

Our Evaluation
B-279035

Page 23 GAO/GGD-99-124 Taxpayer Advocate Office

Chairman, and Senator Daniel P. Moynihan, Ranking Minority Member,

Senate Committee on Finance. We are also sending copies to The

Honorable Lawrence H. Summers, Secretary of the Treasury; The

Honorable Charles O. Rossotti, Commissioner of Internal Revenue; The

Honorable Jacob J. Lew, Director, Office of Management and Budget; and

other interested parties. Copies of this report will be made available to

others upon request.

If you have any questions regarding this letter, please contact me or David

Attianese at (202) 512-9110. Key contributors to this assignment were

Kelsey Bright, Isidro Gomez, and Susan Malone.

Sincerely yours,

Cornelia M. Ashby

Associate Director, Tax Policy

and Administration Issues
Page 24 GAO/GGD-99-124 Taxpayer Advocate Office

Contents

1 Letter

26

Offices Visited 26

Program Information Reviewed 27

Staffing Surveys 27

Appendix I

Detailed Scope and

Methodology

28

Survey Questions and Responses 28 Appendix II

Summary of

Responses to the

Taxpayer Advocate

Staffing Survey

35

Survey Questions and Responses 35 Appendix III

Summary of

Responses to the

Functional PRP

Staffing Survey

Appendix IV 43

Selected Survey

Results for PRP

Caseworkers

46

Broad Interpretation of PRP Criteria 46

IRS Initiatives Place Demands on Program Resources 47

Legislative Requirement May Increase Demands on PRP 49

Appendix V

Factors That Have

Increased and Could

Increase PRP

Workload
Contents

Page 25 GAO/GGD-99-124 Taxpayer Advocate Office

50

Performance Measures 50 Appendix VI

PRP Performance

Measures and

Information Systems

Information Systems 51

Appendix VII 53

Comments From the

Internal Revenue

Service

Abbreviations

EOSCO Executive Office for Service Center Operations

GS General Schedule

IDRS Integrated Data Retrieval System

IRS Internal Revenue Service

PROMIS Problem Resolution Office Management Information System

PRP Problem Resolution Program
Appendix I

Detailed Scope and Methodology

Page 26 GAO/GGD-99-124 Taxpayer Advocate Office

We interviewed agency officials at the Internal Revenue Service’s (IRS)

National Office, all 4 IRS regional offices, the Executive Office for Service

Center Operations (EOSCO), and 17 local offices, including 9 district

offices, 4 former district offices,1

 and 4 service centers (see table I.1 for a

list of the regional and local offices we visited).

Regional Offices

Midstates Region (Dallas, TX)

Northeast Region (New York, NY)

Southeast Region (Atlanta, GA)

Western Region (San Francisco, CA)

District Offices

Delaware-Maryland (Baltimore, MD)

Central California (San Jose, CA)

Kentucky-Tennessee (Nashville, TN)

Manhattan (New York, NY)

Northern California (Oakland, CA)

North Texas (Dallas TX)

Pacific Northwest (Seattle, WA)

Pennsylvania (Philadelphia, PA)

Virginia-West Virginia (Richmond, VA)

Former District Offices

August, ME (part of the New England District)

Pittsburgh, PA (part of the Pennsylvania District)

Portland, OR (part of the Pacific Northwest District)

Sacramento, CA (part of the Northern California District)

Service Centers

Atlanta, GA

Brookhaven, NY

Fresno, CA

Philadelphia, PA

We selected the 17 local offices on the basis of suggestions from Advocate

Office staff; our stratification of offices to obtain a variety by size, type of

work, and organization; and geographic convenience. At the National

Office, we interviewed the National Taxpayer Advocate, his predecessor,

and members of his staff. We interviewed the EOSCO advocate; and, at the

regional and local offices, we interviewed the advocates and their staffs.

Additionally, at the local offices, we interviewed Problem Resolution

Program (PRP) coordinators and PRP caseworkers. We also attended two

regional advocacy council meetings and discussed PRP operations with

council members.

 

1

 In fiscal year 1996, IRS consolidated its field operations and reduced the number of districts from 63

to 33. The former 30 districts continue to have staff and operations, including a local advocate’s office.

Offices Visited

Table I.1: Regional and Local Offices

Visited
Appendix I

Detailed Scope and Methodology

Page 27 GAO/GGD-99-124 Taxpayer Advocate Office

We reviewed documents, including sections of the Internal Revenue

Manual pertaining to the Advocate’s Office and PRP; IRS Internal Audit

reports on the Advocate’s Office and PRP; and National Office, regional,

district, and service center program documents.

We reviewed program data on advocacy efforts at IRS. These data included

Internal Revenue Manual instructions on advocacy and databases on

ongoing and completed advocacy projects. We interviewed Advocate

Office staff responsible for advocacy and local advocates and their staffs

to determine how advocacy projects are identified and implemented. We

also attended two Regional Advocacy Council meetings to increase our

awareness of program operations. We did not assess IRS’ effectiveness in

implementing proposed advocacy projects because IRS Internal Audit had

an ongoing assignment with that specific objective.

We reviewed program management information for the Advocate’s Office

and PRP. This information included program goals and measures and the

systems by which these data are captured. Data for the Advocate’s Office

and PRP are captured on the Taxpayer Advocate Management Information

System, which includes three separate systems—the Problem Resolution

Office Management Information System, the PRP Case Identification and

Tracking System, and the Customer Feedback System.

Through our surveys and with the help of the Advocate’s Office, we

obtained staffing information from all IRS locations where Advocate Office

and PRP work was being done. We attempted to get information for all IRS

staff doing Advocate Office or PRP work, including PRP caseworkers, as

of June 1, 1998. (See apps. II and III for summaries of the responses to our

surveys.) When necessary, we verified responses to the staffing surveys by

telephone. However, we did not verify that we received responses for all

staff doing Advocate Office or PRP work. The results of our surveys were

limited to a specific time (June 1, 1998), and responses may vary based on

how staff interpreted our questions.

