Taxpayer Service: State Experiences Indicate IRS Would Face Challenges Developing an Internet Filing System with Net Benefits
Released: 2007-04-12T00:00:00

Letter

Background

Individual federal taxpayers have several options for preparing and filing their returns as shown in figure 1.

Using the traditional method, taxpayers or their preparers prepare paper returns and then file the returns by mailing them to one of IRS’s submission processing centers. At the submission processing centers, paper returns are opened and sorted, checked for completeness, numbered with an identifying code, manually transcribed into IRS’s computerized databases, and checked for accuracy. Transcribing paper returns inevitably introduces errors that then must be resolved by IRS and taxpayers. IRS devoted 2,798 staff years to paper processing in 2006. About 58 million taxpayers submitted their returns on paper in 2006.

For a number of years, some taxpayers or preparers have used tax preparation software to prepare returns electronically. However, after returns have been electronically prepared taxpayers cannot transmit them directly to IRS in order to electronically file them. Instead, only paid tax preparers and tax preparation software companies that IRS has designated as electronic return originators (ERO) can transmit tax returns electronically to IRS. These companies may charge taxpayers for the services they provide, including electronic filing. Taxpayers who prepare their returns on their home computer and then use the electronic filing option are actually sending their returns electronically to an ERO. The EROs typically bundle returns from many taxpayers and then electronically forwards them to IRS. IRS conducts suitability checks of applicants who are applying to become EROs. These checks may include checking the applicants’ criminal background, credit history, and tax compliance. In 2006, approximately 72 million returns were submitted electronically. As shown in figure 1, electronic filing eliminates a number of steps necessary for processing paper returns.

In 2002, IRS entered into an agreement with the Free File Alliance, a consortium of tax preparation companies, to provide on-line electronic preparation and filing to eligible taxpayers at no charge. Taxpayers can access Free File on IRS’s Web site, which provides links to the Web sites of the Free File Alliance companies. Taxpayers prepare their returns using free software on the companies’ Web sites and then electronically file their returns from the Web sites. In 2005, eligibility was restricted to taxpayers with incomes of $50,000 or less. The number of tax returns filed through Free File for filing season 2006 was about 4 million. As part of the Free File agreement, IRS agreed not to compete with the Alliance members by providing free, on-line tax return preparation and filing services to taxpayers on its Web site.

Some taxpayers electronically prepare their returns but they choose to print and mail the tax return to IRS. These taxpayers are known as “v- coders” because IRS codes these returns with a “v” for processing purposes and to track separately from other paper filers. As shown in table 1, out of the 58.3 million paper returns submitted last year, approximately 42 million were v-coded returns. V-coders are an attractive target for conversion to e-filing because these taxpayers already have access to computers and electronically prepare their returns, both prerequisites for electronic filing.

Until 2005, federal taxpayers had the option to Telefile. Telefile allowed taxpayers with simple returns to file electronically via telephone. This service was discontinued in 2005 because of declining usage and relatively high costs.

Very generally, I-file is a Web site application that allows users to prepare and submit information to an agency electronically. Since the late 1990s, almost half of the states have offered an I-file service to taxpayers. Currently, 20 states and the District of Columbia currently offer this service to taxpayers. Three states have discontinued an I-file service for taxpayers. In addition, several foreign tax agencies offer I-file services. Also, some federal agencies offer nontax I-file services that, for example, allow users to apply for benefits on-line. Individuals applying for federal student aid, agricultural grants and loans, and veterans’ benefits may choose to use the agencies’ Web sites to prepare and submit applications rather than using paper to prepare forms and the mail to submit forms. For example, since 1997, the Department of Education has offered individuals an I-file service for preparing and submitting the Free Application for Federal Student Aid.

Figure 2 shows the growth of federal electronic filing since 1997. According to IRS officials, it is getting harder to convert taxpayers to electronic tax return filing since those who might convert most readily have already done so.

Electronic filing has also grown at the state level, as shown in figure 3. Several states imposed electronic filing mandates on tax preparers who meet certain criteria, such as filing 100 state tax returns or more, which contributed to increased electronic filing. Moreover, state taxing authorities are using technologies such as I-file and 2-D barcode to enable more efficient processing of returns.

Within IRS, the Wage and Investment Division (W&I) and Modernization and Information Technology Services (MITS) have a role in electronic filing. W&I’s Electronic Tax Administration (ETA) administers IRS’s electronic filing programs and is responsible for receiving and processing tax returns electronically filed through EROs by taxpayers and preparers. MITS has the information technology (IT) and programming staff that develops and maintains IRS’s electronic filing systems, including hardware and software.

IRS currently has a project underway, Modernized e-File (MeF), to replace its current electronic filing technology with a modernized, Internet-based electronic filing application. Successful implementation of the MeF system will give IRS increased capability to accept electronically filed returns (including individual returns) from EROs. Neither the current e-filing technology nor MeF does allow direct electronic filing by individuals.

