- 13.2.2 Inventory Control and Working an Assignment
- 18.104.22.168 Introduction
- 22.214.171.124 Identifying an Advocacy Issue
- 126.96.36.199 Advocacy Submission Processing
- 188.8.131.52.1 Scope
- 184.108.40.206.2 Interest/Visibility/Sensitivity
- 220.127.116.11.3 Taxpayer Burden
- 18.104.22.168.4 Taxpayer Rights
- 22.214.171.124.5 Ability to Effect Change
- 126.96.36.199 Creating Systemic Advocacy Projects
- 188.8.131.52 Project Assignment, Development, Management and Working a Project
- 184.108.40.206.1 Project Assignments
- 220.127.116.11.2 Project Development
- 18.104.22.168.3 Project Management
- 22.214.171.124.4 Team Composition
- 126.96.36.199.5 Working a Project
- 188.8.131.52.5.1 Project Charter
- 184.108.40.206.5.2 Action Plan
- 220.127.116.11.5.3 Project Research
- 18.104.22.168.5.4 Project Action Dates
- 22.214.171.124.6 Substantive Actions and Project Responsibilities
- 126.96.36.199.7 Required Internal Coordination
- 188.8.131.52 Key Contact Information
- 184.108.40.206.1 Project Status Updates
- 220.127.116.11.2 Project Resolution or Remedies
- 18.104.22.168.2.1 Informal Agreements
- 22.214.171.124.2.2 Advocacy Proposal
- 126.96.36.199.2.3 Published Guidance Projects
- 188.8.131.52.2.4 Legislative Proposals
- 184.108.40.206.3 Closing an Advocacy Project
- 220.127.116.11.4 Submitter Closing Notification
- 18.104.22.168.5 Review and Enactment by the Operating Division or Function
- 22.214.171.124.6 Monitoring Outcomes
- 126.96.36.199 Project Executive Summary
- 188.8.131.52.1 Project Closing Letters
- 184.108.40.206 Systemic Advocacy Management System (SAMS)
- 220.127.116.11.1 Overview
- 18.104.22.168.2 Access to SAMS
- 22.214.171.124.3 Submitting Advocacy Issues
- 126.96.36.199.4 Reporting SAMS Problems
- 188.8.131.52 Systemic Advocacy and the Employee Suggestion Program
- 184.108.40.206 Taxpayer Advocacy Panel (TAP) SAMS Submission
- 220.127.116.11 Methods of Submitting Changes to Systems, IRMs, Forms, Publications, Notices, and Letters
- 18.104.22.168.1 Forwarding Forms and Publications Change Requests
- 22.214.171.124.2 Coordination of Change Requests by the TAS IMD/SPOC
- 126.96.36.199.3 System Change Request (Form 5391) for IRM Procedural Changes
- 188.8.131.52.4 Editorial Change Request (Form 9345)
- 184.108.40.206.5 Other Change Requests
- 220.127.116.11.6 System Production Evaluation Report (Form 5715)
- 18.104.22.168 Systemic Advocacy and Internal Management Document (IMD) Reviews
- 22.214.171.124 Systemic Advocacy and Task Force Participation
- 126.96.36.199 Systemic Advocacy Time Reporting
- 188.8.131.52 Systemic Advocacy Submission Transfer Guidelines
- 184.108.40.206 Systemic Advocacy Measures
- Exhibit 13.2.2-1 SAMS Issue Evaluation and Project Creation Process
- Exhibit 13.2.2-2 Advocacy Proposal Template
- Exhibit 13.2.2-3 TAMIS Research Request Form
- Exhibit 13.2.2-4 TAS Communications Assistance Request (CAR)
- Exhibit 13.2.2-5 Memorandum to Request a Counsel Legal Opinion
- Exhibit 13.2.2-6 Executive Summary Template
- Exhibit 13.2.2-7 TAS Research Request Form
- Exhibit 13.2.2-8 IRS Operating Division or Function Research Request Form
- Exhibit 13.2.2-9 Advocacy Closing Letter
- Exhibit 13.2.2-10 SA Quality Attributes
Part 13. Taxpayer Advocate Service
Chapter 2. Systemic Advocacy
Section 2. Inventory Control and Working an Assignment
The TAS Office of Systemic Advocacy (OSA) and Field Systemic Advocacy (FSA) each play a vital role in identifying, analyzing, and resolving broad-based taxpayer problems. Projects arise from several sources, including field offices within TAS, IRS employees in other functions, and external stakeholders.
