13.2.2  Inventory Control and Working an Assignment (Cont. 1)

13.2.2.6 
Key Contact Information

13.2.2.6.5  (07-16-2009)
Review and Enactment by the Operating Division or Function

  1. If the process owner agrees with an advocacy proposal, the OD or function will implement the suggested change and periodically update the EDSA on its status as requested. The analyst will document Advocacy Proposal recommendations on SAMS by individual recommendation and proposed implementation date, on the SAMS "Recommendations" tab.

  2. If the process owner does not support the proposal and TAS decides to continue with the proposal, OSA management will work with the NTA to resolve the matter. If the NTA concurs with the proposal, the NTA will submit either a proposed Taxpayer Advocate Directive (TAD), or a Taxpayer Rights Impact Statement (TRIS) to the appropriate head of office, depending on the expediency or sensitivity of the issue. See IRM 13.2.1.5, Processing Advocacy Issues, Taxpayer Advocate Directives, and IRM 13.1.4, TAS Authorities.

13.2.2.6.6  (07-16-2009)
Monitoring Outcomes

  1. Project leads are responsible for updating the status of advocacy proposals, informal recommendations, published guidance, and legislative change proposals on SAMS. Record advocacy effectiveness on the "Recommendations" tab for IMD product reviews, II and AP recommendations, Advocacy Proposals, and ARC recommendations.

  2. Projects whose recommendations require monitoring will be placed in Closed-Monitor status on SAMS with a closing date. It is the project lead’s responsibility to notify the manager and Director when it is necessary to close a project with this status.

  3. Project leads are responsible for monitoring outstanding recommendations scheduled for implementation for one year post closure for immediate interventions projects and two years post closure for advocacy projects.

13.2.2.7  (07-16-2009)
Project Executive Summary

  1. The Executive Summary is divided into the following sections:

    1. Project issue;

    2. Issue submitter;

    3. Summary of research;

    4. Summary of contacts;

    5. Analysis of data findings;

    6. Conclusions;

    7. Formal Advocacy Proposal submitted; and

    8. Recommendations (date made, date accepted and date implemented).

  2. An executive summary is required in all immediate interventions and advocacy projects except when: :

    • The project is closed as related to another open project;

    • The project is closed as a duplicate;

    • The project develops into a task force; or

    • The project is closed and the issue is transferred. (This does not include transfers among project leaders in FSA or OSA).

  3. A copy of the Executive Summary should be included in the project file. See Exhibit 13.2.2-6., Executive Summary Template, for the details and format of this report.

13.2.2.7.1  (07-16-2009)
Project Closing Letters

  1. A closing letter is required in all immediate interventions and advocacy projects except when:

    • The project is closed as related to another open project;

    • The project is closed as a duplicate;

    • The project develops into a task force; or

    • The project is closed and the issue is transferred. (This does not include transfers among project leaders in FSA or OSA).

  2. When a project is closed under the listed exceptions, the project lead will be responsible for completing and documenting a closing contact by email or phone. Input the exception and contact in SAMS under the "Notes" tab, labeled as "contact. "

  3. A signed (electronic or copy signature) of the closing letter will be included in the project file at closing and an electronic copy should be attached to the project on SAMS

  4. If a TAS or IRS employee submitted the issue, it is considered an internal submission, and the project closing letter can be approved at the director level. Therefore, the signature line on the letter will be:_, Director Immediate Intervention, or _, Director Advocacy Projects, as determined by the issue.

  5. External issues are submitted by stakeholders outside the IRS or TAS, such as practitioners. These letters must be approved at the executive level. Therefore, the signature line will be:_, Executive Director Systemic Advocacy.

    Reminder:

    When sending letter to an external stakeholder, make sure the unique identifying number is added to the letter as required by RRA 98 § 3705; i.e., the employee's job title and identifying number.

  6. The approval path of the letter is:

    1. The Project Lead or Technical Analyst prepares the letter and sends it to his or her manager or Director as appropriate.

    2. The project lead's manager can either approve the letter, thereby determining that the project lead's proposed resolution is an acceptable resolution to the project and the letter is drafted in a professional manner, or return the letter to the project lead with instructions to perform additional work on the project.

    3. After approval by the project lead's manager, the closing letter will follow different paths depending on whether the issue was an advocacy project or an immediate intervention.

    4. If the issue was an advocacy project, the FSA project lead's manager should forward the closing letter to the Field Systemic Advocacy Director (FSA). If the issue was an immediate intervention, the project lead should forward the letter on to the DII designee who assigned the immediate intervention. After approval by the FSA Director or the DII designee, the closing letter will be forwarded on to the DII or the DAP, as appropriate. If additional work is required on the closing letter, the DII or the DAP may at his or her discretion either return the letter to the project lead's Director or make the necessary edits.

    5. Upon approval of closing letters to issue submitters internal to the IRS, the DII or DAP will sign the letter, sending the original to the submitter by the U.S. Postal Service. The DII or DAP may send electronic copies of the letter to any individuals internal to the IRS for whom copies are appropriate.

    6. Upon approval of closing letters to submitters external to the IRS, the DII or DAP will forward the approved letter on to the EDSA for review and signature.

