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entitled 'Tax Debt Collection: IRS Is Addressing Critical Success 
Factors for Contracting Out but Will Need to Study the Best Use of 
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Report to Congressional Committees: 

May 2004: 

TAX DEBT COLLECTION: 

IRS Is Addressing Critical Success Factors for Contracting Out but Will 
Need to Study the Best Use of Resources: 

GAO-04-492: 

GAO Highlights: 

Highlights of GAO-04-492, a report to congressional committees

Why GAO Did This Study: 

Congress is considering legislation to authorize IRS to contract with 
private collection agencies (PCA) and to pay them out of the tax 
revenue that they collect. Some have expressed concerns that this 
proposal might be unsuccessful, inefficient, or result in taxpayers 
being mistreated or having their private tax information compromised. 

This report discusses (1) the critical success factors for contracting 
with PCAs for tax debt collection; (2) IRS’s actions to address these 
factors in developing the PCA program and actions left to be done; and 
(3) whether IRS, if it receives the authority to use PCAs, plans to do 
a study that will help policy makers judge whether PCAs are the best 
use of funds to meet IRS’s collection objectives. 

What GAO Found: 

Based on our analysis of information from various parties, including 
officials from selected state revenue departments and federal agencies 
that use PCAs, five factors are critical to the success of a PCA 
collection program. Together, these factors increase the chances for 
success and, as illustrated below, help the program achieve desired 
results.

Although incomplete, IRS has taken actions to address these factors. 
For example, IRS has been developing (1) program performance measures 
and goals, (2) plans for a computer system to transmit data to PCAs, 
(3) a method to select cases for PCAs, and (4) contract provisions to 
govern data security and PCAs’ interactions with taxpayers. IRS 
officials recognize that major development work remains and have plans 
to finish it. Officials said they would suspend work if PCA authorizing 
legislation is not passed during 2004. If legislation passes, officials 
estimated that it would take 18 to 24 months to send the first cases to 
PCAs. 
 
Aware of concerns about the efficiency of using PCAs, IRS intends to 
study the relative performance of PCAs and IRS employees in collecting 
tax debts after gaining some experience with them. However, the initial 
idea for a study would provide limited information to judge whether or 
when the PCA approach is the best use of resources. The tentative idea—
comparing PCA and IRS performance for the same type of simpler cases to 
be sent to PCAs—does not recognize that IRS officials believe that 
using IRS employees on such cases would not be the best use of staff. 
Federal guidance emphasizes efficiently and effectively using resources 
to achieve results and identifying the most realistic and cost-
effective program option. Experience gained in using PCAs and a new IRS 
case selection process would help officials design such a study.

Critical Success Factors Help Achieve Desired Results: 

[See PDF for image]

[End of figure]

What GAO Recommends: 

If Congress authorizes the use of PCAs, as soon as practical after 
experience is gained using PCAs, the IRS Commissioner should ensure 
that a study is completed that compares the use of PCAs to a collection 
strategy that officials determine to be the most effective and 
efficient overall way of achieving collection goals. 

In commenting on a report draft, IRS said it would plan a study to 
ensure that IRS is making the most effective and cost efficient use of 
total resources available. 

[End of section]

Contents: 

Letter: 

Results in Brief: 

Background: 

Objectives, Scope, and Methodology: 

Five Factors Are Critical for a Successful PCA Collection Program: 

IRS Has Taken Steps to Address Aspects of the Critical Success Factors 
but Has Much Work Remaining: 

Potential Study Design Would Provide Limited Information to Judge 
Whether Contracting with PCAs Is the Best Use of Resources: 

Conclusions: 

Recommendation: 

Agency Comments and Our Evaluation: 

Appendixes: 

Appendix I: Trends in IRS Collections Programs, 1996-2003: 

Appendix II: Actions IRS Has Taken to Address Critical Success Factors: 

Appendix III: Comments from the Internal Revenue Service: 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Acknowledgments: 

Tables Tables: 

Table 1: Critical Success Factors and Related Subfactors for Contracting 
with PCAs for Tax Debt Collection: 

Table 2: Examples of Key Actions IRS Has Taken to Address Critical 
Success Factors and Examples of Major Tasks Remaining: 

Figures: 

Figure 1: Five Critical Success Factors Help Achieve Desired Results: 

Figure 2: Annual Gap Between Collection Cases Assigned and Cases Closed 
as a Percentage of Cases Assigned, Fiscal Years 1996 through 2003: 

Figure 3: Number of Revenue Officers Working on Delinquent Accounts, 
1996 through 2003: 

Letter May 24, 2004: 

Congressional Committees: 

For the last several years, Congress, the Internal Revenue Service 
(IRS), and others have been concerned that performance declines in 
IRS's programs to collect known unpaid taxes due the 
government[Footnote 1] might be affecting taxpayers' confidence in the 
fairness of our tax system and voluntary compliance. In testimonies and 
reports, we have highlighted such declines in the collection programs, 
including a growing gap between the number of cases assigned for 
collection action and the number of cases closed each year. Also, the 
amount of potentially collectable known tax debt has grown. As of 
September 30, 2003, IRS had an inventory of unpaid taxes with some 
collection potential--including interest and penalties--of $120 
billion,[Footnote 2] up from $112 billion the previous year. According 
to IRS, the backlog of outstanding tax debt continues to grow 3 to 4 
percent each year. Because of potential revenue losses and the threat 
to voluntary compliance, we have designated collection of unpaid taxes 
as a high-risk area for the federal government.[Footnote 3]

To help address the growing tax debt inventory, the Department of the 
Treasury has proposed that Congress pass legislation to authorize IRS 
to use private collection agencies (PCA) to help collect tax debts for 
simpler types of cases, paying them out of a revolving fund of tax 
revenues that they collect. IRS officials said that this proposal 
arose, in part, because of the belief that Congress was not likely to 
provide the increased budget to hire enough IRS staff to work on the 
inventory of collection cases. Although the proposal has received 
support, some have expressed concerns that it might be unsuccessful, 
inefficient, or result in taxpayers being mistreated or having private 
tax information compromised. In addition, some in Congress and 
elsewhere in the tax community have said that increasing IRS collection 
staff--instead of contracting out tax collection--could result in tax 
debts being collected at less cost. A 1996 IRS pilot test to contract 
with PCAs was discontinued, in part, because the revenue collected was 
less than IRS's direct costs plus revenues lost from using IRS 
employees to support PCAs rather than to collect taxes. Our review of 
the pilot found that, among other limitations, IRS's computer systems 
and inability to transfer data hampered efforts to send appropriate 
cases to PCAs.[Footnote 4]

Due to congressional interest in the legislation being considered to 
authorize IRS contracts with PCAs to collect simpler tax debts, we 
reviewed, as part of our basic legislative responsibility for reviewing 
federal programs and activities, various issues related to IRS's 
preparations to implement the proposal, if enacted, and to report on 
the role of PCAs in IRS's overall collections strategy. Specifically, 
our objectives were to (1) identify the critical success factors for 
contracting with PCAs for tax debt collection; (2) determine whether 
IRS has addressed the critical success factors in developing the 
proposed PCA contracting program and, if not, what is left to be done; 
and (3) determine whether, if IRS receives authority to use PCAs, it 
will do a study that will enable policymakers to judge whether 
contracting with PCAs is the best use of limited federal funds to 
achieve IRS's collection objectives.