Program Information

Reviewed

Staffing Surveys
Appendix II

Summary of Responses to the Taxpayer

Advocate Staffing Survey

Page 28 GAO/GGD-99-124 Taxpayer Advocate Office

This appendix contains a summary of responses to the survey we sent to

the National Taxpayer Advocate, the four regional advocates, the

advocates at EOSCO and the Office of the Assistant Commissioner

(International), and the 43 local advocates. In that survey, we asked for

information on each person on their staffs as of June 1, 1998, including the

advocate or associate advocate, where appropriate. We received responses

for 508 staff, including staff detailed to advocate offices by the operating

functions.

1. Series? (Provide the position series number.)

SeriesaOccupationb

Number

of staff

Percentage

 of staff

301 Miscellaneous administration & program 66 13.0

303 Miscellaneous clerk & assistant 32 6.3

313 Work unit supervising 1 0.2

318 Secretary 36 7.1

322 Clerk-typist 1 0.2

326 Office automation clerical & assistance 6 1.2

340 Program management 34 6.7

343 Management & program analysis 201 39.6

344 Management & program clerical & assistance 20 3.9

345 Not listed 1 0.2

356 Data transcriber 1 0.2

392 General telecommunications 1 0.2

503 Financial clerical & assistance 2 0.4

511 Auditing 1 0.2

512 Internal revenue agent 4 0.8

526 Tax technician 39 7.7

592 Tax examining 35 6.9

962 Contact representative 5 1.0

987 Tax law specialist 1 0.2

1169 Internal revenue officer 8 1.6

None No response 13 2.6

Total 508 100.2

Note: Percentages do not equal 100 due to rounding.

a

"Series" means a number identifying a recognized occupation in the federal service that includes all

jobs at the various skill levels in a particular kind of work.

b

"Occupation" means an occupational series listed in the Handbook of Occupational Groups and

Families developed by the U.S. Office of Personnel Management to aid federal agencies in classifying

positions under the Classification Act of 1949 and P.L. 92-392.

2. Grade? (Provide the person’s current grade level.)

Survey Questions and

Responses
Appendix II

Summary of Responses to the Taxpayer Advocate Staffing Survey

Page 29 GAO/GGD-99-124 Taxpayer Advocate Office

GradeaNumber of staff Percentage of staff

General Schedule-4 27 5.3

General Schedule-5 26 5.1

General Schedule-6 38 7.5

General Schedule-7 42 8.3

General Schedule-8 10 2.0

General Schedule-9 93 18.3

General Schedule-10 1 0.2

General Schedule-11 95 18.7

General Schedule-12 77 15.2

General Schedule-13 45 8.9

General Schedule-14 42 8.3

General Schedule-15 11 2.2

Executive Schedule-5 1 0.2

Total 508 100.2

Note: Percentages do not equal 100 due to rounding.

a

"Grade" means the level of classification an employee has under a position classification system (i.e.,

referring to the duties, tasks, and functions he or she performs).

3. Permanent or detailed? (Indicate whether the person is assigned to the

Taxpayer Advocate’s Office on a permanent or detailed basis.)

Assignment basis Number of staff Percentage of staff

Permanent 436 85.8

Detailed 63 12.4

Othera 7 1.4

No response 2 0.4

Total 508 100.0

a

"Other" includes interim and temporary assignments.

4. Full-time or part-time? (Indicate whether the person is a full-time or

part-time IRS employee.)

IRS employment basis Number of staff Percentage of staff

Full-time 495 97.4

Part-time 8 1.6

No response 5 1.0

Total 508 100.0
Appendix II

Summary of Responses to the Taxpayer Advocate Staffing Survey

Page 30 GAO/GGD-99-124 Taxpayer Advocate Office

5. Percent of time spent on Advocate Office work? (Estimate the

percentage of time the person does work related to the Advocate’s Office,

including Problem Solving Day cases. Response should be 100 percent,

unless the person also does work for another office or function.)

Percentage of time spent

on Advocate Office worka

Number of staff Percentage of staff

1-24 1 0.2

25-49 0 0.0

50-74 0 0.0

75-99 2 0.4

100 505 99.4

Total 508 100.0

a

"Advocate Office work" includes work related to PRP.

6. Years at IRS? (Provide the number of years the person has worked at

IRS. Do not include other government experience.)

Years at IRS Number of staff Percentage of staff

Less than 1 2 0.4

1-5 7 1.4

6-10 68 13.4

11-15 123 24.2

16-20 108 21.3

More than 20 186 36.6

No response 14 2.8

Total 508 100.1

Note: Percentages do not equal 100 due to rounding.

7. Years in PRP? (Provide the number of years the person has done PRP

work.)

Years in PRP Number of staff Percentage of staff

Less than 1 102 20.1

1-5 141 27.8

6-10 152 29.9

11-15 67 13.2

16-20 26 5.1

More than 20 4 0.8

No response 16 3.1

Total 508 100.0
Appendix II

Summary of Responses to the Taxpayer Advocate Staffing Survey

Page 31 GAO/GGD-99-124 Taxpayer Advocate Office

8. Prior IRS function(s)? (Check all that apply.) (Indicate the IRS

operating function(s) where the person worked before coming to the

Taxpayer Advocate’s Office.)

Prior IRS function(s) Number of staff Percentage of staff

Collection 181 35.6

Customer Service

 Automated Collection System 37 7.3

 Taxpayer Service 224 44.1

Examination 164 32.3

Othera 221 43.5

None 11 2.2

No response 6 1.2

Note: Percentages are based on a total of 508 Advocate Office staff. Percentages total more than

100, because some respondents checked more than one response to this question.

a

"Other" includes IRS functions not in the categories above, such as Information Systems, Resources

Management, and Submission Processing.

9. How acquired by the Advocate’s Office? (Check one.) (Indicate how

the person obtained a position in the Advocate’s Office.)