    7. The EDSA may also request that additional work be performed on the project or will forward the approved letter on to the DNTA or NTA for review and signature.

    8. The EDSA may also request that additional work be performed on the project or that addition or deletions be made to the letter. Upon approval of the closing letter, the EDSA will sign the closing letter, sending the original to the submitter by the Postal Service. The EDSA may send electronic copies of the letter to any individuals internal to the IRS for whom copies are appropriate.

  7. See Exhibit 13.2.2-9. , Advocacy Closing Letter.

13.2.2.8  (07-16-2009)
Systemic Advocacy Management System (SAMS)

  1. This section provides information for all IRS employees about using the Systemic Advocacy Management System, known as SAMS, to bring issues to the attention of the TAS Office of Systemic Advocacy.

13.2.2.8.1  (07-16-2009)
Overview

  1. The web-based SAMS database is also the primary tool for recording and managing advocacy projects, advocacy portfolios, IMD Reviews, and Systemic Advocacy task force participation.

  2. SAMS inventory controls allow Systemic Advocacy managers and their delegates to review issues based on ranking criteria and priority, and track outcomes. Data stored in SAMS can be used with other management information sources to develop a more comprehensive understanding of taxpayer issues and improve the tax system.

13.2.2.8.2  (07-16-2009)
Access to SAMS

  1. SAMS allows all IRS employees and external stakeholders to submit issues to the TAS OSA . Any employee can search the system to find out whether similar issues are being worked or have been resolved. Employees may also research submissions and track their status.

13.2.2.8.3  (07-16-2009)
Submitting Advocacy Issues

  1. IRS and TAS employees who wish to submit systemic issues to the Office of Systemic Advocacy should access SAMS through the TAS intranet. External stakeholders can also submit issues through the Internet at IRS.gov.

  2. Before submitting issues, employees should search the database for existing issues that address their concerns, and for similar problems that might have been submitted or resolved in the past. To search for an issue:

    1. From the SAMS Dashboard select "Issues " under the SAMS Navigation tab on the left navigation bar, then click on "Advanced Search" link in the upper right hand corner.

    2. Enter issue search criteria, such as the issue number (if known), the Functional Business Unit (FBU) where the issue originated, the submitter's name, or other key words. When searching for like-kind issues it is best to search for key words in the summary or description sections.

    3. Click the "Search for Issues" tab. The results will display in the "Search" field at the bottom of the screen.

    4. If there is a related issue on SAMS, submit the issue and reference the related SAMS issue number in the description field.

    5. Employees can still submit issues even if they find related ones already exist on the system. Additional submissions can alert Systemic Advocacy to the scope of an issue and may lead to the creation of a project to resolve the problem.

  3. Any IRS or TAS employee may submit a new systemic advocacy issue by using the following procedure:

    1. From the SAMS Dashboard click on "Issues" under the "Create" tab on the left navigation bar.

    2. Enter the requested information in the fields, most of which are required. The information includes the name, address, phone number, email address and FBU of the person submitting the issue.

    3. Enter a brief description in the "Short Title" field that briefly outlines the concerns raised by the issue. Include important key words for others to search for later.

    4. Give details of the problem in the "Description" field. Does the problem follow a pattern? Who or what is affected by this problem? Provide TAMIS case number(s) if applicable, symptoms, possible causes and possible solution(s) (if known), and relevant IRC or IRM references.

    5. Do not include any taxpayer information in submissions.

    6. Do not paste text from Microsoft Word into SAMS. This imports hidden characters that seriously impact the system. Plain text is acceptable.

    7. Submit a separate issue for each unrelated problem. A submitter who has more information about a certain issue than the "Description" field will hold should not continue that description in a second submission; he or she should simply add a line to the "Description" saying, "Contact submitter for further information."

    8. Do not use acronyms that are not familiar to all IRS employees in the description of the problem. The person reviewing and ranking the issue must be able to understand the problem and processes described.

    9. When all information has been completed, click the "Save " button at the top right of the screen to send the issue to Systemic Advocacy for processing. The user will see a confirmation screen indicating that the issue was received. SAMS will automatically send the submitter a separate confirmation message, provided a correct email address has been provided.

  4. Taxpayers, businesses, professional groups and other external stakeholders may submit advocacy issues through the Internet version of SAMS. This system is available on the Systemic Advocacy pages of the TAS public website at http://www.irs.gov/advocate.

  5. If speaking with an external stakeholder, caution him or her to omit taxpayer identifying information from submissions. If you need to discuss the details of the submission with the external stakeholder but only have the stakeholder's email address, consult with your manager before contacting the stakeholder by email. If you manager determines email is appropriate, you can use language similar to the following:

    • "I am writing you in response to your submission on the Systemic Advocacy Management System made on XX/XX/XXXX. I want to discuss further details with you regarding your submission, but due to security concerns, the IRS does not generally correspond with the public via email. Please call me at XXX-XXX-XXXX."

    • When sending email to an external stakeholder, make sure your signature line includes your name, your job title and your unique employee identification number. See IRM 13.2.2.5.5(4).