To identify the critical success factors, we interviewed officials from 
selected state revenue departments and federal agencies that use PCAs 
and PCA contractors for government debt collection. We reviewed related 
documentation from these sources. In addition, we analyzed our reports 
on contracting practices. For our other objectives, we gathered and 
analyzed PCA program development documents and interviewed IRS 
officials responsible for developing the PCA program. We conducted our 
work between June 2003 and March 2004 in accordance with generally 
accepted government auditing standards. Our scope and methodology are 
discussed in detail beginning on page 7.

Results in Brief: 

Five broad factors are critical to the success of a program for 
contracting with PCAs to collect tax debt. Although addressing these 
factors does not guarantee success, together they can improve the 
chances. First, the PCA program should have a results orientation, 
including established PCA program goals and performance measures, such 
as for the amounts of tax debt collected. Second, agency resources 
needed to help achieve desired program results should be obtained and 
deployed, such as computer systems to exchange data and staff to work 
on cases that PCAs refer back to IRS. Third, PCAs' workload should be 
carefully considered, such as selecting the type and volume of cases on 
which PCAs work. Fourth, taxpayer issues should be addressed, such as 
protecting taxpayer data shared with PCAs and ensuring that PCAs treat 
taxpayers properly. Fifth, the agency should do evaluations, including 
ongoing monitoring of PCAs, program results, and costs compared to 
program goals.

IRS has taken a number of steps to address each of the critical success 
factors. For example, IRS has (1) developed program performance goals 
and measures, (2) been planning development of a computer system to 
send cases and case data to PCAs, (3) been developing a method to 
select PCA cases based on collection potential, and (4) drafted 
contract provisions to govern the security of taxpayer data and PCA 
interactions with taxpayers. As for the evaluation factor, IRS 
officials have been developing approaches for monitoring and measuring 
contractor performance, and said that they intend to start developing 
an evaluation of whether the PCA program achieves its goals after they 
receive legislative authority. The officials recognize that major work 
needs to be done to sufficiently address each factor and have a project 
plan to finish work on the factors. In January 2004, Congress approved 
the IRS fiscal year 2004 budget, which would provide the funding to 
further develop the PCA program, but IRS delayed spending the funds 
until passage of the legislation appears to be more imminent. IRS 
officials said that if authorizing legislation did not pass during 
2004, IRS would suspend work on developing the program. IRS officials 
estimated that it would take 18 to 24 months after the authorizing 
legislation passes to finish the remaining work and send cases to PCAs.

Aware of concerns about the efficiency and effectiveness of using PCAs, 
IRS officials also said that they intend to study the relative 
performance of PCAs and IRS employees in collecting delinquent taxes. 
However, the tentative study approach being considered would provide 
policymakers limited information to judge whether or when the PCA 
strategy is the best use of resources. This tentative approach--
comparing PCA and IRS performance for the same type of simpler cases 
that would be sent to PCAs--does not recognize that IRS officials 
believe that using employees on simpler cases would not be the best use 
of these employees given the need to work on other, higher priority 
cases. Various guidance on federal programs emphasizes that managers 
are to ensure that resources are used efficiently and effectively to 
achieve intended results, to consider benefits and costs in deciding on 
program options, and to determine which program option is the most 
realistic and cost effective.

If Congress authorizes IRS to use PCAs, we are recommending that the 
Commissioner of IRS ensure that, after experience is gained using PCAs 
to collect tax debt, a study be conducted that compares the use of PCAs 
to another collection strategy, which might include hiring more IRS 
employees, that officials determine to be the most efficient and 
effective overall way of achieving collection goals.

In providing written comments on this report (see app. III), the 
Commissioner of Internal Revenue agreed that IRS would need to analyze 
the PCA program to determine its effectiveness and impact on the 
overall collection of delinquent taxes. He said that IRS's plans for 
evaluating the use of PCAs will include a study to ensure that IRS is 
making the most effective and cost efficient use of total resources 
available.

Background: 

IRS has two major programs to collect tax debts: telephone collection 
and field collection. If taxpayers become delinquent (that is, do not 
pay their taxes after being notified of amounts owed), IRS staff 
assigned to the telephone collection program may attempt collection 
over the phone or in writing. According to IRS officials, IRS 
collection staff who make phone calls have not been initiating many 
calls to ask taxpayers to pay their tax debts but rather have been 
responding to phone calls from taxpayers about mailed tax due notices. 
If more in-depth collection action or analyses of the taxpayer's 
ability to pay tax debt is required, telephone collection staff may 
refer the case to field collections, where staff may visit delinquent 
taxpayers at their homes or businesses as well as contact them by 
telephone and mail. Under certain circumstances, the telephone or field 
staff are authorized to initiate enforced collection action, such as 
recording liens on taxpayer property and sending notices to levy 
taxpayer wages, bank accounts, and other financial assets held by third 
parties. Field staff also can be authorized to seize other assets owned 
by the taxpayer to satisfy the tax debt.

As we have previously reported, in recent years IRS has deferred 
collection action on billions of dollars of delinquent tax debt and IRS 
collection program performance indicators have declined. By the end of 
fiscal year 2003, IRS's inventory of tax debt with some collection 
potential was $120 billion (up from $112 billion in the previous year). 
As we reported in May 2002, from fiscal years 1996 through 2001, IRS 
had almost universal declines in collection performance, including 
declines in coverage of workload, cases closed, direct staff time used, 
productivity, and dollars of unpaid taxes collected.[Footnote 5] 
Although IRS's collection workload declined, the collection cases 
closed declined more rapidly, increasing the gap between the number of 
cases assigned for collection action and the number of cases closed 
each year (see fig. 2 in app. I). As a result, in March 1999, IRS 
started deferring collection action[Footnote 6] on billions of dollars 
in delinquencies. By the end of fiscal year 2002, IRS had deferred 
collection action on about $15 billion, and, as of May 2003, was 
deferring action on about one of every three collection cases.

Furthermore, IRS's collection staffing has declined overall comparing 
1996 to 2003 (see fig. 3 in app. I) despite IRS's efforts to increase 
collection staffing in its budget requests since 2001. As we previously 
reported,[Footnote 7] IRS officials have said that collection staffing 
declines and delays in hiring have been caused by increased workload in 
other essential operations (such as as processing returns, issuing 
refunds, and answering taxpayer mail), other priorities (such as 
taxpayer service), and unbudgeted cost increases (such as rent and pay 
increases).

