Management Report:

Improvements Are Needed to Enhance the Internal Revenue Service's Internal Controls and Operating Effectiveness

GAO-11-494R: Published: Jun 21, 2011. Publicly Released: Jun 21, 2011.

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In November 2010, we issued our report on the results of our audit of the financial statements of the Internal Revenue Service (IRS) as of, and for the fiscal years ending, September 30, 2010, and 2009, and on the effectiveness of its internal control over financial reporting as of September 30, 2010. We also reported our conclusions on IRS's compliance with selected provisions of laws and regulations and on whether IRS's financial management systems substantially comply with the requirements of the Federal Financial Management Improvement Act of 1996. In March 2011, we issued a report on information security issues identified during our fiscal year 2010 audit, along with associated recommendations for corrective actions. The purpose of this report is to present internal control issues identified during our audit of IRS's fiscal year 2010 financial statements for which we do not already have any recommendations outstanding. While two of these issues contributed to a significant deficiency in internal control discussed in our report on the results of our fiscal year 2010 financial statement audit, they all warrant IRS management's attention. This report provides 29 recommendations to address the internal control issues we identified. We will issue a separate report on the status of IRS's implementation of the recommendations from our prior IRS financial audits and related financial management reports, as well as this one.

During our audit of IRS's fiscal year 2010 financial statements, we identified several internal control issues for which we do not already have recommendations outstanding. These issues involved the following: (1) First-Time Homebuyer Tax Credits. IRS's internal controls were not fully effective in identifying instances where taxpayers improperly made duplicate First-Time Homebuyer Credit (FTHBC) claims during fiscal year 2010. (2) Authorization of manual refunds. Manual refund units at two IRS service center campuses (SCC) did not have current lists of officials authorized to approve manual refunds. (3) Authorization of goods and services. IRS did not always obtain approval before requesting and receiving services from vendors as required by IRS policy. (4) Approval of personnel actions. IRS did not always timely approve personnel actions for promotions prior to their effective dates as required by Office of Personnel Management guidelines. (5) Recording time and attendance. IRS did not always record Office of Chief Counsel employees' approved time card changes into IRS's electronic time and attendance system. (6) Verification of National Finance Center payroll changes. IRS did not timely detect payroll errors made by the National Finance Center (NFC), which processes IRS's payroll. (7) Cash receipts at the Beckley Finance Center. IRS did not have internal controls in place to appropriately safeguard and account for cash receipts at the Beckley Finance Center (BFC). (8) Contract employee background investigations. IRS did not ensure that background investigations were performed for certain SCC mail couriers who were transporting mail that included taxpayer information from the SCC to the post office. (9) Deposit courier trip times. Allowable time limits IRS established for some of its deposit courier routes greatly exceeded the average trip time and thus were not effective in identifying potential instances of SCC and lockbox bank deposit couriers making unauthorized stops during transit. (10) Transfer of taxpayer information between processing facilities. A courier vehicle's cargo door was not locked after it was loaded with taxpayer returns and other information, contrary to a requirement in the courier's contract. (11) Document transmittal forms. IRS's Small Business/Self-Employed Division managers were not adequately performing or documenting required reviews of internal control procedures over tracking and monitoring taxpayer receipts and information transmitted between IRS locations. (12) Compliance reviews of off-site processing facilities. IRS did not complete compliance reviews for its off-site processing facilities every 2 years as required by the Internal Revenue Manual (IRM). (13) After dark security controls. IRS's physical security controls intended to help prevent and detect unauthorized access to its processing facilities were not always effective. (14) Property and equipment records. IRS incorrectly recorded the asset purchase price for some assets in its property management system. (15) Disposal process for copiers. IRS disposed of copiers without ensuring that the copiers did not contain confidential taxpayer information or sensitive information on IRS employees or operations on the hard drives. These issues increase the risk that IRS may not prevent or promptly detect and correct (1) unauthorized or improper refunds, purchases, or promotions; (2) errors in the hours credited or amounts paid to staff; (3) loss or theft of cash receipts or taxpayer information; (4) security and control deficiencies at its SCCs and processing facilities; (5) data errors in its property records; and (6) improper disclosure of taxpayer and other sensitive data.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: During our fiscal year 2012 audit, we verified that IRS officials put procedures in place to peridically monitor the effectiveness of the new FTHBC validity checks for the duration of the filing of FTHBC claims to ensure they are working as intended.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to put procedures in place to periodically monitor the effectiveness of the new FTHBC validity checks for the duration of the filing of FTHBC claims to verify that they are working as intended.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  2. Status: Closed - Implemented