  6. External stakeholders who lack Internet access may submit issues by filling out and submitting a Form 14411, Advocacy Issue Submission Form. The form is available by calling 1-800-TAX FORM. For those with internet access, the form can be downloaded from the IRS website at www.irs.gov.It can be faxed to the EDSA office at 202-622-3125.

  7. All issues received are reviewed to determine if they meet established criteria and are individually ranked to prioritize them for project consideration.

  8. Not all issues become projects. However, all issues remain in the database for trend analysis and potential future projects. See IRM 13.2.2.3, Advocacy Submission Processing.

13.2.2.8.4  (07-16-2009)
Reporting SAMS Problems

  1. IRS employees who encounter technical or programming problems with SAMS should report them to the MITS Help Desk by telephone or through the MITS website and may also notify or send inquiries to the SAMS Administrator once a ticket has been created.

  2. Use this procedure only for immediate problems that interfere with your use of SAMS. To obtain SAMS training, visit http://elms.web.irs.gov and search for "Systemic Advocacy" in the catalog.

  3. Employees who have non-urgent questions about SAMS or wish to request long-term system changes or enhancements should submit suggestions using the Systemic Advocacy Tools page of the TAS website. Click on "Systemic Advocacy Management System (SAMS)" under "Database/Systems" .

13.2.2.9  (07-16-2009)
Systemic Advocacy and the Employee Suggestion Program

  1. Submitting an advocacy issue through SAMS is separate and distinct from the IRS Employee Suggestion Program (ESP), a formal process that offers employees the chance to receive monetary awards for suggestions that increase efficiency and savings within the Service. The OSA seeks to lessen taxpayer problems by recommending changes to IRS policy, procedures, and the tax code and does not compensate employees for suggesting improvements.

  2. The two programs differ in scope. Only IRS employees can make suggestions through the ESP: Systemic Advocacy allows both IRS employees and external stakeholders to submit issues or problems.

  3. The OSA and the ESP use different criteria. Systemic advocacy has the objective of working for changes that will prevent taxpayer problems; the ESP is designed to provide IRS employees with monetary awards for approved and implemented suggestions (see (4) and (5) below for more details).

  4. A systemic issue is one that affects a segment of taxpayers; an employee suggestion is a voluntary, written proposal, submitted by an employee or employees, which identifies and describes a specific need for improvement and proposes a solution, or proposes a specific improvement to an existing situation.

  5. To be considered acceptable by the ESP, an employee's suggestion must:

    1. Be a constructive proposal;

    2. Contribute to economy;

    3. Contribute to efficiency;

    4. Directly increase the effectiveness of Government operations; and

    5. Be an original idea.

  6. Both the ESP and Systemic Advocacy use web-based systems to receive, track, and approve suggestions or study problems. However, an idea submitted to the ESP must be presented in sufficient detail to determine what needs to be changed and how, so that appropriate coordinators can review it and make an assessment. An issue or problem submitted to SAMS need only describe the issue or problem, and is sent directly to the OSA at IRS Headquarters with no intervening review.

  7. Employees who propose to resolve a systemic problem in a way that also has the potential to save the government money should submit their suggestions to both the ESP and the SA program.

13.2.2.10  (07-16-2009)
Taxpayer Advocacy Panel (TAP) SAMS Submission

  1. TAP will submit its advocacy suggestions directly to the NTA. The National TAP Program Manager will screen the suggestions and forward them to the EDSA.

  2. TAP suggestions that are accepted as advocacy projects will be added to the management system. The TAP Program Manager will provide comments to the originating panel.

  3. TAP suggestions not accepted as projects will be discussed between the NTA, EDSA, and National TAP Program Manager to determine alternative courses of action.

13.2.2.11  (07-16-2009)
Methods of Submitting Changes to Systems, IRMs, Forms, Publications, Notices, and Letters

  1. This section describes different ways to make corrections, submit suggestions, or raise issues and concerns to the appropriate process owner:

13.2.2.11.1  (07-16-2009)
Forwarding Forms and Publications Change Requests

  1. When OSA receives issue submissions related to form and publication revisions, the SAMS Program Manager will forward these requests to the TAS IMD/SPOC for coordination of the review process. The TAS IMD/SPOC will forward the issue internally to subject matter experts based upon their portfolios and externally to committee contacts, such as Notice Communication Advisory Group (NCAG) and Tax Products Coordination Committee (TPCC).

  2. These reviews could result in the creation of virtual technical teams or recommendations for change. See IRM 13.2.1.6.1.6 for information on virtual technical teams.

13.2.2.11.2  (07-16-2009)
Coordination of Change Requests by the TAS IMD/SPOC

  1. TAS has new procedures for submitting all changes, suggestions, and recommendations concerning new or revised IRMs and internal IRS forms, notices and publications.

  2. All TAS employees should submit forms/letters/notices/pubs change requests through the TAS IMD/SPOC.

    Note:

    External requests for TAS review of these documents will be handled by the TAS IMD/SPOC using procedures outlined in IRM 13.2.1.5, Reviewing Internal Management Documents (IMDs) For Systemic Issues.

  3. Analysts should compile requests for any notice or internal form changes resulting from projects or advocacy issues. The TAS IMD/SPOC will consolidate and present these suggestions to the NCAG for review.

