11.3.38  Role and Responsibilities of Disclosure Managers

Manual Transmittal

August 13, 2013

Purpose

(1) This transmits revised text for IRM 11.3.38, Disclosure of Official Information, Role and Responsibilities of Disclosure Managers.

Material Changes

(1) Changes have been made throughout the IRM to add clarity or to change references to organizational titles.

(2) IRM 11.3.38.2 has been updated to incorporate a discussion of the programs from the Privacy, Information Protection and Data Security function that are now a part of the combined Privacy, Governmental Liaison and Disclosure function of the IRS and to reflect changes to the organizational structure due to realignment of the Disclosure and Governmental Liaison (GL) operations.

(3) IRM 11.3.38.3 has been revised to focus on the program management aspects. Supervisory responsibilities are covered in IRM 11.3.38.8. The title of the subsection has been changed to Program Responsibilities of the Disclosure Manager.

(4) IRM 11.3.4 has been renamed to Disclosure Programs and sections 11.3.38.4.1, Disclosure Awareness, 11.3.38..4.2, Quality/Privacy Reviews, 11.3.38..4.3, Help Desk, and 11.3.38..4.4, Training, have been added and subsequent sections renumbered.

(5) References to Functional Coordinators found in IRM 11.3 38.4.1(6) assisting in conducting Quality/Privacy reviews have been deleted. Disclosure no longer uses functional employees dedicated to supporting Disclosure operations on a part-time basis. Subsequent paragraphs have been renumbered accordingly. Other references to Functional Coordinators in this IRM were also deleted or revised.

(6) IRM 11.3.38.5 has been renamed Disclosure Coordination with GL and Safeguards Programs. Sections 11.3.38.5.1 and 11.3.38.5.2 have been added.

(7) Added 11.3.38.6.2 to address the Erroneous Correspondence reporting requirements and the distinction between those requirements and the reporting requirements for CSIRC for data loss notifications.

(8) Revised IRM 11.3.38.7 to reflect the changes to the Deputy Associate Director (DAD) responsibilities and incorporate recent changes to the geographical alignment and removal of GL responsibilities.

(9) IRM 11.3.38.12 titled "Role of Functional Disclosure Coordinators" has been removed.

(10) IRM 11.3.38.4.1, Exhibits 11.3.38-1, Disclosure, Privacy Awareness Plans, and 11.3.38-2, Quality/Privacy Reviews, have been deleted. IRM 11.3.38.4.1 and 11.3.38.4.2 have been revised to delete the requirement for an annual plan and replaced with the need to support the Governmental Liaison and Disclosure (GLD) Strategic Plan or other initiatives rather than create a local plan.

Effect on Other Documents

This material supersedes IRM 11.3.38, Role and Responsibilities of Disclosure Managers, dated October 23, 2009.

Audience

All Operating Divisions and Functions

Effective Date

(08-13-2013)

Related Resources

The Governmental Liaison and Disclosure intranet home page can be found at the following web site: http://discl.web.irs.gov/Default.asp..


Bernice B. Fischer
Director, Governmental Liaison and Disclosure

11.3.38.1  (10-23-2009)
Purpose

  1. This section provides guidelines to assist Disclosure Managers in administering an effective and balanced Disclosure program.

11.3.38.1.1  (10-23-2009)
Background

  1. The confidence the public has in the ability of the Internal Revenue Service (IRS) to protect the confidentiality of tax information influences the public's willingness to opt into our voluntary tax system. A perception that the IRS is careless in preserving privacy rights can have serious compliance ramifications.

  2. Congress has expressed concern over situations where privacy violations appear to have occurred. This can be expected whenever there are indications of improper disclosures or improper use of information by IRS employees.

  3. The privacy of employee information is also important and employee information must only be released in accordance with the Privacy Act or other applicable laws.

  4. Disclosure Managers are responsible for implementing activities that promote privacy principles and/or improve the efficiency of tax administration (program management) and provide for timely and accurate responses to requests for information (casework).