How position obtained Number of staff Percentage of staff

Competed 304 59.8

Volunteered 28 5.5

Assigned 64 12.6

Detailed 60 11.8

Othera 43 8.5

No response 9 1.8

Total 508 100.0

a

"Other" includes methods not in the categories above, such as reassignments resulting from IRS’

reorganization and hardship transfers.
Appendix II

Summary of Responses to the Taxpayer Advocate Staffing Survey

Page 32 GAO/GGD-99-124 Taxpayer Advocate Office

10. Grade when entered PRP? (Provide the person’s grade level when he

or she entered PRP.)

GradeaNumber of staff Percentage of staff

General Schedule-3 5 1.0

General Schedule-4 38 7.5

General Schedule-5 43 8.5

General Schedule-6 36 7.1

General Schedule-7 77 15.2

General Schedule-8 13 2.6

General Schedule-9 99 19.5

General Schedule-10 2 0.4

General Schedule-11 70 13.8

General Schedule-12 54 10.6

General Schedule-13 47 9.3

General Schedule-14 11 2.2

General Schedule-15 6 1.2

Executive Schedule-4 1 0.2

No response 6 1.2

Total 508 100.3

Note: Percentages do not equal 100 due to rounding.

a

"Grade" means the level of classification an employee has under a position classification system (i.e.,

referring to the duties, tasks, and functions he or she performs).

11. Report to? (Provide the title and home function of the individual to

whom the person reports.)

Employee reports to Number of staff Percentage of staff

IRS managementa 53 10.4

Advocate Office managementb 440 86.6

Functional managementc 8 1.6

No response 7 1.4

Total 508 100.0

a

"IRS management" means the head of an IRS office or his or her designee.

b

"Advocate Office management" means the head of an Advocate office or his or her designee.

c

"Functional management" means the head of an IRS division, function, or functional unit, or his or her

designee.
Appendix II

Summary of Responses to the Taxpayer Advocate Staffing Survey

Page 33 GAO/GGD-99-124 Taxpayer Advocate Office

12. Evaluated by? (Provide the title and home function of the individual

who evaluates the person’s performance.)

Employee evaluated by Number of staff Percentage of staff

IRS managementa 53 10.4

Advocate Office managementb 423 83.3

Functional managementc 25 4.9

No response 7 1.4

Total 508 100.0

a

"IRS management" means the head of an IRS office or his or her designee.

b

"Advocate Office management" means the head of an Advocate office or his or her designee.

c

"Functional management" means the head of an IRS division, function, or functional unit, or his or her

designee.

13. Percent of time currently spent on? (Estimate the percentage of time

the person currently spends on each type of work listed. Note: Total

should equal 100 percent.)

Type of work Average percentage of time spent

Advocacy 10.4

Applications for Taxpayer Assistance

Ordersa

18.8

Congressional inquiries 10.0

PRP cases 19.0

Problem Solving Day cases 9.4

Senate Finance Committee casesb 4.7

Otherc 27.8

Total 100.1

Note: Average percentages are based on a total of 494 Advocate Office staff. We received no

response to this question for 14 Advocate Office staff. Percentages do not equal 100 due to rounding.

a

Requests for relief from hardship.

b

Cases sent to IRS by the Senate Finance Committee.

c

"Other" includes types of work not in the categories above, such as program management and

program support.
Appendix II

Summary of Responses to the Taxpayer Advocate Staffing Survey

Page 34 GAO/GGD-99-124 Taxpayer Advocate Office

14. Training completed? (Check all that apply.) (Indicate the type of

training that the person has completed for his or her current position.)

Type of training Number of staff Percentage of staff

PRP course for current positiona 179 35.2

PRP quality standardsb 226 44.5

PRP updatesc 211 41.5

PROMIS/Intelligent Queryd 246 48.4

Continuing professional education

provided by IRS functions 218 42.9

On the job 413 81.3

No response 47 9.3

Note: Percentages are based on a total of 508 Advocate Office staff. Percentages total more than

100, because some respondents checked more than one response to this question.

a

"PRP course for current position" includes training for the positions of advocate, analyst, and PRP

specialist.

b

Standards for doing PRP casework.

c

Annual training to update Advocate Office and PRP staff on current issues and new laws affecting

PRP.

d

"Intelligent Query" is a software package for generating specialized reports using the PROMIS

database.
Appendix III

Summary of Responses to the Functional PRP

Staffing Survey

Page 35 GAO/GGD-99-124 Taxpayer Advocate Office

This appendix contains a summary of responses to the survey we sent to

the 43 local advocates and the advocate at the Office of the Assistant

Commissioner (International). In that survey, we asked for information on

each district office and service center employee assigned to functional

PRP work as of June 1, 1998. We received responses for 2,215 staff—1,018

district office staff and 1,197 service center staff.

1. PRP role(s): (Check all that apply.) (Indicate each person’s role(s) in

PRP.)

District office staff Service center staff

PRP role Number Percent Number Percent

PRP manager 69 6.8 71 5.9

PRP coordinator 74 7.3 152 12.7

PRP caseworker 726 71.3 806 67.3

Othera 175 17.2 188 15.7

No response 14 1.4 25 2.1

Note: Percentages are based on totals of 1,018 for district office staff and 1,197 for service center

staff. Percentages total more than 100, because some respondents checked more than one response

to this question.

a

"Other" includes PRP roles not in the categories above, such as clerical support.