  4. The Letter/Notice/Internal Form Change Recommendation Form should include:

    • Name and number of notice or letter for recommended change;

    • Project Lead name and telephone number;

    • Description of the changes to be made;

    • Reasons for change; and

    • Supporting documentation, including examples.

  5. The TAS IMD/SPOC will send recommendations on to the SPOCs for the ODs and functions that own the particular letters/notices. The Division Commissioner will ultimately approve or reject the change. The appropriate OD will redesign cross-divisional notices and letters, and then phase out the older ones.

13.2.2.11.3  (07-16-2009)
System Change Request (Form 5391) for IRM Procedural Changes

  1. Employees use Form 5391, System Change Request, to suggest technical corrections to IRM procedures and instructions.

    Note:

    This process is for changes to IRMs other than those forwarded to TAS employees for review during the IMD Clearance process discussed above. See IRM 13.2.1.5, Reviewing Internal Management Documents (IMDs) For Systemic Issues.

  2. A statement of the problem and a statement of the impact must accompany the request. Access this form at http://publish.no.irs.gov.

13.2.2.11.4  (07-16-2009)
Editorial Change Request (Form 9345)

  1. Use Form 9345, Editorial Change Request, to make editorial, i.e., typographical or printing corrections to the IRM.

  2. You can access the form at http://publish.no.irs.gov. Refer to IRM 3.31.125, Procedures/System Change Request, for specific procedures relating to these forms.

  3. A list of IRM contacts is available on the Servicewide Policy, Directives and Electronic Research (SPDER) website at http://spder.web.irs.gov/IRM/IMDOversightCouncil.htm.

13.2.2.11.5  (07-16-2009)
Other Change Requests

  1. Suggestions for changes or improvements to internal TAS procedures or policies, Service Level Agreements, or IRM 13 should be forwarded to the appropriate TAS office for consideration.

  2. If received on SAMS, these suggestions will be closed and transferred to the appropriate office.

13.2.2.11.6  (07-16-2009)
System Production Evaluation Report (Form 5715)

  1. Employees use this form to advise the National Office of systemic programming and operational problems that result in work stoppages.

  2. The electronic Form 5715, System Production Evaluation Report, is available under the Integrated Network and Operations Management Systems (INOMS) Problem Management Process Network and Operations Command Center (NOCC) website at http://nocc.web.irs.gov.

13.2.2.12  (07-16-2009)
Systemic Advocacy and Internal Management Document (IMD) Reviews

  1. The TAS SPOC is responsible for coordinating the IMD reviews for TAS. For further information on this process see IRM 13.2.1.5, Reviewing Internal Management Documents (IMDs) for Systemic Issues.

13.2.2.13  (07-16-2009)
Systemic Advocacy and Task Force Participation

  1. Systemic Advocacy analysts are at times asked to participate on cross-functional task forces. See IRM 13.2.1.4.2.5 , Proactive Advocacy Assignments.

  2. With concurrence from the Manager or Director, the SAMS Program Managers will assist the analyst in setting up the task force project on SAMS. The analyst will need to contact the SAMS Program Manager(s) for assistance.

  3. The task force activity will be documented on SAMS.

  4. The time spent on task force activity will also be documented on SAMS following the procedures for documenting project time.

13.2.2.14  (07-16-2009)
Systemic Advocacy Time Reporting

  1. SAMS will track project time with greater efficiency and convenience for both management and anyone working an advocacy project, task force or IMD review. Any OSA employee working an advocacy project, task force, IMD review, or the Annual Report to Congress is required to report direct project time on SAMS.

  2. Anyone who works on a project, including leads and team members, will be required to record their time on SAMS. From the SAMS Dashboard, click on the "Timesheet" link on the top menu bar. Select edit to open a project and to add time. Record direct project time, including any travel time associated with the project, in half-hour increments. Input time separately for each day in which project work occurred. To properly capture the time, select "Save" when entries are completed.

  3. SETR Time Reporting will require the use of the appropriate Function and Program Codes. All OSA Analysts, II, DAP, FSA, and EDSA Technical Liaison should input their time under Function code 900 with the appropriate Project Codes.

  4. Appropriate SA Project Codes include:

    • 36760 - Advocacy Projects;

    • 36761 - Immediate Interventions;

    • 36762 - Proactive Advocacy - IMD Reviews, Task Force Participation and SAMS Submission Responses;

    • 36764 - Annual Report to Congress; and

    • 36765 - Portfolio.

  5. Additional Program Codes for Outreach may also be utilized to identify time applied to these outreach activities.

    • 36751 - Outreach - Congressional Offices

    • 36752 - Outreach - Tax Practitioners

    • 36753 - Outreach External MTGS/Speeches

    • 36754 - Outreach - Media

  6. Time charged to outreach program codes require the completion and forwarding of an outreach event report. See IRM 13.5.1.5.7, Outreach Effectiveness.

  7. The use of Program Code 59100 - Management and Support, should be limited to Management or Support staff use when their activities are otherwise not directly related to a specific project, ARC, IMD or Taskforce.

    Note:

    Update your timesheet or review SETR to ensure the Function Code 900 is present and used when charging time to appropriate direct SA Program Codes.