11.3.38.1.2  (08-13-2013)
Objectives

  1. The primary objectives of Disclosure offices are as follows:

    1. Promoting the protection and confidentiality of tax information;

    2. Preserving the privacy rights of taxpayers and employees;

    3. Releasing all requested tax and other sensitive information as appropriate;

    4. Implementing programs to ensure that IRS employees are fully aware of their disclosure responsibilities; and

    5. Responding to requests for access to tax or other sensitive information from various sources.

11.3.38.2  (08-13-2013)
Organizational Structure and Placement

  1. The Disclosure Manager (DM) serves as the first line manager over a staff of employees who provide disclosure services to IRS employees and other stakeholders .

  2. The DM reports directly to the Deputy Associate Director (DAD).

  3. The DAD is responsible for evaluating and reviewing the DM’s management of the Disclosure program.

  4. DADs report to the Associate Director, Disclosure, who reports to the Director, GLD. The Director GLD reports to the Director, Privacy, Governmental Liaison and Disclosure (PGLD) .

  5. Privacy, Governmental Liaison and Disclosure is a service-wide organization that was organized in June 2011 that includes the former Privacy, Information Protection and Data Security (PIPDS) functions as well as the GLD and Safeguards programs.

  6. The following table lists other PGLD offices and their responsibilities:

    Offices Responsibilities
    Office of Privacy Policy
    • Establishes overall IRS Privacy Policy

    Office of Privacy and Information Protection
    • Privacy Compliance including the live data protection program;

    • The privacy Impact Assessment (PIA) process

    • IRS Pseudonym program

    Identity Protection Office
    • Supports initiatives set out in the President's Identity Theft Task Force; and,

    • Implements new identity theft protection measures and works with the Identity Protection Specialized Unit.

    Incident Management Office
    • Manages the reporting and notification of data loss incidents;

    • Leads information protection projects identified in the Data Loss Prevention Action Plan; and,

    • Oversees the data shipping process.

    Office of Information Protection Projects
    • SSN reduction initiatives

    • UNAX Program and,

    • Media Destruction

    Online Fraud Detection and Prevention Office
    • Responsible for detecting efforts to "hack" into "IRS systems and identify outside web pages that attempt to use IRS logos for identity theft purposes."

11.3.38.3  (08-13-2013)
Program Responsibilities of Disclosure Manager

  1. The Disclosure program is divided into two categories:

    • Case management

    • Program management

    Note:

    The case management responsibilities for caseworkers are described throughout various sections in IRM 11.3. This IRM section will describe specific program management and other management responsibilities and the actions necessary to carry out these responsibilities.

  2. Guidelines for the Disclosure program are often provided by the DADs.

  3. The DM is responsible for planning and maintaining a balanced program consistent with operational priorities. .

  4. Despite the size of the case management workload, program management responsibilities are equally important and must be met. Efficient and appropriate use of resources is the key in meeting this objective.

  5. Disclosure office staff serve as the technical experts in all disclosure/privacy matters. Staff's ability to provide accurate and timely guidance is a key element of an effective program.

  6. Disclosure Managers are responsible for the following:

    1. Supervisory duties as described in IRM 11.3.38.8 and the Roles and Responsibilities document.

    2. Coordinating and integrating the Disclosure program with other functions within their area of geographic responsibility.

  7. An effective disclosure program requires the balancing of resources and priorities directed towards delivery of both case and program management objectives. A DM must be technically and administratively competent to accomplish both objectives.

  8. Most disclosures made by employees in any given IRS office are made by individuals other than Disclosure personnel. Through program management delivery, the DM imparts the knowledge necessary for IRS management and front-line personnel to make correct disclosure decisions.

  9. The DM serves as liaison in disclosure matters with other governmental agencies.

  10. The DM supports the GL by reviewing negotiated agreements to ensure appropriate provisions are included where the disclosure of federal tax information (FTI), personally identifiable information (PII) or other sensitive but unclassified information is involved.

  11. There are many aspects of the work that are also affected by privacy policies and initiatives promulgated by the Office of Privacy, Governmental Liaison and Disclosure (PGLD). The DM, because of his/her expertise, may be called on to assist or advise in matters that impact privacy policy for field operations or may be asked to provide resources in support of various PGLD programs or projects.

11.3.38.4  (08-13-2013)
Disclosure Programs

  1. Disclosure is responsible for several programs that have a Servicewide impact:

    • Awareness - ensure that all employees understand Disclosure and Privacy principles and apply them correctly in the performance of their duties.