Survey Questions and

Responses
Appendix III

Summary of Responses to the Functional PRP Staffing Survey

Page 36 GAO/GGD-99-124 Taxpayer Advocate Office

2. Series? (Provide the position series number.)

District office

staff

Service center

staff

SeriesaOccupationbNumber Percent Number Percent

301 Miscellaneous administration & program 15 1.5 1 0.1

303 Miscellaneous clerk & assistant 11 1.1 55 4.6

304 Information receptionist 0 0.0 1 0.1

305 Mail & file 0 0.0 8 0.7

318 Secretary 27 2.7 1 0.1

322 Clerk-typist 1 0.1 0 0.0

326 Office automation clerical & assistance 0 0.0 7 0.6

334 Computer specialist 1 0.1 1 0.1

340 Program management 4 0.4 1 0.1

343 Management & program analysis 8 0.8 13 1.1

356 Data transcriber 2 0.2 1 0.1

501 Financial administration & program 2 0.2 12 1.0

503 Financial clerical & assistance 9 0.9 111 9.3

512 Internal revenue agent 130 12.8 17 1.4

525 Accounting technician 0 0.0 9 0.8

526 Tax technician 314 30.8 11 0.9

529 Not listed 3 0.3 1 0.1

530 Cash processing 1 0.1 0 0.0

579 Not listed 1 0.1 0 0.0

582 Not listed 5 0.5 0 0.0

592 Tax examining 203 19.9 937 78.3

905 General attorney 2 0.2 2 0.2

930 Hearing & appeals 9 0.9 0 0.0

962 Contact representative 105 10.3 0 0.0

963 Legal instruments examining 0 0.0 1 0.1

987 Tax law specialist 2 0.2 0 0.0

1101 General business & industry 2 0.2 0 0.0

1169 Internal revenue officer 123 12.1 1 0.1

3012 Not listed 1 0.1 0 0.0

None No response 37 3.6 6 0.5

Total 1,018 100.1 1,197 100.3

Note: Percentages do not equal 100 due to rounding.

a

"Series" means a number identifying a recognized occupation in the federal service that includes all

jobs at the various skill levels in a particular kind of work.

b

"Occupation" means an occupational series listed in the Handbook of Occupational Groups and

Families developed by the U.S. Office of Personnel Management to aid federal agencies in classifying

positions under the Classification Act of 1949 and P.L. 92-392.
Appendix III

Summary of Responses to the Functional PRP Staffing Survey

Page 37 GAO/GGD-99-124 Taxpayer Advocate Office

3. Grade? (Provide the person’s current grade level.)

District office staff Service center staff

GradeaNumber Percent Number Percent

General Schedule-3 0 0.0 1 0.1

General Schedule-4 16 1.6 69 5.8

General Schedule-5 32 3.1 11 0.9

General Schedule-6 6 0.6 76 6.3

General Schedule-7 199 19.6 645 53.9

General Schedule-8 102 10.0 207 17.3

General Schedule-9 353 34.7 78 6.5

General Schedule-10 7 0.7 69 5.8

General Schedule-11 158 15.5 8 0.7

General Schedule-12 94 9.2 20 1.7

General Schedule-13 41 4.0 5 0.4

General Schedule-14 5 0.5 1 0.1

General Schedule-15 5 0.5 0 0.0

No response 0 0.0 7 0.6

Total 1,018 99.9 1,197 100.1

Note: Percentages do not equal 100 due to rounding.

a

"Grade" means the level of classification an employee has under a position classification system (i.e.,

referring to the duties, tasks, and functions he or she performs).

4. Permanent or detailed? (Indicate whether the person is assigned to

PRP work on a permanent or detailed basis.)

District office staff Service center staff

Assignment basis Number Percent Number Percent

Permanent 695 68.3 1120 93.6

Detailed 296 29.1 58 4.8

Othera 1 0.1 2 0.2

No response 26 2.6 17 1.4

Total 1,018 100.1 1,197 100.0

Note: Percentages do not equal 100 due to rounding.

a

"Other" includes temporary and seasonal assignments.
Appendix III

Summary of Responses to the Functional PRP Staffing Survey

Page 38 GAO/GGD-99-124 Taxpayer Advocate Office

5. Full-time or part-time? (Indicate whether the person is a full-time or

part-time IRS employee.)

District office staff Service center staff

IRS employment basis Number Percent Number Percent

Full-time 952 93.5 1,150 96.1

Part-time 37 3.6 25 2.1

No response 29 2.8 22 1.8

Total 1,018 99.9 1,197 100.0

Note: Percentages do not equal 100 due to rounding.

6. Percent of time on PRP work? (Estimate the percentage of time the

person does work related to PRP, including Problem Solving Day cases.

Response should be 100 percent, unless the person also works outside of

PRP.)

Percentage of time District office staff Service center staff

spent on PRP work Number Percent Number Percent

1-24 106 10.4 417 34.8

25-49 44 4.3 199 16.6

50-74 45 4.4 78 6.5

75-99 94 9.2 98 8.2

100 718 70.5 383 32.0

No response 11 1.1 22 1.8

Total 1,018 99.9 1,197 99.9

Note: Percentages do not equal 100 due to rounding.

7. Years at IRS? (Provide the number of years the person has worked at

IRS. Do not include other government experience.)

District office staff Service center staff

Years at IRS Number Percent Number Percent

Less than 1 3 0.3 2 0.2

1-5 44 4.3 11 0.9

6-10 263 25.8 219 18.3

11-15 314 30.8 405 33.8

16-20 210 20.6 216 18.0

More than 20 157 15.4 323 27.0

No response 27 2.7 21 1.8

Total 1,018 99.9 1,197 100.0

Note: Percentages do not equal 100 due to rounding.
Appendix III

Summary of Responses to the Functional PRP Staffing Survey

Page 39 GAO/GGD-99-124 Taxpayer Advocate Office

8. Years in PRP? (Provide the number of years the person has done PRP

work.)

District office staff Service center staff

Years in PRP Number Percent Number Percent

Less than 1 375 36.8 166 13.9

1-5 304 29.9 556 46.4

6-10 205 20.1 312 26.1

11-15 81 8.0 75 6.3

16-20 10 1.0 17 1.4

More than 20 2 0.2 0 0.0

No response 41 4.0 71 5.9

Total 1,018 100.0 1,197 100.0

9. Position funded by? (Check one.) (Indicate the function that funds the

person’s position.)