    Comments: IRS incorporated a procedural change in the Internal Revenue Manual requiring quarterly reviews to validate changes to the lists of officials authorized to approve manual refunds. During our FY 2012 audit, we verified the validated reviews of the list of officials authorized.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to establish a mechanism to enforce the existing requirement for appropriate managers to immediately notify the manual refund units of any personnel changes affecting the approval or processing of manual refunds. This may be accomplished through mechanisms such as issuing periodic alerts, providing training, having the manual refund unit perform quarterly validations of the list of manual refund approving officials, or a combination of these.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  3. Status: Closed - Implemented

    Comments: During our fiscal year 2011 audit, we verified that IRS sent out a reminder to remind staff to obtain approval and funding prior to entering into an agreement with vendors. Furthermore, we did not identify any instances in which IRS entered into an agreement without first obtaining approval and funding for the purchase during our detailed testing of fiscal year 2011 nonpayroll expenses.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to send out a reminder to all staff to follow policies and procedures for obtaining approval and funding of proposed purchases prior to entering into an agreement with vendors.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  4. Status: Closed - Implemented

    Comments: In June 2013, IRS issued a memorandum to its procurement staff as part of IRS's procurement policies that requires staff to review purchase contract terms against the goods and services received to date before requesting additional goods or services. Specifically, the memorandum reiterated principles, policies, and procedures, which required staff to know the quantity and other ceiling limits on their respective contracts and orders and to not exceed those limits unless the contract or order is appropriately modified increasing those limits.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to establish formal written procedures requiring staff to review purchase contract terms against the goods and services received to date before requesting additional goods or services.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  5. Status: Open

    Comments: IRS's efforts to address this recommendation are ongoing. In fiscal year 2013, IRS's Human Capital Office (HCO) took various actions related to this recommendation, such as (1) communicating the results of its analysis on the timeliness of personnel action requests (PAR) to Employment Operations senior and frontline leadership and (2) issuing Leader's Alerts and conducting training for managers to educate them on the importance of the timely submission of PARs. For fiscal year 2014, IRS stated that it plans to increase its performance goals on the processing and timely submission of PARs and focus its efforts on increasing accountability at all levels. IRS plans to analyze the timeliness of PAR actions and report the results to leadership on a quarterly basis. However, IRS still has not documented any procedures related to the PAR analysis or other monitoring activities. We will continue to evaluate IRS's actions to address this recommendation during our fiscal year 2014 IRS financial statement audit.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to establish procedures to centrally review and monitor the timeliness of personnel action requests and approvals to help ensure compliance with the IRM and applicable OPM regulations and guidance.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  6. Status: Closed - Implemented

    Comments: The revised SOP states that business units may develop local office timekeeping procedures for entering and verifying the accuracy of time and attendance information entered into SETR if employees do not enter their own time. However, regardless of the specific procedures established, managers are now responsible for ensuring that the time entered in SETR for both weeks of the pay period for employees that do not enter their own time into SETR matches the source document prior to validating and electronically signing the employee's SETR timecard.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to adopt the local field office's timekeeping procedures or similar procedures for entering and verifying the accuracy of time and attendance information entered into Single Entry Time Reporting System (SETR) throughout IRS for use by all units in which employees do not enter their own time charges directly to SETR.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  7. Status: Closed - Implemented

    Comments: We reviewed IRS's revised SOP and verified that it clarifies the criteria for determining which program changes are subject to validation and identifies the officials responsible for making these determinations. Furthermore, the revised SOP establishes guidelines for post-validation random sample testing from the population affected by the programming change.