I-file Systems Use Two Main Technologies and Offer a Range of Features and Taxpayer Eligibility Requirements

I-file systems have a range of design options. Two main technologies used to collect data from taxpayers exist: PDF fillable form technology often looks like the paper version of a form and Web page technology is interactive and prompts the user to respond to preformatted questions. Figure 4 illustrates the variety of features available with either technology. Tax agencies that have I-file systems also established a variety of eligibility requirements for taxpayers.

PDF Fillable Forms

PDF fillable form technology can closely resemble or reproduce the paper version of the form. This is one technology often used when agencies want to show users the paper version of a form. The PDF fillable forms are accessed through the agencies’ Web site, but users need additional software (PDF readers are available for free on the Internet) to view and fill in the fields.

The U.S. Department of Agriculture (USDA) has offered PDF fillable forms with direct submission to support USDA’s Rural Development eForms System since 2002. USDA initially offered 200–300 on-line forms but later expanded the system to about 1,500 eForms for the public and USDA employees to prepare and submit forms directly on USDA’s Web site. Individuals may use the agency’s Web site to apply for a number of programs such as agriculture conservation, crop disaster, rural water, and farm loans. Users of USDA’s eForms can access the system with and without a user account. If a user creates an account with USDA, the user may save forms on USDA’s Web space and electronically submit the forms to the agency via the agency Web site. With an account, users may also bundle several forms together for submission. Once the forms are submitted electronically, the user receives an instant confirmation code, which users may reference if any questions arise. Additionally, users may use the account to view the status of the forms, and resubmit any form that may need corrections. Figure 5 shows a USDA fillable form with save and submission features.

Without an account, users can search and download forms from the Web site, fill the forms in, and print the forms. However, users cannot submit forms electronically. USDA’s eForms provide basic instructions, like the paper version, and more detailed instructions are provided in separate PDF documents. After the user completes the form, it may be saved on a personal computer or printed and mailed to the agency.

IRS currently provides PDF fillable form versions of some tax return forms and schedules. These forms can be downloaded to a home computer, filled in, printed, and mailed back to IRS. They cannot be filed electronically with IRS and, therefore, are not an I-file option.

Web Pages That Allow Data Entry

Another technology uses Web pages (HMTL),an interactive, ease-of-use Web site feature, containing checkboxes, option lists, text boxes, and buttons that allow users to respond to preformatted questions. Web pages do not always resemble the paper version of the form but collect similar information. Because these Web pages can be viewed using a regular Web browser, users usually do not need additional software.

Similar to the PDF fillable forms, Web pages allow the agency to choose the features offered to the user. Some agencies offer fewer features to users. For example, both Utah’s TaxExpress and California’s CalFile systems allow users to log-in/create an account, perform calculations, link to other forms and publications, and submit directly to the agency. Other agencies have more sophisticated systems which offer more features. For example, United Kingdom’s Self Assessment system allows users to save their partially completed forms and return to the system at a later time, edit the forms, and view any changes made.

Another example of a more sophisticated system with multiple features is Maryland’s I-file. Maryland offers features such as account access, calculations, and hyperlinks to other forms and publications. It also allows users to save work and return later and view prior years’ returns. The Maryland system also prepopulates some of the taxpayer’s biographic information and allows users to check the status of their current return. Figure 6 shows a computer screen picture/image of Web page technology with calculations and hyperlinks to help features from Maryland’s I-file system.

Eight States We Profiled Offer I-file Systems with a Variety of Features and Taxpayer Eligibility Requirements

Table 2 describes the I-file systems we profiled in eight states. As mentioned, state tax agencies offered a range of features such as calculations and save and return. Some states restricted eligibility by income, residency requirements, or number of itemized deductions.

Appendix I provides additional information about each state’s I-file system such as the extent to which the state used contractors to develop and operate the system. Some systems do not operate on computer hardware owned by the states, but instead operate on hardware owned by contractors.

State Agencies’ I-file Benefits and Costs Have Been Relatively Modest

Both the benefits states received from their I-file systems and costs of developing and operating them have been relatively modest. Based on the available information, it is unclear whether the benefits to the states were greater than their costs.

State I-file Systems Reduced Paper Filing, but the Magnitude of the Benefits Was Limited by Low Usage

According to officials in five of the eight states we profiled, state I-file systems generated benefits (before subtracting the costs of system development and operation) by increasing e-filing and reducing paper filing. However, the benefits were limited by the low usage. As shown in table 3, I-file users as a percentage of total filers ranged from less than 1 percent to just over 5 percent. Only three states gave us estimates of the number of taxpayers eligible to I-file. Pennsylvania had 20 percent of eligible taxpayers I-filing in 2006 while California and South Carolina both had less than 2 percent. While Pennsylvania had 20 percent of eligible taxpayers using I-file, GAO is interpreting this as a low usage rate since the state instituted the system in 2000.

The benefits to state tax agencies included reducing the costs of processing paper returns plus related costs due to correcting math and transcription errors and contacting taxpayers about such errors. The magnitude of the benefits to tax agencies depends on the savings per return and the number of taxpayers converted from paper to electronic filing. Returns prepared and filed through I-file that would have otherwise been electronically filed do not generate significant benefits in the form of reduced costs for the tax agencies. Only returns converted from paper to electronic filing generate benefits in terms of cost savings for the tax agency.