    • Quality and Privacy Reviews - determine the level at which IRS employees understand and observe disclosure/privacy rules, principles and procedures.

    • Help Desk - respond to IRS employee questions related to IRS disclosure and confidentiality statutes.

    • Training - provide employee training regarding disclosure and non-disclosure of information and Privacy Act responsibilities.

  2. Headquarters Disclosure staff (under the supervision of the Associate Director, Disclosure or the Deputy Associate Director, HQ Disclosure) may also participate in disclosure/privacy awareness activities.

11.3.38.4.1  (08-13-2013)
Disclosure Awareness

  1. The principal objective of the Disclosure/Privacy Awareness program is to ensure, to the extent possible, that all employees know the disclosure and privacy statutes and principles and apply this knowledge correctly in the performance of their duties.

  2. A successful disclosure/privacy awareness program is predicated on a multiplier effect (awareness being further shared and disseminated by recipients). This increases the likelihood of employee compliance with disclosure/privacy statutes and principles. A high degree of compliance translates into the following:

    1. Taxpayer and employee confidence that confidential information is not being misused.

    2. Reduced incidences of unauthorized access (UNAX) and disclosures.

    3. Assurance to Congress that the IRS is providing its employees with the knowledge they need to understand and apply disclosure and privacy rules consistently and correctly.

  3. Headquarters Disclosure is responsible for helping to identify awareness issues and develop materials for field DMs’ use and distribution. These products should be used to ensure delivery of a consistent and accurate message. Copies of various presentations and Hot Topics are contained on the GLD website.

  4. The following actions must be taken by Disclosure Managers to address awareness program objectives:

    1. Implement plans to deliver awareness activities on an on-going basis. The plans are established by PGLD management and identified in the annual GLD Strategic Plan or in other initiatives.

      Note:

      Resources must be made available to provide sufficient coverage of those areas required to be addressed as identified by Director, GLD or by the Headquarters Disclosure Office.

    2. Document all efforts to promote awareness using the electronic inventory system. Issues covered in awareness efforts should be relevant, timely and accurate. Copies of outlines or notes must be maintained and available for review by managers and others with oversight responsibilities.

  5. Headquarters Disclosure staff (under the supervision of the Associate Director, Disclosure or the Deputy Associate Director, HQ Disclosure) may also participate in disclosure/privacy awareness activities.

11.3.38.4.2  (08-13-2013)
Quality/Privacy Reviews

  1. Quality/privacy reviews are used to determine the level at which IRS employees understand and observe disclosure/privacy rules, principles and procedures.

  2. Quality/privacy reviews:

    1. Allow analysis of the effectiveness of awareness efforts.

    2. Isolate areas of disclosure weakness.

    3. Assess progress in overcoming these weaknesses.

    4. Determine areas where additional emphasis is appropriate.

  3. Reviews to be conducted will be determined by PGLD management and identified in the annual GLD Strategic Plan or other management directives.

  4. Quality/privacy reviews conducted by the functions are methods of measuring disclosure compliance.

    Note:

    Records management (destruction) requirements must be considered during reviews, especially in light of Privacy Act and IRS Privacy Principles standards that generally require only relevant and necessary records be maintained.

  5. The DM is responsible for the following:

    1. Supervising their employees that are supporting the reviews initiated by HQ.

    2. Advising HQ Disclosure on any perceived needs for quality reviews based on their observations.

    3. Sharing the results of the HQ Quality/Privacy reviews with their employees, ensuring an understanding of the issues and remedies

    4. Ensuring review results are included in awareness activities with the functions reviewed.

  6. The following is a non-exhaustive list of suggested topics that may warrant a quality/privacy review. The planning of reviews will occur at the HQ level and be predicated upon the availability of resources to deliver the review.

