22.24.1  Burden Reduction Activities

Manual Transmittal

November 06, 2013

Purpose

(1) This transmits revised text for IRM 22.24.1, IRS Service-wide Burden Reduction Activities.

Material Changes

(1) IRS.GOV link updated to direct viewers to Taxpayer Burden Reduction landing page.

(2) IRWEB link updated to direct viewers to Taxpayer Burden Reduction landing page.

Effect on Other Documents

This supersedes IRM 22.24.1, Office of Taxpayer Burden Reduction - Burden Reduction Activities, dated June 18, 2012.

Audience

All IRS employees who perform work impacting taxpayers or in support of Taxpayer Burden Reduction programs.

Effective Date

(11-06-2013)


Laurie Tuzynski
IRS Senior Advisor, Taxpayer Burden Reduction

22.24.1.1  (11-06-2013)
Taxpayer Burden Reduction Service-wide Goals

  1. The IRS Strategic Plan, within its mission and goals, includes the foundation for incorporation of taxpayer burden reduction and burden mitigation considerations for all Service employees whose work impacts taxpayers. In support of Strategic Goal 1, Improve Service to Make Voluntary Compliance Easier, the IRS Senior Advisor, Taxpayer Burden Reduction (TBR) position was created.

  2. The Office of Taxpayer Burden Reduction (OTBR) was established in January 2002 as part of a taxpayer burden reduction strategy. Over time, the role of taxpayer burden reduction has evolved consistently with comprehensive cultural shifts within the IRS and improvements in service performance. The mission to reduce taxpayer burden and improve service is embedded in the IRS culture and is the responsibility of all functions. With this shift, the need for a separate office diminished. The current structure, with a Senior Advisor single point of contact, provides a link across the enterprise to ensure burden reduction continues to be a priority and is incorporated within decision-making frameworks. In addition, this single point of contact acts as an advocate and liaison with external stakeholders.

  3. Additional information about Service-wide Taxpayer Burden Reduction efforts can be found on IRS.GOV (http://www.irs.gov/Businesses/Small-Businesses-&-Self-Employed/Taxpayer-Burden-Reduction-(TBR)) and IRWEB (http://sbseservicewide.web.irs.gov/tbr/default.aspx).

22.24.1.1.1  (11-06-2013)
Mission

  1. The mission of IRS Taxpayer Burden Reduction efforts is to achieve a significant reduction in unnecessary burden for all taxpayers by each IRS function with programs impacting taxpayers. The functions will:

    • Consider taxpayer burden when implementing policy and procedures.

    • Review existing policy and procedures periodically to identify taxpayer burden reduction opportunities.

    • Work with IRS, state, federal, and other external stakeholders to develop and implement meaningful burden reduction efforts that are consistent with IRS customer service and compliance goals.

22.24.1.1.1.1  (11-06-2013)
Roles and Responsibilities of the IRS Senior Advisor, Taxpayer Burden Reduction

  1. The IRS Senior Advisor, Taxpayer Burden Reduction, has Service-wide responsibilities for taxpayer burden reduction. Organizationally, the position reports directly to the SB/SE Commissioner. The IRS Senior Advisor, TBR will:

    • Provide a link across the enterprise to ensure burden reduction continues to be a priority and is incorporated within decision-making frameworks,

    • Champion burden reduction efforts throughout IRS,

    • Act as an advocate and liaison with external stakeholders,

    • Partner with internal and external stakeholders to more effectively and efficiently identify and address burden reduction initiatives, and

    • Participate on the IRS Services Committee to gain support for burden reduction efforts throughout the Service.

22.24.1.2  (11-06-2013)
Measuring Taxpayer Burden

  1. The ability to demonstrate the tangible results of burden reduction initiatives, through a reliable measurement system, is important for the IRS. Taxpayer burden is defined as the time or money expended by taxpayers to fulfill their responsibilities. Burden is reported using the IRS Taxpayer Burden Model that estimates the burden impact of various proposed legislative, policy and administrative changes, as well as prioritizing various proposals both in terms of time spent and costs incurred. This model estimates the cost to taxpayers in addressing their pre-filing, filing, and post-filing US federal tax payment, reporting, and filing responsibilities. Out-of-pocket costs reported include the cost of tax preparation software and assistance as well as miscellaneous costs such as postage. The latter measure is especially significant since most taxpayers use some form of tax preparer or software assistance in preparing their federal income tax returns.

  2. Efficiency and effectiveness may be used as a secondary measure to gauge the impact of burden reduction initiatives. This measure focuses on IRS cost savings, including staff costs, and reflects the savings realized by the elimination of "downstream" work, such as data entry, adjustments, notices/correspondence and compliance activities. Often these resources can be redirected to more productive efforts.

  3. In keeping with a balanced measures approach, taxpayer burden reduction is not considered at in isolation. It is viewed as a component of customer service/satisfaction and is balanced with compliance. By weighing these two components and the number of taxpayers impacted, the IRS can ensure that unnecessary taxpayer burden is addressed and that tax compliance is not jeopardized.

  4. Taxpayer Burden measures and risk analyses come in both formal and informal formats based on the organization, function, or employees performing the evaluation.

    1. Research, Analysis, & Statistics (RAS) Office of Research develops and maintains the Taxpayer Burden Model. It uses this model, together with subject matter input, to perform burden estimates and evaluations. It conducts ongoing research to support integration of compliance burden into IRS tax administration and Treasury policy analysis.