OSA starts with Systemic Advocacy Management System (SAMS) submissions and then applies the tools of project management when working the projects developed from these submissions, informing stakeholders of the progress on a project and the final results. These items are the essence of OSA analysis and initiatives.
This section will provide guidance and instruction on how to:
Identify a project;
Accept a project;
Assign a project;
Work a project (developing, managing, proposing solutions, closing procedures and communications); and
Issues that adversely impact taxpayers come to the attention of TAS through various external and internal sources. The sources internal to TAS and IRS include:
Employee suggestions and ideas;
LTA (Local Taxpayer Advocate) offices (including Advocacy Portfolio issues);
Area Directors' offices;
TAS case activity;
The National Taxpayer Advocate (NTA);
Senior advisors to the NTA;
Other senior TAS leadership;
The Taxpayer Advocacy Panel (TAP) and Low Income Taxpayer Clinics (LITCs);
TAS data analysis; and
Operating divisions (ODs) or functions.
External (outside of the IRS) sources of advocacy issues could include:
Individual and business taxpayers;
Customer satisfaction surveys; and
Organizations such as the IRS Oversight Board, TIGTA and the GAO (Government Accounting Office).
Generally, issues are submitted to the OSA through SAMS. The OSA may also receive submissions from sources other than SAMS (i.e.,Form 14411 , Advocacy Issue Submission Form). When such a submission is received, the OSA will:
Input the issue on SAMS;
Immediately date stamp any paper document(s); and
Email the SAMS Program manager with submitter information;
The SAMS Program Manager will review and prioritize the issue submissions and refer them to the DII (Director Immediate Intervention). The DII then makes an initial assessment as to whether the issue should become a project. Each submission is considered for potential advocacy project (AP) status using a series of factors and detailed process steps. See Exhibit 13.2.2-1, SAMS Issue Evaluation and Project Creation Process.
The SAMS Program Managers initially rank submissions utilizing ranking questions. The questions fall into five categories:
Taxpayer Rights; and
Ability to Effect Change.
The following three factors help determine how widespread the problem may be.
Potential Volume of Taxpayers Affected Within the Identified Segment - Of the taxpaying population within the identified segment (Individuals, Small Business, etc.) how many could be impacted by this issue? Designate as a high, medium, or low number relative to the overall segment. For example, a problem with Line 5 on Schedule D would affect a relatively low number of people, because out of 127 million individual filers, approximately 25 million file Schedule D and only a portion of that group fills in Line 5.
Geographic Scope - Does the issue impact taxpayers across the nation (national), in clustered areas (area, region, or campus), or only in certain places (local)?
Issue Frequency - Does the issue happen on a recurring or cyclical basis, on a limited or sporadic basis or only one time?
The following three factors help determine the amount of interest, visibility, and or sensitivity associated with the problem.
Congressional Interest/Support - How much support or interest has Congress expressed concerning this issue? Did the support or interest come from one member’s office or is it widespread in the House or Senate (high, moderate, or low)?
Community/External Stakeholder Interest/Support - How much support or interest have external stakeholders expressed concerning this issue? Was the support from one specific group (American Bar Association (ABA), American Association of Retired Persons (AARP), etc.) or is it spread across various sectors such as accountants, lawyers, and other special interest groups (high, moderate, or low)?
Media Interest/Publicity - How much interest has the media shown in this issue? What level of coverage does this issue rate (high, moderate, or low)?
Four factors help determine the level of burden placed on the taxpayer trying to resolve the issue. Always consider burden from the taxpayer's or stakeholder’s point of view.
How long to resolve - How long does it take to resolve this issue (from the taxpayer's perspective)? The choices range from "Less than three months" to " Greater than one year." The longer it takes, the more points are awarded.
Effort - How much effort is required to resolve this issue (again, from the taxpayer's or other stakeholder’s perspective) -- minimal, moderate or significant? The more effort it takes to resolve the issue, the more points are awarded.
