Taxpayer Advocate acknowledges shortcomings

National Taxpayer Advocate Erin Collins issued a mea culpa admitting to the findings of a recent report faulting the Taxpayer Advocate Service that she runs for slow responsiveness to taxpayers.

In a blog post Thursday, Collins initially seemed to blame the local offices for problems with answering the phones, but then acknowledged wider problems with TAS at the national level.

The local phone lines were the subject of a report by the Treasury Inspector General for Tax Administration that found local TAS phone lines were not consistent in giving taxpayers the ability to speak with a TAS representative. TIGTA called all 76 local TAS telephone lines in the United States, including offices in the District of Columbia and Puerto Rico, using the telephone numbers listed on the TAS and IRS websites. The calls found some telephone lines were not in service, voicemail boxes were full, and inconsistent recorded scripted messaging and callback time frames. Only two telephone lines were answered by a TAS representative.  Voicemail prompts indicated that callbacks would be received within time frames ranging from one business day to four weeks.  

Collins wrote that the problem with the local phone lines was limited in scope because most calls are placed to TAS's national toll-free number, and TAS immediately took corrective actions to address TIGTA's findings.

But she acknowledged a larger issue in the findings. "Although TAS ultimately serves most taxpayers well, we are not starting to work cases and we are not returning telephone calls as quickly as we would like," Collins wrote. "Part of my job is to highlight areas where the IRS is not meeting expectations, so it's only fair that I be transparent in acknowledging where TAS is falling short."

She added that TAS is taking actions to improve its level of service to taxpayers, including new technology, as well as hiring and training more personnel. TAS's workload has grown in recent years and Collins said she hears about the problems when she speaks to practitioners. However, she insisted that TAS resolves the majority of taxpayer problems satisfactorily and she pointed to surveys of thousands of customers, 81% of whom reported they were satisfied overall, compared to 15% who aren't satisfied.

But she has been receiving negative feedback, at least from tax professionals. 

"Having said that, I regularly speak to groups of practitioners and hear more complaints than I would like of unreturned phone calls, delays in providing updates, and delays in resolving cases," Collins wrote. "In a nutshell, TAS faces three core challenges in case advocacy:

1. We are receiving more cases;
2. We have recently hired a considerable number of new case advocates who require training before they can effectively assist taxpayers; and
3. We are using a functionally limited case management system that is more than two decades old and causes inefficiencies and delays."

In terms of caseload, she pointed out that TAS has received about 18% more cases in fiscal year 2024 than in the previous two fiscal years, when it received around 220,000 cases, and TAS case advocates are carrying active inventories of over 100 cases at a time. 

In response, TAS has been hiring more case advocates and improving its case management system, leveraging additional funding from Congress. However, Collins pointed out that it takes months, even years, to train these new hires as they will work on cases involving a wide array of procedural and technical issues, including tax return processing, identity theft, audits, collection matters and appeals.

Approximately 30% of TAS's case advocates have less than a year of experience, and around 50% have less than two years of experience. 

"That means nearly one-third of our case advocate workforce is still receiving training and working limited caseloads or have no caseloads yet, and half are likely to require extra support for complex cases," Collins wrote. "TAS has never had a year when so many case advocates were new. To compound the challenges, we have to temporarily reassign experienced case advocates to provide training and supervision for the new hires, further straining our resources to work current cases." 

In response, TAS is looking at improving its training processes, for example, by training new hires on the most prevalent issues first, so they can start working on those high-volume cases faster, while continuing to receive comprehensive training so they can become effective all-around advocates over time. 

Like much of the IRS, TAS is also relying on outdated technology, which is finally being upgraded thanks to recent funding boosts. The current case management system, known as the Taxpayer Advocate Management Information System, or TAMIS, is over 20 years old and lacks the kinds of features common in more modern case management systems. That means TAS case advocates need to spend extra time doing work that could be partially or fully automated.

In response, TAS is developing a new customer relationship management system, called "Phoenix," which it plans to deploy next year. In designing and building the system, TAS is getting feedback from case advocates who use TAMIS to help identify areas where the technology can automate tasks and otherwise improve efficiencies.

"The improvements in efficiency will be significant because we will be better able to understand, see and prioritize work across our workforce from both an employee and a management perspective," said Collins.

The new system will have the flexibility to support continuous improvement. Like the IRS's Where's My Refund? app or online account, one long-term goal is to allow taxpayers, tax pros and congressional staff to communicate with TAS and receive case updates through a What's the Status of my TAS Case? portal or online account. 

"We know our taxpayers want more secure digital communication options and faster service," Collins wrote. "We envision providing more real-time information and updates using system capabilities, while also allowing our case advocates to spend more of their time on case resolution. The data security concerns of allowing direct access to a portal are significant, so this functionality is probably several years away. But we are actively planning toward that goal to improve the taxpayer experience while we advocate on their behalf."