    • IRC § 6103(c) disclosure consents

    • IRC § 6103(e) material interest

    • IRC § 6103(k)(2) amount of outstanding lien

    • IRC § 6103(k)(6) investigative disclosures

    • IRC § 6103(h)(1) Treasury employees

    • IRC § 6103(l)(4)(A) personnel action disclosures

    • IRC § 6013(l)(2) Department of Labor and Pension Benefit Guaranty Corporation

    • Government Accountability Office

    • Privacy Act of 1974 requirements such as Privacy Act notices, Computer Matching Act compliance, and Employee Performance File (EPF) maintenance

    • Projects with State tax agencies

  7. Reports on the results of the reviews will be completed by an analyst on the HQ staff and will include the following:

    1. Subject: Information about what was reviewed.

      Note:

      Language similar to the following can be used: "A review of open case files was conducted on Revenue Agent Groups"

    2. References: A brief discussion or summary establishing the authority for Disclosure to conduct the review or reference to the applicable IRM provision or program letter that requires these reviews. References to IRM 11.3.38 and the GLD Program Letter are acceptable.

    3. Background: A brief discussion about the purpose and intent of the review. Including comments regarding what or who was reviewed and the overall reasons why the review was conducted.

      Note:

      Language similar to the following can be used: "A review of Revenue Agent groups was conducted to determine the level of understanding that compliance employees have with disclosure provisions. Information gathered from the review will be used to focus future awareness activities and to correct any weaknesses found as a result of this review. "

    4. Method of Review: A discussion of what was reviewed and how, the scope and sample size of the review, and the methodology for the selection of cases for review. Include in this section of the report information on how the sample was selected and other important information on the choice of that sample or selected cases for review.

    5. Findings/Analysis: This should include an in-depth discussion of the results of the review, highlighting both the positives and the negatives of what was noted. Where improvements are needed or issues are found must include as findings. Many times, check sheets are available specific to the function or the disclosure issues likely to be encountered. Authors have a lot of latitude in how this part of the report is written, but it may be helpful to take each section of the check sheet and write a brief summary of whether or not any issues or findings were noted. There is no set format as long as adequate details pertaining to the results of the review are listed.

    6. Recommendations: Actions the function should take to address any findings noted. For every finding, there must be a recommendation. The recommendations should be something affirmative that management or IRS employees can control or accomplish with either a change in procedure, increased awareness or some other action.

    7. Conclusions: A discussion and calculation of the compliance rate (take the number of errorless cases divided by the number of cases reviewed, and convert to a percentage to get the overall compliance rate), whether the overall results were favorable or not, recommendations for any follow-up reviews or awareness activities and when, if known.

  8. The staff of the Associate Director, Disclosure will conduct an analysis of significant trends for use in drafting an overall executive summary report discussing results of the review and planned actions to address disclosure issues noted to share with appropriate PGLD management.

11.3.38.4.3  (08-13-2013)
Help Desk

  1. The DADs, Disclosure (East and West) are required to provide resources (managers and staff) to support the Servicewide Disclosure Help Desk.

  2. The Help Desk is responsible for responding to IRS employee questions and inquiries related to IRS disclosure and confidentiality statutes and the employees' responsibilities in adhering to them.

  3. The DADs ensure their DMs provide adequate staff coverage of the phone system.

  4. DMs also ensure their staff direct calls for Disclosure Office assistance to the Help Desk and encourage all callers to use thesystem when questions requiring Disclosure expertise arise.

11.3.38.4.4  (08-13-2013)
Training

  1. DMs are responsible for providing employee training regarding disclosure and non-disclosure of information and Privacy Act responsibilities.

  2. The DMs should use the following guidelines to carry out training responsibilities:

    1. Provide technical guidance and direction to all employees (includes providing new functional coordinators with the appropriate training as soon as practicable).

    2. Ensure the adequacy, quality and effectiveness of disclosure-related training programs by assisting in development of local training materials and attending local training classes to address employees’ concerns and answer disclosure-related questions.

  3. See IRM 6.410.1, Learning and Education, for Disclosure training requirements, and IRM 11.3.14.9, Privacy Principles, for Privacy Act training.

11.3.38.5  (08-13-2013)
Disclosure Coordination with GL and Safeguards Programs

  1. Disclosure coordinates certain activities with other offices within PGLD, primarily the Office of Governmental Liaison (GL) and the Office of Safeguards.

