Page 1 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Financial Literacy: Overlap of 

Programs Suggests There May Be 

Opportunities for Consolidation

GAO-12-588 07/23/2012 Administration of 

Program Operations

To help ensure effective and efficient use of federal financial literacy 

resources, the Secretary of the Treasury and the Director of the Consumer 

Financial Protection Bureau, in their capacity as Chair and Vice Chair of the 

Financial Literacy and Education Commission, and in concert with other 

agency representatives of the commission should identify for federal 

agencies and Congress options for consolidating federal financial literacy 

efforts into the activities and agencies that are best suited or most effective.

Treasury - DO Implemented. Pending auditor validation.

Financial Literacy: Overlap of 

Programs Suggests There May Be 

Opportunities for Consolidation

GAO-12-588 07/23/2012 Administration of 

Program Operations

To help ensure effective and efficient use of federal financial literacy 

resources, the Secretary of the Treasury and the Director of the Consumer 

Financial Protection Bureau, in their capacity as Chair and Vice Chair of the 

Financial Literacy and Education Commission, and in concert with other 

agency representatives of the commission should revise the commission's 

national strategy to incorporate clear recommendations on the allocation of 

federal financial literacy resources across programs and agencies.

Treasury - DO Implemented. Pending auditor validation.

Financial Stability: New Council and 

Research Office Should Strengthen the 

Accountability and Transparency of 

Their Decisions

GAO-12-886 09/11/2012 Administration of 

Program Operations

FSOC and OFR should clarify responsibility for implementing requirements 

to monitor threats to financial stability across FSOC and OFR, including 

FSOC members and member agencies, to better ensure that the monitoring 

and analysis of the financial system are comprehensive and not unnecessarily 

duplicative.

Treasury - DO Implemented. Pending auditor validation.

Financial Stability: New Council and 

Research Office Should Strengthen the 

Accountability and Transparency of 

Their Decisions

GAO-12-886 09/11/2012 Administration of 

Program Operations

To strengthen accountability and collaboration in FSOC's decision making, 

FSOC should establish a collaborative and comprehensive framework for 

assessing the impact of its decisions for designating FMUs and nonbank 

financial companies on the wider economy and those entities. This 

framework should include assessing the effects of subjecting designated 

FMUs and nonbank financial companies to new regulatory standards, 

requirements, and restrictions; establishing a baseline from which to measure 

the effects; and documenting the approach.

Treasury - DO Implemented. Pending auditor validation.

Financial Stability: New Council and 

Research Office Should Strengthen the 

Accountability and Transparency of 

Their Decisions

GAO-12-886 09/11/2012 Administration of 

Program Operations

To strengthen accountability and collaboration in FSOC's decision making, 

FSOC should develop more systematic forward-looking approaches for 

reporting on potential emerging threats to financial stability in annual 

reports. Such an approach should provide methodological insight into why 

certain threats to financial stability are included or excluded over time, 

separate current or past threats from those that are potentially emerging, and 

prioritize the latter.

Treasury - DO Implemented. Pending auditor validation.
Page 2 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Organizational Transformation: 

Enterprise Architecture (EA) Value 

Needs to be Measured and Reported

GAO-12-791 09/26/2012 Information 

Technology

To enhance federal agencies' ability to realize enterprise architecture 

benefits, the Secretaries of the Departments of Agriculture, the Air Force, the 

Army, Commerce, Defense, Education, Energy, Homeland Security, the 

Interior, Labor, the Navy, State, Transportation, the Treasury, and Veterans 

Affairs; the Attorney General; the Administrators of the Environmental 

Protection Agency, General Services Administration, National Aeronautics 

and Space Administration, and Small Business Administration; the 

Commissioners of the Nuclear Regulatory Commission and Social Security 

Administration; and the Directors of the National Science Foundation and 

the Office of Personnel Management should fully establish an approach for 

measuring enterprise architecture outcomes, including a documented method 

(i.e., steps to be followed) and metrics that are measurable, meaningful, 

repeatable, consistent, actionable, and aligned with the agency's enterprise 

architecture's strategic goals and intended purpose.

Treasury - DO Implemented. Pending auditor validation.

Organizational Transformation: 

Enterprise Architecture (EA) Value 

Needs to be Measured and Reported

GAO-12-791 09/26/2012 Information 

Technology

To enhance federal agencies' ability to realize enterprise architecture 

benefits, the Secretaries of the Departments of Agriculture, the Air Force, the 

Army, Commerce, Defense, Education, Energy, Homeland Security, the 

Interior, Labor, the Navy, State, Transportation, the Treasury, and Veterans 

Affairs; the Attorney General; the Administrators of the Environmental 

Protection Agency, General Services Administration, National Aeronautics 

and Space Administration, and Small Business Administration; the 

Commissioners of the Nuclear Regulatory Commission and Social Security 

Administration; and the Directors of the National Science Foundation and 

the Office of Personnel Management should periodically measure and report 

enterprise architecture outcomes and benefits to top agency officials (i.e., 

executives with authority to commit resources or make changes to the 

program) and to OMB.

Treasury - DO Implemented. Pending auditor validation.

TAX GAP: IRS Could Significantly 

Increase Revenues by Better Targeting 

Enforcement Resources

GAO-13-151 12/05/2012 Tax Administration and 

Compliance

Review disparities in the ratios of direct revenue yield to costs across 

different enforcement programs and across different groups of cases and 

consider this evidence as a potential basis for adjusting its allocation of 

enforcement resources each year.

IRS Implemented. Pending auditor validation.

2012 Tax Filing: IRS Faces Challenges 

Providing Service to Taxpayers and 

Could Collect Balances Due More 

Effectively

GAO-13-156 12/18/2012 Tax Administration and 

Compliance

Outline a strategy that defines appropriate levels of telephone and 

correspondence service and wait time and lists specific steps to manage 

service based on an assessment of time frames, demand, capabilities, and 

resources.

IRS Rejected. IRS disagreed with the 

recommendation. Although IRS does not plan 

to pursue the specific actions recommended as 

explained in response to GAO dated December 

13, 2012, it has other activities in place such 

as applying more Customer Service 

Representatives to answer calls, improving 

contact center efficiency, providing issue 

resolution alternatives to reduce demand, and 

enhancing the Where's My Refund (WMR) 

web application that will achieve program 

improvements as intended by the 

recommendation.
Page 3 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

IRS WEBSITE: Long-Term Strategy 

Needed to Improve Interactive Services

GAO-13-435 04/16/2013 Administration of 

Program Operations

Develop business cases for all new online services, describing the potential 

benefits and costs of the project, and use them to prioritize future projects.

IRS Implemented. Pending auditor validation.

IRS WEBSITE: Long-Term Strategy 

Needed to Improve Interactive Services

GAO-13-435 04/16/2013 Administration of 

Program Operations

Establish a numerical or other measurable goal to improve taxpayer 

satisfaction and a timeframe for achieving it.

IRS Implemented. Pending auditor validation.

INFORMATION TECHNOLOGY: 

Consistently Applying Best Practices 

Could Help IRS Improve the Reliability 

of Reported Cost and Schedule 

Information

GAO-13-401 04/17/2013 Information 

Technology

To improve the reliability of reported cost and schedule variance information 

for the seven major investments GAO reviewed, GAO recommends that the 

Acting Commissioner of IRS direct the Chief Technology Officer to improve 

the reliability of cost estimates by addressing the weaknesses GAO identified 

in this report so that each investment at least substantially meets each of the 

characteristics of a reliable cost estimate.

IRS Implemented. Pending auditor validation.

INFORMATION TECHNOLOGY: 

Consistently Applying Best Practices 

Could Help IRS Improve the Reliability 

of Reported Cost and Schedule 

Information

GAO-13-401 04/17/2013 Information 

Technology

To improve the reliability of reported cost and schedule variance information 

for the seven major investments GAO reviewed, GAO recommends that the 

Acting Commissioner of IRS direct the Chief Technology Officer to develop 

and implement guidance that specifies best practices-such as including 

evaluating critical path (for projected schedule), using earned value 

management data, evaluating the performance of completed work and 

comparing it to the remaining budget, assessing commitment values for 

material needed to complete remaining work, and estimating future 

conditions-to consider when determining projected cost and schedule 

amounts.

IRS Implemented. Pending auditor validation.

INFORMATION TECHNOLOGY: 

Consistently Applying Best Practices 

Could Help IRS Improve the Reliability 

of Reported Cost and Schedule 

Information

GAO-13-401 04/17/2013 Information 

Technology

To improve the reliability of reported cost and schedule variance information 

for the seven major investments GAO reviewed, GAO recommends that the 

Acting Commissioner of IRS direct the Chief Technology Officer to improve 

the extent to which schedules are well-constructed and controlled by 

addressing the weaknesses GAO identified in this report so that each 

investment at least substantially meets each of these characteristics.

IRS Implemented. Pending auditor validation.

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Controls

GAO-13-420R 05/13/2013 Administration of 

Program Operations

Perform a risk assessment to determine the appropriate level of IDRS access 

that should be granted to employee groups that handle hard-copy taxpayer 

receipts and related sensitive taxpayer information as part of their job 

responsibilities.

IRS PCA Due Date: Oct-2019

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Controls

GAO-13-420R 05/13/2013 Administration of 

Program Operations

Based on the results of the risk assessment, update the IRM accordingly to 

specify the appropriate level of IDRS access that should be allowed for (1) 

remittance perfection technicians and (2) all other employee groups with 

IDRS access that handle hard-copy taxpayer receipts and related sensitive 

information as part of their job responsibilities.

IRS PCA Due Date: Oct-2020

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Controls

GAO-13-420R 05/13/2013 Administration of 

Program Operations

Establish procedures to implement the updated IRM, including required 

steps to follow to prevent (1) remittance perfection technicians and (2) all 

other employee groups that handle hard-copy taxpayer receipts and related 

sensitive information as part of their job responsibilities from gaining access 

to command codes not required as part of their designated job duties.

IRS PCA Due Date: Oct-2020
Page 4 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

TAX ADMINISTRATION: IRS Could 

Improve Examinations by Adopting 

Certain Research Program Practices

GAO-13-480 05/24/2013 Tax Administration and 

Compliance

Transcribe data from paper-filed Form 1040 Schedules C and E that are not 

currently transcribed and make that data available to SB/SE examiners for 

classification. If IRS has evidence that the costs related to transcribing all 

such data on Schedules C and E exceed the benefits or are otherwise 

prohibitive, IRS could transcribe less data by transcribing only the missing 

data for selected line items, such as certain large expense line items, and/or 

develop a budget proposal to fund an initiative for transcribing the Schedule 

C and E data.

IRS Implemented. Pending auditor validation.

Management Report: Improvements 

Needed in Controls over the Preparation 

of the U.S. Consolidated Financial 

Statements

GAO-13-540 6/28/2013 Financial Statements To improve the reliability of the information presented in the CFS budget 

statements, the Secretary of the Treasury should direct the Fiscal Assistant 

Secretary, working in coordination with the Controller of OMB's Office of 

Federal Financial Management, to establish and implement effective 

procedures for reporting amounts in the CFS budget statements that are fully 

consistent with the underlying information in significant federal entities' 

audited financial statements and other financial data.

Fiscal Service PCA Due Date: Sep-2022

Management Report: Improvements 

Needed in Controls over the Preparation 

of the U.S. Consolidated Financial 

Statements

GAO-13-540 6/28/2013 Financial Statements To improve the reliability of the information presented in the CFS budget 

statements, the Secretary of the Treasury should direct the Fiscal Assistant 

Secretary, working in coordination with the Controller of OMB's Office of 

Federal Financial Management, to establish and implement effective 

procedures for identifying and reporting all items needed to prepare the CFS 

budget statements.

Fiscal Service PCA Due Date: Sep-2020

Corporate Tax Compliance: IRS 

Should Determine Whether Its 

Streamlined Corporate Audit Process Is 

Meeting Its Goals

GAO-13-662 08/22/2013 Tax Administration and 

Compliance

Track savings from Compliance Maintenance and Compliance Assurance 

Process (CAP) overall and develop a plan for reinvesting any savings.

IRS Implemented. Pending auditor validation.

INFORMATION TECHNOLOGY: 

Additional OMB and Agency Actions 

Are Needed to Achieve Portfolio 

Savings

GAO-14-65 11/06/2013 Administration of 

Program Operations

To improve the department's implementation of PortfolioStat, as the 

department finalizes and matures its enterprise architecture and valuation 

methodology, the Secretary of the Treasury should direct the CIO to utilize 

these processes to identify whether there are additional opportunities to 

reduce duplicative, low-value, or wasteful investments.

Treasury - DO Implemented. Pending auditor validation.

INFORMATION TECHNOLOGY: 

Additional OMB and Agency Actions 

Are Needed to Achieve Portfolio 

Savings

GAO-14-65 11/06/2013 Administration of 

Program Operations

To improve the department's implementation of PortfolioStat, in future 

reporting to OMB, the Secretary of the Treasury should direct the CIO to 

fully describe the following PortfolioStat action plan elements: (1) 

consolidate commodity IT spending under the agency CIO and (2) establish 

criteria for identifying wasteful, low-value, or duplicative investments.

Treasury - DO Implemented. Pending auditor validation.

Private Pensions: Clarity of Required 

Reports and Disclosures Could Be 

Improved

GAO-14-92 11/21/2013 Administration of 

Program Operations

To ease the burden on plan sponsors, enhance compliance, and help ensure 

that disclosures to participants are written in a manner that can be understood 

by the average participant, Labor, IRS, and PBGC should work together to: 

Create and regularly update a comprehensive online tool for plan sponsors to 

search for the reports and disclosures they are required to provide based on 

plan type, design, and circumstances.

IRS Implemented. Pending auditor validation.
Page 5 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Civilian Intelligence Community: 

Additional Actions Needed to Improve 

Reporting on and Planning for the Use 

of Contract Personnel

GAO-14-204 01/29/2014 Administration of 

Program Operations

To improve civilian IC elements' or their respective departments' ability to 

mitigate risks associated with the use of contractors, the Director of National 

Intelligence, Director of the Central Intelligence Agency, Attorney General 

of the United States, and Secretaries of Energy and the Treasury should 

direct responsible agency officials to set time frames to develop guidance 

that fully addresses the Office of Federal Procurement Policy, Policy Letter 

11-01's requirements related to closely supporting inherently governmental 

functions.

Treasury - DO Implemented. Pending auditor validation.

PARTNERSHIPS AND S 

CORPORATIONS: IRS Needs to 

Improve Information to Address Tax 

Noncompliance

GAO-14-453 05/14/2014 Tax Administration and 

Compliance

While IRS works to improve the quality of its Schedule K-1 data, develop a 

plan for conducting testing or other analysis to determine whether the 

improved Schedule K-1 data, perhaps combined with other IRS information 

about businesses and taxpayers, could be used more effectively to ensure 

compliance with the reporting of flow-through income.

IRS Rejected. IRS disagreed with the 

recommendation. IRS understands the 

objective of this recommendation and, at such 

time that resources are available to enhance 

capabilities, we would consider this 

methodology of advanced testing. However, 

currently we will not be pursing the actions 

recommended. IRS views this GAO 

recommendation as not providing a sufficient 

return on investment to warrant allocating 

limited resources for implementing the 

recommendation. 

IRS Correspondence Audits: Better 

Management Could Improve Tax 

Compliance and Reduce Taxpayer 

Burden

GAO-14-479 06/05/2014 Tax Administration and 

Compliance

To clarify the desired results of the correspondence audit program and its 

linkages to IRS-wide activities, 

.Establish formal program objectives.

.Ensure that the program measures reflect those objectives. 

.Clearly link those measures with strategic IRS-wide goals on ensuring 

compliance in a cost effective way while minimizing taxpayer burden.

IRS Implemented. Pending auditor validation.

IRS 2015 BUDGET: Long-Term 

Strategy and Return on Investment Data 

Needed to Better Manage Budget 

Uncertainty and Set Priorities

GAO-14-605 06/12/2014 Administration of 

Program Operations

Because ROI provides insights on the productivity of a program and is one 

important factor in making resource allocation decisions, GAO recommends 

IRS calculate actual ROI for implemented initiatives, compare the actual ROI 

to projected ROI, and provide the comparison to budget decision makers for 

initiatives where IRS allocated resources.

IRS Implemented. Pending auditor validation.

IRS 2015 BUDGET: Long-Term 

Strategy and Return on Investment Data 

Needed to Better Manage Budget 

Uncertainty and Set Priorities

GAO-14-605 06/12/2014 Administration of 

Program Operations

Because ROI provides insights on the productivity of a program and is one 

important factor in making resource allocation decisions, GAO recommends 

IRS use actual ROI calculations as part of resource allocation decisions.

IRS Implemented. Pending auditor validation.

Debt Management: Floating Rate Notes 

Can Help Treasury Meet Borrowing 

Goals, but Additional Actions Needed 

to Help Manage Risk

GAO-14-535 06/16/2014 Banking and Lending To help minimize Treasury borrowing costs over time by better 

understanding and managing the risks posed by Treasury floating rate notes 

and by enhancing demand for Treasury securities, the Secretary of the 

Treasury should track and report an additional measure of the length of the 

portfolio that captures the interest rate reset frequency of securities in the 

portfolio.

Treasury - DO Implemented. Pending auditor validation.
Page 6 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Management Report: Improvements 

Needed in Controls over the Processes 

Used to Prepare the U.S. Consolidated 

Financial Statements

GAO-14-543 6/19/2014 Financial Statements The Secretary of the Treasury should direct the Fiscal Assistant Secretary, 

working in coordination with the Controller of OMB, to establish and 

implement policies and procedures for accounting for and reporting all 

significant General Fund activity and balances, obtaining assurance on the 

reliability of the amounts, and reconciling the activity and balances between 

the General Fund and federal entities.

Fiscal Service PCA Due Date: Sep-2022

Management Report: Improvements 

Needed in Controls over the Processes 

Used to Prepare the U.S. Consolidated 

Financial Statements

GAO-14-543 6/19/2014 Financial Statements The Secretary of the Treasury should direct the Fiscal Assistant Secretary, 

working in coordination with the Controller of OMB, to establish a 

formalized process to require the performance of additional audit procedures 

specifically focused on intragovernmental activity and balances between 

federal entities to provide increased audit assurance over the reliability of 

such information.

Fiscal Service Rejected. Treasury disagreed with the 

recommendation. The Office of Management 

and Budget (OMB) and Treasury do not think 

they need to place additional audit burden on 

agencies. With respect to this 

recommendation’s reference to a need for 

additional agency audit procedures for 

intragovernmental activity and balances, 

Treasury’s plan already contains multiple 

corrective actions aimed at increasing the 

quality of intragovernmental data. These 

actions are proving effective, as reflected by a 

reduction of over 80 percent in elimination 

differences of intragovernmental data 

submitted by federal entities from FY 2015 to 

FY 2016. Moreover, in alignment with the 

current administration’s efforts to reduce 

agency burden, we do not support 

encumbering agencies with the cost and 

burden of the additional audit procedures 

being recommended. However, Treasury will 

continue to work collaboratively with OMB 

and the federal agency community on existing 

corrective actions.

PRIVATE PENSIONS: Targeted 

Revisions Could Improve Usefulness of 

Form 5500 Information

GAO-14-441 07/07/2014 Administration of 

Program Operations

To improve the usefulness, reliability, and comparability of Form 5500 data 

for all stakeholders while limiting the burden on the filing community, the 

Secretaries of DOL and Treasury, and the Director of PBGC should consider 

implementing the findings from the GAO panel when modifying plan 

investment and service provider fee information, including: revise Schedule 

H plan asset categories to better match current investment vehicles and 

provide more transparency into plan investments;

IRS Implemented. Pending auditor validation.

PRIVATE PENSIONS: Targeted 

Revisions Could Improve Usefulness of 

Form 5500 Information

GAO-14-441 07/07/2014 Administration of 

Program Operations

To improve the usefulness, reliability, and comparability of Form 5500 data 

for all stakeholders while limiting the burden on the filing community, the 

Secretaries of DOL and Treasury, and the Director of PBGC should consider 

implementing the findings from the GAO panel when modifying plan 

investment and service provider fee information, including: revise the 

Schedule of Assets attachments to create a standard searchable format;

IRS Implemented. Pending auditor validation.
Page 7 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

PRIVATE PENSIONS: Targeted 

Revisions Could Improve Usefulness of 

Form 5500 Information

GAO-14-441 07/07/2014 Administration of 

Program Operations

To improve the usefulness, reliability, and comparability of Form 5500 data 

for all stakeholders while limiting the burden on the filing community, the 

Secretaries of DOL and Treasury, and the Director of PBGC should consider 

implementing the findings from the GAO panel when modifying plan 

investment and service provider fee information, including: develop a central 

repository for EIN and PN numbers for filers and service providers to 

improve the comparability of form data across filings.

IRS Rejected. IRS disagreed with the 

recommendation. IRS currently does not have 

the funding and staffing needed to develop the 

type of electronic repository that GAO has 

recommended. Further, IRS views this GAO 

recommendation as not providing a sufficient 

return on investment to warrant allocating 

limited resources for implementing the 

recommendation.

PRIVATE PENSIONS: Targeted 

Revisions Could Improve Usefulness of 

Form 5500 Information

GAO-14-441 07/07/2014 Administration of 

Program Operations

To improve the usefulness, reliability, and comparability of Form 5500 data 

for all stakeholders while limiting the burden on the filing community, the 

Secretaries of DOL and Treasury, and the Director of PBGC should consider 

implementing the findings from the GAO panel when modifying plan 

investment and service provider fee information, including: clarify Schedule 

C instructions for direct, eligible indirect, and reportable indirect 

compensation so plan fees are reported more consistently and, as we 

recommended in the past, better align with the 408(b)(2) fee disclosures.

IRS Rejected. IRS disagreed with the 

recommendation. The collection of 

information via Schedule C is within the 

exclusive jurisdiction of the DOL pursuant to 

Title I of ERISA. Accordingly, the IRS must 

defer to the DOL on the action and timing for 

those recommendations

PRIVATE PENSIONS: Targeted 

Revisions Could Improve Usefulness of 

Form 5500 Information

GAO-14-441 07/07/2014 Administration of 

Program Operations

To improve the usefulness, reliability, and comparability of Form 5500 data 

for all stakeholders while limiting the burden on the filing community, the 

Secretaries of DOL and Treasury, and the Director of PBGC should consider 

implementing the findings from the GAO panel when modifying plan 

investment and service provider fee information, including: simplify and 

clarify Schedule C service provider codes to increase reporting consistency.

IRS Rejected. IRS disagreed with the 

recommendation. The collection of 

information via Schedule C is within the 

exclusive jurisdiction of the Department of 

Labor (DOL) pursuant to Title I of ERISA. 

Accordingly, IRS must defer to the DOL on 

the action and timing for those 

recommendations.

LARGE PARTNERSHIPS: With 

Growing Number of Partnerships, IRS 

Needs to Improve Audit Efficiency

GAO-14-732 09/18/2014 Tax Administration and 

Compliance

Track the results of large partnerships audits: (a) define a large partnership 

based on asset size and number of partners; (b) revise the activity codes to 

align with the large partnership definition; and (c) separately account for 

field audits and campus audits.

IRS Implemented. Pending auditor validation.

LARGE PARTNERSHIPS: With 

Growing Number of Partnerships, IRS 

Needs to Improve Audit Efficiency

GAO-14-732 09/18/2014 Tax Administration and 

Compliance

Analyze the audit results by these activity codes and types of audits to 

identify opportunities to better plan and use IRS resources in auditing large 

partnerships.

IRS PCA Due Date: Sep-2019

Troubled Asset Relief Program: 

Treasury Could Better Analyze Data to 

Improve Oversight of Servicers' 

Practices

GAO-15-5 10/06/2014 Administration of 

Program Operations

To improve monitoring and oversight of Treasury's HAMP, the Secretary of 

the Treasury should conduct periodic evaluations using analytical methods, 

such as econometric modeling as appropriate, to help explain differences 

among MHA servicers in redefault rates that may inform its compliance 

reviews of individual servicers, identify areas of weaknesses and best 

practices, and determine the potential need for additional program policy 

changes.

Treasury - DO Implemented. Pending auditor validation.
Page 8 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

INDIVIDUAL

RETIREMENT ACCOUNTS: IRS 

Could Bolster Enforcement on

Multimillion Dollar Accounts, but More 

Direction from

Congress Is Needed

GAO-15-16 10/20/2014 Tax Administration and 

Compliance

To improve IRS's ability to detect and pursue noncompliance associated

with undervalued assets sheltered in IRAs and prohibited transactions, 

conduct research using the new Form 5498 data to identify IRAs holding 

nonpublic asset types, such as profits interests in private equity firms and 

hedge funds, and use that information for an IRS-wide strategy to target 

enforcement efforts.

IRS Implemented. Pending auditor validation.

INDIVIDUAL

RETIREMENT ACCOUNTS: IRS 

Could Bolster Enforcement on

Multimillion Dollar Accounts, but More 

Direction from

Congress Is Needed

GAO-15-16 10/20/2014 Tax Administration and 

Compliance

To improve IRS's ability to detect and pursue noncompliance associated

with undervalued assets sheltered in IRAs and prohibited transactions, work 

in consultation with the Department of the Treasury on a legislative proposal 

to expand the statute of limitations on IRA noncompliance to help IRS 

pursue valuation-related misreporting and prohibited transactions that may 

have originated outside the current statute's 3-year window.

IRS Implemented. Pending auditor validation.

INDIVIDUAL

RETIREMENT ACCOUNTS: IRS 

Could Bolster Enforcement on

Multimillion Dollar Accounts, but More 

Direction from

Congress Is Needed

GAO-15-16 10/20/2014 Tax Administration and 

Compliance

To help taxpayers better understand compliance risks associated with

certain IRA choices and improve compliance, building on research data on 

IRAs holding nonpublic assets, identify options to provide outreach targeting 

taxpayers with nonpublic IRA assets and their custodians, such as reminder 

notices that engaging in prohibited transactions can result in loss of the IRA's 

tax-favored status.

IRS Implemented. Pending auditor validation.