Financial - What is the financial impact on the taxpayer (excluding tax, penalties and interest) -- minimal, moderate or significant? Factors include issues such as the cost of representation and the taxpayer's ability to pay for this representation, and the cost of repeated photocopies or express mail for documentation, etc.
Fairness - Is this taxpayer treated disparately compared to other taxpayers? If the taxpayer is treated fairly, the issue is not awarded criteria points; if not treated fairly the issue is awarded points.
Two factors help determine how the problem affects taxpayers' rights.
Denial of Taxpayer Rights - Did the taxpayer have the opportunity to exercise a right or was the taxpayer denied something (privacy, collection, appeal, etc.) that the taxpayer had the right to? If taxpayers' rights are violated, award criteria points; otherwise do not award points.
Enhancement of Taxpayer Rights - Does this issue enhance taxpayers' rights? If so, award criteria points; otherwise do not award points.
Two factors help identify issues that may not be resolved without TAS intervention.
Likelihood of Independent IRS Action - How likely is it that the OD or function will fix the problem without TAS intervention? The higher the likelihood of independent action, the fewer criteria points are awarded.
TAS Ability to Influence Change - How likely is it that TAS will be able to influence the OD or function to address the issue? The higher the likelihood of TAS influencing change, the more criteria points are awarded.
After the issues are ranked, recommendations are forwarded to the DII. The DII decides whether the issue requires immediate intervention (II). Immediate intervention determinations are made considering the following factors.
Is the harm such that multiple stakeholders need to be involved immediately?
What is the underlying cause of the problem?
Are the right stakeholders involved?
What is the scope of the problem?
What is the impact on one or more of the balanced measures (customer service, employee satisfaction, and business results)?
What are the possible short and long term solutions?
Will the issue need long-term project analysis?
Notice 54 mailed with refund checks: A POA had notified Systemic Advocacy that Notice 54 was being included with the mailed refund checks that IRS mailed. Notice 54 states, "The amount of the enclosed refund check is different than the amount shown on your return. You should be receiving a notice in a few days that explains why the amount of the check is different and what additional information, if any, you need to provide to the IRS." In actuality the refund issued agreed with the refund requested by the taxpayer on their return, and no additional notice explaining why the check amount was different was scheduled by IRS to be sent, as there was not a discrepancy.
This notice was generating taxpayer confusion, and increased phone calls and correspondence from taxpayers requesting clarification. Notice 54 was generating from the Fresno Service Center. Math error notices were not sent and it appeared the only item generating the notice was the interest amount paid with the refund for the telephone tax credit.
Within this project, research indicated that CI-Refund Crimes, SB/SE Compliance, the Fresno Campus Manual Refund Unit, IRS Application Development, Notice Gatekeeper, Financial Management Service (FMS), and the W&I Program Office all needed to be contacted as critical stakeholders. Procedures in FSC required that Notice 54 be sent when a paper refund was issued, including EITC. This procedure began over six years ago to address concerns addressed by FMS when working EITC fraud cases. The confusion regarding the generation of Notice 54 when TETR interest was involved also had an impact on the actual coding of the error file. Traditionally, this notice is issued when a math error adjustment has been made, adjusting the amount of refund the taxpayer may be expecting. However in this case no math error adjustment was involved and the refund had not been adjusted.
Systemic Advocacy coordinated the fact-finding and the stakeholders' interest to secure agreement regarding a systemic programming change. This issue had the potential for nationwide impact and significant burden to numerous taxpayers. The resolution of the project was systemic programming.
Disaster Relief Denied Part of Maine was proclaimed a disaster area due to storms April 14 through 18, 2007. As a result of the disaster declaration, taxpayers were given until June 25, 2007, to file and pay the tax due on or after the incident date. The problem stems from the FEMA declaration that the incident date was April 18, 2007. Because the Form 1040 was due April 17, 2007, IRS disaster units were taking the position that Maine taxpayers were not eligible for penalty or interest relief. Maine zip codes were not included in the systemic S freeze for disaster. However, the IRS news release and the local IRS press release, ME- 2007-22, stated "Deadline for affected taxpayers to file returns, pay taxes and perform other time-sensitive acts falling on or after April 14, 2007, and on or before June 25, 2007, have been postponed to June 25, 2007."