District office staff Service center staff

Position funded by Number Percent Number Percent

Appeals 16 1.6 0 0.0

Collection 383 37.6 161 13.5

Customer Service

 Automated Collection System 34 3.3 12 1.0

 Taxpayer Service 183 18.0 422 35.3

Employee Plans and Exempt

Organizations 37 3.6 1 0.1

Examination 317 31.1 244 20.4

Advocate Office 12 1.2 0 0.0

Othera 21 2.1 346 28.9

No response 15 1.5 11 0.9

Total 1,018 100.0 1,197 100.1

Note: Percentages do not equal 100 due to rounding.

a

"Other" includes IRS functions not in the categories above. It also includes functions found only in

service centers, such as Accounting, Taxpayer Relations, Adjustments, and Returns Processing.
Appendix III

Summary of Responses to the Functional PRP Staffing Survey

Page 40 GAO/GGD-99-124 Taxpayer Advocate Office

10. How acquired by PRP? (Check one.) (Indicate how the person

obtained a functional position in PRP.)

District office staff Service center staff

How position obtained Number Percent Number Percent

Competed 235 23.1 212 17.7

Volunteered 195 19.2 204 17.0

Assigned 315 30.9 645 53.9

Detailed 221 21.7 42 3.5

Othera 46 4.5 51 4.3

No response 6 0.6 43 3.6

Total 1,018 100.0 1,197 100.0

a

“Other” includes methods not in the categories above, such as redeployment and assigned “as

needed.”

11. Grade when entered PRP? (Provide the person’s grade level when he

or she entered PRP.)

District office staff Service center staff

GradeaNumber Percent Number Percent

General Service-3 0 0.0 5 0.4

General Service-4 23 2.3 63 5.3

General Service-5 46 4.5 37 3.1

General Service-6 34 3.3 157 13.1

General Service-7 303 29.8 592 49.5

General Service-8 45 4.4 131 10.9

General Service-9 266 26.1 63 5.3

General Service-10 5 0.5 47 3.9

General Service-11 141 13.9 5 0.4

General Service-12 77 7.6 18 1.5

General Service-13 33 3.2 3 0.3

General Service-14 6 0.6 0 0.0

General Service-15 2 0.2 0 0.0

No response 37 3.6 76 6.3

Total 1,018 100.0 1,197 100.0

a

"Grade" means the level of classification an employee has under a position classification system (i.e.,

referring to the duties, tasks, and functions he or she performs).
Appendix III

Summary of Responses to the Functional PRP Staffing Survey

Page 41 GAO/GGD-99-124 Taxpayer Advocate Office

12. Report to? (Provide the title and home function of the individual to

whom the person reports.)

District office staff Service center staff

Employee reports to Number Percent Number Percent

Advocate Office managementa 308 30.3 83 6.9

Functional managementb 699 68.7 1,104 92.2

No response 11 1.1 10 0.8

Total 1,018 100.1 1,197 99.9

Note: Percentages do not equal 100 due to rounding.

a

"Advocate Office management" means the head of an Advocate office or his or her designee.

b

"Functional management" means the head of an IRS division, function, or functional unit, or his or her

designee.

13. Evaluated by? (Provide the title and home function of the individual

who evaluates the person’s performance.)

District office staff Service center staff

Employee evaluated by Number Percent Number Percent

Advocate Office managementa 287 28.2 83 6.9

Functional managementb 712 69.9 1,103 92.1

No response 19 1.9 11 0.9

Total 1,018 100.0 1,197 99.9

Note: Percentages do not equal 100 due to rounding.

a

"Advocate Office management" means the head of an Advocate office or his or her designee.

b

"Functional management" means the head of an IRS division, function, or functional unit, or his or her

designee.
Appendix III

Summary of Responses to the Functional PRP Staffing Survey

Page 42 GAO/GGD-99-124 Taxpayer Advocate Office

14. Percent of time currently spent on? (Estimate the percentage of time

the person currently spends on each type of work listed. Note: Total

should equal 100 percent.)

Average percentage of time spent

Type of work District office staff Service center staff

Advocacy 0.6 0.5

Applications for Taxpayer Assistance Ordersa 4.5 1.9

Congressional inquiries 11.7 3.5

PRP cases 45.9 40.4

Problem Solving Day cases 12.0 0.6

Senate Finance Committee casesb 3.0 0.3

Otherc 22.4 52.9

Total 100.1 100.1

Note: Average percentages are based on totals of 1,005 for district office staff and 1,174 for service

center staff. We received no response to this question for 13 district office staff and 23 service center

staff. Percentages do not equal 100 due to rounding.

a

Requests for relief from hardship.

b

Cases sent to IRS by the Senate Finance Committee.

c

"Other" includes types of work not in the categories above, such as functional work not related to

PRP activities.

15. Training completed? (Check all that apply.) (Indicate the type of

training that the person has completed for his or her current position.)

District office staff Service center staff

Type of training Number Percent Number Percent

PRP course for current positiona 416 40.9 471 39.3

PRP quality standardsb 680 66.8 864 72.2

PRP updatesc 548 53.8 886 74.0

PROMIS/Intelligent Queryd 248 24.4 268 22.4

Continuing professional education

provided by IRS functions 506 49.7 515 43.0

On the job 861 84.6 995 83.1

No response 36 3.5 52 4.3

Note: Percentages are based on totals of 1,018 for district office staff and 1,197 for service center

staff. Percentages total more than 100, because some respondents checked more than one response

to this question.

a

“PRP course for current position” includes training for the positions of PRP manager, coordinator,

and caseworker.

b

Standards for doing PRP casework.

c

Annual training to update PRP staff on current issues and new laws affecting PRP.

d

“Intelligent Query” is a software package for generating specialized reports using the PROMIS

database.
Appendix IV

Selected Survey Results for PRP Caseworkers

Page 43 GAO/GGD-99-124 Taxpayer Advocate Office

Following are five tables with selected results from our survey of district

office and service center functional employees assigned to PRP work as of

June 1, 1998. The results in this appendix are for the 726 district office and

806 service center staff who were identified as PRP caseworkers in the

responses to our functional PRP staffing survey.