Financial Stability Oversight Council: 

Further Actions Could Improve the 

Nonbank Designation Process

GAO-15-51 11/20/2014 Administration of 

Program Operations

To help ensure that FSOC is comprehensively identifying and considering 

companies, the Secretary of the Treasury in consultation with FSOC 

members, should establish procedures to evaluate companies in Stage 2 and 

Stage 3 under both statutory determination standards when an evaluation in 

either stage concludes that a company does not meet one of the standards, or 

document--on a company-specific or more general basis--why the second 

determination standard is not relevant for determination evaluations

Treasury - DO Implemented. Pending auditor validation.

Financial Stability Oversight Council: 

Further Actions Could Improve the 

Nonbank Designation Process

GAO-15-51 11/20/2014 Administration of 

Program Operations

To help ensure that FSOC is comprehensively identifying and considering 

companies, the Secretary of the Treasury in consultation with FSOC 

members, should develop a process to collect information necessary for 

Stage 1 analysis, as appropriate, from certain nonbank financial companies 

for which public or regulatory information is otherwise unavailable. For 

example, FSOC could have companies for which such information is 

unavailable and that meet certain characteristics (such as quantitative 

thresholds similar to those used in Stage 1) report necessary information to 

the Office of Financial Research.

Treasury - DO Implemented. Pending auditor validation.

Private Pensions: Participants Need 

Better Information When Offered Lump 

Sums That Replace Their Lifetime 

Benefits

GAO-15-74 01/27/2015 Administration of 

Program Operations

To provide participants with useful information and to provide for lump 

sums that are based on up-to-date assumptions, Treasury should review its 

regulations governing the information contained in relative value statements 

to ensure these statements provide a meaningful comparison of all benefit 

options, especially in instances where the loss of certain additional plan 

benefits may not be disclosed.

Treasury - DO No Action Taken. 
Page 9 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Private Pensions: Participants Need 

Better Information When Offered Lump 

Sums That Replace Their Lifetime 

Benefits

GAO-15-74 01/27/2015 Administration of 

Program Operations

To provide participants with useful information and to provide for lump 

sums that are based on up-to-date assumptions, Treasury should review the 

applicability and appropriateness of allowing sponsors to select a "lookback" 

interest rate for use in calculating lump sums associated with a lump sum 

window that can serve to advantage the interests of the sponsor.

Treasury - DO No Action Taken. 

Private Pensions: Participants Need 

Better Information When Offered Lump 

Sums That Replace Their Lifetime 

Benefits

GAO-15-74 01/27/2015 Administration of 

Program Operations

To provide participants with useful information and to provide for lump 

sums that are based on up-to-date assumptions, Treasury should establish a 

process and a timeline for periodically updating the mortality tables used to 

determine minimum required lump sums-- including a means for monitoring 

when experts' views may indicate that mortality tables may have become 

outdated, and for taking expedited action if warranted.

Treasury - DO No Action Taken. 

Critical Technologies: Agency 

Initiatives Address Some Weaknesses, 

but Additional Interagency 

Collaboration Is Needed

GAO-15-288 02/10/2015 Administration of 

Program Operations

To ensure a consistent and more collaborative approach to the protection of 

critical technologies, GAO recommends that the Secretaries of the 

Departments of Commerce, Defense, Homeland Security, State, and the 

Treasury; as well as the Attorney General, who have lead and stakeholder 

responsibilities for the eight programs within the critical technologies 

portfolio, take steps to promote and strengthen collaboration mechanisms 

among their respective programs while ongoing initiatives are implemented 

and assessed. These steps need not be onerous; for example, they could 

include conducting an annual meeting to discuss their programs, including 

the technologies they are protecting, their programs' intent, any new 

developments or changes planned for their programs, as well as defining 

consistent critical technologies terminology and sharing important updates.

Treasury - DO Implemented. Pending auditor validation.

INFORMATION TECHNOLOGY - 

Management Needs to Address 

Reporting of IRS Investments' Cost, 

Schedule, and Scope Information

GAO-15-297 02/25/2015 Information 

Technology

To improve the reliability and reporting of investment performance 

information and management of selected major investments, GAO 

recommends that the Commissioner of the IRS direct the Chief Technology 

Officer to take the following action: Modify reporting of ACA testing status 

to senior management to include a comprehensive report on all impacted 

systems-including an explanation for why impacted systems were not tested 

at a particular level-and ensure this reporting is aligned with the manner in 

which testing is being performed.

IRS Rejected. IRS disagreed with the 

recommendation. We followed a rigorous riskbased process for planning the tests of 

Affordable Care Act (ACA) impacted systems, 

including the types and levels of testing. ACA 

Release 5.0 was complex and high-risk, thus 

reporting for testing within and outside IRS 

was frequent (sometimes daily), with test 

progress formally delivered via planned crossorganizational checkpoints and the Filing 

Season readiness assessment. 

Information Security: IRS Needs to 

Continue Improving Controls over 

Financial and Taxpayer Data

GAO-15-337 03/19/2015 Information 

Technology

Take the following action to effectively implement key elements of the IRS 

information security program: Update the remedial action verification 

process to ensure actions are fully implemented.

IRS Implemented. Pending auditor validation.

Information Security: IRS Needs to 

Continue Improving Controls over 

Financial and Taxpayer Data

GAO-15-337 03/19/2015 Information 

Technology

Take the following action to effectively implement key elements of the IRS 

information security program: Ensure that control testing methodology and 

results fully meet the intent of the control objectives being tested.

IRS PCA Due Date: Jul-2020
Page 10 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Telecommunications: Agencies Need 

better Controls to Achieve Significant 

Savings on Mobile Devices and 

Services

GAO-15-431 05/21/2015 Information 

Technology

Secretary of Treasury should ensure an inventory of mobile devices and 

services is established department-wide (i.e. all components' devices and 

associated services are accounted for).

Treasury - DO Implemented. Pending auditor validation.

Telecommunications: Agencies Need 

better Controls to Achieve Significant 

Savings on Mobile Devices and 

Services

GAO-15-431 05/21/2015 Information 

Technology

Secretary of the Treasury should ensure procedures to monitor and control 

spending are established department-wide. Specifically ensure: procedures 

include assessing devices for zero, under and over usage; personnel with 

authority and responsibility for performing the procedures are identified and 

the specific steps to be taken to perform the process are documented.

Treasury - DO Implemented. Pending auditor validation.

Management Report: Improvements 

Are Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-15-480R 05/29/2015 Financial Statements Determine why staff did not consistently comply with IRS's existing 

requirements for the final candling of receipts at Service Center Campuses 

(SCCs) and lockbox banks, including logging remittances found during final 

candling on the final candling log at the time of discovery, safeguarding the 

remittances at the time of discovery, transferring the remittances to the 

deposit unit promptly, and passing one envelope at a time over the light 

source, and based on this determination, establish a process to better enforce 

compliance with these requirements.

IRS PCA Due Date: Dec-2019

Management Report: Improvements 

Are Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-15-480R 05/29/2015 Financial Statements Establish procedures to monitor whether non-IRS contractors with 

unescorted physical access to IRS facilities are receiving unauthorized access 

awareness training.

IRS Implemented. Pending auditor validation.

Management Report: Improvements 

Are Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-15-480R 05/29/2015 Financial Statements Establish a process to ensure that the requirement for unauthorized access 

awareness training is explicitly communicated to non-IRS contractors who 

have unescorted access to IRS facilities.

IRS Implemented. Pending auditor validation.

Mortgage Reforms: Actions Needed to 

Help Assess Effects of New Regulations

GAO-15-185 07/27/2015 Banking and Lending To enhance the effectiveness of their preparations for conducting a 

retrospective review of the QRM regulations, the agencies responsible for 

the QRM regulations--Federal Deposit Insurance Corporation, Federal 

Housing Finance Agency, Board of Governors of the Federal Reserve 

System, HUD, Office of the Comptroller of the Currency, and Securities and 

Exchange Commission--should develop a plan that identifies the metrics, 

baselines, and analytical methods to be used and specify the roles and 

responsibilities of each agency in the review process. Furthermore, to 

account for and help mitigate limitations of existing data and the uncertain 

availability of enhanced datasets, the six agencies should include in their 

plan alternate metrics, baselines, and analytical methods that could be used if 

data were to remain unavailable.

OCC Implemented. Pending auditor validation.
Page 11 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

PATIENT PROTECTION AND 

AFFORDABLE CARE ACT: IRS 

Needs to Strengthen Oversight of Tax 

Provisions for Individuals

GAO-15-540 07/29/2015 Tax Administration and 

Compliance

To strengthen oversight of the individual shared responsibility and premium 

tax credit provisions, GAO recommends that the Commissioner of Internal 

Revenue take the following action: Assess whether or not the data received 

from the health insurance marketplaces are sufficiently complete and 

accurate to enable effective correction of tax returns at-filing based on 

matching with the marketplace data and, if the assessment determines that 

such corrections would be effective, seek legislative authority to correct tax 

returns at-filing based on the marketplace data.

IRS Implemented. Pending auditor validation.

PATIENT PROTECTION AND 

AFFORDABLE CARE ACT: IRS 

Needs to Strengthen Oversight of Tax 

Provisions for Individuals

GAO-15-540 07/29/2015 Tax Administration and 

Compliance

To strengthen oversight of the individual shared responsibility and premium 

tax credit provisions, we recommend that the Commissioner of Internal 

Revenue take the following action: Evaluate IRS efforts to collaborate and 

communicate with key external stakeholders to inform efforts related to 

implementation of the new 2015 PPACA requirements.

IRS Implemented. Pending auditor validation.

IRS CASE SELECTION: Collection 

Process Is Largely Automated, but 

Lacks Adequate Internal Controls

GAO-15-647 07/29/2015 Tax Administration and 

Compliance

Establish, document, and implement clear objectives for the collection 

program and enterprise-wide case categorization and routing processes, and 

define key terms, such as "fairness" and "risk."

IRS Implemented. Pending auditor validation.

IRS CASE SELECTION: Collection 

Process Is Largely Automated, but 

Lacks Adequate Internal Controls

GAO-15-647 07/29/2015 Tax Administration and 

Compliance

Build upon existing Enterprise Risk Management (ERM) guidance to help 

managers identify internal and external risks to collection program 

objectives, and better understand how long-standing risk processes integrate 

with new ERM approaches; incorporate this guidance into existing or future 

ERM or collection program risk assessment processes.

IRS Implemented. Pending auditor validation.

IRS CASE SELECTION: Collection 

Process Is Largely Automated, but 

Lacks Adequate Internal Controls

GAO-15-647 07/29/2015 Tax Administration and 

Compliance

Clearly establish, document, and implement case categorization and routing 

procedures-such as those for IDS, high priority case selection, and any other 

important processes-to support collection program objectives and IRS goals.

IRS Implemented. Pending auditor validation.

IRS CASE SELECTION: Collection 

Process Is Largely Automated, but 

Lacks Adequate Internal Controls

GAO-15-647 07/29/2015 Tax Administration and 

Compliance

Establish, document, and implement procedures for the periodic evaluation 

of the efficiency and effectiveness of collection-wide case categorization, 

routing rules, and case selection processes.

IRS Implemented. Pending auditor validation.

IRS CASE SELECTION: Collection 

Process Is Largely Automated, but 

Lacks Adequate Internal Controls

GAO-15-647 07/29/2015 Tax Administration and 

Compliance

Establish, document, and implement procedures for periodic updates of 

dollar thresholds for categorizing case selection, including those identified as 

"high risk."

IRS Implemented. Pending auditor validation.

IRS CASE SELECTION: Automated 

Collection System Lacks Key Internal 

Controls Needed to Ensure the Program 

Fulfills Its Mission

GAO-15-744 09/10/2015 Tax Administration and 

Compliance

Establish, document, and implement objectives for the collection program 

and ACS, and define the key term of "fairness" as it applies to collection 

activities, which can be communicated to IRS staff.

IRS Implemented. Pending auditor validation.

Information Technology Reform: 

Billions of Dollars in Savings Have 

Been Realized, but Agencies Need to 

Complete Reinvestment Plans

GAO-15-617 09/15/2015 Information 

Technology

To improve the department's IT savings reinvestment plans, the Secretary of 

the Treasury should direct the CIO, as part of any future update to the 

department's Information Resources Management (IRM) strategic plan or 

equivalent document, to include information regarding the approach to 

reinvesting savings from the consolidation of commodity IT resources 

(including data centers) in accordance with OMB's guidance.

Treasury - DO Implemented. Pending auditor validation.
Page 12 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Information Technology Reform: 

Billions of Dollars in Savings Have 

Been Realized, but Agencies Need to 

Complete Reinvestment Plans

GAO-15-617 09/15/2015 Information 

Technology

To improve the department's IT savings reinvestment plans, the Secretary of 

the Treasury should direct the CIO to ensure that the department's integrated 

data collection submission to OMB includes, for all reported initiatives, 

complete plans to use any resulting cost savings and avoidances from OMBdirected IT reform-related efforts.

Treasury - DO Implemented. Pending auditor validation.

Critical Infrastructure Protection: SectorSpecific Agencies Need to Better 

Measure Cybersecurity Progress

GAO-16-79 11/19/2015 Information 

Technology

To better monitor and provide a basis for improving the effectiveness of 

cybersecurity risk mitigation activities, informed by the sectors' updated 

plans and in collaboration with sector stakeholders, the Secretary of the 

Treasury should direct responsible officials to develop performance metrics 

to provide data and determine how to overcome challenges to monitoring the 

financial services sector's cybersecurity progress.

Treasury - DO Implemented. Pending auditor validation.

2015 Tax Filing Season GAO-16-151DO 01/14/2016 Tax Administration and 

Compliance

To improve performance management of taxpayer services, the Secretary of 

the Treasury should update the Department's performance plan to include 

overage rates for handling taxpayer correspondence as a part of Treasury's 

performance goals.

Treasury - DO Implemented. Pending auditor validation.

IRS Referral Programs: Opportunities 

Exist to Strengthen Controls and 

Increase Coordination across 

Overlapping Programs

GAO-16-155 02/23/2016 Financial Statements The Commissioner of Internal Revenue should direct the referral programs to 

establish a mechanism to coordinate on a plan and timeline for developing a 

consolidated, online referral submission in order to better position IRS to 

leverage specialized expertise while exploring options to further consolidate 

the initial screening operations.

IRS Implemented. Pending auditor validation.

IRS Referral Programs: Opportunities 

Exist to Strengthen Controls and 

Increase Coordination across 

Overlapping Programs

GAO-16-155 02/23/2016 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should ensure that the Internal 

Revenue Manual (IRM) has internal controls for processing information 

referrals by establishing, documenting, and implementing procedures for 

maintaining and communicating the information referral screening and 

routing guidelines to the Image Control Team (ICT) and IRS units receiving 

information referrals as well as procedures for ICT screening and routing 

operations.

IRS Implemented. Pending auditor validation.

IRS Referral Programs: Opportunities 

Exist to Strengthen Controls and 

Increase Coordination across 

Overlapping Programs

GAO-16-155 02/23/2016 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should ensure that the IRM has 

internal controls for processing information referrals by establishing, 

documenting, and implementing ongoing monitoring of information referrals 

retained for destruction, including a mechanism for tracking the reasons 

referrals were retained prior to destruction.

IRS Implemented. Pending auditor validation.

IRS Referral Programs: Opportunities 

Exist to Strengthen Controls and 

Increase Coordination across 

Overlapping Programs

GAO-16-155 02/23/2016 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should ensure that the IRM has 

internal controls for processing information referrals by establishing, 

documenting, and implementing procedures for each IRS operating unit 

receiving information referrals to provide feedback on the number and types 

of referrals misrouted and on their disposition, and a mechanism to analyze 

patterns of misroute errors.

IRS Implemented. Pending auditor validation.

IRS Referral Programs: Opportunities 

Exist to Strengthen Controls and 

Increase Coordination across 

Overlapping Programs

GAO-16-155 02/23/2016 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should ensure that the IRM has 

internal controls for processing information referrals by establishing, 

documenting, and implementing supervisory review and segregation of 

duties for inventory management reporting procedure.

IRS Implemented. Pending auditor validation.

IRS Referral Programs: Opportunities 

Exist to Strengthen Controls and 

Increase Coordination across 

Overlapping Programs

GAO-16-155 02/23/2016 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should establish a coordination 

mechanism to facilitate communication and information sharing across IRS 

referral programs on crosscutting tax issues and ways to improve efficiency 

in the mechanisms for public reporting of possible tax violations.

IRS Implemented. Pending auditor validation.
Page 13 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

IRS Referral Programs: Opportunities 

Exist to Strengthen Controls and 

Increase Coordination across 

Overlapping Programs

GAO-16-155 02/23/2016 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should establish, document, and 

implement an organizational structure identifying responsibility for defining 

objectives with an appropriate line of reporting for measuring costs and 

results for information referrals.

IRS Implemented. Pending auditor validation.

Data Center Consolidation: Agencies 

Making Progress, but Planned Savings 

Goals Need to Be Established

GAO-16-323 03/04/2016 Information 

Technology

The Secretaries of the Departments of Agriculture, Commerce, Defense, 

Education, Energy, Health and Human Services, Homeland Security, 

Housing and Urban Development, the Interior, Labor, State, Transportation, 

the Treasury, and Veterans Affairs; the Attorney General of the United 

States; the Administrators of the Environmental Protection Agency, General 

Services Administration, National Aeronautics and Space Administration, 

and U.S. Agency for International Development; the Director of the Office of 

Personnel Management; the Chairman of the Nuclear Regulatory 

Commission; and the Commissioner of the Social Security Administration 

should take action to improve progress in the data center optimization areas 

that GAO reported as not meeting OMB's established targets, including 

addressing any identified challenges.

Treasury - DO Implemented. Pending auditor validation.

Information Security: IRS Needs to 

Further Improve Controls over Financial 

and Taxpayer Data

GAO-16-398 03/28/2016 Financial Statements The Commissioner of Internal Revenue should update system and 

application audit plans based on the current version of referenced policies 

and guidelines and when significant changes are made to a system or 

application.

IRS PCA Due Date: Dec-2019

Cloud Computing: Agencies Need to 

Incorporate Key Practices to Ensure 

Effective Performance

GAO-16-325 04/07/2016 Information 

Technology

To help ensure continued progress in the implementation of effective cloud 

computing SLAs, the Secretaries of Health and Human Services, Homeland 

Security, Treasury, and Veterans Affairs should direct appropriate officials to 

develop SLA guidance and ensure key practices are fully incorporated as the 

contract and associated SLAs expire.

Treasury - DO Implemented. Pending auditor validation.

Low-Income Housing Tax Credit: Some 

Agency Practices Raise Concerns and 

IRS Could Improve Noncompliance 

Reporting and Data Collection

GAO-16-360 05/11/2016 Improper Payments To improve IRS's processes for identifying the most significant 

noncompliance issues, the IRS Commissioner should evaluate how IRS 

could use HUD's Real Estate Assessment Center databases, including how 

the information might be used to reassess reporting categories on the Form 

8823 and to reassess which categories of noncompliance information have to 

be reviewed for audit potential.

IRS Implemented. Pending auditor validation.

Low-Income Housing Tax Credit: Some 

Agency Practices Raise Concerns and 

IRS Could Improve Noncompliance 

Reporting and Data Collection

GAO-16-360 05/11/2016 Improper Payments To receive more consistent information on LIHTC noncompliance, the IRS 

Commissioner should collaborate with the allocating agencies to clarify 

when allocating agencies should report such information on the Form 8823 

(report of noncompliance or building disposition). The IRS Commissioner 

should collaborate with the Department of the Treasury in drafting such 

clarifications to help ensure that any new guidance is consistent with 

Treasury regulations.

IRS Implemented. Pending auditor validation.

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-16-457R 05/18/2016 Financial Statements Determine the reason(s) why staff did not always comply with IRS's 

established policies and procedures related to initiating, monitoring, and 

reviewing the monitoring of manual refunds and, based on this 

determination, establish a process to better enforce compliance with these 

requirements.

IRS On Hold. Agreed with the recommendation. 

Due to funding constraints, the 

recommendation is put on hold.
Page 14 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-16-457R 05/18/2016 Financial Statements Develop and provide training, on a recurring basis, to all Facilities 

Management and Security Services specialists and managers involved in the 

duress alarm validation and testing process to reinforce the related policies 

and procedures.

IRS Implemented. Pending auditor validation.

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-16-457R 05/18/2016 Financial Statements Enhance the training program provided to Certifying Officers (Cos) to 

address all the job responsibilities related to certifying manual refunds for 

payment, including the required review of supporting documentation for 

manual refunds.

IRS Implemented. Pending auditor validation.

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-16-457R 05/18/2016 Financial Statements Establish a policy and procedures requiring IRS officials to review and 

address situations in which it is later discovered that an employee deemed 

unsuitable for employment during the prescreening process was erroneously 

allowed to enter on duty.

IRS Implemented. Pending auditor validation.

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-16-457R 05/18/2016 Financial Statements Establish a process to prevent Employment Operations staff from allowing 

potential employees to enter on duty without favorable determinations of 

suitability by Personnel Security adjudicators.

IRS Implemented. Pending auditor validation.

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-16-457R 05/18/2016 Financial Statements Establish and implement monitoring procedures designed to reasonably 

assure that the key detailed information for tangible capitalized P&E is 

properly recorded and updated in the KISAM system.

IRS IRS is in the process of developing a new PCA 

for this recommendation. 

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-16-457R 05/18/2016 Financial Statements Identify the cause of and implement a solution for dealing with the periodic 

backlogs of ICO inventory that is hampering the performance of quality 

reviews.

IRS Implemented. Pending auditor validation.

Identity Theft and Tax Fraud: IRS 

Needs to Update Its Risk Assessment 

for the Taxpayer Protection Program

GAO-16-508 05/24/2016 Tax Administration and 

Compliance

To improve the quality of the Taxonomy's IDT refund fraud estimates, the 

Commissioner of Internal Revenue should utilize return-level data--where 

availableto reduce over-counting and improve the quality and accuracy of the 

refunds-prevented estimates.

IRS Implemented. Pending auditor validation.

Information Technology: Federal 

Agencies Need to Address Aging 

Legacy Systems

GAO-16-468 05/25/2016 Information 

Technology

To monitor whether existing investments are meeting the needs of their 

agencies, the Secretaries of Commerce and the Treasury should direct the 

respective agency CIO to ensure that required analyses are performed on 

investments in the operations and maintenance phase.

Treasury - DO Implemented. Pending auditor validation.

Information Technology: Federal 

Agencies Need to Address Aging 

Legacy Systems

GAO-16-468 05/25/2016 Information 

Technology

To address obsolete IT investments in need of modernization or replacement, 

the Secretaries of Agriculture, Commerce, Defense, Energy, Health and 

Human Services, Homeland Security, State, the Treasury, Transportation, 

and Veterans Affairs; the Attorney General; and the Commissioner of Social 

Security should direct their respective agency CIOs to identify and plan to 

modernize or replace legacy systems as needed and consistent with OMB's 

draft guidance, including time frames, activities to be performed, and 

functions to be replaced or enhanced.

Treasury - DO Rejected. Treasury disagreed with the 

recommendation. Treasury will develop the 

corresponding policy once OMB finalizes its 

guidance.
Page 15 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Refundable Tax Credits: 

Comprehensive Compliance Strategy 

and Expanded Use of Data Could 

Strengthen IRS's Efforts to Address 

Noncompliance

GAO-16-475 05/27/2016 Tax Administration and 

Compliance

To strengthen efforts to identify and address noncompliance with the EITC, 

ACTC, and AOTC, we recommend that the Commissioner of Internal 

Revenue direct Refundable Credits Policy and Program Management 

(RCPPM) to, take necessary steps to ensure the reliability of collections data 

and periodically review those data to (a) compute a collections rate for postrefund enforcement activities and (b) determine what additional analyses 

would provide useful information about compliance results and costs of postrefund audits and document-matching reviews.

IRS Rejected. IRS disagreed with the 

recommendation. The Wage and Investment 

compliance workload is predominantly prerefund audits, where taxpayer claims for 

refundable credits are not paid prior to the 

conclusion of the examination. By holding 

potential refunds, revenue is protected and any 

subsequent disallowance of the claimed 

credits, generally, does not result in balances 

due that require follow-up collection activity. 

The level of effort to complete the 

recommended analysis would consume limited 

resources and would not justify the results. 

Further, it would not provide meaningful data 

to the program. IRS views this GAO 

recommendation as not providing a sufficient 

return on investment to warrant allocating 

limited resources for implementing the 

recommendation. 

Managing for Results: Agencies Need 

to Fully Identify and Report Major 

Management Challenges and Actions to 

Resolve them in their Agency 

Performance Plans

GAO-16-510 06/15/2016 Administration of 

Program Operations

To improve the public reporting of major management challenges and to 

ensure performance information is useful, transparent, and complete, the 

Secretary of the Treasury should include performance goals, performance 

measures, milestones, and an agency official responsible for resolving major 

management challenges as part of the Department of the Treasury's agency 

performance plan.

Treasury - DO PCA Due Date: Nov-2019

Information Technology: IRS Needs to 

Improve Its Processes for Prioritizing 

and Reporting Performance of 

Investments

GAO-16-545 06/29/2016 Information 

Technology

To help IRS improve its process for determining IT funding priorities and to 

provide timely information on the progress of its investments, the 

Commissioner of IRS should direct the Chief Technology Officer to 

establish, document, and implement policies and procedures for selecting 

new and reselecting ongoing business systems modernization activities, 

consistent with IRS's process for prioritizing operations support priorities, 

which addresses (1) prioritization and comparison of IT assets against each 

other, (2) criteria for making selection and prioritization decisions, and (3) 

ensuring IRS executives' final funding decisions on IT proposals are based 

on IRS's prioritization process.

IRS Implemented. Pending auditor validation.

Information Technology: IRS Needs to 

Improve Its Processes for Prioritizing 

and Reporting Performance of 

Investments

GAO-16-545 06/29/2016 Information 

Technology

To help IRS improve its process for determining IT funding priorities and to 

provide timely information on the progress of its investments, the 

Commissioner of IRS should direct the Chief Technology Officer to modify 

existing processes for Foreign Account Tax Compliance Act (FATCA) and 

Return Review Program (RRP) for measuring work performed by IRS staff 

to incorporate best practices, including accounting for actual work performed 

and using the level of effort measure sparingly.