  8. Other Function Codes used by SA include:

    • 790 - Support Staff - Secretaries and Management Assistants

    • 990 - Managers and Staff Assistants

      Note:

      Function Code 990 should only be used by Analysts or Support staff when charging time to leave codes.

13.2.2.15  (07-16-2009)
Systemic Advocacy Submission Transfer Guidelines

  1. Advocacy submissions that are not selected as projects using the submission analysis process may still merit action by TAS case advocates, other TAS offices, or other IRS functions, and if so, should be transferred appropriately. Submissions transferred within TAS will require submitter contact by the receiving program staff. A copy of all closing contacts must be provided to the SAMS program manager who will attach the document to the SAMS issue to document the closed status.

  2. Issues that must be transferred include:

    Taxpayer cases: Internal Submission -- If the taxpayer case is already in TAS, the issue will be transferred via email to the TAG office. TAG will contact the local office and case advocate assigned and answer any questions or clarify any issues.
    Taxpayer cases: External Submission -- Following disclosure guidelines, the SAMS Program Managers will send the DC Local Taxpayer Advocate (LTA) an email advising him or her of the SAMS submission. The DC LTA will contact the taxpayer and work the issue, as appropriate. See IRM 13.1.2.3, RRA 98 § 3705, Identify Yourself.
    Training issues – Transfer to the appropriate operating division or function.
    Allegation of fraud or other criminal activity -- Discuss with DII for potential transfer to Criminal Investigation (CI).
    Notice/Form/Publication/Letter Change Request – All submissions relating to notices, forms publications, or letters that do not become projects will be transferred to the IMD/SPOC Program Manager in OSA, who will elevate the issues as a member of the NCAG.
    System Change Request -- Send the submitter an email advising him or her to submit Form 5715.
    TAS IRM 13 or TAS case work procedures and policy changes --Transfer to the TAS TAG Office to be input on CAPER (Cases/Correspondence, Analysis, Policy/Procedures, Evaluative (Program), Reviews) system. Send an email to the TAG designated employee with the SAMS issue number and issue description.
    Legislative change consideration or statutory impact review -- Send an email to the Attorney Advisor Manager for assignment with the SAMS issue number, issue description and the expected response date of 30 days. The SAMS Program Manager will notify the submitter of the transfer and the expected response date.
    HQ Directors - Submissions relating to TAS HQ Directorate Program responsibilities, i.e., LITC, C&L, TAP, etc. Send an email to the appropriate HQ Director or their designee for assignment with the SAMS issue number, issue description and the expected date of 30 days. The SAMS Program Manager will notify the submitter of the transfer and the expected response date.

13.2.2.16  (07-16-2009)
Systemic Advocacy Measures

  1. Systemic Advocacy has established a series of organizational measurements to address program effectiveness.

  2. These measures include;

    • Accuracy – The correctness of actions defined by statute and guidance;

    • Efficiency – The cost of producing a quality (accurate, complete, timely) product;

    • Timeliness – Completing actions within timeframes in statute and guidelines;

    • Customer Satisfaction – Customer’s view of product provided;

    • Employee Satisfaction – Employee’s view of work life; and

    • Effectiveness – TAS’s success in resolving taxpayer’s problems.

  3. The initial delivery of the SA Measurement Program included the development of SA quality standards, completed and approved by the NTA in September 2005. Baseline data was collected on closed projects for fiscal year 2007.

  4. The standards fall within the following categories, timeliness, accuracy and communication with assigned attributes. See Exhibit 13.2.2-10, SA Quality Attributes

  5. The SA quality review of closed Immediate Intervention, Advocacy Projects and IRM/SPOC reviews, will provide organization performance measurement of the accuracy and timeliness of key SA product delivery.

  6. Fiscal year 2008 SA Objectives included the full implementation of all of key performance measures and a process for reporting the results of the measures as described in the Systemic Advocacy Monthly Performance Report. See Figure 13.2.2-1.

    Figure 13.2.2-1
    This image is too large to be displayed in the current screen. Please click the link to view the image.

    This is an example of a Systemic Advocacy Monthly Performance Report

Exhibit 13.2.2-1  (07-16-2009)
SAMS Issue Evaluation and Project Creation Process

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Exhibit 13.2.2-2  (07-16-2009)
Advocacy Proposal Template

ADVOCACY PROPOSAL TEMPLATE
At a minimum, the following major headings should be used in preparing an Advocacy Proposal:
  • Introduction • Problem(s) • Agreements Reached (if any) • Agreements Needed • Requested Action • TAS Contacts • Attachments
 
 
1 Introduction
Provide brief introduction of the nature of the problem, its designation as a project by the National Taxpayer Advocate or the Executive Director of Systemic Advocacy, along with a statement that the purpose of the Advocacy Proposal is to document the existence of the problem(s) and recommendations for resolution of the problem(s).
 
2 Problem(s)
Describe, in detail, the nature of the problem, including a description of the facts and application of applicable law and regulations (i.e., IRC section, Treasury Regulations, case law, IRM, or other guidance) to the facts. Describe any research conducted that supports the existence of the problem, and describe the harm that the problem causes to the taxpayers.
 