According to statements by the previous and current IRS commissioners, 
IRS's growing workload has outpaced its resources. The former IRS 
Commissioner's report to the IRS Oversight Board during September 2002 
made a case for additional staff to check tax compliance and collect 
taxes owed. The Commissioner recognized that IRS needed to improve the 
productive use of its current resources, but also cited a need for an 
annual 2 percent staffing increase over 5 years to help reverse the 
trends. According to the Commissioner, IRS would require 5,450 new 
full-time collection staff. IRS officials said that the PCA program 
proposal was undertaken because it is unlikely that IRS will receive 
funding adequate to handle the growing collection workload.

Since current law requires IRS to collect tax debts, legislation has 
been proposed[Footnote 8] to authorize IRS to use PCAs to collect 
simpler tax debts under defined activities--including locating 
taxpayers, requesting full payment of the tax debt or offering 
taxpayers an installment agreement if full payment cannot be made, and 
obtaining financial information from taxpayers. Given the limited 
authorities proposed for PCAs,[Footnote 9] IRS would refer those cases 
that are simplest to collect and have no need for IRS enforcement 
action, including cases in which (1) taxpayers filed a tax return 
showing taxes due but that have not been paid and (2) taxpayers made 
three or more voluntary payments to satisfy an additional tax assessed 
by IRS but have stopped the payments.

In 1996, Congress directed IRS to test the use of PCAs, earmarking $13 
million for that purpose. IRS canceled the pilot project in 1997, in 
part, because it resulted in significantly lower amounts of collections 
and contacted significantly fewer taxpayers than expected (about 14,000 
of 153,000 taxpayers). IRS reported that through January 1997, this 
program accounted for about $3.1 million in collections and about $4.1 
million in expenses ($3.1 million in design, start-up, administrative 
expenses, and about $1 million in PCA payments). IRS also reported lost 
opportunity costs of about $17 million because IRS collection staff 
shifted from collecting taxes to helping with the pilot.

The current proposal to use PCAs has some significant differences from 
the 1996 pilot test of PCAs. First, PCAs in the current proposal will 
actually try to resolve collection cases within certain guidelines. In 
the 1996 test, PCAs only contacted taxpayers to remind them of their 
outstanding tax debt and suggest payment options. Second, PCAs under 
the current proposal will be paid a percentage of dollars they help 
collect from a revolving fund of all PCA collections. In the 1996 test, 
PCAs were paid a fixed fee for such actions as successfully locating 
and contacting taxpayers, even if payments were not received. Third, 
IRS will electronically transmit cases and data about the taxpayer and 
taxes owed to PCAs. In 1996, IRS's computers were not set up to 
electronically transmit the cases and data to PCAs. For the current 
proposal, IRS intends to develop the capability to make secure 
transmissions to PCAs and protect confidentiality.

Objectives, Scope, and Methodology: 

To identify the critical success factors for contracting with PCAs for 
tax debt collection, we used multiple sources. We reviewed three of our 
reports on leading practices in contracting[Footnote 10] and 
interviewed our staff that review government contracting. We also 
interviewed parties with experience in contracting for government debt 
collection, including both tax and non-tax debt, to identify any 
factors common to both debt types. Specifically, we interviewed 
officials from: 

* 11 state revenue departments that, according to officials from the 
Federation of Tax Administrators (FTA),[Footnote 11] represented a mix-
-in aspects such as amount of resources and PCA roles--of experience in 
contracting with PCAs for tax debt collection and provided examples of 
program practices in such areas as case selection and use of 
performance data;[Footnote 12]

* the Department of the Treasury's Financial Management Service and 
Department of Education--two federal agencies with large-scale, non-tax 
debt collection contracting; and: 

* the three PCA firms that IRS selected as subject matter experts to 
assist in drafting the provisions of a contract for PCA collection 
services.

To help corroborate the factors that others identified, we interviewed 
officials from the IRS office that is developing the proposed PCA 
program, the IRS Office of Taxpayer Advocate, and the National Treasury 
Employees Union, which represents IRS employees.

To summarize and categorize the critical success factors identified, we 
grouped together similar factors that were most frequently cited by the 
officials with experience in government debt collection contracting. We 
first grouped factors associated with the start of a program and with a 
maturing program into two broad time-oriented factors, including topics 
we identified as implicit in the interviews and documents cited above. 
Between these two time-oriented factors, we categorized three other 
factors according to the broad topics that were most frequently cited. 
To validate our summarization and categorization, we asked for comments 
on our draft list of critical success factors from those who we had 
consulted to identify the factors as well as from officials at four 
additional PCA firms that, according to interviewed officials from two 
state revenue departments and the two federal agencies, had experience 
in government debt collection. In commenting on the draft list of 
factors, some officials stressed certain factors more than others or 
elaborated on selected factors or subfactors, but generally did not 
suggest factors beyond those encompassed in our draft list. We made 
changes based on their comments where appropriate.

To determine whether IRS has addressed the critical success factors in 
developing the PCA contracting program and, if not, what is left to be 
done, we interviewed IRS program officials. We analyzed program 
documents, including the draft PCA contract as outlined in IRS's 
Request for Quotes (RFQ)[Footnote 13] and the Office of Management and 
Budget (OMB) Form E-300[Footnote 14] budgetary document that describes 
goals and plans for the program. We did not attempt to analyze how well 
or to what extent IRS addressed the factors, or whether IRS made the 
right decisions on issues such as the program goals or measures.

To determine whether, if IRS receives authority to use PCAs, it will do 
a study that will enable policymakers to judge whether contracting with 
PCAs is the best use of federal funds to achieve IRS's collection 
objectives, we interviewed IRS program officials. We reviewed any 
studies IRS had done to compare the use of PCAs with other strategies 
and assessed IRS's intended approach for any future studies. We also 
applied our knowledge of how to study the cost-effectiveness of options 
to meet a desired result or benefit.

We did our work from June 2003 through March 2004 in accordance with 
generally accepted government auditing standards.

Five Factors Are Critical for a Successful PCA Collection Program: 

Our work identified and validated five broad factors that are critical 
to the success of a proposed program for contracting with PCAs to 
collect tax debt. A general description of each critical success factor 
follows: 

* Results orientation involves establishing expectations, measures, and 
desired results for the program.

* Agency resources involve obtaining and deploying various resources.

* Workload involves ensuring that the appropriate cases and case 
information are provided to PCAs.

* Taxpayer issues involve ensuring that taxpayer privacy and other 
rights are protected.

* Evaluation involves monitoring performance and collecting data to 
assess the performance of PCAs and the overall program.[Footnote 15]

As figure 1 illustrates, the factors are considered "success" factors 
because each one, if adequately addressed, can help ensure that the PCA 
program achieves desired results, such as in collecting tax debts. 
Although addressing all factors during program design and 
implementation does not guarantee success, doing so could improve the 
chances.