11.3.38.5.1  (08-13-2013)
Coordination with Office of Governmental Liaison

  1. Liaison activities with state tax agencies are carried out by the local GL.

  2. Disclosure Managers ensure compliance with law and policy such as:

    • IRC § 6103(d)

    • Policy Statement P-1-1, Mission of the IRS

    • Policy Statement P-1-35, Agreements to exchange information with States entered into when in the interest of good tax administration

    • Policy Statement P-6-14, FedState Relations

  3. The Disclosure Manager, in coordination with the GL, has responsibility for the following:

    1. Negotiating and ensuring compliance (e.g. need and use determinations) with the basic agreement, all supporting agreements, and all memorandums of understanding.

    2. Coordinating activities (based on local assignment for responsibility).

    3. Ensuring preparation of disclosure accountings.

  4. The DM is responsible for ensuring that disclosure standards are maintained in the basic agreement, implementing agreements, or any other type of agreement or memorandum of understanding that may exist between state tax agencies and the IRS. To carry out this responsibility, DMs must:

    1. Consult with the GL and state tax agency officials regarding disclosure problems involved in proposed formal agreements on coordination of tax administration. Review the execution of such agreements as necessary.

    2. Assist the GL in negotiations with state tax agency officials concerning the provisions of agreements that will supplement the basic agreement. Specify the nature, quantity, and mechanics for exchange of tax information, including tolerances and criteria for selection.

    3. Conduct ongoing need and use determinations prior to releasing or approving the release of tax information and ensure need and use documentation is maintained for each item of tax information to be disclosed, including all items pursuant to the agreement, MOU and electronic data exchange (See IRM 11.3.32, Disclosure to State and Local Governments).

    4. Conduct ongoing need and use determinations with every specific request to ensure, particularly, where the information relates to an individual or entity that resides outside the states geographical boundaries, that the appropriate nexus has been established.

  5. The GL program is administered by the local Governmental Liaison. DMs are expected to advise the GLs on disclosure provisions.

  6. All exchanges of tax information fall into one of the following categories:

    1. Implementing agreements or memorandums of understanding or

    2. Specific requests (made outside of the Implementing Agreement or Memorandum of Understanding) or

    3. Electronic data exchanges (that can be referenced in Implementing Agreements or Memorandums of Understanding or specific requests).

  7. DMs and staff also support efforts by GLs in exploring opportunities for exchange of tax information with other federal agencies and provide advice related to various disclosure provisions related to these exchanges.

11.3.38.5.2  (08-13-2013)
Coordination with Office of Safeguards

  1. The purpose of the Safeguard review program is to ensure:

    1. Disclosure of tax returns and tax return information by the IRS to external agencies, their authorized agents, and their authorized contractors is in accordance with statutory authority.

    2. Tax information is used by these recipients only as authorized by the enabling legislation and/or implementing regulations.

    3. Returns and return information are protected from unauthorized disclosure and inspection as specified in IRC § 6103(p)(4) and supplemented by IRS’ Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies.

  2. The Office of Safeguards within the Privacy, Governmental Liaison, and Disclosure function is responsible for all on-site safeguard reviews of:

    • State Tax Agencies

    • Child Support Agencies

    • Public Assistance Agencies

    • Other State and Federal Agencies receiving tax information

  3. The Pre-award reviews of IRS contractors is the responsibility of AWSS, Office of Physical Security and Emergency Preparedness. The required post-award on-site safeguard reviews are performed by AWSS, Real Estate and Facilities Management. If tax information is contained on computer systems controlled by the contractor, IT, Office of Cybersecurity, conducts reviews of contractor compliance with computer security requirements.

  4. DMs and staff assist the Office of Safeguards, AWSS and IT Cybersecurity personnel with issues related to the interpretation and application of IRC § 6103 and the Privacy Act as they relate to information shared with or disclosed by the various agencies and contractors.

11.3.38.6  (08-13-2013)
Reporting Unauthorized Accesses or Disclosures

  1. IRS employees are required to report suspected willful unauthorized inspections/disclosures of returns and return information and Privacy Act violations to the Treasury Inspector General for Tax Administration (TIGTA). Field employees should report these matters to the local TIGTA Special Agent. Washington, DC metro area employees should report to TIGTA’s main office. Non-willful unauthorized disclosures of tax or Privacy Act protected information are to be reported in accordance with IRM 11.3.13.38. 6.1, Reporting Inadvertent Disclosures of Sensitive Information, below .