Maine taxpayers and preparers relied on information supplied via the IRS press release and website, and were receiving bills for penalty and interest. Systemic Advocacy determined the underlying cause of the problem to be that the IRS did not realize there had been an amendment of the FEMA dates on the declaration for the state of Maine. Upon notification of key stakeholders, the MITS programing was revised. The resolution was confirmed within 3 days of the SAMS review of the issue.
If the issue is determined not to be an Immediate Intervention, the DII and DAP will determine whether the issue should be an advocacy project. The consideration of issues for advocacy project selection includes a series of factors listed below.
Whether the issue is statutory (Internal Revenue Code), covered by the Treasury Regulations or addressed in the IRM?
Whether the issue has been previously addressed in the Annual Report to Congress, and if so how long ago and what was the outcome? If the issue was addressed recently, the submission may not be selected for a new project unless the IRS has failed to take an action it agreed to take. The issue may be made into a project if a significant period of time has lapsed since the issue was addressed. To the extent the issue has not been previously addressed in the annual report, the creation of a project may be warranted.
Whether the issue has been submitted multiple times, indicating additional consideration, as an emerging issue that warrants development. See Exhibit 13.2.2-1, SAMS Issue Evaluation and Project Creation Process.
Bulk Filing - P&I The IRS has charged penalties and interest due to late filing on bulk paper filings. Upon review, it appeared the decision to charge late filing penalties and interest was based on the "date of receipt" instead of the "date mailed" on the tax returns. To support the claim, the submitter enclosed copies of the stamped certified mail receipt and transmittal letters showing that the returns were timely filed on April 17, 2006. The submitter received notices from three different IRS offices for the same issue, adding additional confusion. A minimum of two SA projects were selected and worked regarding this issue coordinating the research and input from both the internal and external stakeholder. The data gathered and analyzed supported the project recommendation to establish a national team. The recommendation was accepted by the Office of Taxpayer Burden Reduction as a featured Taxpayer Burden Reduction Project. Campus locations implemented several of the team's suggestions.
Incorrect ES Penalty when disaster freeze present Interest, FTP and FTF penalties were correctly adjusting on accounts when the Disaster Extensions are input; however, the Estimated Tax Penalty was not always adjusting correctly when taxpayers self-identify as being affected by the hurricane disasters. Command Code PIEST shows the ES penalty on several TAS cases. If the Disaster freeze had a revised date and posted to Masterfile before the return posted, the ES penalty, FTF, FTP and interest were computed correctly. However, if a disaster freeze was input after the return posted, the program recomputed interest, FTF or FTP penalties, but did not recompute the ES penalty.
Systemic Advocacy project efforts included the validation of the root cause. Individual Master File account taxpayers who were granted disaster relief but overpaid their estimated tax payments were impacted when the -O freeze was manually set on accounts where a return has already posted for tax years 2004, 2005 and 2006, for specified FEMA declarations, resulting in an incorrect computation. Systemic Advocacy coordinated communication with the IRS Disaster Coordinator and MITS, to conduct a systemic recovery to adjust the accounts, abating the inappropriate assessment of penalties and related interest, and notify effected taxpayers of the corrections to their accounts.
The SAMS program managers will systemically notify the submitter when a decision regarding project selection status is made.
Submissions not selected for an AP will be considered for other appropriate action, including referral to the other TAS HQ program staff; such as Portfolio Advisors, Technical Analysis and Guidance (TAG), Attorney Advisors, Internal Technical Advisory Program (ITAP), Taxpayer Advocacy Panel (TAP), Communications & Liaison (C&L), and Low Income Taxpayer Clinic (LITC). The submissions will be forwarded for their consideration and written response to the submitter, generally within 30 days of issue receipt. Program staff members are required to provide copies of the closing response to the SAMS program managers. A signed (electronic or copy signature) of the Closing Letter or email will be included in the project file at closing and an electronic copy should be attached to the project on SAMS. Responses to internal submitters may be via email. Responses to external submitters often require a formal letter, including the employee's job title and identifying number.