Three of the tax agencies we profiled gave us estimates of how much converting a return from paper to electronic filing saved them in processing costs. California estimated that each taxpayer converted from paper to e-filing saved the state about $1.00 in processing costs per return. Pennsylvania officials reported it costs about $4.72 to process paper returns, while electronically filed returns costs them only $1.25—a cost savings of $3.47 per return. One of the largest cost savings on a per return basis was reported by Kansas where agency officials reported saving $11 per electronic return filed. These savings reflect operations in each state and may not indicate savings that other states or IRS might achieve.

State agency officials provided some information about savings beyond reduced processing costs but could not provide dollar estimates of the savings. Kansas officials said the state had less than a 1 percent math error rate for I-filed returns compared to a 17 percent rate for paper returns. California officials reported a decrease in math and transcription errors. The state agency reported that fewer contacts with taxpayers can benefit the agency and yield a savings from fewer notices. Maryland officials said they have less need to contact taxpayers who I-file.

The number of taxpayers converted from paper filing to electronic filing due to state I-file systems is relatively modest. In an evaluation conducted 3 years after CalFile was implemented, California estimated that as many as 67,000 I-filers were new e-filers in 2004. That number is less than 1 percent of eligible filers in California the same year. The other tax agencies we profiled could not document how many returns were converted from paper to electronic filing as a result of I-file, but the number has to be relatively small because the total number of I-file users is relatively small.

Low usage may be due to a number of reasons, including little marketing and the lack of integration with the federal tax system. Officials in five states said the amount budgeted for marketing was minimal. Pennsylvania reported allocating $20,000 to $40,000 for marketing during calendar years 2000 to 2002. The other tax agencies did not provide dollar amounts. Using different methods to prepare and file state and federal returns can be an inconvenience to taxpayers. Many tax preparation software packages offer the convenience of integrating federal and state tax return preparation. Much of the required data has to be entered only one time and is automatically transferred from the federal to the state tax return. Users of state I-file systems would have to prepare their federal tax return using one preparation method and then learn a second, to prepare their state return.

Foreign tax agencies with I-file systems and federal agencies with on-line application systems reported higher usage rates than the state agencies we profiled, as shown in table 4. Reasons differed for the higher usage rates among foreign tax agencies and federal agencies. French officials offered a financial incentive of 20 euros (approximately $26) in 2005 to French taxpayers who filed tax returns on-line and paid taxes electronically. An official with France’s General Tax Directorate said the rebate increased usage to such a degree the system was overloaded and officials needed to extend the filing deadline. One federal agency attributed high usage to the type of user the agency serves. An official with the Department of Education said usage of the on-line financial aid system was high, due in part, to the target population of students who are Internet-savvy.

In addition to the benefits to the tax agencies, state I-file systems also generated benefits for users. Taxpayers who convert from paper to electronic filing because of the availability of I-file received the benefits of electronic filing, such as faster refunds. Compared to paper filing, Utah’s TaxExpress I-file system reduced return processing time to 4-5 days from 8-10 days and generated faster refunds. South Carolina’s SCnetFile! users received direct deposit of refunds within 9-10 days, paper checks were processed within about 3 weeks, according to agency officials. Some taxpayers who convert from paper may benefit by not having to respond to notices for math errors, by having lower compliance burdens, and by preferring electronic confirmation that the tax agency received their return. A benefit to some taxpayers using I-file is saving on electronic filing fees. Taxpayers who were charged electronic filing fees and convert to I-file would save. Taxpayers, who electronically file for free, such as users of the Free File program, would not save on fees. Another benefit to some taxpayers using state I-file systems is the security of not having to file through a third party such as an ERO. However, as was noted earlier and shown in appendix I, some state I-file systems are operated by contractors on the contractors’ computer hardware.

Table 5 compares some of the advantages and disadvantages of the various methods of preparing and filing federal tax returns from a taxpayer’s perspective.

Available Information Indicates That I-file Costs Were Relatively Modest Because States Limited Features, Eligibility, and Capacity Needs

The cost data we were able to gather from the state tax and federal agencies we profiled, while incomplete, implies that costs were relatively modest. No state tax agency had complete, documented data on the costs of developing their I-file systems. In many cases, I-file costs were not tracked separately from department-wide activities. No state tax agency had available data on costs such as management planning and conceptualization or contractor oversight. However, some state tax agencies did have estimates for large portions of their I-file costs, such as systems development or operating costs, as shown in table 6.

As already noted, state tax agencies varied in the extent to which they used contractors or in-house staff to develop or operate I-file systems. Three states profiled-Indiana, Kansas, and Utah-used a contractor and relied almost wholly on the contractor to provide I-file services. The software and servers (computer hardware) are owned and operated by the contractors. Some taxpayer support for individuals, including technical help desk assistance, is provided by the contractor as well. Other states used a contractor to develop the system, but the state owned and operated the server. Some states, such as California and Maryland, primarily used in-house staff to develop and operate their systems. In these states, taxpayers prepared returns on state-owned servers.