    Note:

    A willful act is one where there is an intentional violation of a known legal duty.

    Note:

    If any employee reports an unauthorized willful disclosure/inspection to a Disclosure Manager before reporting it to TIGTA, the Disclosure Manager will direct the employee to TIGTA without delay.

  2. Suspected incidents of unauthorized access/inspection (UNAX) should be handled in accordance with current procedures.

  3. Non-IRS agencies and their employees/contractors/agents subject to IRC § 7213 or IRC § 7213A should have internal procedures in place to substantially replicate the provisions of these IRM instructions. Any suspicion of a willful IRC § 7213 or IRC § 7213A violation must be reported to TIGTA.

    Note:

    See IRM 11.3.36, Safeguard Review Program for a discussion of requirements for agencies subject to IRC § 6103(p)(4) safeguards.

11.3.38.6.1  (08-13-2013)
Reporting Inadvertent Disclosures of Sensitive Information

  1. When sensitive information, including tax information and information protected by the Privacy Act, is disclosed in any way, it is required to be reported using procedures developed by the Computer Security Incident Response Center (CSIRC) office.

  2. Form 10848, Report of Unauthorized Inadvertent Disclosure of Tax or Privacy Act Information is obsolete and no longer used to report such incidents.

  3. The CSIRC incident reporting form is to be used to report inadvertent disclosures of sensitive information. It is designed to be used on line and can be accessed at the following: http://www.csirc.web.irs.gov/reporting/.

    Note:

    These procedures apply to incidents involving the shipment of Personally Identifiable Information (PII) where information is lost or misplaced. See the CSIRC web page for more information.

  4. Upon becoming aware of an inadvertent, unintentional disclosure, you are required to report the incident within one hour to the following:

    • Your immediate manager

    • CSIRC online or at (866) 216-4809

      Note:

      You will not contact TIGTA in these situations.

  5. Generally, employees commit inadvertent disclosure errors once (e.g., because of a misunderstanding of rules or procedures) and no further corrective action is necessary once the matter is discussed with the employee. Occasionally, errors are repeated by the same employee or are serious enough even in one incident to warrant corrective action. When managers believe additional corrective action is necessary, they should consult with Labor Relations staff to determine if conduct or performance actions are appropriate. If the manager believes the unauthorized disclosure is willful or deliberate, they should report it to TIGTA instead of CSIRC.

  6. Incidences involving erroneous notice issuances are also reported differently. Employees who learn of erroneous notice issuances do not contact CSIRC, but the Office of Taxpayer Correspondence, who will contact CSIRC as necessary. See IRM 21.3.1.1.1, Erroneous Correspondence Procedures for more information.

  7. Non-IRS agencies and their employees, contractors, and/or agents subject to IRC § 7213 or § 7213A should have internal procedures in place to substantially replicate the provisions of these IRM instructions concerning inadvertent disclosures.

11.3.38.6.2  (08-13-2013)
Erroneous Correspondence Reporting Procedures

  1. Each type of erroneous correspondence, defined as correspondence that contains taxpayer information and includes either correspondence generated in error or correspondence sent to the wrong party is reported differently.

  2. IRM 25.13.1.3, Erroneous Correspondence Procedures - Red Button Process contains procedures on how to report these incidents. They are not to be reported using CSIRC procedures.

  3. Further information can be found at the Servicewide Notice Information Program (SNIP) web site at the following URL:

11.3.38.7  (08-13-2013)
Role of the Deputy Associate Director

  1. The DADs, Disclosure HQ, Disclosure East and Disclosure West, serve as the managers for the field DMs under their areas of responsibility and report to the Associate Director, Disclosure.

  2. The DAD:

    • Manages the Disclosure program in his/her area

    • Assists the Director, GLD, and Associate Director, Disclosure in implementing the national disclosure program

  3. To be effective, the DAD should:

    1. Provide necessary managerial assistance and support to DMs and staff.

    2. Assess the effectiveness of the Disclosure programs through visitations and reviews.

    3. Prepare procedures and instructions for local offices concerning Disclosure programs.

    4. Support the importance of privacy as well as the importance of the Disclosure program. Understand and embrace the role the local Disclosure staff plays in protecting the confidentiality of tax information and sensitive non-tax information.