IRS Implemented. Pending auditor validation.
Page 16 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

IRS Could Improve Presentation of 

Budget Data in Its Congressional 

Justification

GAO-16-695 07/21/2016 Administration of 

Program Operations

To enhance the budget process and to improve transparency, the 

Commissioner of Internal Revenue, to the extent feasible, should ensure that 

the CJ includes data by appropriation account on the amount of funding 

requested to maintain current services for each future state theme.

IRS Implemented. Pending auditor validation.

INLAND WATERWAYS FUEL TAX: 

Additional Data Could Enhance IRS's 

Efforts to Ensure Taxpayer Compliance

GAO-16-682 07/29/2016 Tax Administration and 

Compliance

To maximize resources for the Inland Waterways Trust Fund, the 

Commissioner of Internal Revenue should consult with the U.S. Army Corps 

of Engineers to explore options to obtain proprietary data to enhance IRS's 

efforts to ensure taxpayer compliance with the inland waterways fuel tax.

IRS Implemented. Pending auditor validation.

Tax Debt Collection: IRS Needs to 

Define Field Program Objectives and 

Assess Risks in Case Selection

GAO-16-787 09/13/2016 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should develop, document, and 

communicate control procedures guidance for group managers to exercise 

professional judgment in the Field Collection program case selection process 

to achieve fairness and other program and collection case selection 

objectives.

IRS Implemented. Pending auditor validation.

Tax Debt Collection: IRS Needs to 

Define Field Program Objectives and 

Assess Risks in Case Selection

GAO-16-787 09/13/2016 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should develop, document, and 

communicate Field Collection program and case selection objectives, 

including the role of fairness, in clear and measurable terms sufficient for use 

in internal control.

IRS Implemented. Pending auditor validation.

Tax Debt Collection: IRS Needs to 

Define Field Program Objectives and 

Assess Risks in Case Selection

GAO-16-787 09/13/2016 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should develop, document, and 

implement performance measures clearly linked to the Field Collection 

program and case selection objectives.

IRS Implemented. Pending auditor validation.

Tax Debt Collection: IRS Needs to 

Define Field Program Objectives and 

Assess Risks in Case Selection

GAO-16-787 09/13/2016 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should develop, document, and 

implement procedures to periodically monitor and assess the design and 

operational effectiveness of both automated and manual control procedures 

for collection case selection to assure their continued effectiveness in 

achieving program objectives.

IRS Implemented. Pending auditor validation.

Tax Debt Collection: IRS Needs to 

Define Field Program Objectives and 

Assess Risks in Case Selection

GAO-16-787 09/13/2016 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should incorporate program and case 

selection objectives into existing risk management systems or use other 

approaches to identify and analyze potential risks to achieving those 

objectives so that Field Collection can establish risk tolerances and 

appropriate control procedures to address risks.

IRS Implemented. Pending auditor validation.

Information Technology Reform: 

Agencies Need to Increase Their Use of 

Incremental Development Practices

GAO-16-469 09/15/2016 Information 

Technology

To improve the quality of the seven departments' information on project 

incremental delivery reported to the IT Dashboard, the Secretaries of 

Commerce, Defense, Education, Health and Human Services, Homeland 

Security, Transportation, and the Treasury should direct their CIOs to review 

major IT investment project data reported on the IT Dashboard and update 

the information as appropriate in the following areas: (1) whether the project 

is in-progress or complete; (2) whether the project is a software development 

project or not; and (3) the status of the delivery of functionality every 6 

months, ensuring that these data are consistent across all reporting channels.

Treasury - DO Implemented. Pending auditor validation.
Page 17 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Information Technology Reform: 

Agencies Need to Increase Their Use of 

Incremental Development Practices

GAO-16-469 09/15/2016 Information 

Technology

To improve the certification of adequate incremental development, the 

Secretaries of Defense, Education, Health and Human Services, and the 

Treasury should direct their CIOs to establish a department policy and 

process for the certification of major IT investments' adequate use of 

incremental development, in accordance with OMB's guidance on the 

implementation of the Federal Information Technology Acquisition Reform 

Act.

Treasury - DO Implemented. Pending auditor validation.

Information Technology: Agencies 

Need to Improve Their Application 

Inventories to Achieve Additional 

Savings

GAO-16-511 09/26/2016 Information 

Technology

To improve federal agencies' efforts to rationalize their portfolio of 

applications, the heads of the Departments of Agriculture, Commerce, 

Education, Energy, Health and Human Services, Housing and Urban 

Development, the Interior, Labor, State, Transportation, the Treasury, and 

Veterans Affairs; and heads of the Environmental Protection Agency; 

National Aeronautics and Space Administration; National Science 

Foundation; Nuclear Regulatory Commission; Office of Personnel 

Management; Small Business Administration; Social Security 

Administration; and U.S. Agency for International Development should 

direct their Chief Information Officers (CIOs) and other responsible officials 

to improve their inventories by taking steps to fully address the practices 

GAO identified as being partially met or not met.

Treasury - DO Implemented. Pending auditor validation.

Improper Payments - Strategy and 

Additional Actions Needed to Help 

Ensure Agencies Use the Do Not Pay 

Working System as Intended

GAO-17-15 11/14/2016 Information 

Technology

Modify the working system to track adjudication of matches obtained 

through all functionalities.

Fiscal Service Implemented. Pending auditor validation.

401(K) Plans: Effects of Eligibility and 

Vesting Policies on Workers' 

Retirement Savings

GAO-17-69 11/21/2016 Administration of 

Program Operations

To ensure that current vesting policies appropriately balance plans' needs and 

interests with the needs of workers to have employment mobility while also 

saving for retirement, Treasury should evaluate the appropriateness of 

existing maximum vesting policies for account-based plans, considering 

today's mobile labor force, and seek legislative action to revise vesting 

schedules, if deemed necessary. The Department of Labor could provide 

assistance with such an evaluation.

Treasury - DO No Action Taken. 

IT Workforce: Key Practices Help 

Ensure Strong Integrated Program 

Teams; Selected Departments Need to 

Assess Skill Gaps

GAO-17-8 11/30/2016 Information 

Technology

To facilitate the analysis of gaps between current skills and future needs, the 

development of strategies for filling the gaps, and succession planning, the 

Secretary of the Treasury should require the Chief Information Officer, Chief 

Human Capital Officer, and other senior managers as appropriate to address 

the shortfalls in IT workforce planning noted in this report, including the 

following actions: (1) establish and maintain a workforce planning process; 

(2) develop competency and staffing requirements for all positions; (3) 

assess competency and staffing needs regularly; (4) assess gaps in 

competencies and staffing for all components of the workforce; (5) develop 

strategies and plans to address gaps in competencies and staffing for all 

components of the workforce; (6) implement activities that address gaps, 

including a career path for program managers and special hiring authorities, 

if justified and cost-effective; (7) monitor the department's progress in 

addressing competency and staffing gaps; and (8) report to department 

leadership on progress in addressing competency and staffing gaps for all 

components of the workforce.

Treasury - DO PCA Due Date: Sep-2020
Page 18 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Retirement Security: Improved 

Guidance Could Help Account Owners 

Understand the Risks of Investing in 

Unconventional Assets

GAO-17-102 01/09/2017 Tax Administration and 

Compliance

Provide guidance to IRA owners and custodians on how to determine and 

document fair market value (FMV) for certain categories of hard-to -value 

unconventional assets. For example, IRS could consider updating Form 

5498 instructions to custodians on how to document FMV for hard-to-value 

assets (e.g., last-known FMV based on independent appraisal, acquisition 

price) and provide guidance directed at account owners that provides 

examples of how to ascertain FMV for different types of unconventional 

assets.

IRS Implemented. Pending auditor validation.

IRS RETURN SELECTION: Improved 

Planning, Internal Controls, and Data 

Would Enhance Large Business 

Division Efforts to Implement New 

Compliance Approach

GAO-17-324 03/28/2017 Tax Administration and 

Compliance

In accordance with federal internal control standards, the IRS Commissioner 

should direct LB&I to adopt a standard process for monitoring audit 

selection decisions in the field, such as by modifying the existing quality 

control system.

IRS PCA Due Date: Oct-2019

IRS RETURN SELECTION: Improved 

Planning, Internal Controls, and Data 

Would Enhance Large Business 

Division Efforts to Implement New 

Compliance Approach

GAO-17-324 03/28/2017 Tax Administration and 

Compliance

The IRS Commissioner should ensure that the documentation gaps in 

policies and procedures are addressed for the following internal control 

principles for the selection method: communicate internally the necessary 

quality information about the objectives

IRS Implemented. Pending auditor validation.

IRS RETURN SELECTION: Improved 

Planning, Internal Controls, and Data 

Would Enhance Large Business 

Division Efforts to Implement New 

Compliance Approach

GAO-17-324 03/28/2017 Tax Administration and 

Compliance

The IRS Commissioner should ensure that the documentation gaps in 

policies and procedures are addressed for the following internal control 

principles for the selection method: define objectives to identify risk and 

define risk tolerances

IRS Implemented. Pending auditor validation.

IRS RETURN SELECTION: Improved 

Planning, Internal Controls, and Data 

Would Enhance Large Business 

Division Efforts to Implement New 

Compliance Approach

GAO-17-324 03/28/2017 Tax Administration and 

Compliance

The IRS Commissioner should ensure that the documentation gaps in 

policies and procedures are addressed for the following internal control 

principles for the selection method: design control activities to achieve 

objectives and respond to risks

IRS Implemented. Pending auditor validation.

IRS RETURN SELECTION: Improved 

Planning, Internal Controls, and Data 

Would Enhance Large Business 

Division Efforts to Implement New 

Compliance Approach

GAO-17-324 03/28/2017 Tax Administration and 

Compliance

The IRS Commissioner should ensure that the documentation gaps in 

policies and procedures are addressed for the following internal control 

principles for the selection method: evaluate issues and remediate identified 

internal control deficiencies on a timely basis

IRS Implemented. Pending auditor validation.

IRS RETURN SELECTION: Improved 

Planning, Internal Controls, and Data 

Would Enhance Large Business 

Division Efforts to Implement New 

Compliance Approach

GAO-17-324 03/28/2017 Tax Administration and 

Compliance

The IRS Commissioner should ensure that the documentation gaps in 

policies and procedures are addressed for the following internal control 

principles for the selection method: identify, analyze, and respond to risks to 

achieving the objectives

IRS Implemented. Pending auditor validation.
Page 19 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

IRS RETURN SELECTION: Improved 

Planning, Internal Controls, and Data 

Would Enhance Large Business 

Division Efforts to Implement New 

Compliance Approach

GAO-17-324 03/28/2017 Tax Administration and 

Compliance

The IRS Commissioner should ensure that the documentation gaps in 

policies and procedures are addressed for the following internal control 

principles for the selection method: use quality information to achieve 

objectives

IRS Implemented. Pending auditor validation.

IRS RETURN SELECTION: Improved 

Planning, Internal Controls, and Data 

Would Enhance Large Business 

Division Efforts to Implement New 

Compliance Approach

GAO-17-324 03/28/2017 Tax Administration and 

Compliance

To further ensure that the new campaigns under LB&I's new approach for 

addressing tax compliance are implemented successfully, the IRS 

Commissioner should create a timetable with specific dates for implementing 

its new compliance approach.

IRS Implemented. Pending auditor validation.

IRS RETURN SELECTION: Improved 

Planning, Internal Controls, and Data 

Would Enhance Large Business 

Division Efforts to Implement New 

Compliance Approach

GAO-17-324 03/28/2017 Tax Administration and 

Compliance

To further ensure that the new campaigns under LB&I's new approach for 

addressing tax compliance are implemented successfully, the IRS 

Commissioner should develop and document criteria to use in choosing 

selection methods for campaigns using audits.

IRS Implemented. Pending auditor validation.

IRS RETURN SELECTION: Improved 

Planning, Internal Controls, and Data 

Would Enhance Large Business 

Division Efforts to Implement New 

Compliance Approach

GAO-17-324 03/28/2017 Tax Administration and 

Compliance

To further ensure that the new campaigns under LB&I's new approach for 

addressing tax compliance are implemented successfully, the IRS 

Commissioner should document lessons learned from stakeholder input and 

past performance.

IRS Implemented. Pending auditor validation.

IRS RETURN SELECTION: Improved 

Planning, Internal Controls, and Data 

Would Enhance Large Business 

Division Efforts to Implement New 

Compliance Approach

GAO-17-324 03/28/2017 Tax Administration and 

Compliance

To further ensure that the new campaigns under LB&I's new approach for 

addressing tax compliance are implemented successfully, the IRS 

Commissioner should establish metrics to help determine whether the 

campaign effort overall meets LB&I's goals.

IRS Implemented. Pending auditor validation.

IRS RETURN SELECTION: Improved 

Planning, Internal Controls, and Data 

Would Enhance Large Business 

Division Efforts to Implement New 

Compliance Approach

GAO-17-324 03/28/2017 Tax Administration and 

Compliance

To further ensure that the new campaigns under LB&I's new approach for 

addressing tax compliance are implemented successfully, the IRS 

Commissioner should finalize and document plans to evaluate the human 

resources expended on campaign activities.

IRS Implemented. Pending auditor validation.

IRS RETURN SELECTION: Improved 

Planning, Internal Controls, and Data 

Would Enhance Large Business 

Division Efforts to Implement New 

Compliance Approach

GAO-17-324 03/28/2017 Tax Administration and 

Compliance

To further ensure that the new campaigns under LB&I's new approach for 

addressing tax compliance are implemented successfully, the IRS 

Commissioner should monitor overall performance across future campaigns, 

not just individual compliance projects, and in doing so ensure that the data 

used for monitoring accounts for the costs beyond the auditor's time can 

clearly be linked with specific selection methods, including the Discriminant 

Analysis System (DAS) method, to the extent that the selection methods 

continue to operate.

IRS Implemented. Pending auditor validation.
Page 20 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

IRS RETURN SELECTION: Improved 

Planning, Internal Controls, and Data 

Would Enhance Large Business 

Division Efforts to Implement New 

Compliance Approach

GAO-17-324 03/28/2017 Tax Administration and 

Compliance

To further ensure that the new campaigns under LB&I's new approach for 

addressing tax compliance are implemented successfully, the IRS 

Commissioner should set a timetable to analyze and mitigate risks and 

document specific metrics for assessing mitigation of identified risks.

IRS Implemented. Pending auditor validation.

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-17-454R 05/17/2017 Financial Statements Develop and implement a process to reasonably assure that IRS operating 

divisions and the IT organization effectively coordinate with the CFO 

organization when making programming changes to information systems 

affecting financial reporting.

IRS Implemented. Pending auditor validation.

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-17-454R 05/17/2017 Financial Statements Provide clear guidelines as to what events constitute removal from IRS 

premises and the disposal date that should be recorded in its inventory 

system, either through an update of the IRM or other property and equipmentrelated desk guides.

IRS Implemented. Pending auditor validation.

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-17-454R 05/17/2017 Financial Statements Revise the applicable IRM sections pertaining to manual refunds to require 

employees to verify the validity of the digital signatures on the manual 

refund request forms and the manual refund signature authorization forms.

IRS Implemented. Pending auditor validation.

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-17-454R 05/17/2017 Financial Statements Strengthen the process for reasonably assuring that the IRM is reviewed 

annually to align with the current control procedures and guidance being 

implemented by agency personnel. This should include a mechanism for 

reasonably assuring that program owner directors (1) review their respective 

program control activities and related guidance annually and timely update 

the IRM as needed, (2) document their reviews, and (3) utilize interim 

guidance and supplemental guidance correctly for their intended purposes.

IRS PCA Due Date: Dec-2021

EMPLOYMENT TAXES: Timely Use 

of National Research Program Results 

Would Help IRS Improve Compliance 

and Tax Gap Estimates

GAO-17-371 05/18/2017 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should develop and document plans 

for addressing the noncompliance identified in IRS's analysis of the NRP 

employment tax results.

IRS PCA Due Date: Dec-2019

EMPLOYMENT TAXES: Timely Use 

of National Research Program Results 

Would Help IRS Improve Compliance 

and Tax Gap Estimates

GAO-17-371 05/18/2017 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should develop and document plans 

for assessing the results of the NRP employment tax study to estimate the 

current state of the employment tax gap.

IRS PCA Due Date: Jan-2020

EMPLOYMENT TAXES: Timely Use 

of National Research Program Results 

Would Help IRS Improve Compliance 

and Tax Gap Estimates

GAO-17-371 05/18/2017 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should develop and document plans 

to analyze the results in 2017 of the NRP employment tax study to identify 

the major issues of noncompliance.

IRS Implemented. Pending auditor validation.
Page 21 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Data Center Optimization: Agencies 

Need to Complete Plans to Address 

Inconsistencies in Reported Savings

GAO-17-388 05/18/2017 Information 

Technology

The following 17 agencies (the Secretaries of the Departments of Commerce, 

Defense, Energy, Health and Human Services, Interior, Labor, State, 

Transportation, Treasury, and Veterans Affairs; the Attorney General; and 

the Administrators of the Environmental Protection Agency, National 

Aeronautics and Space Administration, Small Business Administration, and 

U.S. Agency for International Development; the Chairman of the Nuclear 

Regulatory Commission; and the Commissioner of the Social Security 

Administration) should each take action to complete the missing elements in 

their respective DCOI strategic plan, including addressing any identified 

challenges, and submit their completed strategic plan to OMB.

Treasury - DO Implemented. Pending auditor validation.

Data Center Optimization: Agencies 

Need to Complete Plans to Address 

Inconsistencies in Reported Savings

GAO-17-388 05/18/2017 Information 

Technology

The following 11 agencies (the Secretaries of the Departments of Commerce, 

Education, Health and Human Services, Interior, Labor, State, 

Transportation, and Treasury; the Administrators of the Environmental 

Protection Agency, General Services Administration, and the U.S. Agency 

for International Development) should also each take action to ensure that 

the amounts of achieved data center cost savings and avoidances are 

consistent across all reporting mechanisms, including the quarterly data 

submissions and DCOI strategic plans.

Treasury - DO Implemented. Pending auditor validation.

Management Report: Improvements 

Needed in Controls over the Processes 

Used to Prepare the U.S. Consolidated 

Financial Statements

GAO-17-524 7/12/2017 Financial Statements The Secretary of the Treasury should direct the Fiscal Assistant Secretary, 

working in coordination with the Controller of OMB, to improve corrective 

action plans for (1) treaties and international agreements, (2) additional audit 

procedures for intragovernmental activity and balances, and (3) the 

Reconciliation Statements so that they include sufficient information to 

address the control deficiencies in these areas effectively.

Fiscal Service Rejected. Treasury disagreed with the 

recommendation as it considers this 

recommendation redundant to existing open 

recommendations issued in previous years. 

Treasury will continue to work with agencies 

to facilitate improvement of processes, 

minimizing the need for Treasury adjustments 

to agency reporting. Ultimate responsibility for 

the desired outcome of minimizing the need 

for Treasury adjustments rests with the agency 

community and their auditors, and is 

dependent on the quality and completeness of 

agency data provided to Treasury.

Improper Payments: Improvements 

Needed in CMS and IRS Controls over 

Health Insurance Premium Tax Credit

GAO-17-467 07/13/2017 Improper Payments Assess and document the feasibility of approaches for incorporating 

information from the marketplaces on individuals who did not demonstrate 

that they met the eligibility requirements for citizenship or lawful presence in 

the tax compliance process. If determined feasible, IRS should work with 

Treasury to require marketplaces to periodically provide such information on 

individuals and use such information to recover advance PTC made for those 

individuals.

IRS PCA Due Date: Sep-2019
Page 22 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Improper Payments: Improvements 

Needed in CMS and IRS Controls over 

Health Insurance Premium Tax Credit

GAO-17-467 07/13/2017 Improper Payments Assess the program against applicable IPIA-defined thresholds and conclude 

on its susceptibility to significant improper payments, and revise the scope of 

its improper payments susceptibility assessment for the PTC program to 

include instances in which advance PTC is greater than or equal to the 

amount of PTC claimed on the tax return. If the program meets the IPIA 

definition for being susceptible to significant improper payments based on 

this assessment, estimate and report improper payments associated with the 

PTC program consistent with IPIA requirements.

IRS Implemented. Pending auditor validation.

Improper Payments: Improvements 

Needed in CMS and IRS Controls over 

Health Insurance Premium Tax Credit

GAO-17-467 07/13/2017 Improper Payments Assess whether IRS should require its examiners to verify health care 

coverage of individuals to determine eligibility for PTC. To do this, IRS 

should complete its evaluation on the level of noncompliance related to 

duplicate health insurance coverage. Based on this evaluation and if cost 

effective, IRS should design and implement formal policies and procedures 

to routinely identify individuals inappropriately receiving PTC because of 

their eligibility for or enrollment in health care programs outside of the 

marketplaces and notify such individuals of their ineligibility for PTC.

IRS PCA Due Date: Oct-2020

Improper Payments: Improvements 

Needed in CMS and IRS Controls over 

Health Insurance Premium Tax Credit

GAO-17-467 07/13/2017 Improper Payments Design and implement procedures in the IRM to regularly notify nonfilers of 

the requirement to file tax returns in order to continue to receive advance 

PTC in the future.

IRS Implemented. Pending auditor validation.

Information Security:Control 

Deficiencies Continue to Limit IRS's 

Effectiveness in Protecting Sensitive 

Financial and Taxpayer Data

GAO-17-395 07/26/2017 Financial Statements Ensure that system administrators and security operations analysts are alerted 

in the event of audit processing failures.

IRS PCA Due Date: Dec-2020

Information Security:Control 

Deficiencies Continue to Limit IRS's 

Effectiveness in Protecting Sensitive 

Financial and Taxpayer Data

GAO-17-395 07/26/2017 Financial Statements Identify and review service organizations' listing of user controls that are 

deemed relevant and test those controls to appropriately draw conclusions 

about the operating effectiveness of controls.

IRS PCA Due Date: Nov-2020

Information Security:Control 

Deficiencies Continue to Limit IRS's 

Effectiveness in Protecting Sensitive 

Financial and Taxpayer Data

GAO-17-395 07/26/2017 Financial Statements Implement a compliance verification application, or other appropriate 

process, to ensure configuration policies are comprehensively tested on the 

mainframe.

IRS PCA Due Date: Jan-2020

Information Security:Control 

Deficiencies Continue to Limit IRS's 

Effectiveness in Protecting Sensitive 

Financial and Taxpayer Data

GAO-17-395 07/26/2017 Financial Statements Implement the audit plans for the 12 systems and applications that GAO 

reviewed in the production computing environment.

IRS PCA Due Date: Dec-2019

Information Security:Control 

Deficiencies Continue to Limit IRS's 

Effectiveness in Protecting Sensitive 

Financial and Taxpayer Data

GAO-17-395 07/26/2017 Financial Statements Regularly update configuration standards and guidelines for network devices 

to incorporate recommendations from industry leaders, security agencies, and 

key practices from IRS partners to address known vulnerabilities applicable 

to IRS's environment.

IRS PCA Due Date: Feb-2021
Page 23 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Data Center Optimization:

Agencies Need to Address Challenges 

and Improve Progress to Achieve Cost 

Savings Goal

GAO-17-448 09/06/2017 Information 

Technology

The Secretaries of Agriculture, Commerce, Defense, Homeland Security, 

Energy, HHS, Interior, Labor, State, Transportation, Treasury, and VA; the 

Attorney General of the United States; the Administrators of EPA, GSA, and 

SBA; the Director of OPM; and the Chairman of NRC should take action to, 

within existing OMB reporting mechanisms, complete plans describing how 

the agency will achieve OMB's requirement to implement automated 

monitoring tools at all agency-owned data centers by the end of fiscal year 

2018.

Treasury - DO Implemented. Pending auditor validation.

Small Business Contracting: Actions 

Needed to Demonstrate and Better 

Review Compliance with Select 

Requirements for Small Business 

Advocates

GAO-17-675 09/25/2017 Administration of 

Program Operations

To address demonstrated noncompliance with section 15(k) of the Small 

Business Act, as amended, the Secretary of the Treasury should comply with 

sections 15(k)(8) and (k)(11) or report to Congress on why the agency has 

not complied, including seeking any statutory flexibilities or exceptions 

believed appropriate.

Treasury - DO Implemented. Pending auditor validation.

DATA Act: OMB, Treasury, and 

Agencies Need to Improve 

Completeness and Accuracy of 

Spending Data and Disclose Limitations

GAO-18-138 11/08/2017 Information 

Technology

The Secretary of the Treasury should reasonably assure that ongoing 

monitoring controls to help ensure the completeness and accuracy of agency 

submissions are designed, implemented, and operating as designed.

Treasury - DO Implemented. Pending auditor validation.

DATA Act: OMB, Treasury, and 

Agencies Need to Improve 

Completeness and Accuracy of 

Spending Data and Disclose Limitations

GAO-18-138 11/08/2017 Information 

Technology

The Secretary of the Treasury should disclose known data quality issues and 

limitations on the new USAspending.gov

Treasury - DO Implemented. Pending auditor validation.

IDENTITY THEFT: Improved 

Collaboration Could Increase Success of 

IRS Initiatives to Prevent Refund Fraud

GAO-18-20 11/28/2017 Tax Administration and 

Compliance

The Acting Commissioner of Internal Revenue should ensure that the 

Information Sharing and Analysis Center (ISAC) pilot better aligns with 

leading practices for effective pilot design. This should include (1) 

establishing criteria for assessing whether the pilot's objectives have been 

met before making decisions about its scalability and whether, how, and 

when to when to proceed to full implementation; and (2) developing a data 

analysis plan that identifies data sources and criteria necessary for effectively 

evaluating the pilot.

IRS Implemented. Pending auditor validation.

IDENTITY THEFT: Improved 

Collaboration Could Increase Success of 

IRS Initiatives to Prevent Refund Fraud

GAO-18-20 11/28/2017 Tax Administration and 

Compliance

The Acting Commissioner of Internal Revenue should ensure that the ISAC 

Partnership develops an outreach plan to expand membership and improve 

states' and industry partners' understanding of the ISAC's benefits.

