TIGTA Says IRS Needs to Improve Emergency Preparedness

By Jason Bramwell
 
As the IRS continues to get back on its feet following the sixteen-day federal government shutdown, a new report released October 30 by the Treasury Inspector General for Tax Administration (TIGTA) concluded the IRS needs to improve certain aspects of its continuity program.
 
The TIGTA report, Improvements Are Needed to Ensure Timely Resumption of Critical Business Processes After an Emergency, which was issued on September 24, one week before the government shutdown began, found the IRS did not always demonstrate that its continuity capability plan would ensure that critical business processes, such as collecting taxes, issuing refunds, and responding to taxpayer inquiries, are resumed in a timely manner. 
 
Since opening its doors again on October 17, the IRS has had to delay the 2014 tax-filing season by up to two weeks so it can prepare and test the more than fifty systems needed to handle the processing of 150 million tax returns. The agency has also reported heavy demand on its toll-free telephone lines, walk-in sites, and other services after the sixteen-day government closure ended. The IRS received 400,000 pieces of correspondence during the shutdown, in addition to the one million items that were already being processed before the agency had to temporarily close its doors.
 
According to the report, TIGTA stated the IRS did not meet the fiscal year 2012 annual reporting requirement to the Treasury Department certifying its continuity capability plan. Also, systemwide continuity plans for four of the IRS's twenty-two business units were not prepared to facilitate the resumption of critical IRS operations. Those four units included:
  1. Return Preparer Office: Responsible for registration, testing, and suitability of federal tax preparers.
  2. Office of Online Services: Responsible for delivering strategy, policy, and initiatives to strengthen the IRS online services experience.
  3. Affordable Care Act Program Office: Responsible for implementing tax provisions for Affordable Care Act legislation.
  4. Office of Compliance Analytics: Responsible for strategic compliance priorities.
Of the four business units selected, TIGTA found that continuity plans for two of the business units were incomplete. 
 
"Specifically, the Large Business and International (LB&I) and Tax Exempt and Government Entities (TE/GE) divisions' plans failed to include sufficient detail and all of the required elements prescribed in the IRS's standard continuity plan template," the report stated. "For example, the two continuity plans provided limited details above the preformatted language contained in the standard template regarding their essential functions and plans for resuming their business operations. Both plans stated that emergency conditions may require the relocation of staff to a continuity facility; however, the plans failed to identify the alternate continuity facilities and continuity communications, which include systems and IT capabilities to support connectivity among key government leadership."
 
Additionally, TIGTA found the two plans did not identify the vital records needed by employees to perform their duties or document key details and recovery strategies as well as the delegation of authorities, which TIGTA said are critical in providing the legal authority for management to make key policy decisions during an emergency.
 
TIGTA recommended that David Grant, chief of IRS Agency-Wide Shared Services, make the following eight improvements: 
  1. Implement a process to ensure that the annual reporting requirement to the Treasury Department certifying its continuity capability plan is met.
  2. Ensure that systemwide continuity plans are immediately prepared for the Return Preparer Office, Office of Online Services, Affordable Care Act Program Office, and the Office of Compliance Analytics.
  3. Ensure that the existing IRS continuity plan template is current and used by all business units and local offices.
  4. Identify appropriate training that should be completed by field personnel responsible for continuity planning activities and establish an effective monitoring process to ensure that training is completed.
  5. Develop a plan that establishes the actions and time frames for the implementation of a centralized working database for continuity plan tracking. Management should also ensure that all current continuity plans are obtained from business unit personnel and maintained for immediate reference.
  6. Develop and issue written procedures requiring necessary personnel to create and update future continuity plans on the Toolkit Suite Command Centre (TSCC) when the system is fully functional.
  7. Establish a process to monitor the continuity testing and exercise program to ensure that an adequate number of exercises are available so that business unit continuity personnel meet the annual testing and exercise requirements.
  8. Establish a process to monitor deficiencies identified during continuity exercises to ensure that weaknesses are addressed as appropriate. 
In his response to the TIGTA report, Grant said the IRS agrees with the eight recommendations and will develop and implement corrective actions for each one. 
 
"We are committed to ensuring our continuity program will enable the IRS to resume the processing of critical functions in a timely manner, in the event of an emergency," he wrote.
 
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