District office caseworkers Service center caseworkers

Position funded by Number Percent Number Percent

Appeals 4 0.6 0 0.0

Collection 271 37.3 130 16.1

Customer Service

 Automated Collection System 30 4.1 6 0.7

 Taxpayer Service 145 20.0 265 32.9

Employee Plans and Exempt Organizations 32 4.4 1 0.1

Examination 209 28.8 189 23.4

Advocate Office 8 1.1 0 0.0

Othera 14 1.9 208 25.8

No response 13 1.8 7 0.9

Total 726 100.0 806 99.9

Note: Percentages do not equal 100 due to rounding.

a

"Other" includes IRS functions not in the categories above. It also includes functions found only in

service centers, such as Accounting, Taxpayer Relations, Adjustments, and Returns Processing.

Source: GAO survey.

District office caseworkers Service center caseworkers Total

Employee reports to Number Percent Number Percent Number Percent

Advocate Office managementa 234 32.2 62 7.7 296 19.3

Functional managementb 485 66.8 744 92.3 1,229 80.2

Cannot determine 7 1.0 0 0.0 7 0.5

Total 726 100.0 806 100.0 1,532 100.0 a

"Advocate Office management" means the head of an Advocate office or his or her designee.

b

"Functional management" means the head of an IRS division, function, or functional unit, or his or her

designee.

Source: GAO survey.

Table IV.1: Funding Source of Functional PRP Caseworkers

Table IV.2: Reporting Structure of Functional PRP Caseworkers
Appendix IV

Selected Survey Results for PRP Caseworkers

Page 44 GAO/GGD-99-124 Taxpayer Advocate Office

District office caseworkers Service center caseworkers Total

Employee evaluated by Number Percent Number Percent Number Percent

Advocate Office managementa 214 29.5 62 7.7 276 18.0

Functional managementb 499 68.7 744 92.3 1,243 81.1

Cannot determine 13 1.8 0 0.0 13 0.8

Total 726 100.0 806 100.0 1,532 99.9

Note: Percentages do not equal 100 due to rounding.

a

"Advocate Office management" means the head of an Advocate office or his or her designee.

b

"Functional management" means the head of an IRS division, function, or functional unit, or his or her

designee.

Source: GAO survey.

District office caseworkers Service center caseworkers Total

Type of training Number Percent Number Percent Number Percent

PRP caseworker course 332 45.7 335 41.6 667 43.5

PRP quality standardsa 550 75.8 644 79.9 1,194 77.9

PRP updatesb 436 60.1 637 79.0 1,073 70.0

PROMIS/Intelligent Queryc 158 21.8 132 16.4 290 18.9

Continuing professional education

 provided by IRS functions 400 55.1 380 47.1 780 50.9

On the job 613 84.4 696 86.4 1,309 85.4

No response 20 2.8 22 2.7 42 2.7

Note: Percentages are based on totals of 726 district office and 806 service center caseworkers.

Percentages total more than 100, because some respondents checked more than one response to

this question.

a

Standards for doing PRP casework.

b

Annual training to update Advocate Office and PRP staff on current issues and new laws affecting

PRP.

c

"Intelligent Query" is a software package used to generate specialized reports from the PROMIS

database.

Source: GAO survey.

Table IV.3: Evaluation of Functional PRP Caseworkers

Table IV.4: Training Completed by Functional PRP Caseworkers
Appendix IV

Selected Survey Results for PRP Caseworkers

Page 45 GAO/GGD-99-124 Taxpayer Advocate Office

Average percentage of time spent

Type of work District office caseworkers Service center caseworkers Total

Advocacy 0.4 0.1 0.2

Applications for Taxpayer

Assistance Ordersa 5.3 2.2 3.7

Congressional inquiries 12.8 2.9 7.6

PRP cases 55.6 46.1 50.6

Problem Solving Day cases 10.0 0.6 5.1

Senate Finance Committee casesb 2.7 0.2 1.4

Otherc 13.3 47.8 31.5

Total 100.1 99.9 100.1

Note: Average percentages are based on totals of 721 for district office caseworkers and 801 for

service center caseworkers. We did not receive a response to this question for five district office

caseworkers and five service center caseworkers. Percentages do not equal 100 due to rounding.

a

Requests for relief from hardship.

b

Cases sent to IRS by the Senate Finance Committee.

c

"Other" includes types of work not in the categories above, such as functional work not related to

PRP activities.

Source: GAO survey.

Table IV.5: Average Percentage of Time Spent by Functional PRP Caseworkers on Specific Types of Work
Appendix V

Factors That Have Increased and Could

Increase PRP Workload

Page 46 GAO/GGD-99-124 Taxpayer Advocate Office

Factors that have increased and could increase PRP workload include PRP

criteria that can be and have been broadly interpreted to include any

situation; IRS initiatives, such as Problem Solving Days, Citizen Advocacy

Panels, and the introduction of a PRP toll-free telephone number; and a

legislative requirement designed to increase public awareness of advocate

operations.

PRP cases can be generated when a taxpayer contacts a local advocate

with a problem or when a front-line IRS employee, such as a customer

service representative, revenue officer, or revenue agent, determines that a

situation should be referred to the Advocate’s Office.

The Internal Revenue Manual contains the following criteria for

determining whether a situation qualifies as a PRP case:

• any contact on the same issue at least 30 days after an initial inquiry or

complaint;

• any contact that indicates the taxpayer has not received a response from

IRS by the date promised; and

• any contact that indicates regular methods have failed to resolve the

taxpayer’s problem, or when it is in the best interest of the taxpayer or IRS

that the case be worked in PRP.

Officials in the Advocate’s Office said that the way PRP criteria are

interpreted had increased PRP’s workload because the portion of the third

criterion that reads “in the best interest of the taxpayer or IRS that the

case be worked in PRP” can be interpreted so that any case qualifies as a

PRP case. In that regard, the National Taxpayer Advocate said that he was

committed to work any case for which a taxpayer was seeking help from

PRP. In commenting on our draft report, the Commissioner of Internal

Revenue stated that the PRP criteria had recently been modified. IRS has

added the following four criteria:

• The taxpayer is suffering or is about to suffer a significant hardship;

• the taxpayer is facing an immediate threat of adverse action;

• the taxpayer will incur significant costs if relief is not granted (including

fees for professional representation); and

• the taxpayer will suffer irreparable injury, or long-term adverse impact if

relief is not granted.

