Patient Protection and Affordable Care Act: IRS Should Expand Its Strategic Approach to Implementation

IRS defines program goals and objectives in a PPACA Governance Plan issued by the PPACA Executive Steering Committee. The goals link to agency objectives and apply to the entire IRS PPACA effort. IRS maintains separate project plans for Services & Enforcement (S&E) and Modernization, Information Technology Systems Services (MITS). An effort is made to integrate the plan manually on a weekly basis, but the lack of automatic links between the two plans raises concerns about effectiveness to the extent that the manual efforts will not detect delays in progress. IRS is considering ways to electronically integrate the two plans but has not made any decisions on a cost effective way. Update 6/20/13 - A meeting with IRS officials confirmed that the agency has not electronically integrated the two plans. It remains uncertain whether the agency will do it. With almost all of PPACA's provisions taking effect by 2014, it could be that IRS will not electronically integrate the plans in time to impact its implementation of the law. As of October 2014, we are still awaiting evidence to show that the project plan has been integrated into one document. In June 2015, IRS officials provided documentation that the project plans for PPACA have been electronically integrated into one plan.

IRS documented a schedule for developing performance measures that are to link to program goals. IRS anticipates developing the performance measures by July 1, 2012.

IRS did not update its cost estimate for PPACA since our report last year. IRS planned to let a contract in May 2012 for a revised cost estimate that adheres to the four criteria in GAO's cost estimating guide. IRS anticipates that the work will take at least 3 months. Update 6/20/13 - IRS delivered a revised estimate to OMB for review in the Fall of 2012. OMB granted IRS permission to share the revised estimate to GAO for review in June 2013. We have begun reviewing the estimate to determine the agency's progress in implementing our recommendation. In September 2013, we reported that IRS made progress in updating its initial October 2010 PPACA cost estimate in accordance with best practices as identified in the GAO Cost Estimating and Assessment Guide. Based on our review of that progress, we are closing this recommendation as implemented.

IRS modified its risk management plan on February 24, 2012. The revised plan calls for Executive involvement in identifying risks, addressing the need to identify strategic-level risks. The section on evaluating alternative risk mitigation strategies did not change. On May 3, 2013, IRS provided a revised risk management plan to clarify which parties are responsible for analyzing and reviewing mitigation alternatives and to clarify how these alternatives are to be selected and decisions about them are to be documented.