Available data on total I-file costs show costs are a small percentage of state tax agencies’ budgets. For example, California spent just over $700,000 to develop and operate CalFile from 2003 to 2005—less than 0.1 percent of the tax agency’s annual budget. Pennsylvania’s pa.direct.file annual operating cost of $125,000 is less than 0.1 percent of the Revenue Department’s 2006 budget of $176 million. For states that primarily used contractors, data on specific types of costs are not available because many types of costs are covered by the fee per return charged by contractors. We did not verify cost information provided by state agencies or contractors. While the state cost data are incomplete, the data are consistent with what we learned about development and operating costs at USDA and the Department of Veterans Affairs.

The available data also show costs are relatively modest when calculated per tax return. Three states that relied heavily on a contractor were charged $0.75 per return or $1.00 per return to develop and operate I-file systems, as shown in table 6. Based on the data provided, we calculated Pennsylvania’s I-file average costs per return as $0.94 for 2000 to 2006, and California’s average costs per return as $2.30 for 2003 to 2005. These costs per return are relatively modest compared to what the states told us about their costs for processing paper returns. For example, Pennsylvania officials said it cost $4.72 per return to process a paper return.

Several factors contributed to keeping I-file costs relatively modest. Six of the eight state agencies we profiled limited eligibility. Three states developed their system incrementally and increased eligibility over time. As shown in table 2, some states restricted eligibility by income, residency requirements, or number of itemized deductions. States also varied on the extent to which they offered system features, such as the ability to save a partially completed return and the extent to which certain information can be automatically filled in on the form using previous years’ returns. By limiting eligibility and features, agencies can limit certain costs, such as software development and testing, that do not change as the number of users changes (fixed costs). Restricting the eligibility and features also has some effect on costs that do depend on the number of system users (variable costs), such as computer hardware and help desk assistance. Variable costs for purchases of hardware and telecommunications to support the system can also increase if system features become more sophisticated and if the system allows users to file more complex returns.

Another factor that contributed to modest costs was that contracts between states and contractors covered the development and operation of computer systems that provided multiple services, not just tax services. For example, a contractor’s representative told us the contractor may not recoup all its costs for I-file with the fees charged per tax return. Instead, the costs may be recouped from other services provided to the state.

One other factor keeping costs modest was the limited number of anticipated users. As discussed previously, the number of users in all eight states we profiled was less than 6 percent of all taxpayers. Low usage also affects variable costs for purchases of system hardware and telecommunication services. Several states told us that they were able to mitigate additional capacity costs by building upon existing systems hardware. As reported in their feasibility report, California officials planned to build the CalFile system using the existing technical environment and noted that no additional software, hardware, or licenses would need to be procured. It was expected that all project expenditures would be for staff costs only. One contractor indicated that additional capacity was available to support increased usage, if needed, from other existing servers. Some states we profiled did not make significant changes to their current levels of taxpayer support because of the low usage rates. For instance, Maryland’s taxpayer service group provided I-file training to the current staff but did not have any need to hire additional staff.

Whether States Realize Benefits Greater Than Costs from Their I-file Systems Is Unclear

In all states profiled, whether benefits are greater than costs is unclear for two reasons. As previously noted (1) data on benefits and costs was incomplete and (2) based on available data, both benefits and costs were modest.

Although incomplete, the available data combined with the decision by three states to discontinue their systems raise the possibility that in at least some states the benefits were less than costs. According to officials in two of the three states that discontinued their I-file systems, the benefits did not appear greater than costs and the system was not providing a good return on their investment. One agency official reported experiencing low usage and high costs. Officials with Iowa’s Department of Revenue said the state had hoped to see major growth in electronic filing usage by introducing an I-file system, yet the system use peaked at 22,815 I-filed returns in 2004. Iowa officials estimated the system was costing about $7.00 per return. Like Iowa, Arkansas discontinued its I-file services. According to a state official, Arkansas’s I-file system operated for 5 years beginning in tax year 2000 and processed a total of 5,149 returns. The highest usage was in 2005, with only 1,382 returns processed.

Another example of a state in which the benefits may be less than the costs, based on reported information, is California. A study of the CalFile system revealed California overestimated benefits, expecting 400,000 users in 2004 but getting 110,000. Further, the study highlighted that California underestimated costs with development costs expected to be $304,538 but coming in at $511,797. California officials estimated the agency saves approximately $1.00 per return in processing costs by converting paper returns to electronic returns. In 2004, California estimated 67,000 filers converted to electronic filing, which would have saved the agency $67,000. In the same year, California reported spending $256,362 on CalFile for development and operating costs. Consequently, based on reported information, benefits appear less than costs. However, additional benefits could have been realized from decreased math errors, for example, but the amount of such benefits is not known. California officials told us that CalFile may still be beneficial to the state because it provided another method of filing.