Additionally, IRS deleted the portion of the third criterion that read, “in the

best interest of the taxpayer or IRS that the case be worked in PRP.”

Because we received the information on the modified criteria as part of the

Broad Interpretation of

PRP Criteria
Appendix V

Factors That Have Increased and Could Increase PRP Workload

Page 47 GAO/GGD-99-124 Taxpayer Advocate Office

agency comment letter, we did not have time to evaluate the potential

impact that the modified criteria might have on the PRP workload.

IRS officials said that part of the PRP workload increase can be attributed

to an IRS initiative known as Problem Solving Days, which is the

responsibility of the National Taxpayer Advocate. Continuation of that

initiative and the recent start of two other IRS initiatives—Citizen

Advocacy Panels and publication of a unique toll-free telephone number

for taxpayers to call the Advocate’s Office—could place increasing

demands on PRP resources.

In November 1997, IRS began holding a series of monthly Problem Solving

Days in each of its 33 districts. The purpose of these days is to give

taxpayers with unresolved tax problems the opportunity to meet face to

face with IRS staff in an effort to resolve those problems. These days have

been advertised both locally and nationally through newspaper articles,

television and radio interviews with IRS officials, and public service

announcements. From November 1997 to November 1998, over 36,000 PRP

cases were closed as a result of IRS’ Problem Solving Days.

According to local advocates, Problem Solving Days have not only

provided taxpayers with in-person service but also allowed IRS staff to

meet with taxpayers and help solve problems. However, the local

advocates also said that the work involved with planning and executing

these days and the subsequent increase in casework was taking its toll on

Advocate and PRP staff.

In addition to their other duties, some local advocates are responsible for

implementing Citizen Advocacy Panels within their districts. Collectively,

the panels are designed to serve as advisory bodies to the Secretary of the

Treasury and the Commissioner of Internal Revenue to improve IRS

service and responsiveness. The panels are chartered to (1) provide citizen

input into improving IRS customer service by identifying problems and

making recommendations for improving IRS systems and procedures, (2)

identify and elevate problems to appropriate IRS officials and monitor

progress to effect change, and (3) refer taxpayers to the appropriate IRS

office for assistance in resolving their tax problems. Membership on the

panels is to include the local advocate and 8 to 15 citizens from the district.

The South Florida District held the first public meeting of a Citizen

Advocacy Panel in November 1998. Three more districts—Brooklyn,

Midwest, and Pacific Northwest—have established panels and plan to hold

public meetings during fiscal year 1999. Initially, IRS had planned to

IRS Initiatives Place

Demands on Program

Resources

Problem Solving Days

Citizen Advocacy Panels
Appendix V

Factors That Have Increased and Could Increase PRP Workload

Page 48 GAO/GGD-99-124 Taxpayer Advocate Office

establish panels in each of its 33 districts. However, IRS is reevaluating

this need in light of the agency’s planned reorganization. According to

local advocates, the Citizen Advocacy Panels represent a significant time

commitment for them. Not only are the local advocates members of the

panels, but they are also responsible for the administrative duties

associated with the panels, such as securing space and equipment for

meetings. In addition to time commitments for the local advocates,

taxpayers may be referred to PRP for further assistance, which could

increase PRP’s workload.

Local advocates said that the introduction of a toll-free telephone number

for taxpayers to call the Advocate’s Office could increase PRP workloads.

The number was operational as of November 1, 1998, and has been

advertised in IRS publications, such as the tax year 1998 Form 1040 tax

package. IRS has used customer service staff as PRP telephone assistors to

answer the calls, and the assistors have been equipped with computer

systems that allow them to help some taxpayers immediately. There were

241,228 calls placed on this line between November 1, 1998, and April 17,

1999; and, according to the Advocate, 85 percent of these calls were for

non-Advocate Office matters. The Advocate said that the procedure for the

PRP toll-free assistors is to help any caller if the assistor has the time and

ability; and if the assistor cannot help, the assistor should transfer the

caller to IRS’ general assistance phone lines.

There is no way of determining whether taxpayers who were referred to

local advocate offices through the toll-free line would have contacted IRS

anyway or whether it was the availability of the new toll-free line that

prompted them to contact PRP. Therefore, the actual increase in PRP

cases, if any, cannot accurately be determined. However, local advocates

were concerned that the toll-free line would dramatically increase PRP’s

future caseload. They were also concerned that this toll-free line would be

inundated with calls from taxpayers needing general assistance—calls that

would be better handled by another toll-free line that IRS has available for

that purpose.

PRP Toll-free Telephone

Number
Appendix V

Factors That Have Increased and Could Increase PRP Workload

Page 49 GAO/GGD-99-124 Taxpayer Advocate Office

A legislative requirement designed to increase public awareness of

advocate operations may increase demands on PRP. The IRS Restructuring

and Reform Act of 1998 required IRS to include the address and telephone

number of local advocates on statutory notices of deficiency sent to

taxpayers.1

 IRS began sending taxpayers the revised notice in August 1998.

The notices state that the taxpayers can contact their local advocate with

their tax problem for “proper and prompt handling” if the problem is not

resolved through normal IRS channels. IRS officials said that about 1

million statutory notices are sent out each year, and some portion of those

taxpayers will probably be contacting the advocates, which will cause a

corresponding increase in workloads. According to a local advocate, some

taxpayers may have a legitimate reason to contact their local advocates.

For example, a taxpayer may have repeatedly tried without success to

rectify the problem addressed in the notice. Other taxpayers may contact

their local advocates because the telephone number is made available.

 1

A statutory notice of deficiency is a legal notice that a tax deficiency exists and gives taxpayers the

right to petition the Tax Court within 90 days (150 days for taxpayers outside the United States). If the

taxpayer does not respond to this notice within this time period, the deficiency is to be assessed.