    5. Monitor disclosure office compliance with Headquarters’ directives and guidelines and ensure that GLD priorities are followed.

    6. Conduct reviews of Disclosure casework to determine if appropriate quality standards are being met, and procedures are being followed.

    7. Review and approve exchange agreements for conformity with IRC § 6103(d) and the Privacy Act.

    8. Determine which technical issues require Headquarters’ action; suggest new legislation, regulations and procedures to Headquarters as warranted.

    9. Advise Headquarters of procedural problems which may extend beyond Area jurisdiction, detail efforts made to resolve them, and offer suggestions to prevent recurrence.

    10. Provide input as required by Headquarters on the status of Disclosure activities within the Area.

    11. Coordinate, consolidate, and ensure that required reports are complete, timely, and accurate.

  4. The DAD will utilize the Business Performance Review System to monitor performance indicators against the desired outcomes established for the Disclosure programs.

11.3.38.8  (08-13-2013)
Disclosure Manager Supervisory Responsibilities

  1. In addition to program and case management responsibilities, DMs also have supervisory (i.e., front line management) responsibilities for technical and clerical personnel. As such, they must perform the full range of tasks expected of all IRS supervisors.

  2. The supervisory responsibilities of the DM will include:

    1. Ensure employee case actions are timely and in accordance with current law, policies, and procedures;

    2. Ensure employees maintain high standards of professionalism in all their contacts with the public, internal customers and coworkers;

    3. Ensure employees observe taxpayer rights;

    4. Ensure employees are aware of ongoing changes to the laws, policies, and procedures that relate to their responsibilities (preferably during group meetings);

    5. Address systems issues that impact either internal or external customer needs;

    6. Ensure cases are assigned timely and employee workload do the following:

      Reflects current priorities
      Reflects employee experience and skill level
      Addresses Service wide objectives
      Protects public interest
      Allows for effective case processing

    7. Ensure employees are accountable for the appropriateness of their actions;

    8. Provide ongoing employee feedback that is candid and meaningful and will establish a basis for determining an accurate assessment of performance and developmental needs;

    9. Issue the Critical Job Elements (CJE) timely in accordance with the current National Agreement and evaluating employees performance against their CJEs;

    10. Create and maintain a work environment that will promote team work, positive working relationships, and increased employee satisfaction; and

    11. Ensure employees have necessary functioning equipment and supplies.

  3. IRM 1.4.1 , Management Roles and Responsibilities, describes the fundamental responsibilities of management positions at all levels and should be referenced for additional information.

11.3.38.9  (08-13-2013)
Automated Inventory Control System

  1. Disclosure uses an automated inventory management system for input, control, processing, and closing assigned case and program work. This is a helpful tool for DMs to monitor all activities of their office. It is important that the data entries made are accurate and timely. DMs must include comments in case reviews or in other observations about the accuracy and completeness of all required data entry and case history notes.

  2. HQ GLD Data Services is responsible for the operations of the system and should be contacted in the event of any connectivity or functionality issues.

  3. DMs are to use the reports generated by the system as a tool to assist in identifying trends, addressing inventory management issues and in reporting accomplishments to the DAD.

11.3.38.10  (08-13-2013)
The Role of the Disclosure Specialist

  1. The specific duties of Disclosure Specialists are determined by their position descriptions. The assignments are technical and non-supervisory in nature.

  2. Specialists generally handle day-to-day technical issues (i.e., casework).

  3. Disclosure Specialists with sufficient experience may be assigned responsibility for aspects of program management as needed and act for the DM in his or her absence.

  4. Disclosure Specialists may be asked to coordinate or conduct awareness presentations, or complete Quality/Privacy reviews.

11.3.38.11  (08-13-2013)
The Role of the Disclosure Assistant

  1. The Disclosure Assistant performs a variety of duties in assisting in the administration of local disclosure policies, practices and procedures.

  2. These duties normally include processing the more routine type of FOIA, Privacy Act and IRC § 6103 requests, as well as performing many of the administrative duties, such as preparing accountings for disclosure and certification of documents.


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