Pennsylvania estimates show the benefits of its I-file system could exceed costs. Pennsylvania estimated $3.47 per return in cost savings for processing and administrative costs associated with converting paper to electronic filing. Between tax year 1999 and 2005, a total of 1,362,867 taxpayers used the I-file system. Pennsylvania did not provide an estimate of the number of I-file users that converted from paper. However, if 28 percent of users converted from paper to e-filing, Pennsylvania would break even. If more than 28 percent converted, Pennsylvania could realize a net benefit.

Achieving a Net Cost Savings for IRS Depends on the Cost of Developing the System and the Number of Paper Filers Converted

Providing federal taxpayers with an I-file system would be a new service for which IRS would incur new costs. Whether the additional costs of the new program could be offset by reduced costs from processing fewer paper returns depends on a number of factors, such as the costs of developing and operating the system and number of taxpayers converted from paper to I-file.

Providing I-file Would Be a New Service with New Costs for IRS That Could Be Higher Than States’ Costs

I-file would be a new service that IRS would provide for taxpayers. To develop the new service, IRS would have to (1) create or procure return preparation software for IRS’s Web site and (2) extend direct e-filing to individuals, in which the return would be routed into the current stream of electronically filed returns coming in from EROs.

IRS’s fixed costs for I-file could be higher than the fixed costs of the states we profiled for several reasons. Currently, IRS’s Web site is mostly informational, meaning taxpayers can obtain information from IRS but they cannot submit information to IRS’s tax return databases. The information that taxpayers can obtain includes instructions, downloadable forms, and refund status. Developing an I-file system would require IRS to develop a transactional Web site, where taxpayers could enter information that would be submitted to IRS’s tax return databases. Transactional Web sites require more security and other features not necessary for an informational Web site.

Some of the states we profiled had transactional Web sites in place before they developed their I-file systems. Those states included Kansas, California, Indiana, and Utah. To provide I-file, IRS would need to incur the costs of developing a transactional capability.

Other factors that could cause IRS’s fixed costs to differ from the states’ fixed costs include the relative complexity of the federal tax system, the types of taxpayers who are eligible, and the features of the I-file system, such as memory. The federal income tax system is more complex than states’ tax systems, which generally piggyback on the federal return. For example, the federal Form1040 for tax year 2006 contains 77 lines and can require up to 41 other forms, schedules, or worksheets to complete, while Maryland’s Form 502 contains 52 lines (starting with federal adjusted gross income) and can require only 7 other forms, schedules, or worksheets to complete. IRS could limit fixed costs by limiting taxpayer eligibility the way some states did. Limiting eligibility to more simple forms, such as the federal Form1040 EZ, would reduce the complexity of I-file software. Similarly, the features offered on an I-file system would affect the complexity of the software. Features such as save and return and auto- populating can require additional memory and potentially increase costs.

IRS’s variable costs for an I-file system could also be higher than the states’. As previously noted, many of the states we profiled had low variable costs for computer hardware and taxpayer support because they were able to make use of existing capacity, either inside the tax agency or at other state agencies. Several states we profiled said that if their usage rates were significantly higher than current rates, they would incur additional costs to increase capacity. According to IRS officials, IRS does not have excess capacity that could be used to provide I-file services to taxpayers. As a consequence, IRS’s variable costs per return for I-file services could be higher than the states’.

Net Cost Savings Depends on the Number of Paper Filers Converted

The number of paper filers who convert to electronic filing can have a significant impact on the overall cost savings IRS could achieve by operating I-file. IRS data show, each paper return that is processed cost an estimated $2.65 per return in 2003, while each electronic return cost an estimated $0.29, resulting in an estimated cost savings of $2.36 per return processed electronically. However, we cannot independently verify this estimate and its basis is unclear because IRS’s cost accounting system is not yet able to support preparation of such cost estimates.Additionally, other costs may be reduced by electronic filing including costs associated with math errors. Math errors on paper returns may be due to taxpayer error or IRS transcription errors. Both can result in notices being sent to taxpayers and phone contacts with taxpayers. Both types of errors are reduced by electronic filing.

IRS could achieve a net cost savings if the costs saved by reduced paper processing were greater than the costs incurred from developing and operating an I-file system. The key to IRS achieving a net cost savings depends on the number of individuals converted from paper to electronic filing and the savings per return (estimated to be $2.36 per return by IRS). I-file users who previously electronically filed do not generate such savings. In 2006, 58.3 million tax returns (45 percent of all tax returns) were filed on paper. Any savings from reduced paper processing would have to be netted against the cost of the I-file system to determine whether cost savings were realized.

The extent to which federal paper filers would convert to an I-file system is uncertain. According to respondents of an IRS Oversight Board survey, some taxpayers reported not feeling comfortable filing taxes electronically. These taxpayers reported not having confidence that the Internet is secure or that their privacy is protected. These taxpayers also cited other reasons including: the Internet was too complicated, or the taxpayer liked to use paper method or they didn’t want to pay the electronic filing fee. An I-file system would address some of these taxpayer concerns but not all of them. For example, if taxpayers’ security and privacy concerns are focused on third party transmitters, then an I-file system might mitigate the concerns.If the concerns are more general and apply to the Internet as a whole, then an I-file system (only accessible over the Internet) may not mitigate the concerns. Additionally, IRS’s Free File service, which may be the existing service most similar to I-file had 4.0 million users (about 3 percent of total taxpayers and 4 percent of eligible taxpayers) in 2006. This usage rate is an indication of the challenge of converting some taxpayers to electronic filing.