Legislative

Requirement May

Increase Demands on

PRP
Appendix VI

PRP Performance Measures and Information

Systems

Page 50 GAO/GGD-99-124 Taxpayer Advocate Office

At the time of our review, the Advocate’s Office used four measures to

gauge PRP’s performance. They were the (1) average processing time to

close PRP cases, (2) currency of PRP case inventory, (3) quality of

casework, and (4) case identification and tracking rate. Table VI.I shows

actual performance results for the four measures for fiscal years 1996

through 1998.

Performance measure 1996 1997 1998

Average processing time (in days) 38.2 33.4 37.8

Currency of case inventory (in days) n/aa n/aa 91.35

Quality of casework (percentage of

standards met) 72.6 83.7 80.8

PRP case identification (percentage

of PRP-eligible cases that were

identified as PRP cases in IRS

service centers) 86.4 87.0 86.3

a

Data for this measure were not collected until fiscal year 1998.

Source: Office of the National Taxpayer Advocate.

The first indicator, average processing time, represents the average

number of days it took to close a PRP case. The measure does not include

those cases that were opened and closed on the same day because these

cases are not included in PRP’s inventory control system. The measure

also does not include those cases in which the Advocate’s Office made a

determination of hardship, which represent about 10 percent of the total

PRP cases closed during fiscal year 1998. Hardship cases are not included

in this measure because IRS requires that these cases be closed in 2 days;

including these cases might misrepresent the actual average closure times

for PRP cases.

The second indicator, currency of case inventory, is designed to measure

the average number of days that cases have been in the open PRP

inventory.

The third measure, expressed as a percentage, is designed to determine the

quality of PRP casework. This measure is to be based on a statistically

valid sample of PRP cases and provides the National Taxpayer Advocate

with data on timeliness and the technical accuracy of PRP cases. Each

month, sampled cases are to be sent to two locations—one for district

office cases and one for service center cases—for review. Reviewers at

these locations are to check the cases against a list of 13 quality standards,

broken into 3 categories—timeliness, communication, and accuracy. Each

of the 13 standards is worth a certain number of points totaling 100. Cases

are to be reviewed to determine if, among other things, the caseworker

Performance Measures

Table VI.1: Performance Results for the

Office of the Taxpayer Advocate (Fiscal

years 1996-1998)
Appendix VI

PRP Performance Measures and Information Systems

Page 51 GAO/GGD-99-124 Taxpayer Advocate Office

contacted the taxpayer by a promised date, whether copies of any

correspondence with the taxpayer appeared to communicate issues

clearly, and whether the taxpayer’s problem appeared to be completely

resolved. The caseworkers and local advocate staff we talked with said

that the quality measure was helpful because the elements that are

reviewed provide a checklist for working PRP cases. According to staff,

this helps ensure that most cases are worked in a similar manner in

accordance with standard elements.

The fourth measure, PRP case identification, is used only at the service

centers and attempts to determine if service center employees are properly

identifying potential PRP cases from incoming correspondence. Service

center employees responsible for sorting the mail are also responsible for

identifying potential PRP cases. The measure is to be based on a sample of

mail coming into each service center. Analysts at the service centers are to

review each sampled piece of incoming mail, identify potential PRP cases,

and return the mail to the workflow. After the mail has been sorted and

sent to the various service center units for handling, the analysts are to

check to see what percentage of the sampled mail was correctly identified

for PRP.

The Taxpayer Advocate Management Information System is comprised of

the Problem Resolution Office Management Information System

(PROMIS), the Customer Feedback System, and the PRP Case

Identification and Tracking System. PROMIS is a computerized inventory

control and report system for PRP cases. Background information on PRP

cases, such as the taxpayer’s name, address, tax identification number, and

a code to identify the taxpayer’s problem are captured on the system.

Additionally, in a case history section, the system captures a detailed

description of the taxpayer’s problem, along with what actions were taken,

and when, to help the taxpayer. This system produces standard reports for

the Advocate’s Office and can be queried to produce other more specific

reports, including reports for counts of information on any of its data

fields, such as the number of cases opened or closed during a certain time

period or at a certain location. The case history section cannot be queried

as to what specific problems faced the taxpayers. All PRP cases, except

those opened and closed in the same day, are to be entered into PROMIS.

The Customer Feedback System was made necessary by the second

Taxpayer Bill of Rights and is designed to capture taxpayers’ compliments

and complaints about IRS employees and what actions, if any were taken

Information Systems
Appendix VI

PRP Performance Measures and Information Systems

Page 52 GAO/GGD-99-124 Taxpayer Advocate Office

regarding the cases.1 If a taxpayer calls or writes IRS concerning the

behavior of an employee, IRS managers are responsible for recording

information on a customer feedback form. Additionally, forms are to be

filled out if a manager receives a complaint of employee behavior from

another IRS employee. After the forms are filled out, the information is

compiled and reports can be generated. Reports include identifying what

characteristics are more frequently described in customer complaints—

such as the IRS employee using discourteous, unprofessional language.

The system also collects data on what, if any, disciplinary actions—such as

counseling or suspension—were taken against IRS employees.

The PRP Case Identification and Tracking System is the system used to

capture information on the PRP case identification measure.

 1

The Taxpayer Bill of Rights 2, P.L. 104-168 (July 30, 1996), section 1211, requires the Department of the

Treasury to report annually to Congress on or before June 1, all instances of employee misconduct

during the preceding calendar year and the dispositions of any such instances during that same year.
Appendix VII

Comments From the Internal Revenue Service

Page 53 GAO/GGD-99-124 Taxpayer Advocate Office
Appendix VII

Comments From the Internal Revenue Service

Page 54 GAO/GGD-99-124 Taxpayer Advocate Office
Appendix VII

Comments From the Internal Revenue Service

Page 55 GAO/GGD-99-124 Taxpayer Advocate Office
Page 56 GAO/GGD-99-124 Taxpayer Advocate Office
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