Most external submissions are received by IRS.gov and may only have an email response address. Additional actions may be necessary to secure appropriate submitter contact information when a formal response is required. Recommended email language: " You contacted Systemic Advocacy via IRS.gov. for information or assistance. We have been unable to reach you. If you would like to communicate with us, please call XXX-XXXX."
Submissions that warrant action by another IRS organization, e.g., the IRS suggestion program, should be ranked "Not Accepted" and SAMS will automatically deliver a systemic notification to the submitter.
Duplicate issues will not be ranked and will be closed on SAMS by placing them in Duplicate status and associating them to the corresponding duplicate issue.
Related issues will be associated with other like issues (and all work types) and generally be closed if there is an open or recently closed project on the same topic. The SAMS Program Manager will contact the submitter and add him or her as a stakeholder on any open related project. Project Leads will update the submitter of the related issue on the status of the project and will include the submitter on closing correspondence. SAMS Program Managers will be responsible for adding the related issues on the projects as "associations," and notifying Project Leads and their managers of the association. When ranking issues, SAMS Program Managers and their delegates will consider the expanded scope of a topic when several related issues are received and there is not an open project on the topic. This information will be elevated to the DII and DAP for project consideration.
Once issues are accepted as projects, they become the responsibility of the DII and DAP. The DII will usually assign an II to a Technical Analyst. The DAP will assign APs to Technical Analysts or to the FSA (Field Systemic Advocacy) Director for assignment to the FSA staff. The issue work flow state will change to "Issue Closed" on SAMS once an issue has been accepted by the DII or DAP and a project is created. Additionally, a check mark will appear in the box labeled "Promoted to Project" .
Some issues require immediate intervention. For these, the SAMS Program Manager, with concurrence from the DII, will:
Research SAMS and add the II designation, if it is not correct; and
Assign the project to the DII.
The DII then assigns the project to a Technical Analyst.
The Technical Analyst will:
Contact the submitter(s). This provides an opportunity to determine whether additional information is available or changes have occurred.
Develop an action plan for resolution within five calendar days of assignment.
Follow the AP Process.
Maintain a sense of urgency when working the project.
The DAP assigns projects based on the priority of underlying issues.
An AP is designed to:
Identify and address systemic and procedural issues;
Analyze the underlying causes of problems; and
Propose corrective action.
When working on an AP, document all activities on SAMS. An advocacy project should include:
Researching, identifying, and verifying the source(s) of the problem(s);
Researching applicable laws, regulations and procedures, including Internal Revenue Code, case law, Treasury Regulations, and IRM provisions;
Collecting and analyzing the data;
Soliciting feedback from appropriate internal and external sources;
Interacting with the appropriate OD and function contacts in researching, understanding, and identifying proposed solutions; and
Preparing Advocacy Proposals for review by management. See Exhibit 13.2.2-2, Advocacy Proposal Template.
This section provides details of:
Project management; and
Working a project.
The project may be assigned to a single project leader, or if the issue requires multiple resources, a team may be established to address the issue. A team may include Analysts, LTA/Portfolio Advisors, Attorney Advisors, Technical Advisors, and Research Analysts.
The manager adds all team members to the project on SAMS along with the "actual start date." Both of these actions will be done upon assignment to the project leader. Upon receipt of an assigned project, SAMS will be updated to "In Process." Any members joining the team after assignment will be added to the team on SAMS by the project leader.
Project development begins when the project is assigned to a lead or team. Project development consists of tasks that foster and support background research, process analysis, collection and interpretation of data, and coordination with operating divisions.
Project development tasks will include:
Creating (on SAMS) a charter that specifies the project's purpose and requirements;
Determining the project scope, including objectives, deliverables, barriers, and affected customers;
Determining an appropriate remedy or solution;
Creating an action plan on SAMS; and
Devising and delivering project status reports to management as appropriate.
Project management enables team leaders and members to efficiently organize and coordinate efforts. It assists them in creating the appropriate plan, product, or process within the resource limits of an organization.
Project management provides inputs, processes and outputs that provide structure to a project.
A project team is comprised of three primary components:
Project lead, and if required;
The project manager’s responsibilities include:
Monitoring the progress of the project;
Guiding and supporting the project leader and team members; and
Acting as liaison between the team, management, and outside stakeholders.