IRS Implemented. Pending auditor validation.

IRS Needs Specific Goals and 

Strategies for Improving Compliance

GAO-18-39 11/30/2017 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should instruct the appropriate 

officials to develop and document a strategy that outlines how IRS will use 

National Research Program data to update compliance strategies that could 

help address the tax gap.

IRS PCA Due Date: Sep-2019
Page 24 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

IRS Needs Specific Goals and 

Strategies for Improving Compliance

GAO-18-39 11/30/2017 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should re-establish long-term, 

quantitative goals for improving voluntary compliance.

IRS Rejected. IRS disagreed with the 

recommendation. By remaining committed to 

estimating the tax gap and voluntary 

compliance rate, the IRS will be able to 

ascertain whether it is broadly making 

progress toward the goal of increasing 

voluntary compliance, without a quantitative 

target. The voluntary compliance/tax gap data 

are not effective for making strategic, 

operational decisions. They are allencompassing measures, affected by IRS 

actions and non-IRS factors; therefore, it will 

be next to impossible to isolate the effects of 

any given action.

Information Technology: Agencies 

Need to Involve Chief Information 

Officers in Reviewing Billions of 

Dollars in Acquisitions

GAO-18-42 01/10/2018 Information 

Technology 

The Secretary of the Treasury should ensure that IT acquisition plans or 

strategies are reviewed and approved according to OMB's guidance.

Treasury - DO Implemented. Pending auditor validation.

TAX FRAUD AND 

NONCOMPLIANCE: IRS Can 

Strengthen Pre-refund Verification and 

Explore More Uses

GAO-18-224 01/30/2018 Tax Administration and 

Compliance

Based on the assessment in Recommendation 5, the Acting Commissioner of 

Internal Revenue should implement any identified changes to improve prerefund compliance checks.

IRS PCA Due Date: Sep-2019

TAX FRAUD AND 

NONCOMPLIANCE: IRS Can 

Strengthen Pre-refund Verification and 

Explore More Uses

GAO-18-224 01/30/2018 Tax Administration and 

Compliance

Based on the benefits and costs assessment in Recommendation 3, the 

Acting Commissioner of Internal Revenue should use IRS's existing 

authority to modify the refund hold such that it minimizes the risk of 

releasing fraudulent or noncompliant refunds.

IRS Implemented. Pending auditor validation.

TAX FRAUD AND 

NONCOMPLIANCE: IRS Can 

Strengthen Pre-refund Verification and 

Explore More Uses

GAO-18-224 01/30/2018 Tax Administration and 

Compliance

The Acting Commissioner of Internal Revenue should assess options for 

improving enforcement of late W-2 filing penalties, for example, by mailing 

notices before the next filing deadline.

IRS Rejected. IRS disagreed with the 

recommendation. Penalties for late-filed, 

incorrect media, and missing/incorrect TINs 

are assessable systemically under IRC 6721 for 

various information returns including the 

Forms W-2. IRC 6721 has a maximum 

limitation for each payer and a penalty notice 

cannot be issued for each information return 

(Forms W-2 as recommended in this case) 

because it will ignore the maximum limitation 

required by law. In addition, SSA provides to 

IRS a drop-file in December of the year the 

Forms W-2 are due. IRS needs this file to 

exclude these payers from receiving an 

erroneous penalty notice.
Page 25 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

TAX FRAUD AND 

NONCOMPLIANCE: IRS Can 

Strengthen Pre-refund Verification and 

Explore More Uses

GAO-18-224 01/30/2018 Tax Administration and 

Compliance

The Acting Commissioner of Internal Revenue should assess the benefits 

and costs of additional uses and applications of W-2 data for pre-refund 

compliance checks, such as addressing underreporting, employment fraud, 

and other fraud or noncompliance before issuing refunds.

IRS PCA Due Date: Sep-2019

TAX FRAUD AND 

NONCOMPLIANCE: IRS Can 

Strengthen Pre-refund Verification and 

Explore More Uses

GAO-18-224 01/30/2018 Tax Administration and 

Compliance

The Acting Commissioner of Internal Revenue should develop an evaluation 

plan to fully assess the benefits and costs, including taxpayer burden, of 

modifying the February 15 refund hold, and determine how this effort 

informs IRS's overall compliance strategy for refundable tax credits and 

fraud risk management.

IRS Implemented. Pending auditor validation.

Procedures for Reviews Under 

Regulatory Flexibility Act Need to Be 

Enhanced

GAO-18-256 01/31/2018 Banking and Lending Develop and implement specific policies and procedures for how it will 

consistently comply with RFA requirements and key aspects of the Small 

Business Administration's (SBA) Office of Advocacy and OMB guidance.

OCC Implemented. Pending auditor validation.

Procedures for Reviews Under 

Regulatory Flexibility Act Need to Be 

Enhanced

GAO-18-256 01/31/2018 Banking and Lending Coordinate with the Office of Advocacy on whether the Economic Growth 

and Regulatory Paperwork Reduction Act (EGRPRA) review process 

satisfies the requirements of section 610 and, if not, what steps should be 

taken to align the process with section 610 requirements.

OCC On Hold. Agreed with the recommendation 

but currently on hold awaiting input from 

other agencies.

Committee on Foreign Investment in the 

United States: Treasury Should 

Coordinate Assessments of Resources 

Needed to Address Increased Workload

GAO-18-249 02/14/2018 Administration of 

Program Operations

Treasury, as CFIUS lead, should coordinate member agencies' efforts to 

better understand the staffing levels needed to address the current and 

projected CFIUS workload associated with core committee functions.

Treasury - DO Implemented. Pending auditor validation.

Additional Actions Are Essential for 

Assessing Cybersecurity Framework 

Adoption

GAO-18-211 02/15/2018 Information 

Technology

The Secretary of Treasury should take steps to consult with respective sector 

partner(s), such as the SCC, DHS and NIST, as appropriate, to develop 

methods for determining the level and type of framework adoption by 

entities across their respective sector. 

Treasury - DO Implemented. Pending auditor validation.

Derisking along the Southwest Border 

Highlights Need for Regulators to

Enhance Retrospective Reviews

GAO-18-263OCC 02/26/2018 Banking and Lending Work jointly with FinCEN, FDIC and the Federal Reserve conduct a 

retrospective review of BSA/AML regulations and their implementation for 

banks, focusing on how banks' regulatory concerns may be influencing their 

willingness to provide services to certain populations. GAO also 

recommends that FDIC, the Federal Reserve, OCC and FinCEN take steps, 

as appropriate, to revise the BSA regulations or the way they are being 

implemented to help ensure BSA/AML regulatory

objectives are being met in the most effective and least burdensome way.

OCC Implemented. Pending auditor validation.

Bank Secrecy Act - De-risking along the 

Southwest Border Highlights Need for 

Regulators to Enhance Retrospective 

Reviews

GAO-18-263 02/28/2018 Banking and Lending The Director of FinCEN should jointly conduct a retrospective review of 

BSA/AML regulations and their implementation for banks with FDIC, the 

Federal Reserve, and OCC. This review should focus on how banks' 

regulatory concerns may be influencing their willingness to provide services. 

In conducting the review, FDIC, the Federal Reserve, OCC, and FinCEN 

should take steps, as appropriate, to revise the BSA regulations or the way 

they are being implemented to help ensure that BSA/AML regulatory 

objectives are being met in the most effective and least burdensome way.

FinCEN Implemented. Pending auditor validation.
Page 26 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

WORKPLACE RETIREMENT 

ACCOUNTS: Better Guidance and 

Information Could Help Plan 

Participants at Home and Abroad 

Manage Their Retirement Savings

GAO-18-19 03/03/2018 Administration of 

Program Operations

The IRS Commissioner should clarify how U.S. individuals are to report 

their foreign retirement accounts. The clarification could include addressing 

how these accounts should be designated and how the taxpayer should report 

contributions, earnings, and distributions made from the account.

IRS PCA Due Date: Oct-2020

WORKPLACE RETIREMENT 

ACCOUNTS: Better Guidance and 

Information Could Help Plan 

Participants at Home and Abroad 

Manage Their Retirement Savings

GAO-18-19 03/03/2018 Administration of 

Program Operations

The IRS Commissioner should consider revising the letter forwarding 

program in a cost effective manner to again provide information on behalf of 

plan sponsors on unclaimed retirement accounts to participants.

IRS Rejected. IRS disagreed with the 

recommendation. Guidance the Department of 

Labor issued in 2014 affirms the steps plan 

administrators can take to locate missing 

participants which is based on widespread use 

of commercially available locator services. 

With limited IRS staff and resources and the 

many locator services commercially available 

today, it is not feasible for the IRS to reinstate 

this program. Further, IRS views this GAO 

recommendation as not providing a sufficient 

return on investment to warrant allocating 

limited resources for implementing the 

recommendation. 

WORKPLACE RETIREMENT 

ACCOUNTS: Better Guidance and 

Information Could Help Plan 

Participants at Home and Abroad 

Manage Their Retirement Savings

GAO-18-19 03/03/2018 Administration of 

Program Operations

The IRS Commissioner should review taxation issues relating to 

distributions involving incorrect participant addresses and uncashed benefit 

checks and clarify for the public the Internal Revenue Code's requirements in 

these circumstances.

IRS PCA Due Date: Oct-2021

WORKPLACE RETIREMENT 

ACCOUNTS: Better Guidance and 

Information Could Help Plan 

Participants at Home and Abroad 

Manage Their Retirement Savings

GAO-18-19 03/03/2018 Administration of 

Program Operations

The IRS Commissioner should systematically analyze data reported through 

Form 8938 filings on foreign retirement accounts owned by U.S. individuals 

with the goal of developing an evidence-based understanding of how these 

accounts change over time and what level of risk these accounts pose for tax 

evasion. To assist with this analysis, IRS should consider revising Form 

8938 to more clearly distinguish between retirement accounts and other types 

of accounts or assets being reported by taxpayers under current reporting 

requirements.

IRS Rejected. IRS disagreed with the 

recommendation. The modification to the 

Form 8938 suggested in this recommendation 

may seem minor, but systemically collecting 

and analyzing the data would require resources 

beyond those currently available to IRS. 

Further, IRS views this GAO recommendation 

as not providing a sufficient return on 

investment to warrant allocating limited 

resources for implementing the 

recommendation. 

WORKPLACE RETIREMENT 

ACCOUNTS: Better Guidance and 

Information Could Help Plan 

Participants at Home and Abroad 

Manage Their Retirement Savings

GAO-18-19 03/03/2018 Administration of 

Program Operations

The IRS Commissioner should take steps to improve the likelihood that the 

Notice of Potential Private Pension Benefit Information corresponds to 

actual retirement benefits in the future, for example, by working with the 

Social Security Administration as necessary.

IRS PCA Due Date: Oct-2021
Page 27 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Financial Technology: Additional Steps 

by Regulators could Better Protect 

Consumers and Aid Regulatory 

Oversight

GAO-18-254 03/22/2018 Information 

Technology

Engage in collaborative discussions with other relevant financial regulators 

to help market participants address issues surrounding reimbursement for 

consumers who use financial account aggregators and experience 

unauthorized transactions in a group that incorporates leading practices.

OCC Implemented. Pending auditor validation.

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-18-393R 05/07/2018 Financial Statements Based on IRS's research and determination, design and implement the 

corrective actions necessary to reasonably assure that IRS effectively 

resolves and records unpostable transactions in a timely manner, including 

the establishment of clearly defined timeframes in the IRM by which 

unpostable transactions should be corrected by the IRS operating divisions 

and appropriate related oversight and review processes. 

IRS PCA Due Date: Mar-2020

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-18-393R 05/07/2018 Financial Statements Develop and implement policies in the IRM for conducting and monitoring 

the AEHR review. These policies should include or be accompanied by 

procedures for IRS management responsible for establishing policies related 

to safeguarding controls to (1) periodically monitor the results of the review 

and (2) reasonably assure that corrective actions for all identified deficiencies 

are tracked until fully implemented. 

IRS PCA Due Date: Aug-2020

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-18-393R 05/07/2018 Financial Statements Develop and implement policies in the IRM for conducting and monitoring 

the AMC review. These policies should include or be accompanied by 

procedures for IRS management responsible for establishing policies related 

to safeguarding controls to (1) periodically monitor the results of the review, 

(2) clarify the minimum requirements for how frequently the review should 

be completed at its various facilities while considering factors that may affect 

the most appropriate timing of these reviews, such as changes in personnel, 

operational processes, or information technology, and (3) reasonably assure 

that corrective actions for all identified deficiencies are tracked until fully 

implemented.

IRS PCA Due Date: Jul-2020

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-18-393R 05/07/2018 Financial Statements Develop and implement policies in the IRM for conducting and monitoring 

the Submission Processing internal control review. These policies should 

include or be accompanied by procedures to (1) assess and update the review 

questions and cited IRM criteria to reasonably assure they align with the 

controls under review, (2) periodically evaluate and document a review of the 

error threshold methodology to assess its current validity based on changes to 

the operating environment, (3) report findings identified in the Findings and 

Corrective Actions Report, and (4) assess and monitor (a) safeguarding 

internal control activities across all work shifts, particularly during peak 

seasons, (b) safeguarding internal control activities for the appropriate use 

and destruction of hardcopy taxpayer information, and (c) the results of 

relevant functional level reviews. 

IRS Implemented. Pending auditor validation.

Management Report: Improvements Are 

Needed to Enhance the Internal 

Revenue Service's Internal Control over 

Financial Reporting

GAO-18-393R 05/07/2018 Financial Statements Research and determine the reason(s) why IRS's existing policies and 

procedures intended to timely follow-up on, resolve, and record unpostable 

transactions were not fully effective in achieving these objectives. 

IRS Implemented. Pending auditor validation.
Page 28 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should ensure the operational analysis for 

EUSS includes a comparison of current performance with a pre-established 

cost baseline.

IRS Implemented. Pending auditor validation.

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should ensure the operational analysis for 

IDRS addresses the extent to which the investments support customer 

processes as designed, and how well the investments are delivering the goods 

or services they were designed to deliver.

IRS PCA Due Date: Jul-2020

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should ensure the operational analysis for IMF 

fully addresses greater utilization of technology or consolidation of 

investments to better meet organizational goals.

IRS Implemented. Pending auditor validation.

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should ensure the operational analysis for 

MSSS addresses alternative methods of achieving the same mission needs 

and strategic goals.

IRS Implemented. Pending auditor validation.

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should ensure the operational analysis for TSS 

addresses the extent to which the investments support customer processes as 

designed, and how well the investments are delivering the goods or services 

they were designed to deliver.

IRS Implemented. Pending auditor validation.

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should ensure the operational analysis for TSS 

includes a comparison of current performance with a pre-established cost 

baseline.

IRS Implemented. Pending auditor validation.

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement IT workforce planning 

practices, including the following actions (1) setting the strategic direction 

for workforce planning; (2) analyzing the workforce to identify skill gaps; 

(3) developing strategies and implementing activities to address skill gaps; 

and (4) monitoring and reporting on progress in addressing skill gaps.

IRS On Hold. Agreed with the recommendation. 

Due to funding constraints, the 

recommendation is put on hold.

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement the risk management 

key practice associated with analyzing risk for the IDRS investment.

IRS PCA Due Date: Nov-2019

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement the risk management 

key practice associated with analyzing risk for the IMF investment.

IRS PCA Due Date: Nov-2019

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement the risk management 

key practice associated with analyzing risk for the MSSS investment.

IRS PCA Due Date: Oct-2019

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement the risk management 

key practice associated with identifying risk for the MSSS investment.

IRS PCA Due Date: Oct-2019
Page 29 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement the risk management 

key practice associated with mitigating risk for the IDRS investment.

IRS PCA Due Date: Nov-2019

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement the risk management 

key practice associated with mitigating risk for the IMF investment.

IRS PCA Due Date: Nov-2019

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement the risk management 

key practice associated with mitigating risk for the MSSS investment.

IRS PCA Due Date: Oct-2019

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement the risk management 

key practice associated with monitoring, reporting, and controlling risk for 

the IDRS investment.

IRS PCA Due Date: Nov-2019

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement the risk management 

key practice associated with monitoring, reporting, and controlling risk for 

the IMF investment.

IRS PCA Due Date: Nov-2019

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement the risk management 

key practice associated with monitoring, reporting, and controlling risk for 

the MSSS investment.

IRS PCA Due Date: Oct-2019

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement the risk management 

key practice associated with preparing for risk management for the IDRS 

investment.

IRS PCA Due Date: Nov-2019

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement the risk management 

key practice associated with preparing for risk management for the IMF 

investment.

IRS PCA Due Date: Nov-2019

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement the risk management 

key practice associated with preparing for risk management for the MSSS 

investment.

IRS PCA Due Date: Oct-2019

INFORMATION TECHNOLOGY: IRS 

Needs to Take Additional Actions to 

Address Significant Risks to Tax 

Processing

GAO-18-298 06/28/2018 Information 

Technology

The Commissioner of the IRS should fully implement the risk management 

key practice for prioritizing risk for the IMF investment.

IRS PCA Due Date: Nov-2019

Civil Penalties: Certain Federal 

Agencies Need to Improve Inflation 

Adjustment Reporting

GAO-18-519 07/18/2018 Administration of 

Program Operations

The Secretary of the Treasury should include in Treasury's fiscal year 2018 

AFR information about all civil monetary penalties within its jurisdiction, 

including the inflation adjustment of the civil monetary penalties.

Treasury - DO Implemented. Pending auditor validation.

Identity Theft: IRS Needs to Strengthen 

Taxpayer Authentication Efforts

GAO-18-418 07/23/2018 Tax Administration and 

Compliance

Based on the approach developed in Recommendation 10, the Commissioner 

of Internal Revenue should include and prioritize these options, as 

appropriate, in IRS's Identity Assurance Strategy and Roadmap.

IRS PCA Due Date: May-2020
Page 30 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Identity Theft: IRS Needs to Strengthen 

Taxpayer Authentication Efforts

GAO-18-418 07/23/2018 Tax Administration and 

Compliance

Based on the estimates developed in Recommendation 1, the Commissioner 

of Internal Revenue should direct the Identity Assurance Office to prioritize 

foundational initiatives in its Identity Assurance Strategy and Roadmap.

IRS PCA Due Date: May-2020

Identity Theft: IRS Needs to Strengthen 

Taxpayer Authentication Efforts

GAO-18-418 07/23/2018 Tax Administration and 

Compliance

Consistent with the policy developed in Recommendation 3, the 

Commissioner of Internal Revenue should direct the Identity Assurance 

Office and IRS business owners to develop a plan for performing risk 

assessments for telephone, in-person, and correspondence channels for 

authentication.

IRS PCA Due Date: May-2020

Identity Theft: IRS Needs to Strengthen 

Taxpayer Authentication Efforts

GAO-18-418 07/23/2018 Tax Administration and 

Compliance

In accordance with the plan developed in Recommendation 8, the 

Commissioner of Internal Revenue should implement improvements to IRS's 

systems to fully implement NIST's new guidance.

IRS PCA Due Date: Feb-2023

Identity Theft: IRS Needs to Strengthen 

Taxpayer Authentication Efforts

GAO-18-418 07/23/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should develop a repeatable, 

comprehensive process to identify and evaluate alternative options for 

improving taxpayer authentication, including technologies in use by industry, 

states, or other trusted partners.

IRS PCA Due Date: Oct-2019

Identity Theft: IRS Needs to Strengthen 

Taxpayer Authentication Efforts

GAO-18-418 07/23/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should direct the Identity Assurance 

Office and other appropriate business partners to develop a plan-including a 

timeline, milestone dates, and resources needed-for implementing changes to 

its online authentication programs consistent with new NIST guidance.

IRS Implemented. Pending auditor validation.

Identity Theft: IRS Needs to Strengthen 

Taxpayer Authentication Efforts

GAO-18-418 07/23/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should direct the Identity Assurance 

Office, in collaboration with other IRS business partners, to estimate the 

resources (i.e., financial and human) required for the foundational initiatives 

and supporting activities identified in its Identity Assurance Strategy and 

Roadmap.

IRS PCA Due Date: Oct-2019

Identity Theft: IRS Needs to Strengthen 

Taxpayer Authentication Efforts

GAO-18-418 07/23/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should ensure that IRS business 

units have access to complete AMS data to monitor authentication 

performance and identify potential issues.

IRS PCA Due Date: Sep-2019

Identity Theft: IRS Needs to Strengthen 

Taxpayer Authentication Efforts

GAO-18-418 07/23/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should establish a mechanism to 

collect data on outcomes for telephone, in-person, and correspondence 

authentication, consistent with federal standards for internal control.

IRS PCA Due Date: Oct-2019

Identity Theft: IRS Needs to Strengthen 

Taxpayer Authentication Efforts

GAO-18-418 07/23/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should establish a policy for 

conducting risk assessments for telephone, in-person, and correspondence 

channels for authentication. This policy should include, for example, the 

frequency of assessments to be performed and timeframes for addressing 

deficiencies.

IRS PCA Due Date: Oct-2019

Identity Theft: IRS Needs to Strengthen 

Taxpayer Authentication Efforts

GAO-18-418 07/23/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should revise or establish, as 

appropriate, procedures to ensure data quality in the Account Management 

Services (AMS) consistent with federal standards for internal control.

IRS PCA Due Date: Jun-2020

INFORMATION SECURITY: IRS 

Needs to Rectify Control Deficiencies 

That Limit Its Effectiveness in 

Protecting Sensitive Financial and 

Taxpayer Data

GAO-18-391 07/31/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should take steps to improve the 

implementation of IRS's information security program by documenting 

access authorizations for non-unique accounts.

IRS PCA Due Date: Dec-2020
Page 31 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

INFORMATION SECURITY: IRS 

Needs to Rectify Control Deficiencies 

That Limit Its Effectiveness in 

Protecting Sensitive Financial and 

Taxpayer Data

GAO-18-391 07/31/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should take steps to improve the 

implementation of IRS's information security program by entering correct 

contractor password expiration dates, per IRS's policy, in the system used for 

managing user access authorizations.

IRS PCA Due Date: Dec-2019

INFORMATION SECURITY: IRS 

Needs to Rectify Control Deficiencies 

That Limit Its Effectiveness in 

Protecting Sensitive Financial and 

Taxpayer Data

GAO-18-391 07/31/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should take steps to improve the 

implementation of IRS's information security program by reviewing nonunique accounts at least annually, per IRS's policy.

IRS PCA Due Date: Dec-2020

INFORMATION SECURITY: IRS 

Needs to Rectify Control Deficiencies 

That Limit Its Effectiveness in 

Protecting Sensitive Financial and 

Taxpayer Data

GAO-18-391 07/31/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should take steps to improve the 

implementation of IRS's information security program by updating security 

plans for three systems to reflect changes to their operating environment.

IRS Implemented. Pending auditor validation.

Federal Tax Withholding: Treasury and 

IRS Should Document the Roles and 

Responsibilities for Updating Annual 

Withholding Tables

GAO-18-548 07/31/2018 Tax Administration and 

Compliance

The Secretary of the Treasury should work with the Commissioner of 

Internal Revenue to document roles and responsibilities for updating the tax 

withholding tables, such as in the Internal Revenue Manual.

IRS PCA Due Date: Sep-2019

Federal Chief Information Officers: 

Critical Actions Needed to Address 

Shortcomings and Challenges in 

Implementing Responsibilities

GAO-18-93 08/02/2018 Information 

Technology

The Secretary of the Treasury should ensure that the department's IT 

management policies address the role of the CIO for key responsibilities in 

the six areas GAO identified. 

Treasury - DO PCA Due Date: Dec-2019

Community Banks: Effect of 

Regulations on Small Business Lending 

and Institutions Appears Modest, but 

Lending Data Could Be Improved

GAO-18-312 08/06/2018 Banking and Lending Collaborate with the Federal Reserve and FDIC to reevaluate, and modify as 

needed, the requirements for the data banks report in the Consolidated 

Reports of Condition and Incomes to better reflect lending to small 

businesses.

OCC On Hold. Agreed with the recommendation 

but currently on hold awaiting input from 

other agencies.

PAPERWORK REDUCTION ACT: 

Agencies Could Better Leverage 

Review Processes and Public Outreach 

to Improve Burden Estimates

GAO-18-381 08/10/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should include enough information 

in Federal Register notices to allow the public to reasonably calculate or 

determine the number of respondents, the frequency of response, and the 

average burden time per response for each information collection activity.

IRS PCA Due Date: Oct-2019

PAPERWORK REDUCTION ACT: 

Agencies Could Better Leverage 

Review Processes and Public Outreach 

to Improve Burden Estimates

GAO-18-381 08/10/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should leverage existing consultation 

with stakeholders and the public to explicitly seek input on the estimated 

burden imposed by information collections.

IRS Implemented. Pending auditor validation.

Tax Fraud and Noncompliance: IRS 

Could Further Leverage the Return 

Review Program to Strengthen Tax 

Enforcement

GAO-18-544 08/23/2018 Tax Administration and 

Compliance

Based on the assessment in recommendation 2, the Commissioner of Internal 

Revenue should implement the most cost-effective method to digitize 

information provided by taxpayers who file returns on paper.

IRS On Hold. Agreed with the recommendation. 

As the recommendation deals with issues 

outside Treasury's purview, the 

recommendation is on hold.

Tax Fraud and Noncompliance: IRS 

Could Further Leverage the Return 

Review Program to Strengthen Tax 

Enforcement

GAO-18-544 08/23/2018 Tax Administration and 

Compliance

Based on the assessment in recommendation 4, the Commissioner of Internal 

Revenue should expand RRP to support identified activities.

IRS On Hold. Agreed with the recommendation. 

As the recommendation deals with issues 

outside Treasury's purview, the 

recommendation is on hold.
Page 32 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Tax Fraud and Noncompliance: IRS 

Could Further Leverage the Return 

Review Program to Strengthen Tax 

Enforcement

GAO-18-544 08/23/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should evaluate the costs and 

benefits of expanding RRP to analyze individual returns not claiming 

refunds to support other enforcement activities.

IRS PCA Due Date: Oct-2020

Tax Fraud and Noncompliance: IRS 

Could Further Leverage the Return 

Review Program to Strengthen Tax 

Enforcement

GAO-18-544 08/23/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should increase the frequency at 

which incoming W-2 information is made available to RRP.