The 13.6 million v-coders who self-prepared are an attractive target for an I-file program. Because v-coders prepare their return on a computer, they are presumably more comfortable with computers and may be more willing to try I-file than taxpayers who did not use a computer to prepare their returns. Because they file on paper, converting them to I-file results in reduced paper processing costs. V-coded returns prepared by paid preparers may be less susceptible to convert to I-file because these paid preparers have concerns about existing e-file options. Several of the states we profiled emphasized the importance of defining the target population when designing an I-file system. Whether such a narrowly defined population, as v-coders who self prepare, could be successfully targeted at the federal level is unclear.

In addition to the net savings that could be realized from I-file, another factor that should be considered is whether IRS has the systems management capability needed to develop such a program. For well over a decade, IRS has been involved in a multibillion dollar effort to modernize its information systems. While IRS has made noteworthy progress improving its systems management capability, it has had a history of cost increases and schedule delays that led us to designate systems modernization as a high-risk area in 1995. Those cost increases and schedule delays were due, at least in part, to deficiencies in various management controls and capabilities that have not yet been fully corrected. In 2003, we noted that IRS had made significant progress in establishing management controls and foundational systems architecture.However, systems modernization remained at risk because the scope and complexity of modernization activities was increasing. In 2005, we reported that balancing the scope and pace of modernization activities with IRS’s ability to manage them remained a challenge. IRS has made further progress since 2005 addressing concerns about systems management. However, critical management controls and capabilities have still not yet been fully implemented or institutionalized. Before proceeding with I-file, IRS would need to consider the impact of the program on its existing portfolio of systems development projects and the impact of the program on its current modernization vision and strategy. This would entail IRS determining whether it has the management capabilities to take on this new project and what, if any, ongoing and planned programs would need to be deferred.

Agency Comments

In written comments on a draft of this report, the Commissioner of Internal Revenue said he appreciated our observations on the states’ experiences with I-file systems. He summarized the facts presented in the report. He then went beyond our description of the facts to reach the conclusion that the facts support IRS’s current strategy for growing electronic filing.

The full text of the Commissioner’s comments is reprinted in appendix IV.

As agreed with your offices, unless you publicly announce its contents earlier, we plan no further distribution of this report until 30 days after its date. At that time, we will send copies to other appropriate congressional committees and the Commissioner of Internal Revenue. The report is available at no charge on GAO’s Web site at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me at (202) 512-9110 or whitej@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Key contributors to this report are listed in appendix V.

Appendix I: Individual Profiles

We profiled eight state tax agencies, two foreign tax agencies, and three federal agencies with I-file systems. The tables below (tables 7-19) contain information on the characteristics of individual agencies, taxpayer eligibility requirement for 2006, and the costs, benefits, and challenges associated with developing and operating I-file systems. Information on benefits and challenges was collected via structured interviews with open- ended questions. We are reporting information on eligibility found on agencies’ Web sites.

Total costs were $717,000 over 3 years. For years 2003-2005, one-time development costs were $512,000 and ongoing costs for operations were $205,000.

Reported benefits to the agency: Fewer processing errors Increase in taxpayers paying via e-pay Faster payment processing Cost savings per I-filed return Reported benefits to the taxpayers: Direct submission to tax agency/no third party involvement Faster refunds Tax preparation industry objections Ensuring security of the system Updates to system based on late tax law changes Total costs for development of the system were approximately $1 million to $2 million with an annual maintenance fee of $480,000 for individual and business users.

Reported benefits to the agency: Reduced paper processing and reduced paper processing staff Reported benefits to the taxpayers: Confirmation of return receipt Ability to print a PDF copy of the return Direct deposit for refund Attracting taxpayers to use the system Total costs were not available. Contractors charged $1 per return for developing and operating the system, along with some marketing and technical taxpayer support.

Officials with the Indiana Department of Revenue declined several requests for interviews to discuss benefits and challenges associated with developing the I-file system.

Total costs were not available. Contractors charged $1 per return for developing and operating the system, along with some marketing and technical taxpayer support. In 2006 and 2007, Kansas also received a marketing budget of $100,000 for marketing of Webfile and electronic filing.

Reported benefits to the agency: Increase in electronically filed returns Fewer paper returns Fewer processing errors Cost savings Reported benefit to the taxpayers: Less incidence of lost documentation Authentication of taxpayers Maryland did not track any of its costs separate from the operating budget for the Information Technology Division and Revenue Administration Division. They noted that most of their costs would be incurred in staff hours; however, none of their staff is specifically dedicated to the I-file system.