The project lead’s responsibilities include:
Monitoring the progress of the project to ensure that deadlines are met;
Coordinating activities of team members; and
Acting as liaison between the responsible manager of the project and the team members.
The team member’s responsibilities include:
Completing tasks by the established deadlines;
Communicating with the team leader and members on progress of work and any pressing issues; and
Keeping his or her manager apprised of the progress of the project.
The first steps in working a project are:
Review and clarify the issue;
Contact the submitter for validation of issue and obtain supporting case examples;
Conduct initial research;
Validate the problem;
Determine the scope; and
Develop a plan of action.
The project lead should make initial contact with the submitter within the following timeframes:
Immediate Interventions (II) - 1 business day from the "Actual Start Date" on SAMS.
Advocacy Projects (AP) – 3 business days from the "Actual Start Date" on SAMS.
During the initial contact, advise the submitter of project assignment and confirm a clear understanding of the issue. The initial contact also provides an opportunity to determine whether additional information is available or changes have occurred. The project lead should tell the submitter to expect updates as often as every 30 days (or less frequently if the submitter agrees) until the project is complete. All contact will be documented on SAMS and will include substantive detail of what was discussed. The substance of the discussion should be documented on the "Notes" tab and labeled as a "contact." SAMS will need continuous updates throughout the process, regardless of the project status, until it is closed by the director.
If the submitter is not an IRS employee, immediately upon telephone contact tell the taxpayer or representative your name, job title and unique employee identification number. If you do not make telephone contact, your initial letter to the customer must contain the above identifying information. This will satisfy the requirements of RRA 98 § 3705 Identify Yourself. See IRM 220.127.116.11, RRA 98 § 3705 Identify Yourself, for additional information.
Notification to the submitter is not required in the following instance:
No contact information is available. (i.e., Internet user) You need to document attempts to identify the submitter. However, if you have the submitter's email address, after consulting with your manager, you may send an email to the submitter to secure appropriate contact information.
For Advocacy Projects, the project lead will:
Develop an action plan within 30 calendar days of the actual start date on SAMS that includes a course of action to identify and resolve the issue.
Notify the manager that the action plan is available for review/approval and update SAMS that the manager has been notified.
The manager will review the action plan within 15 calendar days of the task assignment and document this review on SAMS. If the lead does not timely notify the manager of the action plan, the manager should follow up.
For Immediate Interventions the project lead will:
Develop an action plan within five (5) calendar days the actual start date on SAMS that includes a course of action to identify and resolve the issue.
Notify the manager that the action plan is available for review, and update SAMS that the manager has been notified.
The manager will review the action plan within four calendar days of notification and document this review on SAMS. If the lead does not timely notify the manager of the action plan, the manager should follow up.
It is mandatory to complete eight (8) items in the project charter and document this action on SAMS.
The 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. For example, if the project is an ARC (Annual Report to Congress) project, an obvious constraint is the December 31 deadline for delivery to Congress.
Risks/Rewards: The project lead should 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), describe the costs of the issue to the customer, and if possible estimate the change in these costs with resolution.
Resolution: Complete this field at the close of the project. However, space is limited, so only a brief description is necessary.
Key issues: Convey any information you have about the progress of the project and address additional information about its resolution that does not fit the "resolution" field. You can also use this area to describe any temporary solutions for immediate intervention issues.
The optional elements of the project charter are:
Opportunities: Include any opportunities that this project may surface (e.g., the opportunity to reduce taxpayer burden or tax law complexity). This item is optional.
The action plan, key deliverable, and critical actions will be entered on the "Task" tab. The purpose of breaking down the project into tasks is to:
Determine the most efficient way to divide up the work;
Assign accountability for each task;
Coordinate the efforts of team members, if applicable;
Determine the resources needed to accomplish the project; and
Identify a potential remedy.
An action plan will contain:
A description of each task or action item;
The due date or scheduled due date for each task/action item;
Tasks are significant events that mark progress in the project, such as a deliverable or the completion on a phase.
A deliverable is the result of an activity (e.g., a product, service, process, or plan). Interim deliverables may be necessary to produce the final deliverable or product delivered to the customer. In an AP, the final deliverable may be defined as the recommended solution(s) to the problem(s) giving rise to the project.
