Recommendations On How to Become Compliant with the New Requirements
Given the significant changes in technical safeguards requirements found in Sections 4, 5 and 6, the IRS has some recommendations for agencies to become compliant with the new requirements.
All on-site safeguard reviews conducted after November 1, 2010, will use the updated Publication 1075 (PDF) requirements. The Office of Safeguards expects that the agencies under review in late 2010 and early 2011 may have gaps due to implementation timing that will be noted in the associated Safeguard Review Report.
While the Office of Safeguards is not requiring agencies to share their gap analysis and/or plan to address identified gaps, we welcome copies via our electronic mailbox at firstname.lastname@example.org. We suggest using a subject line heading of "1075 Implementation Plan."