Reported benefits to the agency: Reduced paper processing staff Less contact with taxpayers via telephone or notices Fewer processing errors Reported benefits to taxpayers: Faster refunds Auto-population of W-2 information (state employees only) Quicker preparation of return Compatibility of system with all user browsers Addressing taxpayers concerns about the security of their information Development and maintenance of the security platforms State officials estimated the system cost $400,000 to develop, $125,000 per year to operate, and $40,000 in improvements for the system. Officials also received between $20,000 – $40,000 to market the system for the first few years.

Reported benefits to the agency: Reduced paper processing Faster return processing Improving customer service and satisfaction Reported benefits to the taxpayers: Faster refunds Confirmation of return receipt Less incidence of lost documents Agreement among stakeholders Designing a user friendly, intuitive system Capacity needs during peak filing Total costs were not documented; however, officials believed the development of the system cost several hundred thousand dollars, while maintenance of the system is expensed to the information technology department.

South Carolina officials did not report any specific benefits for the agency or taxpayers.

Attracting users to the system Maintaining current users to the system Total costs were not captured. Contractors charged the state of Utah $0.75 per return to develop and operate the system along with some marketing and technical taxpayer support.

Reported benefits to the agency: Increase in electronically filed returns Reduced paper processing Reduced paper processing staff Reported benefits to the taxpayers: Faster refunds Ensuring the stability of system during the first year roll-out Authentication of taxpayers Total costs for development was $600,000, with $350,000 for a special license from Adobe, $50,000 for maintenance and $200,000 for forms technology, research, and piloting the initial system.

Reported benefits to agency: Higher than anticipated electronically filed applications Transmission of forms internally (USDA employees only)

Reported benefits to applicants: User authentication Total costs not reported. Reported benefit to agency: High percentage of electronic applications Reported benefits to applicant: Helped users avoid errors Provided quicker application processing Stakeholder agreement System stability and capacity during peak filing Total costs of developing this system was $355,000 with additional associated costs of about $3,500. The annual maintenance contract is $40,000.

Appendix II: One-time, Ongoing, Variable, and Fixed Costs

The costs of developing and operating an I-file system can characterized in several ways. Some types of costs are incurred one-time; other types of costs will recur consistently over time (ongoing). In addition, some costs can be considered to be variable in that they depend on the number of users of the system, while other types of costs can be considered to be fixed—independent of the number of users of the system. Table 20 shows the types of one-time/ongoing and fixed/variable costs that may be incurred to develop and operate an I-file system.

Appendix III: Objectives, Scope, and Methodology

To identify the options available to IRS for developing an I-file system, we conducted literature searches and examined Web sites for all states, 75 executive and independent branch agencies, and two studies listing foreign countries with e-filing services. We also interviewed representatives from the IRS Oversight Board, Federation of Tax Administrators (FTA),four government contractors (Adobe, EZGov, NIC Inc., and Pearson Government Solutions), and the Electronic Tax Administration Advisory Committee (ETAAC).

To identify the universe of states with I-file systems, we reviewed the Web sites of all 50 states and the District of Columbia. We found 20 states and the District of Columbia provided I-file services. Of the remaining 30 states, we found 3 discontinued their I-file program, 9 had no state income tax, and 18 relied on other technologies, such as 2-D barcode.

For data on I-file usage rates, we used data from FTA’s annual state individual income tax filings reports for 1998-2006. FTA annually surveys states on their paper and electronic filing figures. We reviewed FTA’s methodology for collecting the data but did not verify all the numbers reported by states to FTA. However, we corroborated some of FTA’s data with our data on six of the eight states we profiled. We found one discrepancy with the state of Utah due to a definitional misunderstanding. We corrected the inaccuracy using the state’s data. We used this data as background for reporting and determined that the data were sufficiently reliable for this report.

To determine the benefits and costs of I-file systems, we developed in- depth profiles of eight state tax agencies (California, District of Columbia, Indiana, Kansas, Maryland, Pennsylvania, South Carolina, and Utah) to illustrate the range of Internet filing systems, types of features, and level of usage. In less depth, we collected information about two foreign tax agencies and three federal agencies with I-file systems. We used the following criteria to select our eight state tax agencies to profile: (1) number of I-file users (based on data from the Federation of Tax Administrators), (2) year I-file system implemented, (3) contractor or in- house developed, and (4) types of features offered. We selected the states to have a range for each one of our criteria. We selected tax agencies in two foreign countries (United Kingdom and France) based primarily on their having a large volume of users. We selected three federal agencies (Department of Agriculture, Department of Education, and Department of Veterans Affairs) that allow individuals to prepare and submit forms on agencies’ Web sites and have a range of features, users, and technologies.