Figure 1: Five Critical Success Factors Help Achieve Desired Results: 

[See PDF for image]

[End of figure]

Table 1 further describes the critical success factors by showing their 
related subfactors that we identified and validated.

Table 1: Critical Success Factors and Related Subfactors for 
Contracting with PCAs for Tax Debt Collection: 

Critical success factor: Results orientation; 
Related subfactors: 
* Determine expected program goals, costs, and overall results for 
contracting with PCAs; 
* Establish contract provisions and operational expectations, 
measurable PCA performance evaluation standards, and PCA rewards and 
disincentives based on performance and ensure that the government 
agency and PCAs have a common understanding of these elements; 
* Give PCAs as much freedom as practical on how to achieve performance 
goals; 
* Use a contracting process that will help ensure that PCAs selected 
are able to meet operational and performance expectations.

Critical success factor: Agency resources; 
Related subfactors: 
* Provide sufficient staffs to do work associated with contracting with 
PCAs, including administrative functions, contract oversight, and 
working collection cases referred back by the PCAs; 
* Have management commitment to using PCAs; 
* Ensure that PCA employees receive appropriate training on such areas 
as taxes and case handling procedures; 
* Ensure that computer systems will allow data to be exchanged 
electronically between PCAs and the government agency and that payments 
will be tracked and accounts updated; 
* Be aware of and control costs of functions related to contracting.

Critical success factor: Workload; 
Related subfactors: 
* Select the appropriate type and volume of cases for PCAs to work on; 
* Ensure that contractors work on the range of cases that they are 
assigned in terms of ease of collection and amounts due; 
* Provide PCAs appropriate, accurate information on taxpayers and 
accounts.

Critical success factor: Taxpayer issues; 
Related subfactors: 
* Ensure that taxpayers are treated properly by PCAs; 
* Ensure the security of taxpayer information provided to PCAs.

Critical success factor: Evaluation; 
Related subfactors: 
* Perform ongoing monitoring of PCAs in various aspects of operations 
and performance expectations; 
* Measure PCAs' performance in light of performance standards and 
distribute rewards/disincentives; 
* Evaluate whether the program meets its goals and expectations and 
adjust the program as needed.

[End of table]

Source: GAO analysis of selected GAO reports and interviews with 
officials from selected state and federal agencies and PCA firms.

IRS Has Taken Steps to Address Aspects of the Critical Success Factors 
but Has Much Work Remaining: 

IRS has taken steps to address the critical success factors and 
developed a project plan to help finish addressing the factors if 
Congress authorizes use of PCAs. Officials recognize that much work 
needs to be done to sufficiently address each factor, which they 
estimate will take 18 to 24 months after any legislation passes. Table 
2 shows examples of the key actions taken to address the critical 
success factors and major tasks remaining. Discussion after table 2 
elaborates on some of these major tasks.

Table 2: Examples of Key Actions IRS Has Taken to Address Critical 
Success Factors and Examples of Major Tasks Remaining: 

Critical success factor: Results orientation; 
Examples of key actions taken: 
* Developed performance measures and goals, spelling out desired 
results for PCAs; 
* Adopted a performance-based PCA compensation strategy, using 
incentives and disincentives; 
* Provided PCAs freedom to determine how to collect tax debts, but 
imposed certain restrictions (e.g., taxpayer rights, privacy); 
* Decided to use the list of approved federal contractors maintained by 
the U.S. General Services Administration; 
Examples of major tasks remaining: 
* Finalize the goals, measures, and compensation system in the contract
to be put out for bids.

Critical success factor: Agency resources; 
Examples of key actions taken: 
* Identified an infrastructure to administer contracts, provide 
oversight, and work on cases referred back to IRS; 
* Identified initial staff needs; 
* Received IRS management commitment to support the PCA program if 
legislative authority is granted; 
Examples of major tasks remaining: 
* Complete the administration infrastructure; 
* Verify that initial staffing is appropriate; 
* Illustrate management commitment by providing resources; 
* Develop a program to track resources and costs associated with the 
PCA program.

Critical success factor: Workload; 
Examples of key actions taken: 
* Started to develop a risk-scoring model to identify the most 
appropriate cases to be referred to PCAs; 
* Established incentives to encourage PCAs to work on the full range of 
simpler cases assigned to them; 
* Started planning development of a computer interface system to ensure 
that PCAs receive accurate data on taxpayer accounts; 
Examples of major tasks remaining: 
* Finish and test the case selection model; 
* Use the model to annually determine the type and number of cases to 
be referred to PCAs; 
* Finish and test the computer interface system; 
* Train IRS staff on working with PCAs on case selections/referrals and 
data transfers.

Critical success factor: Taxpayer issues; 
Examples of key actions taken: 
* Established draft contract provisions on how; 
* PCAs must treat taxpayers and protect data,; 
* PCAs must follow federal laws, and; 
* IRS will check PCA compliance in these areas; 
Examples of major tasks remaining: 
* Develop training courses and train PCA employees on taxpayer issues; 
* Develop and finalize plans to monitor calls to taxpayers and survey 
their satisfaction with PCAs.

Critical success factor: Evaluation; 
Examples of key actions taken: 
* Established draft contract provisions on monitoring and evaluating 
PCA and program performance against program goals, performance 
measures, and the performance-based compensation system; 
Examples of major tasks remaining: 
* Develop programs for monitoring PCA performance and evaluating 
program performance against the goals; 
* Train IRS staff on how to do the evaluations and monitoring; 
* Use the results to manage the PCA program. 

Source: Interviews with IRS officials and reviews of IRS documents.

[End of table]

IRS officials are aware of these major tasks that must be completed to 
address the critical success factors and implement the PCA program. In 
discussing their intent to address them, IRS officials elaborated on 
some of the major tasks.

* Under "results orientation," IRS is aware that it has to clarify a 
goal on how much it expects to collect. IRS had estimated originally 
that the PCA program would result in $9 billion in tax collections and 
produce $7.2 billion in net revenue over 10 years. The Department of 
the Treasury estimated that $1.5 billion in net revenue would be 
produced over 10 years. IRS officials said the differences arise 
because each estimate was done differently. IRS acknowledged that its 
original estimate may be too high and is reworking it in light of the 
Treasury estimate.

* Under "workload," IRS officials said that they are aware of the 
importance of selecting the right cases to send to PCAs for collection 
and plan to use consumer credit history data on delinquent taxpayers to 
identify those that would be more likely to pay if contacted. IRS 
officials said that the new case collection system will extend beyond 
selecting cases for PCAs, and that the experience and knowledge IRS 
will gain would contribute to IRS's broader modernization program for 
using data to improve how IRS does collection work. For example, IRS 
officials said that, in the future, the case selection data might be 
used to help determine which collection method--such as sending 
notices, using PCAs, or making in-person contact--might be more 
effective in attempting collection from a given taxpayer.