3 Agreements Reached (if any)
Describe any agreements reached as of the date of the Advocacy Proposal, and identify the Operating Division contact with whom the agreement was reached. Describe why the Agreement Reached does not fully resolve the issue.
 
4 Agreements or Actions Needed
Describe additional agreements or actions that are needed to resolve the problem.
 
5 Requested Action
Describe the proposed next steps (i.e., a management-level meeting to discuss the agreements needed).
 
6 TAS Contacts
Provide the names and contact numbers for the Executive Director of Systemic Advocacy, the appropriate Systemic Advocacy Director (e.g., Director of Immediate Interventions or the Director of Advocacy Projects).
 
7 Attachments
Attach relevant factual documents (i.e., sample of IRS notices [redacting all taxpayer specific information]). Reference the Attachments in the body of the Advocacy Proposal.

These two pages provide the elements and format for an Advocacy Proposal.

Exhibit 13.2.2-3  (07-16-2009)
TAMIS Research Request Form

TAMIS Research Request
Requestor: Date Submitted:
Telephone: Requested Due Date:
Project Title: Supervisor:
Research Concurs:
1 Explain Reason for Data Request
Top 20 analysis; Legislative Initiative Analysis; Field Advocacy Issue and Other (please describe)
 
2 Provide Pertinent Background (i.e., any relevant information regarding the history of the issue for which the data is being requested)
 
3 Explain intended use of data (e.g., particularly if the data is being used to provide anecdotal information or to attempt to project to a larger population)
 
4 Indicate number of requested cases (e.g., all PCI 950 cases, or specify specific number of cases (50 cases meeting criteria below). Check box below if requesting Research to determine sample size (required if intending to project to population))
 
5 Specify TAMIS query parameters (e.g., all cases belonging to a certain PCI, cases closed or open between specific dates, cases with certain text strings in the history)
 

Exhibit 13.2.2-4  (07-16-2009)
TAS Communications Assistance Request (CAR)

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Exhibit 13.2.2-5  (07-16-2009)
Memorandum to Request a Counsel Legal Opinion

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Exhibit 13.2.2-6  (07-16-2009)
Executive Summary Template

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Executive Summary

Exhibit 13.2.2-7  (07-16-2009)
TAS Research Request Form

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Exhibit 13.2.2-8  (07-16-2009)
IRS Operating Division or Function Research Request Form

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Exhibit 13.2.2-9  (07-16-2009)
Advocacy Closing Letter

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Exhibit 13.2.2-10  (07-16-2009)
SA Quality Attributes

This exhibit includes the Quality Review Standards for Systemic Advocacy.