    Recommendation: The Commissioner of the IRS should further revise your detailed procedures for implementing the requirement to validate the appropriateness of NFC programming changes after such changes are made. These revisions should (1) clarify the criteria for determining what programming changes will be subject to validation, (2) identify officials responsible for making and documenting these determinations, and (3) require postimplementation statistical sampling from a targeted population that consists of employees who are most likely to be affected by the NFC programming change.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  8. Status: Closed - Implemented

    Comments: During our fiscal year 2011 audit, we verified that IRS effectively implemented procedures at the Beckley Finance Center requiring cash receipts to be immediately logged under dual control when first discovered in the mail room.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to take steps to effectively implement procedures at BFC requiring cash receipts to be immediately logged under dual control when first discovered in the mail room.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  9. Status: Closed - Implemented

    Comments: During our fiscal year 2011 audit, we verified that IRS effectively implemented procedures at the Beckley Finance Center requiring mail room staff to maintain custody of the control log at all times.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to take steps to effectively implement procedures at BFC requiring mail room staff to maintain custody of the control log at all times.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  10. Status: Closed - Implemented

    Comments: During our fiscal year 2011 audit, we verified that IRS effectively implemented procedures at the Beckley Finance Center requiring the amount of cash receipts initially discovered in the mail room to be independently reconciled to the amount deposited and recorded in the general ledger.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to take steps to effectively implement procedures at BFC requiring the amount of cash receipts initially discovered in the mail room to be independently reconciled to the amount deposited and recorded in the general ledger.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  11. Status: Open

    Comments: IRS's efforts to address this recommendation are ongoing. IRS stated that by May 2014 it would complete an analysis of contracts that had previously not included background investigation requirements. IRS stated that it will identify any risks and provide a mitigation plan for each risk identified. We will continue to evaluate IRS's actions to address this recommendation during our fiscal year 2014 audit.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to perform a review of all existing contracts under $100,000 that (1) do not have an appointed contracting officer's technical representative (COTR) and (2) do not require that contract employees obtain background investigations to assess whether the services performed under each contract warrant a requirement that contract employees obtain background investigations.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  12. Status: Open

    Comments: IRS's efforts to address this recommendation are ongoing. IRS stated that by May 2014 it would complete an analysis of contracts that had previously not included background investigation requirements. IRS stated that it will identify any risks and provide a mitigation plan for each risk identified. We will continue to evaluate IRS's actions to address this recommendation during our fiscal year 2014 audit.

    Recommendation: Based on a review of all existing contracts under $100,000 without an appointed COTR that should require contract employees to obtain favorable background investigation results, the Commissioner of the IRS should direct the appropriate IRS officials to amend those contracts to require that favorable background investigations be obtained for all relevant contract employees before routine, unescorted, unsupervised physical access to taxpayer information is granted.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  13. Status: Open

    Comments: IRS's efforts to address this recommendation are ongoing. IRS provided Policy and Procedures Memorandum No. 39.1(F), Contractor Submission of Credit Checks, Fingerprints and Other Security Documentation, dated July 10, 2013, which requires certain contractors with access to IRS-owned or IRS-controlled facilities, sensitive but unclassified information, or information systems to receive favorable background investigations prior to gaining access to taxpayer receipts and information. However, this policy does not explicitly require collaborative oversight between IRS's key offices in determining whether potential service contracts involve routine, unescorted, unsupervised physical access to taxpayer information, thus requiring background investigations, regardless of contract award amount. We will continue to evaluate IRS's actions to address this recommendation during our fiscal year 2014 audit.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to establish a policy requiring collaborative oversight between IRS's key offices in determining whether potential service contracts involve routine, unescorted, unsupervised physical access to taxpayer information, thus requiring background investigations, regardless of contract award amount. This policy should include a process for the requiring business unit to communicate to the Office of Procurement and the Human Capital Office the services to be provided under the contract and any potential exposure of taxpayer information to contract employees providing the services, and for all three units to (1) evaluate the risk of exposure of taxpayer information prior to finalizing and awarding the contract and (2) ensure that the final contract requires favorable background investigations as applicable, commensurate with the assessed risk.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  14. Status: Open

    Comments: IRS established a methodology for calculating and establishing allowable deposit courier trip time limits; however, it is unclear whether the established methodology would assist in detecting potential unauthorized stops or other contractual violations for deposit couriers. For example, the methodology states that the average trip time documented on Form 10160, Receipt for Transport of IRS Deposit, is the base of the allowable time, and that additional time should be added to the base depending on the length of trip time and number of traffic lights. Since the average trip times already include the time required to make the entire trip, adding additional time to the base time does not make this policy effective in detecting potential unauthorized stops or other contractual violations for deposit couriers. During our fiscal year 2013 audit, we found that one of the three lockbox banks we visited instructed deposit couriers to deliver receipts to a depository bank for which there was no established deposit courier time limit. We will continue to evaluate IRS's actions to address this recommendation during our fiscal year 2014 audit.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to establish procedures to provide a consistent methodology for calculating and establishing allowable deposit courier trip time limits to be used by both SCCs and lockbox banks that would assist in detecting potential unauthorized stops or other contractual violations for deposit couriers. Such procedures should include instructions for documenting and supporting how the trip limits were determined and require justification and approval for all established time limits that exceed the average trip time.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  15. Status: Closed - Implemented