* Under "evaluation," IRS officials said that they were aware that they 
had not developed plans or dates for evaluating the program to assess 
how well the PCA program achieves its results. IRS officials said that 
developing the evaluation was premature given the other work needed to 
develop the program and lack of legislative authority. IRS officials 
said they intend to start developing the evaluation plan after they 
receive this authority and to finish it before sending cases to PCAs. 
Evaluation plans developed before program implementation increase the 
likelihood that the necessary data and resources for proper evaluation 
will be available when needed.

* Many of the factors involve the development of an information system. 
Testing of information systems being developed for the PCA program is 
an important task left to do. Our interviews with IRS officials and our 
reviews of IRS documents indicate that IRS plans on testing the 
information systems to be used in the PCA program.

IRS officials informed us that they have slowed development of the 
program due to funding constraints and uncertainty over whether and 
when legislation will pass to authorize contracts with PCAs. Because 
IRS's fiscal year 2004 budget was not passed until January 2004, IRS 
officials said that, since September 2003, IRS slowed work on the PCA 
program. These officials said that, because of various budgetary 
procedures, the appropriated funds were not released to the PCA program 
until March 2004. However, the officials explained that IRS, intending 
to be fiscally prudent, is delaying spending of the funds until passage 
of the legislation appears to be more imminent.

IRS officials stated that if legislation to authorize the program was 
not passed during 2004, IRS eventually would suspend work on developing 
the program. These officials said that they have been balancing and 
managing their existing funds and the timing of their work given that 
the authorizing legislation might not pass. If this legislation passes, 
IRS officials said that they would need another 18 to 24 months 
afterwards to complete the many tasks remaining, as shown in table 2. 
IRS officials said that, if Congress passes authorizing legislation in 
summer 2004, the estimated date for starting to send cases to PCAs is 
July 2006.

Potential Study Design Would Provide Limited Information to Judge 
Whether Contracting with PCAs Is the Best Use of Resources: 

Although IRS officials intend to study the relative performance of PCAs 
and IRS employees in collecting delinquent taxes, the study approach 
under initial consideration would provide policymakers limited 
information to judge whether and when the PCA strategy is the best use 
of resources. The tentative idea for a design--comparing PCA and IRS 
performance for similar types of simple cases that would be sent to 
PCAs--does not recognize that IRS officials believe that using 
employees on these cases would not be their best use given the need to 
work on other, higher priority cases.

The Cost-Effectiveness of the Proposed Use of PCAs Has Been Questioned: 

Among other issues concerning the proposed use of PCAs, policymakers 
and others have questioned whether using PCAs to collect tax debts is 
more efficient or effective than having IRS employees do so. During 
consideration of IRS's proposal, some members of Congress questioned 
whether IRS could collect the taxes that IRS plans to assign to PCAs at 
less cost or whether IRS would be able to collect a higher portion of 
the taxes that are due. During hearings, some witnesses raised similar 
concerns.[Footnote 16]

IRS officials have said that IRS employees might be more effective than 
PCAs in collecting delinquent taxes because IRS employees have greater 
powers to enforce collections. These powers (such as tax liens and wage 
levies) may enable IRS employees to collect a higher portion of the 
taxes from the same types of cases on which PCAs would work.

IRS officials said that the proposal to use PCAs to collect simpler tax 
debts was not based on a judgment that PCAs would necessarily be more 
efficient or effective in collecting delinquent tax debt. Rather the 
proposal was based on a judgment that Congress was unlikely to approve 
a substantial increase in IRS's budget to fund additional staff for the 
collection function. Officials believed that the growing inventory of 
tax debts was not a good signal to taxpayers about the importance of 
complying with their tax obligations. Given constraints in hiring 
staff, IRS officials said that using PCAs was the only practical means 
available to begin working on significantly more collection cases that 
otherwise would not be worked on due to IRS staffing constraints.

Although this policy judgment served as the rationale behind the PCA 
proposal, in March 2004, IRS provided us with projections of revenues 
and federal government costs for the proposed PCA program compared to 
projections for an alternative approach under which IRS would hire 
additional staff to work on the same volume for selected types of cases 
on which the PCAs would work.[Footnote 17] According to the analysis, 
PCAs would generate $4.6 in revenue for every dollar in cost and IRS 
employees would generate $4.1.

We did not review the data and assumptions that underlie these revenue 
and cost projections because the comparison that IRS constructed did 
not address the relevant economic question for policymakers seeking to 
reduce the backlog of uncollected taxes--which is, what is the least 
costly approach for reaching a certain revenue collection goal. IRS's 
analysis did not examine other feasible approaches that IRS might be 
able to use, if given additional resources, to collect the same amount 
of revenue that the PCAs would bring in, but at lower cost.

Study Approach Being Considered: 

Assuming IRS receives authority to use PCAs, IRS officials said they 
would design a study to compare the performance of PCAs versus IRS 
employees. However, the study approach under initial consideration 
would provide policy makers limited information to help determine 
whether the use of PCAs as currently proposed is the best use of 
federal resources to collect tax debts. IRS's approach might show 
whether PCAs or IRS employees are best at working on certain types of 
collection cases, but would not show whether the use of PCAs as planned 
would be the best use of resources to deal with the overall collection 
workload.

IRS officials said that although they believe they should conduct a 
study that compares PCA results to results achieved by IRS employees, 
they have not designed such a study.[Footnote 18]They expect to design 
the study after authorization to use PCAs is enacted and before sending 
cases to PCAs. Although the study approach will evolve, officials said 
that they are considering selecting a sample of the same type of 
simpler cases that will be sent to PCAs and having such cases also sent 
to a group of IRS telephone collection employees. The results generated 
by these IRS employees and by PCAs would be compared to see which 
option is more effective; how effectiveness would be defined and 
measured would be determined in designing the study. This potential 
design would help answer the relatively narrow--but important--question 
of whether and when PCAs or IRS employees are a better choice for 
working on the specific types of cases to be sent to PCAs.

However, IRS officials told us that using IRS employees on these 
simpler cases would be less productive than assigning them to work on a 
different mix of collection cases. These officials said that the 
simpler cases IRS plans to assign to PCAs are generally not those cases 
that IRS would assign to any additional collection employees, if hired. 
IRS employees would work on more complex cases that fit their skills 
and enforcement powers and that have a higher priority due to such 
factors as the type and amount of tax debt or length of the 
delinquency.

Generally, federal officials are responsible for ensuring that they are 
carrying out their responsibilities as efficiently and effectively as 
possible. Various federal and IRS guidance reinforces this 
responsibility. For example, according to OMB Circular A-123 "the 
proper stewardship of Federal resources is a fundamental responsibility 
of agency managers and staff. Federal employees must ensure that 
government resources are used efficiently and effectively to achieve 
intended program results." OMB Circular A-94 states that agencies 
should have a plan for periodic, results-oriented studies of program 
effectiveness to, among other purposes, help determine whether the 
anticipated benefits and costs have been realized and program 
corrections are needed. IRS guidance states that in selecting among 
course of action options, IRS managers should determine which is the 
most realistic and most cost effective. Further, IRS has adopted a 
critical job responsibility for its managers that specifies their 
responsibility to achieve goals by leveraging available resources to 
maximize efficiency and produce high-quality results.