We developed a data collection instrument and conducted structured interviews to collect information on agency benefits and costs associated with developing and operating I-file systems. We asked open-ended questions about usage rates, system features, eligibility requirements, benefits to agencies and taxpayers, and system costs. We interviewed state tax, foreign tax, and federal agency officials and contractors with the California Franchise Board, District of Columbia Office of Tax and Revenue, Indiana Department of Revenue, Kansas Department of Revenue, Comptroller of Maryland, Pennsylvania Department of Revenue, South Carolina Department of Revenue, Utah State Tax Commission, the United Kingdom Her Majesty’s Revenue and Customs, and the France General Tax Directorate. We talked to contractors, program directors, program staff, IT staff for the Department of Agriculture’s Rural Development office, the Department of Education, and the Department of Veterans Affairs’ Office of Compensation and Pension Service. We analyzed and summarized our information and confirmed the accuracy of our analysis and summaries with the appropriate state tax, foreign tax, and federal agency officials.

We used widely accepted economic definitions of benefits and costs and corroborated these definitions with state officials, IRS officials, the IRS Oversight Board, ETAAC, and FTA.

To determine benefits, we asked for information on savings from reduced paper processing, reduced error rates, improvements in processing time and refund issuance, the number of I-file users, and the number of taxpayers converted from paper filing to I-file. When benefit information was not measured in dollars, we asked for other available quantitative measures, such as time saved. In cases where tangible measures of benefits were not available, we asked for qualitative descriptions. We corroborated benefit information reported by the contractors, the IRS Oversight Board, and FTA with information provided by the states profiled. By profiling eight states, we saw consistency in the types of benefits reported. However, we did not verify the amount of cost savings reported by state agencies, but based on previous GAO work and discussions with state agency and IRS officials for this engagement, we understand that electronic filing reduces the number of processing staff needed, for example, and generates dollar savings. We determined that state estimates of savings per return are sufficiently reliable as a general indicator, but not necessarily as a precise indicator, of savings.

To determine costs, we summarized costs on a total cost basis and per return basis. We distinguished between fixed and variable costs and summarized the factors influencing each. We asked for information on development costs, operating costs, marketing costs, and taxpayer support (help desk) costs. No state could give us complete information on costs. For example, no state had information on planning costs, or where applicable, contract management costs. However, the cost information we were able to gather covered large elements of total costs, such as development and operating costs. In such cases, we asked for definitions of terms, dates covered, and other available information about the estimates. Seven of the eight state tax agencies could not provide supporting documentation. California was the one state with extensive documentation on its system’s benefits and costs including a feasibility study, a post-implementation evaluation, and a project overview.

For states that relied on contractors, we asked state officials for information about contract costs. We corroborated information provided on contractor fees per return by interviewing contractors and reviewing contracts. We obtained copies of the contracts for Kansas, Indiana, and Utah from state agency Web sites and publicly available documents. The contracts documented the fee per tax return paid by those states to the contractor for I-file services.

Because the available state data were incomplete and not always documented, the total costs that we calculated can only be interpreted as rough orders of magnitude. Based on the consistency in what was reported from the eight states, we determined that the data were reliable for estimating the rough magnitude of total costs.

To determine the reliability of IRS’s processing cost estimates for paper and electronic filing, we reviewed agency spreadsheets that support the estimates and interviewed knowledgeable officials. We spoke with IRS officials in the Electronic Tax Administration and W&I’s Strategy and Finance about costs included in paper processing and electronic filing costs. These costs include pipeline processing costs, labor, oversight with management and supervision, and non-pipeline processing activities including quality assurance. Because of long standing limitations in IRS’s cost accounting capability, cost data at this detailed level has not been audited. Based on prior reports about staff savings from electronic filing, we determined that IRS’s estimate of savings per return is sufficiently reliable as a general indicator, but not necessarily as a precise indicator, of savings.

To describe the potential for IRS to realize cost savings from providing an I-file service, we compared the types of costs states incurred with the types of costs IRS would likely face in developing and operating an I-file system. We identified (1) the segments of the taxpayer population who may be potential I-file users, (2) the potential for net cost savings, and (3) the likelihood federal paper filers would convert to an I-file system. We reviewed the IRS Oversight Board’s Taxpayer Customer Service and Channel Preference Survey, November 2006, to determine why federal taxpayers do not file returns electronically. Because of the low response rate to this survey, the survey results we report cannot be used to make inferences about the views of all U.S. taxpayers. Instead, the results we present should be interpreted as representing the 1,101 taxpayers who responded to the survey. GAO did not assess the extent to which these respondents over- or under-represent certain segments of the U.S. taxpayer population in terms of such characteristics as age, income, education level, race, or Hispanic origin. We reviewed agency documentation on cost savings associated with reduced paper processing. We reviewed prior GAO reports to determine management capacity for overseeing previous IT projects and IRS’s history of management challenges.

We performed our work from May 2006 through March 2007 in accordance with generally accepted government auditing standards.

Appendix IV: Comments from the Internal Revenue Service

Appendix V: GAO Contact and Staff Acknowledgments

Acknowledgments

In addition to the person named above, Signora J. May, Assistant Director; Michele Fejfar; Evan Gilman; Robyn Howard; Rich Hung; Veronica Mayhand; Donna Miller; Ed Nannenhorn; Cheryl Peterson; Gabriele Tonsil; and Tina L. Younger made key contributions to this report.