# ATTRIBUTE/ REFERENCE DEFINITION APPLICATION
TIMELINESS (T) – 6 Attributes  
T1 Did SA analyst contact the submitter in a timely manner? Reference: The analyst should make an initial contact with the submitter within the following time frames:
• II - 1 business day from the "Actual Start Date"
• AP - 3 business days from the "Actual Start Date"
• "Actual Start Date" should be the date the project is assigned to the analyst. The analyst should advise the submitter of project assignment and ensure that he/she has a clear understanding of the issue submitted. If IRS/TAS closes its offices for inclement weather or any other reason that affects workdays or calendar days, the project history should be documented with the exact dates the office was closed and the reason(s) for the closure.
This attribute is applicable to all immediate interventions and advocacy projects when contact information is available. This attribute is rated as N/A if no contact information is available.
T2 Did SA analyst make all subsequent contacts to the submitter in a timely manner? Reference: For both II and AP subsequent contacts, the submitter should be contacted every 30 calendar days unless the submitter agrees that contact dates may be lengthened. Submitter’s agreement to less frequent contact should be documented on SAMS. If IRS/TAS closes its offices for inclement weather or any other reason that affects workdays or calendar days, the project history should be documented with the exact dates the office was closed and the reason(s) for the closure. This attribute is applicable to all immediate interventions and advocacy projects when contact information is available. This attribute is rated as N/A in the following situations:
• The project is submitted for closure within 30 days of the initial contact, or
• No contact information is available
T3 Was the initial action plan issued timely? Reference: The first steps in working an immediate intervention project or an advocacy project are defining its scope and creating an action plan or list of tasks the project lead or team must accomplish. The following 2 actions need to have timely occurred:
a) Initial action plan has been created timely, and
b) Manager has been notified of the action plan availability. Manager includes Systemic advocacy management, which is the SA Portfolio manager and/or the DAP/DII, as well as the analyst’s manager of record. Notification may be to any of the management officials listed here. Both actions have to be taken within the following timeframe:
• II – 5 calendar days from the "Actual Start Date"
• AP -- 30 calendar days from the "Actual Start Date"
• If IRS/TAS closes its offices for inclement weather or any other reason that affects workdays or calendar days, the project history should be documented with the exact dates the office was closed and the reason(s) for the closure.
This attribute is applicable in all immediate interventions and advocacy projects.
T4 Were the due dates met or updated? Reference: Action dates will be revised as needed to ensure resolution of project. Revised action dates will be documented by analyst on SAMS
Task dates are when major segments of the project are to be completed, usually including the final deliverables and key interim deliverables.
Follow-up or next action dates should be set to help ensure continuity of project work. These dates should be documented as Tasks in the Task tab.
• If a follow up date was set the analyst has 14 calendar days from the follow up date to take action.
• If no follow up date was set the analyst has 14 calendar days from the last action to take next action. If IRS/TAS closes its offices for inclement weather or any other reason that affects workdays or calendar days, the project history should be documented as such with the exact dates the office was closed and the reason(s) for the closure.
This attribute is applicable for all immediate interventions and advocacy projects except for the projects closed on the same day as the actual start date.
T5 Were closing letter and Executive Summary emailed to manager timely? Reference: Analyst is required to email closing letter and Executive Summary (formerly known as Project Closing Report) to manager or designee within 14 calendar days of project work being substantially complete. "Substantially complete" means analyst has completed all the necessary actions (analysis, research, etc.), reached a conclusion, formulated a resolution (if required by the project), and is ready to begin writing the Executive Summary & Closing Letter (if required). If IRS/TAS closes its offices for inclement weather or any other reason that affects workdays or calendar days, the project history should be documented with the exact dates the office was closed and the reason(s) for the closure. This attribute is applicable in most immediate interventions and advocacy projects. If both a closing letter and Executive Summary are prepared, both must be emailed timely in order for this attribute to be rated as "Met" . Since this attribute measures only timeliness, it will be rated as "N/A" if the documents are not prepared – regardless of whether or not they should have been prepared. Failure to prepare necessary documents will be rated under A7.
T6 Were all substantive actions taken on the project in such a way to progressively move it toward resolution? Reference: A project must be worked with no unnecessary delays or periods of inactivity. Responsibilities for project leader and/or team members include:
• Monitoring the progress of the project,
• Monitoring the progress of the project to ensure that deadlines are met and completing tasks by these established deadlines,
• Communication with leader and members on progress of work,
• Coordinating activities of team members. Management officials should be reviewing project work to give appropriate guidance and thus help move the project along to resolution. Each management official is allowed 30 days to complete each review, as necessary. This does not apply to action plan reviews which have shorter timeframes. See Attribute A5. If IRS/TAS closes its offices for inclement weather or any other reason that affects workdays or calendar days, the project history should be documented with the exact dates the office was closed and the reason(s) for the closure.
This attribute is applicable in all immediate interventions and advocacy projects.
ACCURACY (A) – 10 Attributes  
A1 Was the issue behind this project systemic and was a project properly created? Reference: A systemic issue impacts a segment of taxpayers locally, regionally, or nationally. These issues involve systems, processes, policies, procedures, or legislation and require study, analysis, recommendations, and action to effect positive results. Systemic issues involve protecting taxpayer rights, reducing or preventing taxpayer burden, ensuring equitable treatment of taxpayers or providing essential services to taxpayers. This attribute is applicable in all immediate interventions and advocacy projects.
A2 Does the action plan contain all required information? Reference: The action plan must include the following two items:
• A description of each task and/or action item.
• The due date or scheduled due date for each task/action item.
This attribute is applicable in all immediate interventions and advocacy projects.
A3 Was the scope of the project appropriate based on the issued submitted? Reference: When the analyst contacts the submitter it is critical that the analyst accurately determine the actual issue that concerns the submitter. Then the analyst must decide the appropriate scope and proper depth for the project. This helps ensure that the appropriate research path is taken. This attribute is applicable in all immediate interventions and advocacy projects.
A4 Was the project charter complete? Reference: The 8 mandatory elements of a project charter are:
• Statement – Identify the initial problem statement and update it during the life of the project if necessary.
•Constraints – Identify items that will obviously guide project planning.
• Risks/Rewards – Include as risks any consideration(s) that may limit the team’s ability to achieve the project objective.
• Objective – Identify customer or advocacy program expectations from the project.
• Customers – Identify the public or IRS population that will benefit from the solution to the problem.