A study that focuses on the least costly approach to collecting a 
desired amount of tax debts would be more in line with federal guidance 
than the study that officials anticipate performing. Such a study would 
more likely answer the broader question of how IRS can be the most 
efficient and effective in achieving its collection goals. One 
alternative design might entail comparing the results of using PCAs to 
the results from using the same amount of funds to be paid to PCAs in 
an unconstrained manner that IRS determines to be the most effective 
overall way of achieving its collection goals. Determining the most 
effective and efficient overall way of achieving collection goals would 
undoubtedly require some judgment. However, because IRS is developing a 
new case selection model for its own use, after some experience is 
gained both with using PCAs and with new IRS case selection processes, 
IRS should have better data to use in determining the best way of 
achieving its collection goals. If using PCAs as expected under the 
current proposal meets IRS's collection goals at less cost than the 
best unconstrained alternative, policymakers could be comfortable with 
continuing their use. If not, policy makers would have information 
available to consider whether changes in the use of PCAs would be 
appropriate.[Footnote 19]

Regardless of the approach chosen, IRS would have to address several 
challenges in designing a study to compare the use of PCAs and IRS 
employees. For instance, contracting for PCA assistance may provide 
flexibility over hiring additional IRS staff. To recruit, select, and 
train the new staff, IRS could need many months or more and, if 
experienced staff assists in training newly hired staff, the 
experienced staff would not be able to handle normal workloads. 
Further, if the collection workload were to decrease, IRS may be able 
to reduce contract commitments more rapidly than it could reassign and, 
if needed, retrain IRS staff. To some extent, the study would have to 
account for similar types of direct and opportunity costs to hire, 
train, assign, and release employees of the PCA contractor. Accounting 
for these and other factors raises challenges to the design of a 
comparative study.

Because IRS would not assign cases to PCAs for collection until 2006, 
it will have time to take these challenges into account and to better 
ensure that its study would be useful to policy makers. Further, in 
designing the study, IRS would have time to identify the data that 
would be needed for the study and develop systems or processes for 
collecting the data.

Conclusions: 

IRS has an inventory of over $100 billion dollars of tax debts that has 
some potential for being collected. In recent years, IRS has deferred 
collection actions on billions of dollars of debt because it lacked 
collection staff to do the work. The growth in the backlog of unpaid 
taxes poses a risk to our voluntary tax system, particularly as IRS has 
fallen further behind in pursuing existing as well as new tax debt 
cases. We have placed the collection of unpaid taxes on our high-risk 
list since 1990 due to the potential revenue losses and the threat to 
voluntary compliance with our tax laws.

Accordingly, we believe that effective steps need to be taken to 
improve the collection of these unpaid taxes. Because we did not 
analyze available options in this review, we are not taking a position 
on whether the use of PCAs is a preferable option. However, doing 
nothing more than has been done recently is not preferable. The 
compliance signals sent to taxpayers from the backlog of delinquent tax 
debts are not appropriate. When the majority of taxpayers receiving 
phone calls from IRS are those who respond to written IRS notices, 
taxpayers and practitioners may conclude that failing to respond to IRS 
is an effective tactic for avoiding tax responsibilities.

If Congress does authorize PCA use, IRS's planning and preparations to 
address the critical success factors for PCA contracting provide 
greater assurance that the PCA program is heading in the right 
direction to meet its goals and achieve desired results. Nevertheless, 
much work and many challenges remain in addressing the critical success 
factors and helping to maximize the likelihood that a PCA program would 
be successful.

Although IRS did an analysis that suggests that using PCAs may be a 
somewhat more efficient means to collect certain types of delinquent 
debts, that analysis was not done in a manner that informs policymakers 
whether the proposed use of PCAs is the least costly option to achieve 
IRS's collection goals. Further, given the lack of experience in using 
PCAs to collect tax debts, key assumptions are untested. Accordingly, 
if Congress authorizes the use of PCAs, Congress and IRS would benefit 
from a study that uses the experience gained with PCAs and by IRS 
itself in using new case selection processes to better determine 
whether and how the use of PCAs fits into an overall collection 
strategy that is designed to most effectively and efficiently collect 
delinquent taxes. Although IRS officials have preliminary plans to do a 
study that compares the use of PCAs and IRS employees to work the same 
type of cases, this study design would not help policymakers in 
Congress and the executive branch judge whether using PCAs as currently 
proposed is the best use of scarce federal resources.

Recommendation: 

If Congress authorizes the use of PCAs, as soon as practical after 
experience is gained using PCAs, the IRS Commissioner should ensure 
that a study is completed that compares the use of PCAs to a collection 
strategy that officials determine to be the most effective and 
efficient overall way of achieving collection goals.

Agency Comments and Our Evaluation: 

The Commissioner of Internal Revenue provided written comments on a 
draft of this report in a letter dated May 14, 2004 (see app. III). In 
the letter, the Commissioner said that our findings would help IRS 
focus its PCA program development efforts on those areas most critical 
to success of the program if Congress authorizes IRS's use of PCAs. He 
agreed that IRS had taken actions to address the critical success 
factors we identified and acknowledged that significant actions are yet 
to be done, referring to several key PCA program project plan steps 
that have not been completed.

In response to our recommendation that, if Congress authorizes IRS's 
use of PCAs, IRS do a study that compares the use of PCAs to a 
collection strategy that officials determine to be the most effective 
and efficient overall way of achieving collection goals, the 
Commissioner agreed that IRS would need to analyze the PCA program to 
determine its effectiveness and impact on the overall collection of 
delinquent taxes. He said that the detailed design for evaluating the 
PCA program will include a study to ensure that IRS is making the most 
effective and cost efficient use of total resources available.

We are also sending copies to the Secretary of the Treasury, the 
Commissioner of Internal Revenue, the Director, Office of Management 
and Budget, and other interested parties. We will make copies available 
to others on request. In addition, the report will be available at no 
charge on the GAO Web site at [Hyperlink, http://www.gao.gov].

This report was prepared under the direction of Thomas D. Short, 
Assistant Director. Appendix IV also lists major contributors to this 
report. If you have any questions about this report, contact me at 
[Hyperlink, brostekm@gao.gov] or Tom Short at [Hyperlink, 
shortt@gao.gov], or either of us at (202) 512-9110.