    2. Wage & Investment (W&I) Media & Publications coordinates all reporting of official burden estimates through the Department of Treasury to the Office of Management and Budget (OMB). Media & Publications also produces burden estimates for forms and schedules not covered by the efforts in RAS.

    3. Office of Chief Counsel considers the impact of compliance burden associated with implementation of new regulations. It provides estimates to Media & Publications for areas outside the scope of RAS estimation and reporting. It coordinates through Media & Publications with RAS to provide subject matter input for RAS estimates of the impacts of new regulations.

    4. Department of Treasury, Office of Tax Policy oversees the methodology used by the IRS to provide burden estimates and may, at its discretion, ask for burden estimation support for policy analysis.

    5. IRS employees responsible for implementing programs, policies, and procedures that impact taxpayers should perform a burden risk evaluation during initial implementation or when changes are being considered. This evaluation should be used in conjunction with other business metrics to guide decision making.

  5. General guiding principles and items employees should consider when assessing burden include:

    Guiding Principle Consideration
    Leveraging Technology
    • Will a new requirement preclude the taxpayer's ability to e-file?

    • Is there an electronic submission alternative other than paper (e.g. web technology or e-mail)?

    • Can fillable forms be created?

    Leverage Existing Data
    • Are there opportunities to leverage information already being requested by another IRS function, government, or from accessible third party data to limit the information collection burden on the taxpayer? (Inquire through web research, third parties, or impacted stakeholders)

    • Are there opportunities to coordinate with third parties to reduce the burden to taxpayers in meeting the requirements (e.g., consolidate data collection resulting in one form versus two)?

    Consider Pre-decisional Stakeholder Input
    • Do the procedures/requirements conform to current external business processes or recording/reporting practices/

    • Are your documents in plain, coherent, and unambiguous terminology?

    Benefit Must Outweigh Burden
    • Are you requiring documentation that is not necessary to comply with the law and/or which may not actually be reviewed by IRS (or rarely reviewed)?

    • Are there consequences to the taxpayer for failing to provide the data? If not, how sure are we that they will provide accurate information?

    • If there are multiple options for legislative implementation, which options are expected to provide the greatest benefit to tax administration for the public cost imposed?

    • Can the procedure be optional versus mandatory?

    • Can a short form, or other simplified method, be created for some of the population?

    • Can a safe harbor procedure be offered to mitigate burden, especially for low income taxpayers and small businesses?

    • Can the frequency of information collection be limited/reduced?

    • Should transition relief be offered?

  6. Additional information on taxpayer burden, including burden risk evaluation tools, can be found at the Taxpayer Burden Reduction IRWeb page(http://sbseservicewide.web.irs.gov/tbr/default.aspx).

22.24.1.3  (11-06-2013)
Taxpayer Burden Reduction Initiatives

  1. Taxpayer Burden Reduction Initiatives should address administrative, regulatory, process or systemic issues that impact large numbers of taxpayers and significantly reduce burden.

  2. Employees may make taxpayer burden reduction recommendations through the Employee Suggestion Program or by using Form 13285, Catalog Number 34279X, "Taxpayer Burden Reduction Referral" . When completing the form, employees should provide as much information as possible; however, leave the tracking number block blank. The form is available on the Forms/Pubs/Docs section of the IRS Intranet.

    Note:

    The employee suggestion program is the only program through which employees can receive monetary and/or time-off awards for adopted suggestions; therefore, employees seeking an award must instead use the employee suggestion program procedures.

  3. All Taxpayer Burden Reduction Initiatives from all Operating Divisions and functions should be routed through their management channels to their Taxpayer Burden Reduction point of contact or as instructed by their Operating Division to a central contact point. Alternatively, Taxpayer Burden Reduction may be routed directly as indicated on the Form 13285.

  4. An external form for the use of taxpayers and stakeholders, Form 13285A, "Reducing Tax Burden on America's Taxpayers" , is also available on the Forms/Pubs/Docs section of the IRS Intranet and on IRS.gov.

  5. All initiatives must be coordinated with all internal and external stakeholders to ensure that other program areas and interests are not negatively impacted. The IRS Senior Advisor, TBR, utilizing the Service's Committee as necessary, may facilitate this coordination. Initiatives will be undertaken based on the cost benefit-type analysis approach referenced in the Measuring Taxpayer Burden section.

  6. Form 14411 (for external use) and Form 14411A (for internal use), "Systemic Advocacy Issue Submission Form" should be used to submit issues to the Taxpayer Advocate Service to identify potential advocacy issues.

22.24.1.4  (11-06-2013)
Services Committee

  1. The Services Committee serves as the governing body for major service investment and management decisions at the IRS. It discusses and makes decisions or recommendations on items related to taxpayer service investments, resource allocations, and program and process management in the context of IRS-wide strategic planning and budgeting (e.g. Modernization Vision and Strategy, the IRS budget, relevant research conducted by the Office of Research, Analysis, and Statistics and the Operating Divisions, etc.).

  2. The Services Committee will be the forum used as a coordination/facilitation body to raise and support burden reduction initiatives and studies, and ensure a strategic approach to taxpayer burden reduction. The Committee does not supplant line authority and accountability, which resides with the Business Units.


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