• Impact Statement – State the advocacy goal of the project (e.g. Protect Taxpayer Rights) and if estimable, the number of taxpayers impacted.
• Resolution – Complete this field at the close of the project. Space is limited, so only a brief description is necessary.
• Key Issues – Identify major issues; convey any information you have about the progress of the project. This area can also be used to describe any temporary solutions for II’s.
This attribute is applicable in all immediate intervention and advocacy projects. If one element is missed, then the attribute is rated as "not met" .
A5 Was managerial involvement in the action plan noted? Reference: This attribute measures both the managerial involvement AND the timeliness of the managerial action. Both components of this attribute must be met in order for the attribute to be rated as met. Document review on SAMS.
• II: Review and feedback provided within 4 calendar days of notification of action plan availability.
• AP: Review and feedback provided within 15 calendar days of notification of action plan availability.
• If timely notification of action plan issuance is not received from the analyst, the manager should follow-up with the analyst.
This attribute is applicable in all immediate interventions and advocacy projects. If the analyst notified multiple management officials of the action plan availability, any one of them may document the review/feedback.
A6 Was the proposed resolution appropriate? Reference: Advocacy remedy spells out recommended solution and/or corrective action. The four advocacy remedies are:
• Administrative Changes
• Published Guidance
• Legislative Changes
• Other
This attribute is required in most immediate interventions and advocacy projects with the exception of those closed before a remedy is determinable. Any of these exceptions would result in a rating of N/A:
• The project is closed out as related to another open project, or
• The project is closed out as a duplicate, or
• The project develops into a task force, or
• The project is closed and the issue is transferred. This does not include transfers among analysts in Systemic Advocacy.
A7 Were project completion requirements followed? Reference: An Executive Summary (formerly known as Close-Out Report) and a Project Closing Letter are required to be completed at project closing. File should contain the information required to support the conclusions reached. A copy of the Executive Summary and a signed/dated copy of the final letter should be included in the project file. This attribute is required in all immediate interventions and advocacy projects except for those that do not require a closing letter and executive summary.
• An Executive Summary is not required if:
• The project is closed out as related to another open project, or
• The project is closed out as a duplicate, or
• The project develops into a task force, or
• The project is closed and the issue is transferred. This does not include transfers among analysts in Systemic Advocacy.
• Any of these exceptions would result in a rating of N/A for the Executive Summary portion of this attribute.
• A closing letter is not required if no contact information is available.
• A "formal" closing letter is not required if the submitter is one of the following, but a "closing communication" (i.e., email or telephone contact) is required:
• NTA
• DNTA
• EDCA
• EDSA
• DII
• DAP
• Attorney-Advisor
• SAMS Program Manager
• Systemic Advocacy Analyst
• DAP Secretary
• DII Secretary
A8 Does data analysis support the conclusion? Reference: Data includes numerical information as well as other information needing consideration in order to reach conclusions/make recommendations. This attribute is applicable in most immediate interventions and advocacy projects, with the following exceptions:
• The project is closed out as related to another open project, or
• The project is closed out as a duplicate, or
• The project develops into a task force, or
• The project is closed and the issue is transferred. This does not include transfers among analysts in systemic advocacy.
• Any of these exceptions would result in a rating of N/A unless data analysis was performed prior to making the decision to close the project in such manner. Conclusions derived from such analysis could be significant factors in the decision to close as related/duplicate, transfer, or create a task force.
A9 Were tax law and IRM/IRS procedures correctly applied and interpreted? Reference: Proper application of statutes and administrative regulations to the facts and circumstances as well as the correct interpretation of relevant internal guidelines. This attribute is applicable for all immediate interventions and advocacy projects that involve tax law or procedural requirements. This attribute is rated as "N/A" for those with no tax law or procedural impact.
A10 Were all related issues correctly addressed? Reference: The analyst or team must address any issues that arise that are found to be related to the project. There is no requirement to resolve any related issues. What is important is that the related issues are forwarded to the individual who can address them.
• Coordination with impact parties (C& L, BA, TAG, V&S, BSP, Portfolio Advisors, etc.) would be considered as evidence of "addressing" a related issue.
This attribute is applicable in those immediate interventions and advocacy projects that involve related issues. This attribute is rated "N/A" for projects with no related issues.
COMMUNICATION (C) – 4 Attributes  
C1 Were substantive updates provided to the submitter on the initial contact and on all subsequent contacts? Reference: The analyst should provide the submitter substantive updates. The content of the contact should be documented on SAMS. Recording that a contact occurred without documenting the substance of the communication does not meet this attribute. Substantive information includes information such as the projected date of completion, current status, and explanation of current status. This attribute is applicable on all immediate interventions and advocacy projects where contact was made with the submitter. This attribute measures only the content of the contacts that were made. Whether or not a required contact was made is rated under attributes T1 and T2.
C2 Was there contact and coordination with the appropriate internal and external stakeholders as required by the project? Reference: Individuals/teams may need to consult Attorney Advisors, LITC, TAP, CNTA, Sr. Advisor to NTA, Portfolio Advisors, BA, TAG, V&S, C& L, and TAS Research This list is not all inclusive.
• The analyst should check the Advocacy Portfolio Assignment list to determine if there is portfolio which relates to the project issue. If a related portfolio is identified, contact should be made with the Portfolio Advisor to seek information and input.
This attribute is applicable on all immediate interventions and advocacy projects.
C3 Did written communications follow the IRS Correspondence Manual and were they grammatically correct? Reference: All outgoing correspondence is subject to review.
• Only the final version of the letter should be reviewed. No consideration is given to drafts that may have been reworked.
This attribute is applicable in all immediate interventions and advocacy projects where correspondence was sent to the submitter. If no correspondence was sent, this attribute is rated as N/A. If a signed/dated copy of the final letter is not included in the file, this attribute will be rated as N/A. The failure to include the letter will be rated under attribute A-7.
C4 If the project requires outreach or education, were the appropriate actions taken? Reference: Finalization and resolution of a project may require that TAS (through Systemic Advocacy) provide education or communication of changes or clarifications to various stakeholders. Appropriate channels include posting to the TAS intranet homepage at http://tas.web.irs.gov, the Internet site at www.irs.gov/advocate , the Wednesday Weekly, or another TAS newsletter).
• "Education" delivered only to the submitter via the closing letter is not considered education for purposes of this attribute.
This attribute is applicable on immediate interventions and advocacy projects that require outreach/education. This attribute is rated as "N/A" on all other projects.

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