Signed by: 

Michael Brostek, 
Director, Tax Issues: 

List of Committees: 

The Honorable Charles E. Grassley: 
Chairman: 
The Honorable Max Baucus: 
Ranking Minority Member: 
Committee on Finance: 
United States Senate: 

The Honorable William M. Thomas: 
Chairman: 
The Honorable Charles B. Rangel: 
Ranking Minority Member: 
Committee on Ways and Means: 
House of Representatives: 

The Honorable Tom Davis: 
Chairman: 
The Honorable Henry A. Waxman: 
Ranking Minority Member: 
Committee on Government Reform: 
House of Representatives: 

[End of section]

Appendixes: 

Appendix I: Trends in IRS Collections Programs, 1996-2003: 

Figure 2 below shows the annual gap between the number of cases 
assigned to field and telephone collections and the number of 
delinquent accounts worked to closure (excluding accounts for which 
collection workload was deferred) expressed as a percentage of the 
number of cases assigned.

Figure 2: Annual Gap Between Collection Cases Assigned and Cases Closed 
as a Percentage of Cases Assigned, Fiscal Years 1996 through 2003: 

[See PDF for image]

[End of figure]

Figure 3: Number of Revenue Officers Working on Delinquent Accounts, 
1996 through 2003: 

[See PDF for image]

[End of figure]

[End of section]

Appendix II: Actions IRS Has Taken to Address Critical Success Factors: 

The following appendix provides some detail on various IRS actions to 
address the critical success factors.

Critical Success Factor--Results Orientation: 

IRS envisions that the PCA program will meet the following goals: 

* Increase the collection of tax debts by $9.2 billion.

* Increase the closure of tax debt cases by 17 million taxpayers.

* Reduce the tax debt backlog; and: 

* Increase taxpayer satisfaction by 12.5 percent.

To motivate PCAs to achieve these results, IRS is devising a balanced 
set of measures--the "balanced scorecard"--and a related performance-
based compensation system. The performance scores on these measures 
also are to be used in determining financial bonuses and future case 
allocations to PCAs. Specifically, PCAs with above-average performance 
scores are to be eligible for monetary bonuses if they meet minimum 
thresholds for five of six performance measures. Also, the performance 
score is to be translated into a value for each PCA that is to be used 
to determine a proportionate allocation of cases for the next quarter. 
IRS's intent is that the balanced scorecard will ensure that collection 
efforts are balanced appropriately in providing quality service; 
ensuring adherence to taxpayer rights; and complying with IRS policies, 
procedures, and regulations. The performance measures are to include 
the following.

* Collection effectiveness: Dollars collected as a percentage of 
dollars assigned to be collected over the contract period.

* Case resolution: Resolving cases assigned through the payment of the 
tax debts immediately or through installment payments over 3 years, 
identification of bankrupt or deceased taxpayers, or identification of 
hardships that affect the taxpayers' ability to pay.

* Taxpayer satisfaction: Satisfaction will be measured through random 
surveys of taxpayers on the accuracy and quality of actions taken by 
PCA employees and their adherence to various standards, and through 
taxpayer complaints.

* PCA employee satisfaction: Satisfaction will be measured through 
surveys of employees and their retention rates.

* Work quality: Quality will be measured through audits of PCA cases 
and telephone monitoring of interactions with taxpayers.

* Validated taxpayer complaints: Financial penalties will be assessed 
and points will be subtracted from PCA performance scores if taxpayer 
complaints are validated.

Critical Success Factor--Agency Resources: 

IRS has set up an infrastructure to: 

* administer the PCA program,

* oversee PCA contractors, and: 

* work on cases referred back to IRS from PCAs.

IRS has identified initial staffing needs for the PCA program. IRS has 
estimated that 100 full-time equivalency positions (FTE) will be needed 
to initially staff the three elements of the program. IRS estimates 
that it will need 30 FTEs to administer the program and do oversight, 
and 70 FTEs to work on the cases referred back to IRS from PCAs for the 
first round of PCAs selected to work on cases. As IRS learns about its 
staffing needs and sends cases to more PCAs over time, IRS plans to 
adjust its staffing accordingly.

Critical Success Factor--Workload: 

IRS has informed PCAs that the number of cases that they receive over a 
set time period is to be based on their performance scores against 
balanced measures. IRS plans to oversee the assigned workload to ensure 
that PCAs work on the full range of simpler cases. To motivate PCAs to 
work on the full range of cases, IRS plans to measure, among other 
things, the extent to which PCAs resolve cases sent to them, including 
those that PCAs refer back to IRS without resolving the tax debt. IRS 
also is working on systems to help it identify the best cases to send 
to PCAs and to help it transmit and manage those cases.

Critical Success Factor--Taxpayer Issues: 

IRS has drafted provisions to ensure that PCAs know that they have to 
treat taxpayers properly and make them aware of the consequences of not 
treating taxpayers properly. Proper treatment of taxpayers is one of 
the performance measures used to determine a performance score for use 
in granting monetary bonuses and case allocations for PCAs. The 
following provides examples of the draft provisions on proper taxpayer 
treatment.

* PCAs shall comply with all applicable federal and state laws. The 
principal federal statues and regulations currently governing 
collection activities are to be followed. Further, IRS plans to monitor 
PCA collection activities and treatment of taxpayers; any behavior that 
is not in conformance with cited federal and state laws and regulations 
will be considered a breach of contract.

* IRS has informed PCAs that it will be conducting customer 
satisfaction surveys and that customer satisfaction is one of the key 
components of the balanced scorecard to be used to determine financial 
bonuses and future case allocation.

* IRS plans to require that PCAs inform taxpayers orally and in writing 
on how to report improper treatment by PCA employees to IRS.

Critical Success Factor--Program Evaluation: 

IRS has established preliminary plans for monitoring and measuring PCA 
performance through such means as conducting site visits and 
compensating PCAs according to their performance reflected in the 
balanced measures scorecard. However, IRS has deferred doing much work 
on evaluating program performance overall given the other work that had 
to be done and the resources that were available.

[End of section]

Appendix III: Comments from the Internal Revenue Service: 

COMMISSIONER:

DEPARTMENT OF THE TREASURY 
INTERNAL REVENUE SERVICE 
WASHINGTON, D.C. 20224:

May 14, 2004:

Mr. Michael Brostek 
Director, Tax Issues 
U.S. General Accounting Office 
441 G Street, NW Washington, DC 20548:

Dear Mr. Brostek:

I am responding to your draft report titled, Tax Debt Collection: IRS 
Is Addressing Critical Success Factors for Contracting Out but Will 
Need to Study the Best Use of Resources (GAO-04-492). I believe the 
findings presented in your draft report will assist IRS to continue 
focusing our development efforts in those areas most critical to 
successful implementation of the Collection Contract Support (CCS) 
program. This preparation will greatly assist us in implementation, 
should Congress enact legislation authorizing IRS to contract with 
Private Collection Agencies (PCAs).

As noted in your draft report, we have already undertaken a number of 
actions to ensure success in the development of the PICA program, which 
include: developing performance measures and goals; adopting a 
performance-based PCA compensation strategy; identifying an 
infrastructure to administer contracts, providing oversight and working 
accounts not resolved by PCAs; drafting provisions on how taxpayer's 
are to be treated by PCAs; drafting contract provisions for monitoring 
and evaluating PICA and program results against goals, and developing 
measures and the performance-based compensation system.