IRS Implemented. Pending auditor validation.

Tax Fraud and Noncompliance: IRS 

Could Further Leverage the Return 

Review Program to Strengthen Tax 

Enforcement

GAO-18-544 08/23/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should update and expand a 2012 

analysis of the costs and benefits of digitizing returns filed on paper to 

consider any new technology or additional benefits associated with RRP's 

enhanced enforcement capabilities.

IRS PCA Due Date: Oct-2020

Low-Income Housing Tax Credit: 

Improved Data and Oversight Would 

Strengthen Cost Assessment and Fraud 

Risk Management

GAO-18-637 09/18/2018 Tax Administration and 

Compliance

IRS's Associate Chief Counsel, in consultation with Treasury's Assistant 

Secretary for Tax Policy, should communicate to credit allocating agencies 

how to collect information on and review LIHTC syndication expenses, 

including upper-tier partnership expenses.

IRS Rejected. IRS disagreed with the 

recommendation. IRS already communicates 

this information. The Regulations require 

taxpayers to certify to HFAs all sources of 

funds and all development costs. Section 1.42-

17(a)(3)(i) provides that development cost 

information includes, among other costs, 

syndication and legal fees. In addition, IRS 

communicates regularly with HFAs regarding 

LIHTC compliance issues and best practices. 

Low-Income Housing Tax Credit: 

Improved Data and Oversight Would 

Strengthen Cost Assessment and Fraud 

Risk Management

GAO-18-637 09/18/2018 Tax Administration and 

Compliance

IRS's Associate Chief Counsel, in consultation with Treasury's Assistant 

Secretary for Tax Policy, should require general contractor cost certifications 

for LIHTC projects to verify consistency with the developer cost 

certification.

IRS Rejected. IRS disagreed with the 

recommendation. The GAO report describes 

the use of misrepresented contractor costs that 

could potentially produce excess LIHTC 

allocations. IRS considered how general 

contractor cost certifications might be helpful 

in verifying consistency with the costs but is 

concerned that requiring the additional burden 

of these certifications does not comport with 

the flexibility for the States contemplated by 

the statute.

Low-Income Housing Tax Credit: 

Improved Data and Oversight Would 

Strengthen Cost Assessment and Fraud 

Risk Management

GAO-18-637 09/18/2018 Tax Administration and 

Compliance

To help allocating agencies analyze development cost trends and drivers and 

make comparisons to other agencies, IRS's Commissioner of the Small 

Business/Self-Employed Division should encourage allocating agencies and 

other LIHTC stakeholders to collaborate on the development of more 

standardized cost data, considering information in this report about variation 

in data elements, definitions, and formats.

IRS Rejected. IRS disagreed with the 

recommendation. The standardization of 

LIHTC cost data is not statutorily or 

regulatorily required for IRS tax 

administration. Congress has given the States 

broad flexibility and discretion to determine 

allocation practices and the QAPs that guide 

them. Therefore, IRS defers to the HFAs and 

other LIHTC stakeholders to collaborate on 

the development of more standardized cost 

data.
Page 33 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Tax Administration: Opportunities Exist 

to Improve Monitoring and 

Transparency of Appeal Resolution 

Timeliness

GAO-18-659 10/22/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should direct the Chief of Appeals to 

regularly report and share with each compliance unit the data on the time 

elapsed between when a taxpayer requests an appeal to when it is received in 

the Office of Appeals.

IRS PCA Due Date: Oct-2020

Tax Administration: Opportunities Exist 

to Improve Monitoring and 

Transparency of Appeal Resolution 

Timeliness

GAO-18-659 10/22/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should direct the Chief of Appeals, 

in coordination with the IRS Human Capital Office, to conduct a skills gap 

analysis specific to Appeals mission needs, and develop a strategy for 

mitigating any identified gaps.

IRS PCA Due Date: Oct-2020

Tax Administration: Opportunities Exist 

to Improve Monitoring and 

Transparency of Appeal Resolution 

Timeliness

GAO-18-659 10/22/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should establish timeframes and 

monitoring procedures for the timely transfer of taxpayer appeal requests by 

examination compliance units to the Office of Appeals.

IRS PCA Due Date: Sep-2019

Tax Administration: Opportunities Exist 

to Improve Monitoring and 

Transparency of Appeal Resolution 

Timeliness

GAO-18-659 10/22/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should evaluate the existing 

monitoring for collection due process appeal requests and address 

deficiencies in collection staff meeting the requirement for timely transfer to 

the Office of Appeals.

IRS Implemented. Pending auditor validation.

Tax Administration: Opportunities Exist 

to Improve Monitoring and 

Transparency of Appeal Resolution 

Timeliness

GAO-18-659 10/22/2018 Tax Administration and 

Compliance

The Commissioner of Internal Revenue should provide more transparency to 

taxpayers on historical average total appeal resolution times. This could 

include publishing average total resolution times by work stream on an 

Office of Appeals web page, as well as including total expected times in the 

Appeals welcome letter.

IRS PCA Due Date: Jun-2020

Tax Administration: Opportunities Exist 

to Improve Monitoring and 

Transparency of Appeal Resolution 

Timeliness

GAO-18-659 10/22/2018 Tax Administration and 

Compliance

The Secretary of the Treasury, consistent with its responsibilities under 

GPRAMA and Executive Orders for customer service, should ensure that the 

Commissioner of Internal Revenue takes action to develop a mechanism to 

solicit and consider public input and customer feedback on a regular basis on 

current and proposed IRS appeal policies and procedures. This could include 

leveraging existing IRS advisory bodies or establishing an Office of Appeals 

advisory body representing the taxpaying public, the tax practitioner 

community, and businesses to solicit customer perspectives.

IRS PCA Due Date: Jan-2020

Tax Administration: Opportunities Exist 

to Improve Monitoring and 

Transparency of Appeal Resolution 

Timeliness

GAO-18-659 10/22/2018 Tax Administration and 

Compliance

The Secretary of the Treasury, consistent with its responsibilities under 

GPRAMA and Executive Orders for customer service, should ensure that the 

Commissioner of Internal Revenue takes action to make Appeals customer 

service standards and performance results more transparent to the public. 

This could include publishing customer service standards and related 

performance measure results on the Office of Appeals web page on IRS.gov.

IRS PCA Due Date: Jun-2020

WHISTLEBLOWER PROGRAM: IRS 

Needs to Improve Data Controls for 

Some Award Determinations

GAO-18-698 10/29/2018 Improper Payments The Commissioner of Internal Revenue should ensure that the Deputy 

Commissioner for Services and Enforcement develops and documents 

improved controls for the validity, completeness, and accuracy of data on 

FBAR exams and enforcement actions.

IRS PCA Due Date: Jun-2020

WHISTLEBLOWER PROGRAM: IRS 

Needs to Improve Data Controls for 

Some Award Determinations

GAO-18-698 10/29/2018 Improper Payments The Commissioner of Internal Revenue should ensure that the Director of the 

Whistleblower Office modifies the Form 11369 and its accompanying 

instructions to clarify how to document how whistleblower information was 

used in any IRS actions taken, regardless of whether the laws administered, 

examined, or enforced are outside of Title 26, such as FBAR penalties.

IRS Implemented. Pending auditor validation.
Page 34 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Information Technology: Departments 

Need to Improve Chief Information 

Officers' Review and Approval of IT 

Budgets

GAO-19-49DO 11/13/2018 Information 

Technology

The Secretary of the Treasury should direct the department CIO to establish, 

for any OMB common baseline requirements that are related to IT budgeting 

that have been delegated, a plan that specifies the requirement being 

delegated, demonstrates how the CIO intends to retain accountability for the 

requirement, and ensures through quality assurance processes that the 

delegated official will execute such responsibilities with the appropriate level 

of rigor. 

Treasury - DO PCA Due Date: Feb-2020

Information Technology: Departments 

Need to Improve Chief Information 

Officers' Review and Approval of IT 

Budgets

GAO-19-49DO 11/13/2018 Information 

Technology

The Secretary of the Treasury should direct the Office of the CIO and other 

offices, as appropriate, to take steps to ensure that the actions taken to 

comply with OMB's common baseline for implementing FITARA on 

individual investments are adequately documented.

Treasury - DO PCA Due Date: Feb-2020

Information Technology: Departments 

Need to Improve Chief Information 

Officers' Review and Approval of IT 

Budgets

GAO-19-49DO 11/13/2018 Information 

Technology

The Secretary of the Treasury should ensure that the Office of the CIO and 

other offices, as appropriate, address gaps in the department's FITARA plans 

by developing and implementing policies and procedures that document the 

process for the CIO's review and approval of the major IT investments 

portion of the budget request. 

Treasury - DO PCA Due Date: Feb-2020

Information Technology: Departments 

Need to Improve Chief Information 

Officers' Review and Approval of IT 

Budgets

GAO-19-49DO 11/13/2018 Information 

Technology

The Secretary of the Treasury should ensure that the Office of the CIO and 

other offices, as appropriate, address gaps in the department's FITARA plans 

by developing and implementing policies and procedures that document the 

steps the CIO is to take to ensure whether the IT portfolio includes 

appropriate estimates of all IT resources included in the budget request. 

Treasury - DO PCA Due Date: Feb-2020

Information Technology: Departments 

Need to Improve Chief Information 

Officers' Review and Approval of IT 

Budgets

GAO-19-49DO 11/13/2018 Information 

Technology

The Secretary of the Treasury should ensure that the Office of the CIO and 

other offices, as appropriate, address gaps in the department's FITARA plans 

by developing and implementing policies and procedures that establish 

department-wide policy for the level of detail of planned expenditure 

reporting to the CIO for all transactions that include IT resources.

Treasury - DO PCA Due Date: Feb-2020

Information Technology: Departments 

Need to Improve Chief Information 

Officers' Review and Approval of IT 

Budgets

GAO-19-49DO 11/13/2018 Information 

Technology

The Secretary of the Treasury should ensure that the Office of the CIO and 

other offices, as appropriate, address gaps in the department's FITARA plans 

by developing and implementing policies and procedures that include the 

CIO as a member of governance boards that inform decisions regarding all 

IT resources, including component-level boards. 

Treasury - DO PCA Due Date: Feb-2020

Information Technology: Departments 

Need to Improve Chief Information 

Officers' Review and Approval of IT 

Budgets

GAO-19-49DO 11/13/2018 Information 

Technology

The Secretary of the Treasury should ensure that the Office of the CIO and 

other offices, as appropriate, address gaps in the department's FITARA plans 

by developing and implementing policies and procedures that include the 

CIO in the planning and budgeting stages for all programs that are fully or 

partially supported with IT resources. 

Treasury - DO PCA Due Date: Feb-2020

Information Technology: Departments 

Need to Improve Chief Information 

Officers' Review and Approval of IT 

Budgets

GAO-19-49DO 11/13/2018 Information 

Technology

The Secretary of the Treasury should ensure that the Office of the CIO and 

other offices, as appropriate, establish quality assurance processes--such as 

data quality checks, reviews of estimation methods, linkages between the IT 

portfolio and procurement system data, and linkages between the IT portfolio 

and financial system data--for ensuring the annual IT budget is informed by 

complete and reliable information on anticipated government labor, contract, 

and other relevant IT expenditures. 

Treasury - DO PCA Due Date: Feb-2020
Page 35 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Information Technology: Departments 

Need to Improve Chief Information 

Officers' Review and Approval of IT 

Budgets

GAO-19-49IRS 11/13/2018 Information 

Technology

The IRS Commissioner should direct the Office of the CIO and other offices, 

as appropriate, to take steps to ensure that the actions taken to comply with 

OMB's common baseline for implementing FITARA on individual 

investments are adequately documented.

IRS PCA Due Date: Oct-2019

Treasury Judgment Fund--Transparency 

and Reliability Needed in Reporting 

Fund Balances and Activities

GAO-19-44 12/07/2018 Financial Statements The Commissioner of the Bureau of the Fiscal Service should take steps to 

ensure that information provided to Congress undergoes a documented 

review to ensure the quality and responsiveness of the information provided.

Fiscal Service Implemented. Pending auditor validation.

Open Data: Treasury Could Better Align 

USAspending.gov With Key Practices 

and Legal Requirements

GAO-19-72 12/13/2018 Information 

Technology

The Secretary of the Treasury should ensure that users can easily search for 

awards by city and program source, consistent with FFATA requirements. 

Treasury - DO Implemented. Pending auditor validation.

Open Data: Treasury Could Better Align 

USAspending.gov With Key Practices 

and Legal Requirements

GAO-19-72 12/13/2018 Information 

Technology

The Secretary of the Treasury should establish a process to ensure all content 

on USAspending.gov is available from a government domain, consistent 

with OMB requirements. 

Treasury - DO Implemented. Pending auditor validation.

Open Data: Treasury Could Better Align 

USAspending.gov With Key Practices 

and Legal Requirements

GAO-19-72 12/13/2018 Information 

Technology

The Secretary of the Treasury should establish a process to ensure all pages 

on the USAspending.gov website use the secure HTTPS protocol, consistent 

with OMB requirements.

Treasury - DO Implemented. Pending auditor validation.

Open Data: Treasury Could Better Align 

USAspending.gov With Key Practices 

and Legal Requirements

GAO-19-72 12/13/2018 Information 

Technology

The Secretary of the Treasury should fully comply with OMB's requirements 

by communicating licensing information on USAspending.gov. 

Treasury - DO Implemented. Pending auditor validation.

Open Data: Treasury Could Better Align 

USAspending.gov With Key Practices 

and Legal Requirements

GAO-19-72 12/13/2018 Information 

Technology

The Secretary of the Treasury should fully comply with OMB's requirements 

by providing metadata in a single location that are easy to find on the 

USAspending.gov website. 

Treasury - DO Implemented. Pending auditor validation.

Troubled Asset Relief Program: 

Monitoring of Hardest Hit Fund 

Program Could Be Strengthened

GAO-19-100 12/21/2018 Administration of 

Program Operations

The Assistant Secretary for Financial Institutions should annually collect and 

evaluate HFAs' risk assessments, which include HFAs' risk levels. 

Treasury - DO Implemented. Pending auditor validation.

Troubled Asset Relief Program: 

Monitoring of Hardest Hit Fund 

Program Could Be Strengthened

GAO-19-100 12/21/2018 Administration of 

Program Operations

The Assistant Secretary for Financial Institutions should ensure that the 

documentation listing the HFA staff responsible for internal control 

execution is updated routinely. 

Treasury - DO Implemented. Pending auditor validation.

Improper Payments: Selected Agencies 

Need Improvements in Their 

Assessments to Better Determine and 

Document Risk Susceptibility

GAO-19-112 01/10/2019 Improper Payments The Secretary of the Treasury should revise Treasury's processes for 

conducting improper payment risk assessments for Interest on the Public 

Debt and Home Affordable Modification Program to help ensure that the 

processes result in reliable assessments of whether the programs are 

susceptible to significant improper payments. This should include preparing 

sufficient documentation to support its risk assessments. 

Treasury - DO Implemented. Pending auditor validation.
Page 36 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Large Bank Supervision: OCC Could 

Better Address Risk of Regulatory 

Capture

GAO-19-69 01/24/2019 Banking and Lending Revise Large Bank Supervision's policy to require documentation of 

examination teams' internal deliberations that lead to consequential decisions 

for the bank, such as the decision to issue a Matter Requiring Attention, 

among others.

OCC Rejected. OCC disagreed with the 

recommendation. The supervisory conclusions 

of individual examiners are recorded in their 

workpapers and conclusion memos. The 

conclusions reached as a result of internal 

deliberation and consequential decisions are 

fully explained in communications to the bank. 

The ongoing nature of supervision of large 

banks results in a significant amount of 

dialogue among OCC staff and between OCC 

staff and bank management. Spending time 

documenting those discussions would be 

extremely time consuming and result in OCC 

conducting fewer supervisory activities.

Large Bank Supervision: OCC Could 

Better Address Risk of Regulatory 

Capture

GAO-19-69 01/24/2019 Banking and Lending Revise Large Bank Supervision's policy to require that bank examination 

teams retain drafts of key documents, including the conclusion memo and 

supervisory letter that document the supervisory review process.

OCC Rejected. OCC disagreed with the 

recommendation. Initial impressions or early 

assessments of a bank’s process or practice 

often change as examiners gather more facts 

and develop their analyses over the course of a 

supervisory activity. Retaining early drafts of 

conclusion memos and supervisory letters that 

might not have fully informed conclusions 

serves little purpose. The risk of regulatory 

capture is controlled through subjecting 

supervisory decisions to multiple levels of 

quality review. Should examiners have 

concerns regarding the integrity of supervisory 

matters, established processes exist for having 

those concerns investigated internally within 

OCC.
Page 37 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Large Bank Supervision: OCC Could 

Better Address Risk of Regulatory 

Capture

GAO-19-69 01/24/2019 Banking and Lending Systematically track and monitor Large Bank Supervision's use of informal 

recommendations.

OCC Rejected. OCC disagreed with the 

recommendation. This audit and OCC’s 

independent Enterprise Governance reviews 

did not identify instances of inappropriate use 

of recommendations. Examiners make 

informal recommendations for bank policies 

that are already acceptable or for products or 

services that are already satisfactorily 

governed, constructed, and delivered to 

customers in compliance with laws and 

regulations. The suggested enhancement is 

not an action or change that affects bank safety 

and soundness, prudent risk management, or 

compliance with laws and regulations, and 

therefore tracking and monitoring those 

recommendations would not be beneficial.

Large Bank Supervision: OCC Could 

Better Address Risk of Regulatory 

Capture

GAO-19-69 01/24/2019 Banking and Lending Revise Large Bank Supervision's policy to require documentation of 

communications with banks, including those between executive and senior 

management and banks that inform decisions.

OCC Rejected. OCC disagreed with the 

recommendation. OCC cannot conclude that 

extensive documentation of conversations and 

meeting minutes would improve supervision, 

or that without such, examiners and 

management are not considering pertinent 

information when reaching supervisory 

conclusions. The influence of meetings and 

interactions with bankers and other parties 

during the course of supervisory activities is 

reflected in the supervisory decisions and 

conclusions, and documented in supervisory 

activity procedures, conclusion memos, 

supervisory letters, reports of examination, and 

when applicable, in enforcement actions.

Large Bank Supervision: OCC Could 

Better Address Risk of Regulatory 

Capture

GAO-19-69 01/24/2019 Banking and Lending Document the reasons for a modification to the standard scope of recusals on 

the annual financial disclosure form, and record waivers of supplemental 

standards separately from recusals.

OCC PCA Due Date: Mar-2021
Page 38 of 64

APPENDIX 1

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Government Accountability Office (GAO) Recommendations

Report Title Report Number Issue Date Audit Area GAO Recommendation Bureau/Office Implementation Status

Large Bank Supervision: OCC Could 

Better Address Risk of Regulatory 

Capture

GAO-19-69 01/24/2019 Banking and Lending Develop a policy for Large Bank Supervision to check employees' active 

conflict of interests during the staffing process for examinations and other 

supervisory activities and for documenting the results of this check.

OCC Rejected. OCC disagreed with the 

recommendation. The recommendation shifts 

responsibility for ensuring compliance with 

recusal requirements from employees to 

personnel managing the exam staffing process. 

Such a shift runs the risk of undermining the 

expectations of personal responsibility that 

serves as the core of a government ethics 

program and a vigilant supervision program. 

OCC provides training to all employees on the 

government ethics standards, which includes 

employees’ responsibility to comply with the 

recusal requirements. 

Large Bank Supervision: OCC Could 

Better Address Risk of Regulatory 

Capture

GAO-19-69 01/24/2019 Banking and Lending Update the OCC instructions on workpaper reviews and disseminating these 

instructions to employees.

OCC PCA Due Date: Mar-2020

Large Bank Supervision: OCC Could 

Better Address Risk of Regulatory 

Capture

GAO-19-69 01/24/2019 Banking and Lending Conduct a periodic self-assessment of the ethics program and documenting 

the results.

OCC PCA Due Date: Jun-2020

Large Bank Supervision: OCC Could 

Better Address Risk of Regulatory 

Capture

GAO-19-69 01/24/2019 Banking and Lending Revise the OCC risk appetite statement to (1) address risk areas other than 

reputational risk and (2) Identify additional factors to analyze when assessing 

the risk of regulatory capture.

OCC PCA Due Date: Mar-2020
Page 39 of 64

APPENDIX 2

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Office of the Inspector General (OIG) Recommendations

Report Title Report Number Issue Date Audit Area Treasury OIG Recommendation Bureau/Office Implementation 

Status

OSP Needs to Promptly Inform OIG of 

Potential Illegal Activity and Improve Other 

Processes

OIG-15-040 07/27/2015 Administration of 

Program Operations

The Assistant Secretary for Intelligence and Analysis should conduct, in 

conjunction with the Office of the Chief Information Officer, a resource 

analysis of the Office of Security Programs to determine the proper 

information technology software, equipment, and support needed to 

comply with Central Verification System requirements.

Treasury - DO PCA Due: Nov-2019

OSP Needs to Promptly Inform OIG of 

Potential Illegal Activity and Improve Other 

Processes

OIG-15-040 07/27/2015 Administration of 

Program Operations

The Assistant Secretary for Intelligence and Analysis should ensure that 

the Office of Security Programs work with the Office of the Chief 

Information Officer and Office of Personnel Management, as appropriate, 

to resolve the Office of Security Programs system and data issues with the 

Central Verification System so that Treasury employee security clearance 

data is provided to and maintained in the Central Verification System on 

a complete, current, and accurate basis going forward.

Treasury - DO PCA Due: Nov-2019

Libyan Sanctions Case Study OIG-16-001 10/26/2015 Administration of 

Program Operations

The Director of the Office of Foreign Assets Control should develop a 

lessons-learned process to capture and communicate acquired knowledge 

from past sanctions programs at a time appropriate for each sanctions 

program.

Treasury - DO PCA Due: Dec-2019

INFORMATION TECHNOLOGY: 

Department of the Treasury Federal 

Information Security Modernization Act 

Fiscal Year 2015 Performance Audit

OIG-16-010MNT 11/12/2015 Information 

Technology

United States Mint management, for the selected system, should ensure 

access forms are completed, properly reviewed by the help desk prior to 

granting access, and centrally retained by the help desk.

MINT Implemented. Pending 

auditor validation.

INFORMATION TECHNOLOGY: 

Department of the Treasury Federal 

Information Security Modernization Act 

Fiscal Year 2015 Performance Audit

OIG-16-010MNT 11/12/2015 Information 

Technology

United States Mint management. for the selected system, should ensure 

that its third-party cloud service provider provides Federal Information 

Security Modernization Act of 2014 (FISMA)-related artifacts to 

demonstrate FISMA compliance to the U.S. Mint security compliance 

team. 

MINT Implemented. Pending 

auditor validation.

GENERAL MANAGEMENT: Treasury 

Has Policies and Procedures to Safeguard 

Classified Information but They Are Not 

Effectively Implemented

OIG-16-059 09/29/2016 Administration of 

Program Operations

The Assistant Secretary for Intelligence and Analysis should direct the 

Deputy Assistant Secretary for Security to update the Treasury Security 

Manual to include procedures requiring the Office of Security Programs 

to follow-up and obtain all bureau self-inspection reports.

Treasury - DO PCA Due: Dec-2019

TERRORIST FINANCING/MONEY 

LAUNDERING: Federal Agencies Are 

Generally Satisfied with TFFC's 

Collaboration Efforts, but Enhancements 

Can Be Made

OIG-17-044 05/23/2017 Terrorist Financing The Assistant Secretary for Terrorist Financing should address areas of 

concern expressed by Federal agencies regarding the Office of Terrorist 

Financing and Financial Crimes' (TFFC) collaboration that includes 

feedback, intersessional meetings, and invitations to participate in 

bilateral meetings with foreign countries during the Financial Action 

Task Force (FATF) Plenary.

Treasury - DO TFFC agreed with the 

recommendation and is 

in the process of 

developing PCAs.

TERRORIST FINANCING/MONEY 

LAUNDERING: Federal Agencies Are 

Generally Satisfied with TFFC's 

Collaboration Efforts, but Enhancements 

Can Be Made

OIG-17-044 05/23/2017 Terrorist Financing The Assistant Secretary for Terrorist Financing should develop policies 

and procedures to ensure continuity and consistency in collaboration 

efforts with interagency task forces and workgroups.

Treasury - DO TFFC agreed with the 

recommendation and is 

in the process of 

developing PCAs.
Page 40 of 64

APPENDIX 2

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Office of the Inspector General (OIG) Recommendations

Report Title Report Number Issue Date Audit Area Treasury OIG Recommendation Bureau/Office Implementation 

Status

TERRORIST FINANCING/MONEY 

LAUNDERING: Federal Agencies Are 

Generally Satisfied with TFFC's 

Collaboration Efforts, but Enhancements 

Can Be Made

OIG-17-044 05/23/2017 Terrorist Financing The Assistant Secretary for Terrorist Financing should develop and 

implement a mechanism to monitor, evaluate, and report on the 

effectiveness of the Office of Terrorist Financing and Financial Crimes' 

(TFFC) interagency collaboration.

Treasury - DO TFFC agreed with the 

recommendation and is 

in the process of 

developing PCAs.

TERRORIST FINANCING/MONEY 

LAUNDERING: Federal Agencies Are 

Generally Satisfied with TFFC's 

Collaboration Efforts, but Enhancements 

Can Be Made

OIG-17-044 05/23/2017 Terrorist Financing The Assistant Secretary for Terrorist Financing should develop 

meaningful performance measures specific to the Office of Terrorist 

Financing and Financial Crimes (TFFC) collaboration.

Treasury - DO TFFC agreed with the 

recommendation and is 

in the process of 

developing PCAs.

Treasury Continues to Make Progress in 

Meeting DATA Act Reporting 

Requirements, But Data Quality Concerns 

Remain

OIG-18-010R 11/08/2017 Administration of 

Program Operations

Treasury's Assistant Secretary for Management should, working as 

needed with Treasury's senior accountable official (SAO), reporting 

entities, and the Government-wide Program Management Office (PMO), 

as well as the Office of Management and Budget (OMB), continue to 

monitor the resolution for issues identified in corrective action plans 

including, but not limited to, Administrative Resource Center (ARC)'s 

process to report procurement data on behalf of its customer agencies.