    Comments: In response to our recommendation, IRS took action to update IRM 3.8.45 Manual Deposit Process, to include procedures to reassess service center campus deposit courier trip times during unannounced security reviews or whenever there is a change in depository location. In addition, IRS updated LSG 2.16, which requires lockbox banks to perform an annual detailed analysis to establish acceptable courier timeframes.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to establish procedures to require periodic reassessments of, and updates to, deposit courier allowable trip time limits to account for changes in courier routes or other conditions that may affect trip times.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  16. Status: Closed - Implemented

    Comments: On April 6, 2012, IRS updated the IRM to require monthly reviews of the shipping and receiving processes and random on-site reviews to ensure that vehicles' cargo doors are locked prior to delivery and upon receipt of pipeline work from one facility to the other. In addition, during our fiscal year 2013 audit, we verified that Real Estate and Facilities Management staff conducted random monthly reviews of its contract courier routes to ensure that couriers were locking cargo doors.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to enforce existing contractual requirements for the cargo doors of contract courier vehicles to be locked after picking up taxpayer information.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  17. Status: Closed - Implemented

    Comments: On April 6, 2012, IRS updated the IRM to require monthly reviews of the shipping and receiving processes and random on-site reviews to ensure that vehicles' cargo doors are locked prior to delivery and upon receipt of pipeline work from one facility to the other. In addition, during our fiscal year 2013 audit, we verified that Real Estate and Facilities Management staff conducted random monthly reviews of its contract courier routes to ensure that couriers were locking cargo doors.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to establish procedures to prevent or detect unauthorized access to taxpayer information in contract courier vehicles during transit. These procedures should detail specific activities to be performed by both the business units sending and receiving the information transported by the contract courier.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  18. Status: Closed - Implemented

    Comments: On April 6, 2012, IRS updated the IRM to require monthly reviews of the shipping and receiving process and random on-site reviews to ensure that vehicles' cargo doors are locked prior to delivery and upon receipt of pipeline work from one facility to the other. Specifically, the IRM requires the monthly reviews to be documented, initialed and dated by the reviewer, and maintained on file for no less than 1 year. In addition, any discrepancies identified during the review should be reported to the headquarters IRM analyst within 2 business days after the review has been conducted. During our fiscal year 2013 audit, we verified that Real Estate and Facilities Management conducted and documented random monthly reviews of its contract courier routes to ensure that couriers were locking cargo doors.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to revise the guidance for conducting the periodic reviews of the contract couriers transporting taxpayer information from one IRS processing facility to another to include procedures for (1) physically verifying that courier vehicle cargo doors are locked after picking up this information and remain locked during transit to the final destination and (2) documenting the basis for the reviewer's conclusions.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  19. Status: Closed - Implemented

    Comments: In response to our recommendation, in December 2011, IRS published the update to IRM 1.4.50-Collection Group Manager, Territory Manager and Area Director Operational Aid. This revision includes provisions that management should take to determine whether their staff are: (1) maintaining control copies of document transmittal forms, (2) reconciling all document transmittal forms on a biweekly basis to ensure that all transmittals were received, and (3) following up on transmittals that are not timely acknowledged.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to revise the Internal Revenue Manual (IRM) to include a comprehensive process that Small Business/Self-Employed Division (SB/SE) unit managers should follow when performing reviews of the document transmittal process for determining whether staff are (1) maintaining control copies of document transmittal forms, (2) reconciling all document transmittal forms on a biweekly basis to ensure that all transmittals were received, and (3) following up on transmittals that are not timely acknowledged.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  20. Status: Closed - Implemented