We acknowledge there are significant activities that still need to be 
accomplished in order to successfully implement the CCS program, such 
as: finalizing goals, measures, and the compensation system for the 
final request for proposals; developing a program to track resources 
and costs associated with the PICA program; completing development and 
testing of the case selection and inventory management systems; 
developing training courses for PCA and IRS employees and conducting 
the training; and using results to manage the PICA program.

Your report recognizes we have a project plan in place to finish work 
on the critical success factors associated with implementation of this 
legislation. Along with the action items already mentioned, the project 
plan includes: identifying and securing IRS and developing resources to 
ensure all project activities are completed timely; managing the 
technology phases of the project including 
integration into current systems; coding and testing of applications; 
reviewing, certifying and deploying systems security; developing policy 
and procedures; identifying and selecting of PCAs; performing risk 
management planning; and engaging stakeholders. We believe this 
comprehensive and detailed project plan puts us on track to achieve 
success.

Our comments concerning your recommendation follow.

Recommendation: If Congress authorizes the use of PCAs, as soon as 
practical after experience is gained using PCAs the IRS Commissioner 
should ensure that a study is completed that compares the use of PCAs 
to a collection strategy that officials determine to be the most 
effective and efficient overall way of achieving collection goals.

Comments: We agree with the need to perform analysis of the CCS 
program, once data is readily available, to determine its effectiveness 
and the impact on the overall collection of delinquent taxes. The GAO 
has acknowledged we have preliminary plans to develop and conduct 
program evaluation of PCAs after implementation of the CCS program. The 
detailed design of this phase will include a study to ensure we are 
making the most effective and cost efficient use of total resources 
available. As part of those efforts we will evaluate the effectiveness 
of the PCA program and how this program fits into the overall 
Collection strategy.

I appreciate GAO's input and will continue to take the necessary steps 
to ensure the success of the Collection Contract Support program.

If you have any questions, please contact me at (202) 622-9511 or Dale 
F. Hart, Commissioner, Small Business/Self-Employed Division, at (202) 
622-0600.

Sincerely,

Signed by: 

Mark W. Everson:

[End of section]

Appendix IV: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Michael Brostek, (202) 512-9110 Thomas D. Short, (202) 512-9074: 

Acknowledgments: 

In addition to those named above, Evan Gilman, Ronald Jones, John 
Lesser, Cheryl Peterson, and Jim Wozny made key contributions to this 
report.

(450222): 

FOOTNOTES

[1] Known unpaid taxes due the government include delinquent taxes (as 
well as penalties and interest) owed that IRS has attempted to collect 
but has decided not to continue pursuing. 

[2] U.S. General Accounting Office, Financial Audit: IRS's Fiscal Years 
2003 and 2002 Financial Statements, GAO-04-216 (Washington, D.C.: Nov. 
13, 2003). 

[3] U.S. General Accounting Office, Major Management Challenges and 
Program Risks: Department of the Treasury, GAO-03-109 (Washington, 
D.C.: January 2003). The collection of unpaid taxes high-risk area also 
encompasses the amount of unpaid taxes that are due the government but 
that IRS has not identified.

[4] U.S. General Accounting Office, Internal Revenue Service: Issues 
Affecting IRS's Private Debt Collection Pilot, GAO/GGD-97-12R 
(Washington, D.C: July 18, 1997).

[5] U.S. General Accounting Office, Tax Administration: Impact of 
Compliance and Collection Program Declines on Taxpayers, GAO-02-674 
(Washington, D.C.: May 22, 2002).

[6] In 1999, IRS's collection case selection system began forwarding 
cases for collection only if they met certain dollar threshold, age, 
and case characteristics. Those not forwarded were "deferred." 

[7] See U.S. General Accounting Office, Compliance and Collection: 
Challenges for IRS in Reversing Trends and Implementing New 
Initiatives, GAO-03-732T (Washington, D.C.: May 7, 2003); and Internal 
Revenue Service: Assessment of Fiscal Year 2005 Budget Request and 2004 
Filing Season Performance, GAO-04-560T (Washington, D.C.: Mar. 30, 
2004).

[8] See, e.g., S. 1637, 108th Cong. § 487 (2003) and H.R. 3967, 108th 
Cong. § 521 (2004). 

[9] According to IRS officials, decisions such as the adjustment of the 
amount of tax debts and the use of enforcement powers to collect the 
debts are inherently governmental functions that are to be made by 
government employees rather than PCA employees.

[10] U.S. General Accounting Office, Information Technology: Leading 
Commercial Practices for Outsourcing of Services, GAO-02-214 
(Washington, D.C.: Nov. 30, 2001); Contract Management: Guidance Needed 
for Using Performance-Based Service Contracting, GAO-02-1049 (Sep. 30, 
2002); and Contract Management: Commercial Use of Share-in-Savings 
Contracting, GAO-03-327 (Jan. 31, 2003).

[11] FTA is an organization whose membership includes the principal tax 
collection agencies of the 50 states, the District of Columbia, and New 
York City. According to its charter, FTA's mission is to improve the 
quality of state tax administration by providing services to state tax 
authorities and administrators.

[12] According to IRS data, about 40 state revenue departments and the 
District of Columbia have used PCAs for the collection of delinquent 
taxes. 

[13] An RFQ is a solicitation to identify contractors willing to meet 
the statement of work to be done.

[14] OMB Form E-300, Capital Asset Plan and Business Case, 2003.

[15] The purpose of program performance evaluation is to help assess 
how well the program is achieving its goals, rather than whether 
another program option would be a better use of agency resources to 
achieve those goals.

[16] For example, see Subcommittee on Oversight, Committee on Ways and 
Means, U.S. House of Representatives, Hearing on Use of Private 
Collection Agencies to Improve IRS Debt Collection (Washington, D.C.: 
May 13, 2003), http: //waysandmeans.house.gov/
hearings.asp?formmode=view&id=1043 (downloaded Apr. 6, 2004).

[17] The types of cases PCAs would work on include cases in which (1) 
taxpayers filed a tax return showing taxes due but that have not been 
paid and (2) taxpayers made three or more voluntary payments to satisfy 
an additional tax assessed by IRS but have stopped making payments. The 
total cost to the federal government included those paid from IRS's 
budget as well as fees paid to PCAs.

[18] Given other work and limited staff, officials were deferring work 
on the study design until the use of PCAs was authorized.

[19] As noted earlier in this report, IRS 's budget requests for more 
collection staffing have not resulted in increased staffing because of 
such factors as increased workloads in other areas and unfunded cost 
increases. If IRS were to request more staffing to reduce the tax debt 
inventory, and Congress wanted to be assured that funds would be used 
for this purpose, Congress could dedicate the appropriation. Congress 
has done this for selected other areas in which tax compliance has been 
a concern, such as earmarking appropriated funds to address concerns 
with overclaims for the earned income tax credit. 

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