Treasury - DO PCA Due: Nov-2019

TERRORIST FINANCING/MONEY 

LAUNDERING: OFAC Human Resources 

Practices Need Improvement

OIG-18-018 11/27/2017 Administration of 

Program Operations

The Office of Foreign Assets Control (OFAC) Director should work with 

the Office of the Deputy Assistant Secretary for Human Resources and 

Chief Human Capital Officer (DASHR/CHCO) to ensure that required 

records are included in the electronic Official Personnel Folders (e OPF).

Treasury - DO PCA Due: Jan-2020

TERRORIST FINANCING/MONEY 

LAUNDERING: OFAC Human Resources 

Practices Need Improvement

OIG-18-018 11/27/2017 Administration of 

Program Operations

The Office of Foreign Assets Control (OFAC) Director should ensure that 

legacy employees' current position descriptions are evaluated to ensure 

that the documented promotion potential of these non-supervisory 

employees is consistent with OFAC's current promotion practices.

Treasury - DO PCA Due: Jan-2020

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that disbursements exceeded available fund balances, 

the Assistant Secretary for Management, within 60 days of the issuance of 

this report, should finalize the Office of Budget and Travel's internal 

review of its fiscal year 2015 records and request a Government 

Accountability Office decision to determine if the Antideficiency Act 

violations occurred.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that disbursements exceeded available fund balances, 

the Assistant Secretary for Management, should analyze the Office of 

Budget and Travel's fiscal year 2016 and 2017 records to determine 

whether Antideficiency Act violations occurred.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that obligations and expenditures were incurred prior 

to reimbursable agreements being signed, the Assistant Secretary for 

Management, within 60 days of the issuance of this report, should finalize 

the Office of Budget and Travel's internal review of its fiscal year 2015 

records and request a Government Accountability Office decision to 

determine if the Antideficiency Act violations occurred.

Treasury - DO Implemented. Pending 

auditor validation.
Page 41 of 64

APPENDIX 2

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Office of the Inspector General (OIG) Recommendations

Report Title Report Number Issue Date Audit Area Treasury OIG Recommendation Bureau/Office Implementation 

Status

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that obligations and expenditures were incurred prior 

to reimbursable agreements being signed, the Assistant Secretary for 

Management should analyze the Office of Budget and Travel's fiscal year 

2016 and 2017 records to determine whether Antideficiency Act 

violations occurred.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that fiscal year 2016 funds were used to pay for 

fiscal year 2015 reimbursable services costs, the Assistant Secretary for 

Management, within 60 days of the issuance of this report, should finalize 

the Office of Budget and Travel's internal review of its fiscal year 2015 

records and request a Government Accountability Office decision to 

determine if the Antideficiency Act violations occurred.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that fiscal year 2016 funds were used to pay for 

fiscal year 2015 reimbursable services costs, the Assistant Secretary for 

Management should analyze the Office of Budget and Travel's fiscal year 

2016 and 2017 records to determine whether Antideficiency Act 

violations occurred.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that reimbursable agreements were not processed in 

a timely manner, the Assistant Secretary for Management, should ensure 

the Office of Budget and Travel develop, revise, and finalize office-wide 

manuals, policies, and standard operating procedures to strengthen 

processes and procedures for budget formulation and execution, as well 

as reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that reimbursable agreements were not processed in 

a timely manner, the Assistant Secretary for Management, should ensure 

the Office of Budget and Travel (OBT) distribute to its management and 

staff, and provide training on, new or revised OBT policies and standard 

operating procedures.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that reimbursable agreements were not processed in 

a timely manner, the Assistant Secretary for Management, should ensure 

the Office of Budget and Travel comply with Departmental Offices 

Reimbursable Agreement Policy (October 2010) by reviewing and 

updating a procedural manual that addresses roles, responsibilities, and 

activities associated with each phase of the reimbursable agreement 

lifecycle, as necessary, at least once every 2 years.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that reimbursable agreements were not processed in 

a timely manner, the Assistant Secretary for Management, should ensure 

the Office of Budget and Travel perform an analysis to determine whether 

advances should be obtained from Departmental Offices customers at the 

time reimbursable services are ordered.

Treasury - DO Implemented. Pending 

auditor validation.
Page 42 of 64

APPENDIX 2

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Office of the Inspector General (OIG) Recommendations

Report Title Report Number Issue Date Audit Area Treasury OIG Recommendation Bureau/Office Implementation 

Status

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that reimbursable agreements were not processed in 

a timely manner, the Assistant Secretary for Management, should ensure 

the Office of Budget and Travel develop a mandatory training program to 

properly train its staff on the requirements of applicable laws, regulations, 

and policies in the area of budget execution and formulation, as well as 

reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that revenues were not collected in a timely manner, 

the Assistant Secretary for Management, should ensure the Office of 

Budget and Travel develop, revise, and finalize office-wide manuals, 

policies, and standard operating procedures to strengthen processes and 

procedures for budget formulation and execution, as well as reimbursable 

agreements.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that revenues were not collected in a timely manner, 

the Assistant Secretary for Management, should ensure the Office of 

Budget and Travel (OBT) distribute to its management and staff, and 

provide training on, new or revised OBT policies and standard operating 

procedures.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that revenues were not collected in a timely manner, 

the Assistant Secretary for Management, should ensure the Office of 

Budget and Travel comply with Departmental Offices Reimbursable 

Agreement Policy (October 2010) by reviewing and updating a 

procedural manual that addresses roles, responsibilities, and activities 

associated with each phase of the reimbursable agreement lifecycle, as 

necessary, at least once every 2 years.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that revenues were not collected in a timely manner, 

the Assistant Secretary for Management, should ensure the Office of 

Budget and Travel perform an analysis to determine whether advances 

should be obtained from Departmental Offices customers at the time 

reimbursable services are ordered.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that revenues were not collected in a timely manner, 

the Assistant Secretary for Management, should ensure the Office of 

Budget and Travel develop a mandatory training program to properly 

train its staff on the requirements of applicable laws, regulations, and 

policies in the area of budget execution and formulation, as well as 

reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that budget authority was loaded prior to 

reimbursable agreements were signed, the Assistant Secretary for 

Management, should ensure the Office of Budget and Travel develop, 

revise, and finalize office-wide manuals, policies, and standard operating 

procedures to strengthen processes and procedures for budget formulation 

and execution, as well as reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.
Page 43 of 64

APPENDIX 2

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Office of the Inspector General (OIG) Recommendations

Report Title Report Number Issue Date Audit Area Treasury OIG Recommendation Bureau/Office Implementation 

Status

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that budget authority was loaded prior to 

reimbursable agreements were signed, the Assistant Secretary for 

Management, should ensure the Office of Budget and Travel (OBT) 

distribute to its management and staff, and provide training on, new or 

revised OBT policies and standard operating procedures.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that budget authority was loaded prior to 

reimbursable agreements were signed, the Assistant Secretary for 

Management, should ensure the Office of Budget and Travel comply with 

Departmental Offices Reimbursable Agreement Policy (October 2010) by 

reviewing and updating a procedural manual that addresses roles, 

responsibilities, and activities associated with each phase of the 

reimbursable agreement lifecycle, as necessary, at least once every 2 

years.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that budget authority was loaded prior to 

reimbursable agreements were signed, the Assistant Secretary for 

Management, should ensure the Office of Budget and Travel perform an 

analysis to determine whether advances should be obtained from 

Departmental Offices customers at the time reimbursable services are 

ordered.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that budget authority was loaded prior to 

reimbursable agreements were signed, the Assistant Secretary for 

Management, should ensure the Office of Budget and Travel develop a 

mandatory training program to properly train its staff on the requirements 

of applicable laws, regulations, and policies in the area of budget 

execution and formulation, as well as reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that close-out policies, procedures, and guidance 

were not followed, the Assistant Secretary for Management, should 

ensure the Office of Budget and Travel develop, revise, and finalize officewide manuals, policies, and standard operating procedures to strengthen 

processes and procedures for budget formulation and execution, as well 

as reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that close-out policies, procedures, and guidance 

were not followed, the Assistant Secretary for Management, should 

ensure the Office of Budget and Travel (OBT) distribute to its 

management and staff, and provide training on, new or revised OBT 

policies and standard operating procedures.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that close-out policies, procedures, and guidance 

were not followed, the Assistant Secretary for Management, should 

ensure the Office of Budget and Travel comply with Departmental 

Offices Reimbursable Agreement Policy (October 2010) by reviewing 

and updating a procedural manual that addresses roles, responsibilities, 

and activities associated with each phase of the reimbursable agreement 

lifecycle, as necessary, at least once every 2 years.

Treasury - DO Implemented. Pending 

auditor validation.
Page 44 of 64

APPENDIX 2

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Office of the Inspector General (OIG) Recommendations

Report Title Report Number Issue Date Audit Area Treasury OIG Recommendation Bureau/Office Implementation 

Status

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that close-out policies, procedures, and guidance 

were not followed, the Assistant Secretary for Management, should 

ensure the Office of Budget and Travel perform an analysis to determine 

whether advances should be obtained from Departmental Offices 

customers at the time reimbursable services are ordered.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that close-out policies, procedures, and guidance 

were not followed, the Assistant Secretary for Management, should 

ensure the Office of Budget and Travel develop a mandatory training 

program to properly train its staff on the requirements of applicable laws, 

regulations, and policies in the area of budget execution and formulation, 

as well as reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that the Office of Budget and Travel (OBT) 

management and staff lacked adequate training, the Assistant Secretary 

for Management, should ensure OBT develop, revise, and finalize officewide manuals, policies, and standard operating procedures to strengthen 

processes and procedures for budget formulation and execution, as well 

as reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that the Office of Budget and Travel (OBT) 

management and staff lacked adequate training, the Assistant Secretary 

for Management, should ensure OBT distribute to its management and 

staff, and provide training on, new or revised OBT policies and standard 

operating procedures.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that the Office of Budget and Travel (OBT) 

management and staff lacked adequate training, should ensure OBT 

comply with Departmental Offices Reimbursable Agreement Policy 

(October 2010) by reviewing and updating a procedural manual that 

addresses roles, responsibilities, and activities associated with each phase 

of the reimbursable agreement lifecycle, as necessary, at least once every 

2 years.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that the Office of Budget and Travel (OBT) 

management and staff lacked adequate training, the Assistant Secretary 

for Management, should ensure OBT perform an analysis to determine 

whether advances should be obtained from Departmental Offices 

customers at the time reimbursable services are ordered.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that the Office of Budget and Travel (OBT) 

management and staff lacked adequate training, the Assistant Secretary 

for Management, should ensure OBT develop a mandatory training 

program to properly train its staff on the requirements of applicable laws, 

regulations, and policies in the area of budget execution and formulation, 

as well as reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.
Page 45 of 64

APPENDIX 2

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Office of the Inspector General (OIG) Recommendations

Report Title Report Number Issue Date Audit Area Treasury OIG Recommendation Bureau/Office Implementation 

Status

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that policies and standard operating procedures were 

lacking or outdated, the Assistant Secretary for Management, should 

ensure the Office of Budget and Travel develop, revise, and finalize officewide manuals, policies, and standard operating procedures to strengthen 

processes and procedures for budget formulation and execution, as well 

as reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that policies and standard operating procedures were 

lacking or outdated, the Assistant Secretary for Management, should 

ensure the Office of Budget and Travel (OBT) distribute to its 

management and staff, and provide training on, new or revised OBT 

policies and standard operating procedures.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that policies and standard operating procedures were 

lacking or outdated, the Assistant Secretary for Management, should 

ensure the Office of Budget and Travel comply with Departmental 

Offices Reimbursable Agreement Policy (October 2010) by reviewing 

and updating a procedural manual that addresses roles, responsibilities, 

and activities associated with each phase of the reimbursable agreement 

lifecycle, as necessary, at least once every 2 years.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that policies and standard operating procedures were 

lacking or outdated, the Assistant Secretary for Management, should 

ensure the Office of Budget and Travel perform an analysis to determine 

whether advances should be obtained from Departmental Offices 

customers at the time reimbursable services are ordered.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that policies and standard operating procedures were 

lacking or outdated, the Assistant Secretary for Management, should 

ensure the Office of Budget and Travel develop a mandatory training 

program to properly train its staff on the requirements of applicable laws, 

regulations, and policies in the area of budget execution and formulation, 

as well as reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that costs were not recorded in compliance with 

recording statute, the Assistant Secretary for Management, should ensure 

the Office of Budget and Travel develop, revise, and finalize office-wide 

manuals, policies, and standard operating procedures to strengthen 

processes and procedures for budget formulation and execution, as well 

as reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that costs were not recorded in compliance with 

recording statute, the Assistant Secretary for Management, should ensure 

the Office of Budget and Travel (OBT) distribute to its management and 

staff, and provide training on, new or revised OBT policies and standard 

operating procedures.

Treasury - DO Implemented. Pending 

auditor validation.
Page 46 of 64

APPENDIX 2

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Office of the Inspector General (OIG) Recommendations

Report Title Report Number Issue Date Audit Area Treasury OIG Recommendation Bureau/Office Implementation 

Status

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that costs were not recorded in compliance with 

recording statute, the Assistant Secretary for Management, should ensure 

the Office of Budget and Travel comply with Departmental Offices 

Reimbursable Agreement Policy (October 2010) by reviewing and 

updating a procedural manual that addresses roles, responsibilities, and 

activities associated with each phase of the reimbursable agreement 

lifecycle, as necessary, at least once every 2 years.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that costs were not recorded in compliance with 

recording statute, the Assistant Secretary for Management, should ensure 

the Office of Budget and Travel perform an analysis to determine whether 

advances should be obtained from Departmental Offices customers at the 

time reimbursable services are ordered.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that costs were not recorded in compliance with 

recording statute, the Assistant Secretary for Management, should ensure 

the Office of Budget and Travel develop a mandatory training program to 

properly train its staff on the requirements of applicable laws, regulations, 

and policies in the area of budget execution and formulation, as well as 

reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that invoices and interest were not paid in 

compliance with Prompt Payment Act, the Assistant Secretary for 

Management, should ensure the Office of Budget and Travel develop, 

revise, and finalize office-wide manuals, policies, and standard operating 

procedures to strengthen processes and procedures for budget formulation 

and execution, as well as reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that invoices and interest were not paid in 

compliance with Prompt Payment Act, the Assistant Secretary for 

Management, should ensure the Office of Budget and Travel (OBT) 

distribute to its management and staff, and provide training on, new or 

revised OBT policies and standard operating procedures.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that invoices and interest were not paid in 

compliance with Prompt Payment Act, the Assistant Secretary for 

Management, should ensure the Office of Budget and Travel comply with 

Departmental Offices Reimbursable Agreement Policy (October 2010) by 

reviewing and updating a procedural manual that addresses roles, 

responsibilities, and activities associated with each phase of the 

reimbursable agreement lifecycle, as necessary, at least once every 2 

years.

Treasury - DO Implemented. Pending 

auditor validation.

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that invoices and interest were not paid in 

compliance with Prompt Payment Act, the Assistant Secretary for 

Management, should ensure the Office of Budget and Travel perform an 

analysis to determine whether advances should be obtained from 

Departmental Offices customers at the time reimbursable services are 

ordered.

Treasury - DO Implemented. Pending 

auditor validation.
Page 47 of 64

APPENDIX 2

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Office of the Inspector General (OIG) Recommendations

Report Title Report Number Issue Date Audit Area Treasury OIG Recommendation Bureau/Office Implementation 

Status

RESOURCE MANAGEMENT: Treasury's 

Office of Budget and Travel Potentially 

Violated the Antideficiency Act and Needs 

to Improve Its Reimbursable Agreement 

Process

OIG-18-024 12/08/2017 Administration of 

Program Operations

To address the issue that invoices and interest were not paid in 

compliance with Prompt Payment Act, the Assistant Secretary for 

Management, should ensure the Office of Budget and Travel develop a 

mandatory training program to properly train its staff on the requirements 

of applicable laws, regulations, and policies in the area of budget 

execution and formulation, as well as reimbursable agreements.

Treasury - DO Implemented. Pending 

auditor validation.

FINANCIAL REGULATION AND 

OVERSIGHT: Treasury OIG Review of the 

Office of Financial Research's Government 

Purchase Card Program

OIG-18-038 02/08/2018 Administration of 

Program Operations

The Director of the Office of Financial Research (OFR) should ensure a 

review of purchase cardholder files is completed and that all documents 

required by policy and procedures are included in the files.

Treasury - DO PCA Due: Dec-2019

FINANCIAL REGULATION AND 

OVERSIGHT: Treasury OIG Review of the 

Office of Financial Research's Government 

Purchase Card Program

OIG-18-038 02/08/2018 Administration of 

Program Operations

The Director of the Office of Financial Research (OFR) should develop 

and implement a policy for storing and maintaining government purchase 

card (GPC) transaction documentation in a centralized location.

Treasury - DO PCA Due: Dec-2019

FINANCIAL REGULATION AND 

OVERSIGHT: Treasury OIG Review of the 

Office of Financial Research's Government 

Purchase Card Program

OIG-18-038 02/08/2018 Administration of 

Program Operations

The Director of the Office of Financial Research (OFR) should, when 

Approving Official (AO) duties are transferred to OFR employees in 

2018, develop and implement a policy to require OFR AOs to review 

purchase card transactions for potential split purchases on a monthly 

basis.

Treasury - DO PCA Due: Dec-2019

TERRORIST FINANCING/MONEY 

LAUNDERING: OFAC's Licensing 

Program Would Benefit From System 

Enhancements

OIG-18-043 04/03/2018 Administration of 

Program Operations

The Director of the Office of Foreign Assets Control (OFAC) should 

develop performance measures specific for the licensing division.

Treasury - DO PCA Due: Mar-2020

TERRORIST FINANCING/MONEY 

LAUNDERING: Audit of the Office of 

Intelligence and Analysis' Authorities and 

Actions Related to U.S. Persons' Financial 

Information

OIG-18-044 04/09/2018 Terrorist Financing As expeditiously as possible, the Under Secretary for Terrorism and 

Financial Intelligence should ensure that the Office of Intelligence and 

Analysis' (OIA) U.S. Persons (USP) Procedures are finalized and 

submitted for approval to the Attorney General.

Treasury - DO PCA Due: Sep-2019

TERRORIST FINANCING/MONEY 

LAUNDERING: Audit of the Office of 

Intelligence and Analysis' Authorities and 

Actions Related to U.S. Persons' Financial 

Information

OIG-18-044 04/09/2018 Terrorist Financing As expeditiously as possible, the Under Secretary for Terrorism and 

Financial Intelligence should ensure that the Office of Intelligence and 

Analysis (OIA) implement a compliance monitoring program to assess 

whether intelligence analysts' activities are conducted in accordance with 

OIA authorities, and electronic searches and other queries are performed 

in a manner that fully protects the rights of U.S. persons.

Treasury - DO PCA Due: Sep-2019

RESTORE ACT: St. Bernard Parish's 

Internal Control over Federal Awards

OIG-18-049 08/01/2018 Administration of 

Program Operations

The Fiscal Assistant Secretary should consider St. Bernard Parish's 

control deficiencies over grant timekeeping and employees' lack of 

knowledge, experience, and training on Federal grants as part of 

Treasury's oversight and administration of St. Bernard Parish's awards. 

This consideration should also be part of Treasury's risk assessments 

required by the Uniform Guidance for future awards.

Treasury - DO PCA Due: Dec-2019
Page 48 of 64

APPENDIX 2

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Office of the Inspector General (OIG) Recommendations

Report Title Report Number Issue Date Audit Area Treasury OIG Recommendation Bureau/Office Implementation 

Status

INFORMATION TECHNOLOGY: 

Department of the Treasury Federal 

Information Security Modernization Act 

Fiscal Year 2018 Performance Audit

OIG-19-007TIG 10/31/2018 Information 

Technology

Treasury Inspector General for Tax Administration (TIGTA) management 

should develop a plan that incorporates and takes into account 

interruptions in TIGTA System funding. 

TIGTA TIGTA agreed with the 

recommendation and is 

in the process of 

developing PCAs.

INFORMATION TECHNOLOGY: 

Department of the Treasury Federal 

Information Security Modernization Act 

Fiscal Year 2018 Performance Audit

OIG-19-007TIG 10/31/2018 Information 

Technology

Treasury Inspector General for Tax Administration (TIGTA) management 

should develop and disseminate to TIGTA personnel a TIGTA System 

access control policy that addresses purpose, scope, roles, responsibilities, 

management commitment, coordination among organizational entities, 

and compliance. 

TIGTA TIGTA agreed with the 

recommendation and is 

in the process of 

developing PCAs.

INFORMATION TECHNOLOGY: 

Department of the Treasury Federal 

Information Security Modernization Act 

Fiscal Year 2018 Performance Audit

OIG-19-007TIG 10/31/2018 Information 

Technology

Treasury Inspector General for Tax Administration (TIGTA) management 

should establish a current enterprise baseline of software and related 

configurations for the TIGTA System. 

TIGTA TIGTA agreed with the 

recommendation and is 

in the process of 

developing PCAs.

INFORMATION TECHNOLOGY: 

Department of the Treasury Federal 

Information Security Modernization Act 

Fiscal Year 2018 Performance Audit

OIG-19-007TIG 10/31/2018 Information 

Technology

Treasury Inspector General for Tax Administration (TIGTA) management 

should perform and document the Business Impact Analysis for the 

TIGTA System environment every two years as required by the 

Department of Homeland Security, Federal Emergency Management 

Agency, Federal Continuity Directive 1 (FCD-1) and Treasury Directive 

Publication 85-01, Department of the Treasury Information Technology 

Security Program (TD P 85-01). 

TIGTA TIGTA agreed with the 

recommendation and is 

in the process of 

developing PCAs.

INFORMATION TECHNOLOGY: 

Department of the Treasury Federal 

Information Security Modernization Act 

Fiscal Year 2018 Performance Audit

OIG-19-007TIG 10/31/2018 Information 

Technology

Treasury Inspector General for Tax Administration (TIGTA) management 

should develop and disseminate to TIGTA personnel a TIGTA System 

Information System Contingency Plan (ISCP) that addresses purpose, 

scope, roles, responsibilities, management commitment, coordination, and 

compliance to facilitate the implementation of the contingency planning 

policy and associated contingency planning controls. TIGTA should 

conduct disaster recovery and business continuity testing for the TIGTA 

System on the frequency stipulated by a Business Impact Analysis. 

TIGTA TIGTA agreed with the 

recommendation and is 

in the process of 

developing PCAs.

INFORMATION TECHNOLOGY: 

Department of the Treasury Federal 

Information Security Modernization Act 

Fiscal Year 2018 Performance Audit

OIG-19-007TIG 10/31/2018 Information 

Technology

Treasury Inspector General for Tax Administration (TIGTA) management 

should obtain and issue full Authority to Operate (ATO) to include the 

following:

a. Ensure that the TIGTA System's current System Security Plan (SSP) is 

finalized and updated according with Treasury Directive Publication 85-

01 and National Institute of Standards and Technology (NIST) Special 

Publication 800-53 Revision 4 guidance.

b. Develop Plan of Action and Milestones (POA&M) for the security 

controls that were not implemented or were partially implemented.

c. Complete the Security Assessment and Authorization (SA&A) package 

for the TIGTA System in accordance with NIST Special Publication 800-

37 Revision 1, Guide for Applying the Risk Management Framework to 

Federal Information Systems.

TIGTA TIGTA agreed with the 

recommendation and is 

in the process of 

developing PCAs.
Page 49 of 64

APPENDIX 2

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Office of the Inspector General (OIG) Recommendations

Report Title Report Number Issue Date Audit Area Treasury OIG Recommendation Bureau/Office Implementation 

Status

INFORMATION TECHNOLOGY: 

Department of the Treasury Federal 

Information Security Modernization Act 

Fiscal Year 2018 Performance Audit

OIG-19-007TIG 10/31/2018 Information 

Technology

Treasury Inspector General for Tax Administration (TIGTA) management 

should perform vulnerability scanning over the TIGTA System 1 every 30 

days in accordance with Treasury Directive Publication 85-01, 

Department of the Treasury Information Technology Security Program 

(TD P 85-01). 

TIGTA TIGTA agreed with the 

recommendation and is 

in the process of 

developing PCAs.

FINANCIAL MANAGEMENT: Audit of 

the Department of the Treasury's 

Consolidated Financial Statements for 

Fiscal Years 2018 and 2017

OIG-19-016 11/15/2018 Financial Statements Recommendations to address this material weakness have been separately 

provided to Internal Review Service (IRS) management by the auditors of 

the IRS's financial statements. OIG recommended that the Assistant 

Secretary for Management (ASM) and Deputy Chief Financial Officer 

(DCFO) ensure that IRS implements corrective actions to resolve the 

control deficiencies at IRS.

Treasury - DO PCA Due: Dec-2019

FINANCIAL MANAGEMENT: Audit of 

the Department of the Treasury's 

Consolidated Financial Statements for 

Fiscal Years 2018 and 2017

OIG-19-016 11/15/2018 Financial Statements Separate reports with additional details and recommendations for 

corrective action have been provided separately to Bureau of the Fiscal 

Service (Fiscal Service) management. OIG recommended that the 

Assistant Secretary for Management (ASM) and Deputy Chief Financial 

Officer (DCFO) ensure that Fiscal Service implement requisite corrective 

actions to resolve control deficiencies over its cash management and debt 

information systems.

Treasury - DO PCA Due: Dec-2019

FINANCIAL MANAGEMENT: Audit of 

the Department of the Treasury's 

Consolidated Financial Statements for 

Fiscal Years 2018 and 2017

OIG-19-016 11/15/2018 Financial Statements Separate reports with additional details were provided to IRS and Fiscal 

Service management with recommendations to

address the above noncompliance with the federal financial management 

system requirements. OIG recommended that the Assistant Secretary for 

Management (ASM) and Deputy Chief Financial Officer (DCFO) ensure 

that the Internal Review Service (IRS) and Bureau of the Fiscal Service 

(Fiscal Service) develop and implement remediation plans outlining 

actions to be taken to resolve noncompliance with the federal financial 

management system requirements and the resources and responsible 

organizational units for such planned actions.