    Comments: In response to our recommendation, in December 2011, IRS updated IRM 1.4.50, Collection Group Manager, Territory Manager, and Area Manager Director Operational Aid. This includes minimum steps for Small Business/Seld Employed unit managers to follow in their reviews of the document transmittal process.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to include specifying minimally acceptable steps SB/SE unit managers should follow in documenting the results of required reviews of the document transmittal process.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  21. Status: Closed - Implemented

    Comments: We verified that the IRM was updated to reflect the inclusion of off-site campus locations with Receipt and Control and submission processing type functions under the two-year compliance review requirement.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to define and specify in the IRM what types of IRS facilities constitute a processing facility.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  22. Status: Closed - Implemented

    Comments: IRS performed an assessment of the off-site processing facilities. As a result of that assessment and our recommendation, IRS determined compliance reviews for off-site campus locations with Receipt and Control and submission processing type functions should be performed on a recurring basis every two years - the same frequency as processing and computing center facilities.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to perform an assessment of the off-site processing facilities to determine the frequency with which compliance reviews should be performed for these locations commensurate with the specific operational activities performed and the assessed level of risk associated with the facility.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  23. Status: Closed - Implemented

    Comments: IRS performed an assessment of the off-site processing facilities. As a result of that assessment and our recommendation, IRS updated IRM 10.2.2 to require recurring compliance reviews every two years for off-site campus locations with Receipt and Control and submission processing type functions.

    Recommendation: Based on the results of an assessment of off-site processing facilities that process taxpayer receipts and related taxpayer information, the Commissioner of the IRS should direct the appropriate IRS officials to revise the IRM to specify the frequency with which compliance reviews should be performed at these facilities.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  24. Status: Open

    Comments: While following up on IRS's actions to address this recommendation, we found that the post orders at one of IRS's SCC did not include procedures specifying (1) whom to contact to report lighting outages or (2) how to document and track lighting outages until resolved. We will continue to evaluate IRS's actions to address this recommendation during our fiscal year 2014 audit.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to revise the post orders for the service center campuses (SCC) and lockbox bank security guards to include specific procedures for timely reporting exterior lighting outages to SCC or lockbox bank facilities management. These procedures should specify (1) whom to contact to report lighting outages and (2) how to document and track lighting outages until resolved.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  25. Status: Closed - Implemented

    Comments: In January 2013, IRS revised the Audit Management Checklist to include periodic after-dark assessments of physical security controls and verification that guards are properly reporting lighting outages.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to revise the nature and scope of the SCCs' and lockbox banks' physical security reviews to include periodic after dark assessments of physical security controls.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  26. Status: Closed - Implemented

    Comments: In fiscal year 2011, IRS revised its operating procedures to require that property staff conduct research to ensure that the price of an asset on the Asset Management Report agrees with the price listed in IFS and resolve any variances before uploading an asset into its new property management system. During our fiscal year 2012 audit, we verified that procedures were effectively implemented.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to take steps to effectively implement the procedures requiring property staff to verify that the asset purchase price shown in the Asset Management Report agrees with the asset purchase price shown in IFS and to resolve any variances before entering the information into Information Technology Asset Management System (ITAMS).

    Agency Affected: Department of the Treasury: Internal Revenue Service

  27. Status: Closed - Implemented

    Comments: During our fiscal year 2011 audit, IRS finalized procedures requiring that copier hard drives be removed and destroyed or properly cleaned prior to disposal.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to finalize procedures requiring that copier hard drives be removed and destroyed or otherwise appropriately cleaned before disposing of copiers.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  28. Status: Closed - Implemented

    Comments: During our fiscal year 2011 audit, IRS revised its IRM to incorporate the new copier disposal procedures. The IRM now includes guidance for removing and destroying or otherwise appropriately cleaning copier hard drives before disposing of copiers.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to revise the IRM to incorporate the new copier disposal procedures that require that copier hard drives be removed and destroyed or otherwise appropriately cleaned before disposing of copiers.

    Agency Affected: Department of the Treasury: Internal Revenue Service

  29. Status: Closed - Implemented

    Comments: During our fiscal year 2011 audit, IRS issued a memorandum to all business units. The memorandum reminds business units that the disposal of copiers must be coordinated through REFM.

    Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to issue a memorandum to all business units reminding them that only designated Real Estate Facilities Management (REFM) staff are authorized to dispose of copiers.

    Agency Affected: Department of the Treasury: Internal Revenue Service

 

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