Treasury - DO PCA Due: Dec-2019

FINANCIAL MANAGEMENT: 

Management Letter for the Audit of the 

Department of the Treasury's Financial 

Statements for Fiscal Years 2018 and 2017

OIG-19-019 12/06/2018 Financial Statements Departmental Offices (DO) management should focus additional 

resources to perform the following:

a.	Review and analyze the server level security audit logs at the defined 

frequency that has been established. 

b.	Follow DO Incident Response procedure to report any security 

incidents, policy violations, fraudulent activity, and operational problems. 

c.	Track completion of the analysis, review and any escalations based 

upon the review and analysis of the security audit logs.

Treasury - DO Treasury-DO agreed 

with the 

recommendation and is 

in the process of 

developing PCAs.

FINANCIAL MANAGEMENT: 

Management Letter for the Audit of the 

Department of the Treasury's Financial 

Statements for Fiscal Years 2018 and 2017

OIG-19-019 12/06/2018 Financial Statements Departmental Offices (DO) management should focus additional 

resources to perform the following:

Periodically review Information System Security Officer's implementation 

and operation of the review of the security audit logs for the server level 

to determine that they completed the review and analysis of the security 

audit logs consistent with the defined frequency review requirement.

Treasury - DO Treasury-DO agreed 

with the 

recommendation and is 

in the process of 

developing PCAs.
Page 50 of 64

APPENDIX 2

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Office of the Inspector General (OIG) Recommendations

Report Title Report Number Issue Date Audit Area Treasury OIG Recommendation Bureau/Office Implementation 

Status

FINANCIAL MANAGEMENT: 

Management Letter for the Audit of the 

Bureau of Engraving and Printing's 

Financial Statements for Fiscal Years 2018 

and 2017

OIG-19-030 12/20/2018 Financial Statements Bureau of Engraving and Printing (BEP) management should develop and 

implement policies and procedures around Contracting Officer 

requirements and controls to ensure invoice approvals are complete and 

accurate.

BEP PCA Due: Dec-2019

FINANCIAL MANAGEMENT: 

Management Letter for the Audit of the 

Bureau of Engraving and Printing's 

Financial Statements for Fiscal Years 2018 

and 2017

OIG-19-030 12/20/2018 Financial Statements Bureau of Engraving and Printing (BEP) management should develop and 

implement policies and procedures to ensure that the monthly review of 

open purchase orders is completed timely by establishing a timeliness 

threshold.

BEP PCA Due: Dec-2019

FINANCIAL MANAGEMENT: 

Management Letter for the Audit of the 

Bureau of Engraving and Printing's 

Financial Statements for Fiscal Years 2018 

and 2017

OIG-19-030 12/20/2018 Financial Statements Bureau of Engraving and Printing (BEP) management should establish 

and implement policies, procedures, and controls to ensure that the 

Bureau performs a timely, documented, review of the journal entry 

population for entries with the same preparer and reviewer.

BEP PCA Due: Dec-2019

FINANCIAL MANAGEMENT: 

Management Letter for the Audit of the 

Bureau of Engraving and Printing's 

Financial Statements for Fiscal Years 2018 

and 2017

OIG-19-030 12/20/2018 Financial Statements Bureau of Engraving and Printing (BEP) management should establish 

and implement policies, procedures, and controls to ensure that the proper 

inputs are used to create the Bureau's non-GAAP (non-generally accepted 

accounting principles) analysis as well as the review of the non-GAAP 

analysis.

BEP PCA Due: Dec-2019

FINANCIAL MANAGEMENT: 

Management Letter for the Audit of the 

Bureau of Engraving and Printing's 

Financial Statements for Fiscal Years 2018 

and 2017

OIG-19-030 12/20/2018 Financial Statements Bureau of Engraving and Printing (BEP) management should implement 

a formal written policy for computing the non-stock accrual estimate.

BEP PCA Due: Dec-2019

FINANCIAL MANAGEMENT: 

Management Letter for the Audit of the 

Bureau of Engraving and Printing's 

Financial Statements for Fiscal Years 2018 

and 2017

OIG-19-030 12/20/2018 Financial Statements Bureau of Engraving and Printing (BEP) management should document 

their review and subsequent follow up actions to demonstrate that the 

review was complete and accurate.

BEP PCA Due: Dec-2019

FINANCIAL MANAGEMENT: 

Management Letter for the Audit of the 

Bureau of Engraving and Printing's 

Financial Statements for Fiscal Years 2018 

and 2017

OIG-19-030 12/20/2018 Financial Statements Bureau of Engraving and Printing (BEP) management should perform a 

detailed review of any new policy or procedure before implementing.

BEP PCA Due: Dec-2019
Page 51 of 64

APPENDIX 3

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Inspector General for Tax Administration (TIGTA) Recommendations

Report Title Report Number Issue Date Audit Area TIGTA Recommendation Bureau/Office Implementation Status

An Enterprise Approach Is Needed To Address 

The Security Risk Of Unpatched Computers

2012-20-112 09/25/2012 Information Technology The Chief Technology Officer should ensure that the IRS completes the 

deployment of an automated asset discovery tool (or tools if needed) and 

builds an accurate and complete inventory of IT assets (including hardware 

and software) that reside on the IRS network.

IRS PCA Due: Oct-2019

Customer Account Data Engine 2 (Cade 2): 

System Requirements And Testing Processes 

Need Improvements

2012-20-122 09/28/2012 Information Technology The Chief Technology Officer should ensure all database issues identified by 

the Guardium scan are resolved or an action plan is developed with specific 

corrective actions and time periods.

IRS PCA Due: Apr-2021

The Taxpayer Advocate Service Can Improve 

The Processing Of Systemic Burden Cases

2014-10-033 06/24/2014 Tax Administration and 

Compliance

The National Taxpayer Advocate should review the results of sample findings 

and, where appropriate, incorporate lessons learned into future training for 

TAS personnel.

IRS PCA Due: Nov-2019

A Service-Wide Strategy Is Needed To 

Increase Business Tax Return Electronic Filing

2014-40-084 09/24/2014 Administration of 

Program Operations

The Commissioner, Wage and Investment Division, should develop a less 

burdensome electronic signature process for businesses e-filing employment 

tax returns using the MeF system.

IRS PCA Due: Dec-2020

Revising Tax Debt Identification Programming 

And Correcting Procedural Errors Could 

Improve The Tax Refund Offset Program

2016-40-028 03/31/2016 Tax Administration and 

Compliance

The Commissioner, Wage and Investment Division, should revise computer 

programming to ensure that credit elects are offset to any associated tax debt 

on the NMF.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.

Revising Tax Debt Identification Programming 

And Correcting Procedural Errors Could 

Improve The Tax Refund Offset Program

2016-40-028 03/31/2016 Tax Administration and 

Compliance

The Deputy Commissioner for Services and Enforcement should revise 

computer programming to use the LLC indicator on the business tax account 

to ensure that individual tax refunds are not offset to the associated LLC's 

business tax debt.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.

Revising Tax Debt Identification Programming 

And Correcting Procedural Errors Could 

Improve The Tax Refund Offset Program

2016-40-028 03/31/2016 Tax Administration and 

Compliance

The Deputy Commissioner for Services and Enforcement should revise 

identification processes to include sole proprietor information from Form SS4 to identify individual tax refunds to offset to business tax debt.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.

Improvements Are Needed To Strengthen 

Electronic Authentication Process Controls

2016-20-082 09/07/2016 Information Technology The Chief Information Officer should implement enhancements to audit log 

analysis to provide for automated mechanisms to integrate audit review, 

analysis, and reporting processes and to correlate audit records across 

different repositories to gain organization-wide situational awareness.

IRS PCA Due: Oct-2019

Information Technology: Sharepoint Controls 

Need Improvement To Mitigate Risks And To 

Ensure That Possible Duplicate Costs Are 

Avoided

2016-20-075 09/15/2016 Information Technology The Chief Information Officer should ensure that an automated tool is 

identified, deployed, and routinely executed to identify SharePoint sites 

containing PII and SBU data.

IRS PCA Due: Oct-2019

Information Technology: Sharepoint Controls 

Need Improvement To Mitigate Risks And To 

Ensure That Possible Duplicate Costs Are 

Avoided

2016-20-075 09/15/2016 Information Technology The Chief Information Officer should ensure that SharePoint site collections 

containing PII or SBU data have approved PCLIAs.

IRS PCA Due: Oct-2019

Employees Sometimes Did Not Adhere To EMail Policies Which Increased The Risk Of 

Improper Disclosure Of Taxpayer Information

2017-30-010 10/14/2016 Tax Administration and 

Compliance

The Chief Technology Officer should update the EEFax system to allow 

encrypted messages to be sent to the EEFax system server.

IRS PCA Due: Oct-2020
Page 52 of 64

APPENDIX 3

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Inspector General for Tax Administration (TIGTA) Recommendations

Report Title Report Number Issue Date Audit Area TIGTA Recommendation Bureau/Office Implementation Status

Improvements Are Needed To Ensure That 

Tax Accounts On The Automated Non-Master 

File Are Accurately Processed

2017-40-037 05/25/2017 Tax Administration and 

Compliance

The Commissioner, Wage and Investment Division, should correct ANMF 

programming to compute and assess the Failure to File penalty on Form 

1040NR, U.S. Nonresident Alien Income Tax Return, accounts in which the 

Taxpayer Identification Number is an Employer Identification Number.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.

Improvements Are Needed To Ensure That 

Tax Accounts On The Automated Non-Master 

File Are Accurately Processed

2017-40-037 05/25/2017 Tax Administration and 

Compliance

The Commissioner, Wage and Investment Division, should Correct ANMF 

programming to use the correct date when computing the Failure to Pay 

penalty. In addition, programming should be corrected to ensure that the 

proper penalty rate is used to compute the penalty amount.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.

Information Technology: Improvements Are 

Needed In Enterprise-Wide Disaster Recovery 

Planning And Testing

2017-20-024 06/01/2017 Information Technology The Chief Information Officer should collaborate with the IRS business 

operating divisions to reach consensus regarding the maximum tolerable 

downtime or recovery time objective for each mission essential function.

IRS PCA Due: Jul-2020

The Number Of Employment-Related Identity 

Theft Victims Is Significantly Greater Than 

Identified

2017-40-031 06/20/2017 Tax Administration and 

Compliance

The Commissioner, Wage and Investment Division, should correct 

programming as needed to ensure that the employment identity theft marker is 

placed on all victims' tax accounts for ITIN/SSN mismatches on e-filed tax 

returns.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.

Further Actions Are Needed To Reduce The 

Risk Of Employment Tax Fraud To Businesses 

That Use The Services Of Professional 

Employer Organizations

2017-40-085 09/13/2017 Tax Administration and 

Compliance

The Commissioner, Wage and Investment Division, should establish 

processes and procedures to reduce unnecessary resources expended notifying 

employers of an address change when programming incorrectly identifies an 

address change resulting from minor formatting revisions.

IRS On Hold. Agreed with the 

recommendation but currently on 

hold awaiting input from other 

agencies.

The Internal Revenue Services Is Not In 

Compliance With Federal Requirements For 

Software Asset Management

2017-20-062 09/18/2017 Information Technology The Chief Information Officer should establish executive governance for 

SAM within the IRS which acts as a centralized group to ensure that effective 

and knowledgeable decisions are being made timely by authorized personnel.

IRS PCA Due: Sep-2019

Some Legal Requirements To Deactivate 

Individual Taxpayer Identification Numbers 

Have Not Been Met

2018-40-011 01/29/2018 Improper Payments The Commissioner, Wage and Investment Division, should deactivate the 

89,105 ITINs TIGTA identified that should have been deactivated.

IRS PCA Due: Apr-2020

Results Of The 2017 Filing Season 2018-40-012 01/31/2018 Tax Administration and 

Compliance

The Commissioner, Wage and Investment Division, should establish 

processes to use its math error authority to deny all e-filed and paper AOTC 

claims for which the taxpayer does not provide the institution EIN for each 

student claimed on the return.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.

Results Of The 2017 Filing Season 2018-40-012 01/31/2018 Tax Administration and 

Compliance

The Commissioner, Wage and Investment Division, should modify Form 

2441 to ask taxpayers whether or not they fall under one of the exceptions to 

be able to file as Married Filing Separately and revise computer programs to 

allow the credit only when a taxpayer attests that he or she meets the 

exception by checking the applicable box.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.

Most Employment Identity Theft Victims Have 

Not Been Notified That Their Identities Are 

Being Used By Others For Employment

2018-40-016 02/12/2018 Tax Administration and 

Compliance

The Commissioner, Wage and Investment Division, should revise ITIN/SSN 

mismatch programming to ensure that it does not place the employment 

identity theft marker on the accounts of SSN owners who are spouses of ITIN 

holders.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.
Page 53 of 64

APPENDIX 3

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Inspector General for Tax Administration (TIGTA) Recommendations

Report Title Report Number Issue Date Audit Area TIGTA Recommendation Bureau/Office Implementation Status

Additional Actions Are Needed To Make The 

Worker Misclassification Initiative With The 

Department Of Labor A Success

2018-IE-R002 02/20/2018 Tax Administration and 

Compliance

The Commissioner, Small Business/Self-Employed Division, should evaluate 

whether provisions of the MOU require amendment, revision, or termination 

and ensure that the duties and responsibilities of the IRS, as outlined in the 

MOU, are executed as required.

IRS PCA Due: Mar-2020

Employer Noncompliance With Wage 

Reporting Requirements Significantly Reduces 

The Ability To Verify Refundable Tax Credit 

Claims Before Refunds Are Paid

2018-40-015 02/26/2018 Improper Payments The Commissioner, Wage and Investment Division, should correct 

programming errors that resulted in the incorrect calculation of ITIN issuance 

dates and ensure that the RTS and the NAP are updated with the correct 

issuance date.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.

Employer Noncompliance With Wage 

Reporting Requirements Significantly Reduces 

The Ability To Verify Refundable Tax Credit 

Claims Before Refunds Are Paid

2018-40-015 02/26/2018 Improper Payments The Commissioner, Wage and Investment Division, should identify all ITINs 

with a missing issuance date on the NAP and ensure that the NAP is updated 

with the correct issuance date.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.

Affordable Care Act: Processes To Identify 

Employers Subject To The Employer Shared 

Responsibility Payment Need Improvement

2018-43-022 03/21/2018 Tax Administration and 

Compliance

The Commissioner, Small Business/Self-Employed Division, and the 

Commissioner, Wage and Investment Division, should work with the Chief 

Information Officer to develop a Service-wide Taxpayer Identification 

Number (TIN) validation strategy to reduce the number of TIN validation 

systems and programs to streamline and consolidate TIN validation efforts.

IRS PCA Due: Feb-2020

The Research, Applied Analytics, And 

Statistics Organization Project Management 

Practices Need Improvement

2018-10-026 05/04/2018 Administration of 

Program Operations

The Director, RAAS, should develop and implement effective performance 

measures to better assess and demonstrate the impact of its research projects 

on tax administration and taxpayers.

IRS PCA Due: Sep-2019

Security Over High Value Assets Should Be 

Strengthened

2018-20-029 05/18/2018 Information Technology The Chief Information Officer should implement the OMB CSIP actions to 

identify and document current system hardware components for all IRS 

HVAs.

IRS PCA Due: Mar-2020

Programming Errors And Deficiencies In Tax 

Examiner Screening Resulted In Some Health 

Coverage Tax Credit Claims Being 

Erroneously Processed

2018-40-035 05/23/2018 Tax Administration and 

Compliance

The Commissioner, Wage and Investment Division, should implement Error 

Resolution Unit screening procedures to identify individuals who filed a Form 

W-2, indicating that they obtained a new job.

IRS PCA Due: Aug-2019

Programming Errors And Deficiencies In Tax 

Examiner Screening Resulted In Some Health 

Coverage Tax Credit Claims Being 

Erroneously Processed

2018-40-035 05/23/2018 Tax Administration and 

Compliance

The Commissioner, Wage and Investment Division, should review the 2,222 

tax returns TIGTA identified (for which tax examiners erroneously disallowed 

the claim without first corresponding with the taxpayer to obtain missing 

eligibility or payment documentation) to ensure that taxpayers received the 

HCTCs to which they were entitled and that erroneously issued HCTCs are 

recovered.

IRS PCA Due: Aug-2019

Programming Errors And Deficiencies In Tax 

Examiner Screening Resulted In Some Health 

Coverage Tax Credit Claims Being 

Erroneously Processed

2018-40-035 05/23/2018 Tax Administration and 

Compliance

The Commissioner, Wage and Investment Division, should review the 22 tax 

returns TIGTA identified for which the taxpayer incorrectly used employersponsored health insurance premiums, reported on Form W-2, to support an 

HCTC claim. Identify erroneously issued HCTCs and take actions to recover 

the credit.

IRS PCA Due: Aug-2019

Active Directory Oversight Needs 

Improvement And Criminal Investigation 

Computer Rooms Lack Minimum Security 

Controls

2018-20-034 06/27/2018 Information Technology The Chief, CI, with assistance from the Chief Information Officer, should 

complete a cost analysis to 1) determine the efficacy of relocating CI assets in 

each of the field offices to existing IRS computer rooms versus upgrading the 

CI computer rooms to ensure that assets are protected in accordance with 

Federal and IRM security requirements and 2) implement the most cost 

effective solution.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.
Page 54 of 64

APPENDIX 3

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Inspector General for Tax Administration (TIGTA) Recommendations

Report Title Report Number Issue Date Audit Area TIGTA Recommendation Bureau/Office Implementation Status

Active Directory Oversight Needs 

Improvement And Criminal Investigation 

Computer Rooms Lack Minimum Security 

Controls

2018-20-034 06/27/2018 Information Technology The Chief, CI, with assistance from the Chief Information Officer, should 

ensure that CI computer rooms are immediately updated to comply with IRM 

requirements for Limited Areas, key and cipher lock combination controls, 

and stand alone fire extinguishers while a cost effective solution regarding the 

computer room location is identified and implemented.

IRS PCA Due: Oct-2019

Despite Spending Nearly $380 Million, The 

Internal Revenue Service Is Still Not Prepared 

To Enforce Compliance With The Foreign 

Account Tax Compliance Act

2018-30-040 07/05/2018 Tax Administration and 

Compliance

The Commissioner, Large Business and International Division, should 

establish follow-up procedures and initiate action to address error notices 

related to file submissions rejected by the ICMM to ensure that non-IGA FFIs 

and Model 2 IGA FFIs submit FATCA reports properly and to address 

unresolved record level errors to ensure that the FFIs correctly provide data 

for mandatory fields.

IRS PCA Due: Dec-2019

Management Controls Should Be Strengthened 

To Improve Hardware Asset Inventory 

Reliability

2018-20-041 07/13/2018 Information Technology The Chief Information Officer should direct responsible personnel to 

prioritize locating high-risk missing assets that may potentially contain 

Personally Identifiable Information when conducting the 10 research steps and 

immediately report assets determined as lost to the IRS's Computer Security 

Incident Response Center and TIGTA's Office of Investigations.

IRS PCA Due: Feb-2020

Management Controls Should Be Strengthened 

To Improve Hardware Asset Inventory 

Reliability

2018-20-041 07/13/2018 Information Technology The Chief Information Officer should direct responsible personnel to research 

and update the KISAM-AM module records for all in-use assets to ensure that 

all identified blank User Name and/or Contact Name fields are populated 

accordingly.

IRS PCA Due: Feb-2020

Management Controls Should Be Strengthened 

To Improve Hardware Asset Inventory 

Reliability

2018-20-041 07/13/2018 Information Technology The Chief Information Officer should identify high-risk hardware asset 

categories that may potentially contain Personally Identifiable Information, 

update guidance to further define that high-risk assets not verified for one 

inventory cycle be immediately categorized as missing in the KISAM-AM 

module, and specify a time frame to complete the 10 research steps for 

locating missing assets.

IRS PCA Due: Feb-2020

Management Controls Should Be Strengthened 

To Improve Hardware Asset Inventory 

Reliability

2018-20-041 07/13/2018 Information Technology The Chief Information Officer should improve the accuracy of the Location 

field in the KISAM-AM module for shared assets by capturing the specificity 

of the location for future hardware asset inventory certifications and 

transactions.

IRS PCA Due: Feb-2020

Management Controls Should Be Strengthened 

To Improve Hardware Asset Inventory 

Reliability

2018-20-041 07/13/2018 Information Technology The Chief Information Officer should review and update the existing 

Hardware Asset Management Inventory Certification Plan and reconciliation 

process to improve compliance, accountability, and participation of all asset 

inventory owners and stakeholders and to improve the accuracy of 

information of key KISAM-AM module fields during the annual certification 

process.

IRS PCA Due: Apr-2020

The Internal Revenue Service Lacks A 

Coordinated Strategy To Address Unregulated 

Return Preparer Misconduct

2018-30-042 07/25/2018 Tax Administration and 

Compliance

The Commissioner, SB/SE Division, should establish goals that support the 

Service-wide Return Preparer Strategy being developed by the Deputy 

Commissioner for Services and Enforcement and monitor progress towards 

those goals.

IRS PCA Due: Oct-2019

The Internal Revenue Service Lacks A 

Coordinated Strategy To Address Unregulated 

Return Preparer Misconduct

2018-30-042 07/25/2018 Tax Administration and 

Compliance

The Commissioner, Small Business/Self-Employed (SB/SE) Division, should 

consider expanding use of the PRISM feature of the Return Preparer Database 

to assist the LDCs and the Examination function, and with the identification 

and development of the PACs.

IRS PCA Due: Oct-2020
Page 55 of 64

APPENDIX 3

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Inspector General for Tax Administration (TIGTA) Recommendations

Report Title Report Number Issue Date Audit Area TIGTA Recommendation Bureau/Office Implementation Status

The Internal Revenue Service Lacks A 

Coordinated Strategy To Address Unregulated 

Return Preparer Misconduct

2018-30-042 07/25/2018 Tax Administration and 

Compliance

The Deputy Commissioner for Services and Enforcement should develop a 

preparer misconduct strategy that encourages programs with the authority to 

address preparer misconduct to coordinate with one another to establish 

program goals and track progress towards those goals.

IRS PCA Due: Sep-2019

Private Collection Agency Security Over 

Taxpayer Data Needs Improvement

2018-20-039 07/30/2018 Information Technology The Director, Headquarters Collection, SB/SE Division, should provide 

oversight to ensure that stronger security controls are included in the annual 

assessments such as the Lockbox Security Guidelines, including a separate 

secure room for mail processing and securing payments, and enhancing 

security camera coverage to include record times of all sensitive areas where 

taxpayer data are present.

IRS PCA Due: Oct-2019

Criminal Investigation'S Firearms Training 

And Qualification Oversight Needs To Be 

Improved

2018-30-046 07/30/2018 Tax Administration and 

Compliance

The Chief, CI, should consider replacing trigger locks with life jackets to 

provide special agents with another way to safely secure fully loaded firearms 

at the residence and should assure CI agents are regularly trained in the safe 

use of trigger locks.

IRS PCA Due: Oct-2019

Additional Actions Can Be Taken To Further 

Reduce Refund Losses Associated With 

Business Identity Theft

2018-40-061 08/20/2018 Information Technology The Commissioner, Wage and Investment Division, should expand the use of 

business identity theft filters to include employment tax returns (e.g., Form 

940, Employer's Annual Federal Unemployment (FUTA) Tax Return; Form 

941, Employer's Quarterly Federal Tax Return; Form 943, Employer's Annual 

Federal Tax Return for Agricultural Employees; and Form 944, Employer's 

Annual Federal Tax Return).

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.

Controls Over Pocket Commissions Must Be 

Improved

2018-IE-R005 08/20/2018 Tax Administration and 

Compliance

Subsequent to the establishment of a complete and accurate record of nonenforcement commissions in PDS, the Chief, FMSS, should reinstate the 

requirement for an annual reconciliation to account for issued commissions to 

ensure that PDS records remain complete and accurate.

IRS PCA Due: May-2020

Controls Over Pocket Commissions Must Be 

Improved

2018-IE-R005 08/20/2018 Tax Administration and 

Compliance

The Chief, FMSS, should attempt to determine which IRS employees may 

hold commissions that are not recorded in PDS and update PDS as needed.

IRS PCA Due: Feb-2020

Controls Over Pocket Commissions Must Be 

Improved

2018-IE-R005 08/20/2018 Tax Administration and 

Compliance

The Chief, FMSS, should consult with Department of the Treasury officials to 

ensure the Program Report is complete and includes all commission records in 

PDS.

IRS PCA Due: Feb-2020

Controls Over Pocket Commissions Must Be 

Improved

2018-IE-R005 08/20/2018 Tax Administration and 

Compliance

The Chief, FMSS, should require a full physical inventory of all commission 

records with the objective of making the PDS a complete and accurate system 

of records for all non- enforcement commissions.

IRS PCA Due: Feb-2020

Improved Procedures Are Needed To Prevent 

The Fraudulent Use Of Third-Party 

Authorization Forms To Obtain Taxpayer 

Information

2018-40-062 08/27/2018 Information Technology The Commissioner, Wage and Investment Division, should correspond with 

representatives and designees assigned multiple CAF numbers to inform them 

that they are permitted to have one CAF number per location. The 

correspondence should request a response from each representative and 

designee specifying the CAF number that the IRS should retain. Excess 

numbers should then be removed from the CAF.

IRS PCA Due: Sep-2019

Improvements Are Needed To Ensure 

Adequate Consideration Of The Pickup Of 

Prior And/Or Subsequent Returns During Field 

Examinations

2018-30-073 09/17/2018 Tax Administration and 

Compliance

The Director, Examination, Small Business/Self-Employed (SB/SE) Division, 

should provide additional training to field examiners and managers to ensure 

that the Lead Sheet 130 includes an adequate explanation for not expanding to 

prior and/or subsequent year returns.

IRS PCA Due: Jan-2020
Page 56 of 64

APPENDIX 3

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Inspector General for Tax Administration (TIGTA) Recommendations

Report Title Report Number Issue Date Audit Area TIGTA Recommendation Bureau/Office Implementation Status

Improvements Are Needed To Ensure 

Adequate Consideration Of The Pickup Of 

Prior And/Or Subsequent Returns During Field 

Examinations

2018-30-073 09/17/2018 Tax Administration and 

Compliance

The Director, Examination, Small Business/Self-Employed (SB/SE) Division, 

should provide additional training to field examiners on when to expand 

examinations into the prior and/or subsequent tax return years, including the 

use of split closing for cases nearing the statute limitation or over-age cases 

and requesting statute extensions as needed.

IRS PCA Due: Jan-2020

Improvements Are Needed To Ensure 

Adequate Consideration Of The Pickup Of 

Prior And/Or Subsequent Returns During Field 

Examinations

2018-30-073 09/17/2018 Tax Administration and 

Compliance

The Director, Examination, Small Business/Self-Employed (SB/SE) Division, 

should update the IRM with additional guidance on when it is appropriate to 

conduct an examination even though the statute is less than 12 months, and 

include statute extensions as an option to alleviate statute of limitation 

concerns.

IRS PCA Due: Oct-2019

Improvements Are Needed To Ensure 

Adequate Consideration Of The Pickup Of 

Prior And/Or Subsequent Returns During Field 

Examinations

2018-30-073 09/17/2018 Tax Administration and 

Compliance

The Director, Examination, Small Business/Self-Employed (SB/SE) Division, 

should update the IRM with guidance on when field examiners should 

conduct a more detailed comparative analysis for individual nonbusiness 

returns and specific details on how it should be documented.

IRS PCA Due: Oct-2019

Improved Communication And Outreach With 

Federal Agencies Could Reduce The Number 

Of Invalid Retirement Benefit Statements Filed 

Each Year

2018-IE-R007 09/17/2018 Tax Administration and 

Compliance

The Acting Commissioner, Tax Exempt and Government Entities Division, 

should conduct proactive outreach activities with Federal agencies to ensure 

that they understand their filing and withholding requirements.

IRS PCA Due: Oct-2019

Improved Communication And Outreach With 

Federal Agencies Could Reduce The Number 

Of Invalid Retirement Benefit Statements Filed 

Each Year

2018-IE-R007 09/17/2018 Tax Administration and 

Compliance

The Acting Commissioner, Tax Exempt and Government Entities Division, 

should consider using the error notice to alert all Federal agencies when they 

file a benefit statement with a missing or inaccurate SSNs.

IRS PCA Due: Oct-2020

Improved Controls Are Needed To Ensure 

That Corrective Actions For Reported 

Information Technology Weaknesses Are 

Documented And Fully Implemented Prior To 

Closure

2018-20-063 09/19/2018 Information Technology The Chief Financial Officer (CFO) should ensure that complete descriptions 

of the specific actions taken to close PCAs are documented on Forms 13872.

IRS PCA Due: Sep-2019

Improved Controls Are Needed To Ensure 

That Corrective Actions For Reported 

Information Technology Weaknesses Are 

Documented And Fully Implemented Prior To 

Closure

2018-20-063 09/19/2018 Information Technology The Chief Financial Officer (CFO) should ensure that sufficient supporting 

documentation is uploaded to the JAMES to support PCA closure.

IRS PCA Due: Sep-2019

Improved Controls Are Needed To Ensure 

That Corrective Actions For Reported 

Information Technology Weaknesses Are 

Documented And Fully Implemented Prior To 

Closure

2018-20-063 09/19/2018 Information Technology The Chief Financial Officer (CFO) should ensure that the Internal Revenue 

Manual and instructions for Form 13872 are updated so that both the manager 

responsible for implementing the PCA and the executive responsible for the 

PCA are required to approve Form 13872 supporting the PCA's closure.

IRS PCA Due: Sep-2019

Improvements To The Ss-8 Program Are 

Needed To Help Workers And Improve 

Employment Tax Compliance

2018-30-077 09/19/2018 Tax Administration and 

Compliance

The Commissioner, Small Business/Self-Employed (SB/SE) Division, should 

create guidance and training for the responsible functions to ensure the 

accurate processing and determinations of worker classification requests, 

including gig economy worker classification requests.

IRS PCA Due: Dec-2019

Improvements To The Ss-8 Program Are 

Needed To Help Workers And Improve 

Employment Tax Compliance

2018-30-077 09/19/2018 Tax Administration and 

Compliance

The Commissioner, Small Business/Self-Employed (SB/SE) Division, should 

evaluate the process used in making worker classification determinations and 

opinions in the SS-8 Program and make necessary changes to improve 

processing.

IRS PCA Due: Oct-2019
Page 57 of 64

APPENDIX 3

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Inspector General for Tax Administration (TIGTA) Recommendations

Report Title Report Number Issue Date Audit Area TIGTA Recommendation Bureau/Office Implementation Status

Improvements To The Ss-8 Program Are 

Needed To Help Workers And Improve 

Employment Tax Compliance

2018-30-077 09/19/2018 Tax Administration and 

Compliance

The Commissioner, Small Business/Self-Employed (SB/SE) Division, should 

require employees to evaluate whether businesses are complying with 

determinations. Consider program changes and referrals to the Employment 

Tax Examination function as appropriate to increase business compliance 

with worker classification determinations.

IRS PCA Due: Oct-2019

Controls Continue To Need Improvement To 

Ensure That All Planned Corrective Actions 

For Security Weaknesses Are Fully 

Implemented And Documented

2018-20-066 09/20/2018 Information Technology The Chief Financial Officer should ensure that Internal Controls organization 

reviewers improve the development of their skillsets to obtain sufficient, 

appropriate evidence to provide a reasonable basis for their findings and 

conclusions. Part of the development could include attending audit evidence 

training courses offered by the Federal Government and the private sector.

IRS PCA Due: Sep-2019

Controls Continue To Need Improvement To 

Ensure That All Planned Corrective Actions 

For Security Weaknesses Are Fully 

Implemented And Documented

2018-20-066 09/20/2018 Information Technology The Chief Financial Officer should update the Internal Revenue Manual 

(IRM) to broaden the Audit Coordination and OAR offices auditing to include 

reviewing management's corrective actions to ensure that the PCAs are fully 

and appropriately implemented.

IRS PCA Due: Sep-2019

Controls Continue To Need Improvement To 

Ensure That All Planned Corrective Actions 

For Security Weaknesses Are Fully 

Implemented And Documented

2018-20-066 09/20/2018 Information Technology The Chief Financial Officer should update the retention period in the IRM for 

maintaining documentation with the JACs to align with the Treasury 

Department's retention period for maintaining supporting documentation in 

the JAMES.

IRS PCA Due: Sep-2019

Improvements Are Needed In The Withholding 

Compliance Program

2018-30-072 09/20/2018 Tax Administration and 

Compliance

The Commissioner, Small Business/Self-Employed Division, and the 

Commissioner, Tax Exempt and Government Entities Division, should work 

with Federal Government agencies that are not complying with the lock-in 

letters to advise them of the requirement to change withholding based on the 

letters they receive.

IRS PCA Due: Oct-2019

Improvements Are Needed In The Withholding 

Compliance Program

2018-30-072 09/20/2018 Tax Administration and 

Compliance

The Commissioner, Small Business/Self-Employed Division, should analyze 

the current selection criteria used by the WHCS to determine if the taxpayers 

identified for systemic lock-in letter issuance are the best use of limited 

resources. This would include potentially identifying taxpayers with multiple 

years of underwithholding and the percentage of inventory that includes 

nonfilers.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.

Improvements Are Needed In The Withholding 

Compliance Program

2018-30-072 09/20/2018 Tax Administration and 

Compliance

The Commissioner, Small Business/Self-Employed Division, should identify 

noncompliant employers and determine the appropriate actions to enforce 

Internal Revenue Code Section 3403 by holding employers that fail to 

withhold Federal income tax from the employees as instructed in the lock-in 

letters liable.

IRS PCA Due: Dec-2019

Forms, Instructions, Publications, And 

Procedures Need To Be Improved For Some 

Nonresident Aliens Eligible For Treaty-Based 

Income Exemptions

2018-30-074 09/20/2018 Tax Administration and 

Compliance

The Commissioner, Large Business and International Division, should 

consider updating the appropriate forms, instructions, and publications to 

clarify how nonresident aliens who do not file a Form 8233 with their 

employer are still able to claim the treaty exemption.

IRS PCA Due: Jan-2020

Forms, Instructions, Publications, And 

Procedures Need To Be Improved For Some 

Nonresident Aliens Eligible For Treaty-Based 

Income Exemptions

2018-30-074 09/20/2018 Tax Administration and 

Compliance

The Commissioner, Large Business and International Division, should 

increase outreach and education to withholding agents and nonresident aliens 

to improve their knowledge of the information reporting rules, improve the 

accuracy of information reporting, and reduce the number of erroneous tax 

returns.

IRS PCA Due: Jan-2020

The Internal Revenue Service Still Does Not 

Make Effective Use Of Currency Transaction 

Reports

2018-30-076 09/21/2018 Tax Administration and 

Compliance

The Director, Examination, Small Business/Self-Employed (SB/SE) Division, 

should establish formalized procedures for processing BSA Program referrals 

and begin formally tracking the time required to send referrals to the Field 

Exam Support Team.

IRS PCA Due: Dec-2019
Page 58 of 64

APPENDIX 3

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Inspector General for Tax Administration (TIGTA) Recommendations

Report Title Report Number Issue Date Audit Area TIGTA Recommendation Bureau/Office Implementation Status

Billions In Tip-Related Tax Noncompliance 

Are Not Fully Addressed And Tip Agreements 

Are Generally Not Enforced

2018-30-081 09/28/2018 Tax Administration and 

Compliance

The Commissioner, Small Business/Self-Employed Division, should develop 

a risk-based case selection methodology using historical statistics and data 

analysis to identify the highest risk tip examination cases on an annual basis. 

For example, the IRS could focus on taxpayers with projected unreported tips 

in a high dollar value. The cases could then be classified based on the 

updated prioritization of field resources available for tip examinations.

IRS PCA Due: Oct-2019

Billions In Tip-Related Tax Noncompliance 

Are Not Fully Addressed And Tip Agreements 

Are Generally Not Enforced

2018-30-081 09/28/2018 Tax Administration and 

Compliance

The Commissioner, Small Business/Self-Employed Division, should update 

the Internal Revenue Manual (IRM) to provide more specific criteria and 

examples of when to revoke a tip agreement if an establishment is 

substantially noncompliant with the commitments of the agreement and to 

provide more specific criteria and examples on how to perform compliance 

reviews, including the Form 8027 analysis of unreported tips. Provide 

employee training on the changes to the IRM.

IRS PCA Due: Oct-2019

Billions In Tip-Related Tax Noncompliance 

Are Not Fully Addressed And Tip Agreements 

Are Generally Not Enforced

2018-30-081 09/28/2018 Tax Administration and 

Compliance

The Commissioner, Small Business/Self-Employed Division, should use data 

analysis and sampling to monitor tip agreement compliance and identify 

taxpayers that need a compliance review. For example, the IRS could focus 

on the tip agreements with projected unreported tips with a high dollar value.

IRS PCA Due: Jan-2020

Billions In Tip-Related Tax Noncompliance 

Are Not Fully Addressed And Tip Agreements 

Are Generally Not Enforced

2018-30-081 09/28/2018 Tax Administration and 

Compliance

The Commissioner, Small Business/Self-Emplyoyed Division, should use a 

risk-based approach to more effectively prioritize the use of Field 

Examination resources for the NTRCP. The risk-based approach should 

prioritize higher risk work with the greatest impact to tip reporting 

compliance.

IRS PCA Due: Jan-2020

The Human Capital Office Administered The 

Drug Testing Of Employees In Testing 

Designated Positions In Accordance With 

Established Guidelines

2019-10-003 10/18/2018 Tax Administration and 

Compliance

The IRS Human Capital Officer and Chief Counsel should complete union 

negotiations to have bargaining unit employees in TDPs randomly tested for 

illegal drug use.

IRS PCA Due: Feb-2020

Taxpayers Generally Comply With Annual 

Contribution Limits For 401(K) Plans; 

However, Additional Efforts Could Further 

Improve Compliance

2019-10-002 10/25/2018 Tax Administration and 

Compliance

The Acting Commissioner, Tax Exempt and Government Entities Division, 

should identify and provide guidance to 401(k) plans that potentially allow 

taxpayers to exceed annual contributions limits.

IRS PCA Due: Jan-2020

Taxpayers Generally Comply With Annual 

Contribution Limits For 401(K) Plans; 

However, Additional Efforts Could Further 

Improve Compliance

2019-10-002 10/25/2018 Tax Administration and 

Compliance

The Commissioner, Small Business/Self Employed, should take actions to 

bring taxpayers who contribute more than the annual limit to multiple 401(k) 

plans into compliance with the law.

IRS PCA Due: Oct-2020

The Taxpayer Advocate Service Centralized 

Case Intake Program Needs Improvement To 

Provide Better Customer Service

2019-10-009 10/31/2018 Tax Administration and 

Compliance

The National Taxpayer Advocate should develop and implement a process to 

prevent callers from being disconnected from the CCI program at the end of 

the day.

IRS PCA Due: Jun-2020

The Taxpayer Advocate Service Centralized 

Case Intake Program Needs Improvement To 

Provide Better Customer Service

2019-10-009 10/31/2018 Tax Administration and 

Compliance

The National Taxpayer Advocate should develop and implement a staffing 

plan that will reduce the call wait times that taxpayers experience during peak 

call volume periods.

IRS PCA Due: Jun-2020
Page 59 of 64

APPENDIX 3

Good Accounting Obligation in Government Act Report for Fiscal Year 2021 Budget Justification Submission

Implementation Status of Treasury Inspector General for Tax Administration (TIGTA) Recommendations

Report Title Report Number Issue Date Audit Area TIGTA Recommendation Bureau/Office Implementation Status

The Taxpayer Advocate Service Centralized 

Case Intake Program Needs Improvement To 

Provide Better Customer Service

2019-10-009 10/31/2018 Tax Administration and 

Compliance

The National Taxpayer Advocate should develop and measure progress 

toward specific and quantifiable program goals for the CCI program that 

measure benefits to taxpayers, the TAS, and the IRS, such as increased 

customer satisfaction, reduced direct case time, or other measures of program 

impact.

IRS PCA Due: Jan-2020

The Taxpayer Advocate Service Centralized 

Case Intake Program Needs Improvement To 

Provide Better Customer Service

2019-10-009 10/31/2018 Tax Administration and 

Compliance

The Taxpayer Advocate should develop and implement a mandatory process 

whereby the TAS 1) records and summarizes specific reasons why calls 

received by intake advocates do not result in the creation of a TAS case and 2) 

provides formal feedback to the W&I Division on the frequency and reasons 

for inaccurate referrals made from the Wage and Investment (W&I) Division 

to the CCI program.

IRS PCA Due: Jun-2019. The 

Taxpayer Advocate office within 

IRS is in the process of obtaining 

TIGTA’s concurrence to close 

this recommendation. 

The Taxpayer Advocate Service Centralized 

Case Intake Program Needs Improvement To 

Provide Better Customer Service

2019-10-009 10/31/2018 Tax Administration and 

Compliance

The Taxpayer Advocate should update Internal Revenue Manual 13.3 and 

provide up-to-date guidance to Wage and Investment (W&I) Division contact 

representatives who staff the NTA toll-free line pertaining to current 

procedures for the CCI program.

IRS PCA Due: Jan-2020

The Solaris To Linux Migration Project Was 

Delayed And Needs Improved Governance

2019-20-008 12/06/2018 Information Technology The Chief Information Officer should ensure that the procurement of 

hardware, service, and support includes a well-developed plan, process for 

utilization, and reasonable timelines.

IRS PCA Due: Mar-2021

Results Of The 2018 Filing Season 2019-40-013 12/19/2018 Tax Administration and 

Compliance

The Commissioner, Wage and Investment Division, should establish 

processes to use its math error authority to deny all e-filed and paper AOTC 

claims for which the taxpayer does not provide the institution EIN for each 

student claimed on the return.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.

Results Of The 2018 Filing Season 2019-40-013 12/19/2018 Tax Administration and 

Compliance

The Commissioner, Wage and Investment Division, should expand the IP PIN 

opt-in program to allow ITIN holders who are not automatically issued an IP 

PIN the option to obtain an IP PIN. The IRS should notify these individuals 

of the option to obtain an IP PIN and provide instructions on how to do so.

IRS On Hold. Agreed with the 

recommendation. Due to 

funding constraints, the 

recommendation is put on hold.

Fiscal Year 2019 Biannual Independent 

Assessment Of Private Collection Agency 

Performance

2019-30-018 12/31/2018 Tax Administration and 

Compliance

The Director, Collection, Small Business/Self-Employed Division, should 

include payment arrangements of less than 60 months in quality reviews to 

ensure that the new calculator is working properly.

IRS PCA Due: Oct-2019

Fiscal Year 2019 Biannual Independent 

Assessment Of Private Collection Agency 

Performance

2019-30-018 12/31/2018 Tax Administration and 

Compliance

The Director, Collection, Small Business/Self-Employed Division, should 

revise the PPG for payment arrangement options to be consistent with IRS 

policy for taxpayers who owe less than $50,000.

IRS PCA Due: Oct-2019
APPENDIX 4

Good Accounting Obligation in Government (GAO-IG) Act Report for Fiscal Year 2021 Budget Justification Submission

Reconciliation with Treasury IGs' Semi-annual Report (SAR) to Congress

GAO-IG Act Report SAR (September, 2019 issue)

Reporting Criteria As required by the GAO-IG Act, this report includes 

recommendations that remained unimplemented for one year or 

more from the budget justification submission date. This date 

for the fiscal year 2021 budget is estimated at 01/31/2020, 

therefore this report includes recommendations that remained 

unimplemented since their issuance on or before 01/31/2019.

As required by the Inspector General Empowerment Act of 2016, SAR 

includes recommendations that remained unimplemented for six months 

or more from the SAR reporting end date. The September 2019 SAR 

had a reporting end date of 09/30/2019, and therefore includes 

recommendations that remained unimplemented since their issuance on 

or before 03/31/2019.

System of Records Treasury’s Joint Audit Management Enterprise System Treasury’s Joint Audit Management Enterprise System 

OIG A total of 85 recommendations with 37 unimplemented, and 48 

implemented and awaiting auditor verification

A total of 90 unimplemented recommendations 

TIGTA A total of 87 unimplemented recommendations A total of 106 unimplemented recommendations 
Page 61 of 64

Appendix A: Glossary of Abbreviations

Abbreviation Description

ACA Affordable Care Act 

ACS Automated Collection System 

ACTC Additional Child Tax Credit

AEHR All Events History Report 

AFR Agency Financial Report

AMC Audit Management Checklist 

AMS Account Management Services

ANMF Automated Non-Master File

AO Approving Official 

AOTC American Opportunity Tax Credit

ARC Administrative Resource Center

ASFR Automated Substitute For Return 

ASM Assistant Secretary for Management

ATAT Abusive Tax Avoidance Transactions 

ATO Authority to Operate

BEP Bureau of Engraving and Printing

BSA Bank Secrecy Act

BSA/AML Bank Secrecy Act/anti-money laundering 

CAF Centralized Authorization File 

CAP Compliance Assurance Process

CCI Centralized Case Intake

CDFI Community Development Financial Institutions 

CFIUS Committee on Foreign Investment in the United States

CFO Chief Financial Officer

CFS Consolidated Financial Statements of the U.S. Government 

CI Criminal Investigation

CIO Chief Information Officer

CJ Congressional Justification

CMS Centers for Medicare & Medicaid Services

CO Certifying Officer

COTR Contracting Officer's Technical Representative 

CSIP Cybersecurity Strategy and Implementation Plan 

DASHR/CHCO Deputy Assistant Secretary for Human Resources and Chief Human Capital Officer

DATA Act Digital Accountability And Transparency Act

DCAA Defense Contract Audit Agency

DCFO Deputy Chief Financial Officer 

DCOI Data Center Optimization Initiative

DHS Department of Homeland Security

DO Treasury Departmental Offices

Dodd-Frank Act Dodd-Frank Wall Street Reform and Consumer Protection Act

DOL Department of Labor

e OPF electronic Official Personnel Folders

EA Enterprise Architecture 

EEFax Enterprise e-Fax 

EGRPRA Economic Growth and Regulatory Paperwork Reduction Act

EIN Employer Identification Number

EITC Earned Income Tax Credit

EPA Environmental Protection Agency
Page 62 of 64

Appendix A: Glossary of Abbreviations

Abbreviation Description

EUSS End User Systems and Services 

FATCA Foreign Account Tax Compliance Act 

FATF Financial Action Task Force

FBAR Report of Foreign Bank and Financial Accounts 

FCD-1 Federal Continuity Directive 1 

FDIC Federal Deposit Insurance Corporation

FFATA Federal Funding Accountability and Transparency Act 

FFI Foreign Financial Institution

FinCEN Financial Crimes Enforcement Network

Fiscal Service Bureau of the Fiscal Service

FISMA Federal Information Security Modernization Act 

FITARA Federal Information Technology Acquisition Reform Act

FMSS Facilities Management and Support Services

FMU Financial Market Utility

FMV Fair Market Value

FPDS-NG Federal Procurement Data System-Next Generation 

FSOC Financial Stability Oversight Council

FUTA Federal Unemployment Tax Act 

GAAP Generally Accepted Accounting Principles

GAO U.S. Government Accountability Office

GPC Government Purchase Card 

GPRA Government Performance and Results Act

GPRAMA GPRA Modernization Act

GSA General Services Administration

HAMP Home Affordable Modification Program 

HCTC Health Coverage Tax Credit 

HFA Housing Finance Agency

HHS Department of Health and Human Services

HUD Department of Housing and Urban Development 

HVA High Value Assets

IC Intelligence Community

IC PKI Intelligence Community Public Key Infrastructure 

ICMM International Compliance Management Model

ICO Input Correction Operation

ICT Image Control Team

IDRS Integrated Data Retrieval System 

IDS Inventory Delivery System 

IDT Identity Theft

IG Inspector General

IGA Intergovernmental Agreement 

IMF Individual Master File 

IP PIN Identity Protection Personal Identification Numbers

IPIA Improper Payments Information Act 

IRA Individual Retirement Account

IRC Internal Revenue Code

IRM Information Resources Management 

IRM Internal Revenue Manual

IRS Internal Revenue Service
Page 63 of 64

Appendix A: Glossary of Abbreviations

Abbreviation Description

ISAC Information Sharing and Analysis Center 

ISCP Information System Contingency Plan

IT Information Technology

ITIN Individual Taxpayer IdentificationNumber 

JAC JAMES Audit Coordinator

JAMES Joint Audit Management Enterprise System

KISAM Knowledge Incident/Problem Service Asset Management 

KISAM-AM Knowledge Incident Problem Service Asset Management - Asset Management (module) 

LAN Local Area Network

LB&I Large Business and International division

LDC Lead Development Center 

LIHTC Low-Income Housing Tax Credit

LLC Limited Liability Company

MeF Modernized e-File processing system

MHA Making Home Affordable 

Mint The United States Mint

MOU Memorandum of Understanding 

MSSS Mainframes and Servers Services and Support 

MYIP Multiyear Implementation Plan

NAP National Account Profile

NIST National Institute of Standards and Technology

NIST SP National Institute of Standards and Technology Special Publication

NMF Non–Master File system

NMTC New Markets Tax Credit

NRC Nuclear Regulatory Commission

NRP National Research Program 

NSS National Security Systems

NTRCP National Tip Reporting Compliance Program

OAR Outreach, Assessment, and Reporting

OBT Office of Budget and Travel

OCC Office of the Comptroller of the Currency

OFAC Office of Foreign Assets Control 

OFR Office of Financial Research

OIA Office of Intelligence and Analysis

OIG Office of the Inspector General

OMB Office of Management and Budget

OPM Office of Personnel Management

OSP Office of Security Program

OSSP Office of Special Security Programs 

P&E Property and Equipment 

PAC Program Action Case

PBGC Pension Benefit Guaranty Corporation 

PCA Planned Corrective Action

PCLIA Privacy and Civil Liberties Impact Assessment

PDS Personal Identity Verification Data Synchronization

PII Personally Identifiable Information

PMO Program Management Office 

PN Plan Number
Page 64 of 64

Appendix A: Glossary of Abbreviations

Abbreviation Description

POA&M Plan of Action and Milestones

PPACA Patient Protection and Affordable Care Act

PRISM Preparer Risk Identification and Selection Model 

PTC Premium Tax Credit

QRM Qualified Residential Mortgage

RAAS Research, Applied Analytics, And Statistics

Recovery Act American Recovery and Reinvestment Act

RESTORE Act Resources and Ecosystems Sustainability, Tourist Opportunities, and Revived Economies of the Gulf 

C t St t A t RFA Regulatory Flexibility Act

ROI Return On Investment

RRP Return Review Program

RTS Real-Time System

SA&A Security Assessment and Authorization

SAM Software Asset Management

SAO Senior Accountable Official 

SAR Semi-annual Report to Congress

SB/SE Small Business/Self-Employed division

SBA Small Business Administration

SBU Sensitive But Unclassified

SCC Sector Coordinating Council

SCC IRS Service Center Campus

Schedule UTP Schedule UTP, Uncertain Tax Position Statement

SCRO Security RegulatoryCompliance Operations

SLA Service Level Agreement

SOP Standard Operating Procedures

SSA Social Security Administration

SSN Social Security Numbers

SSP System Security Plan

TAS Taxpayer Advocate Service 

TD P Treasury Directive Publication

TDP Testing Designated Position

TFFC Office of Terrorist Financing and Financial Crimes

TFI Office of Terrorism and Financial Intelligence

TIGTA Treasury Inspector General for Tax Administration

TIN Taxpayer Identification Number

TIN Taxpayer Identification Number

TSS Telecommunications Systems and Support 

UIL Uniform Issue List 

UPS U.S. Persons

UWR Unified Work Request

VA Department of Veterans Affairs

VITA Volunteer Income Tax Assistance 

W&I Wage and Investment

WAN Wide Area Network

WebTA Web Time and Attendance

WHCS Withholding Compliance System