Initial research includes detailed research of case examples, a review of the IRC, Treasury Regulations and applicable IRM sections. Initial research may also include a review of past ARCs, interim guidance memoranda, forms, publications, and OD websites. All research will be documented on SAMS in the "Notes" tab and labeled as "Research."
Additionally, most projects will require data gathering from TAS sources such as the Taxpayer Advocate Management Information System (TAMIS), SAMS and Business Performance Management System (BPMS) as well as research of the Integrated Data Retrieval System (IDRS) research and other OD systems.
The OSA has several forms to help formulate clear, concise research requests for TAS or the ODs.
The TAS Research Request form, used within the TAS organization, includes four areas that need to be addressed:
Explanation of the request for the research;
Pertinent background regarding the topic;
Explanation of the goal of the research request and expected results; and
Formulation of the research question.
The OD and function research request form, used outside TAS, has two areas that need to be addressed:
Description of the problem; and
Description of the information requested.
The TAMIS research request form, used specifically to request TAMIS data, includes seven areas for the submitter to address:
Explain the reason for data request (i.e., Top 20 analysis, Legislative Initiative analysis, Field advocacy issue, Other);
Provide pertinent background (i.e., relevant information regarding the history of the issue for which the data is requested);
Explain the intended use of data (particularly if the data is being used to provide anecdotal information or to attempt to project to a larger population);
Indicate the number of requested cases (e.g., all PCI 950 cases, a specific number of cases, or to determine a sample size);
Specify TAMIS query parameters (e.g., all cases belonging to a certain PCI, cases closed or open between specific dates);
Specify requested TAMIS fields (open date, tax periods, MFT, criteria code, etc.); and
Specify the data format (EXCEL, ACCESS, etc.).
See Exhibit 13.2.2-3, TAMIS Research Request.
The TAS Communications Assistance Request template has been prepared to facilitate development and coordination of communication messages within the TAS organization. A Headquarters or AD who needs a message communicated (e.g., a request for case examples for a project) will complete the form and send it to the Director, TAS C&L. See Exhibit 13.2.2-4, TAS Communications Assistance Request (CAR).
When working a project, you may discover you need legal advice. As employees of Systemic Advocacy or Field Systemic Advocacy, any legal advice you would need would generally be provided by the Office of the Special Counsel to the NTA. See Exhibit 13.2.2–5, Memorandum to Request a Counsel Legal Opinion. In rare instances, the field offices of the Division Counsel, Small Business/Self-Employed (SB/SE) division will provide the advice (e.g., you need legal advice about a TAS case rather than a systemic project). The list of SB/SE Counsel contacts can be found on the Special Counsel to the NTA website.
SB/SE should not provide legal advice for the issues listed in paragraph (10) below. See also IRM 18.104.22.168, Obtaining Legal Advice From Chief Counsel.
Request advice on issues personnel, labor, and procurement issues through your local General Legal Services (GLS) office. Seek advice on criminal tax matters from your local Criminal Tax (CT) Counsel office. The lists of GLS and CT contacts can be found on the Special Counsel to the NTA website.
The Special Counsel to the NTA has primary jurisdiction over the following issues:
IRC § 7803(c), including the Local Taxpayer Advocate's discretion not to disclose information per the IRC § 7803(c)(4)(A)(iv);
IRC § 7811;
Taxpayer Advocate Directives;
The scope of TAS's statutory authority or delegated authority; and
Issues regarding TAS legislative proposals or any other matter related to the NTA's annual reports to Congress.
When legal advice is needed, the project lead should seek advice from the appropriate contact (Special Counsel to the NTA, SB/SE Counsel, GLS counsel, or CT Counsel) through management. See Exhibit 13.2.2-5., Memo for Request for Counsel Assistance. Use this memorandum format when seeking assistance from Counsel. All written requests for Counsel assistance must be routed through a manager, and when appropriate, through the EDSA or the EDCA.
Set follow-up or next action dates to provide continuity to the project work.
Document these dates on the "Task" tab on SAMS. The following are criteria for II and AP projects in regards to follow-up dates:
If a follow-up date was set, the project lead has 14 calendar days from the follow-up date to take action,
If no follow-up date was set, the project lead has 14 calendar days from the last action to take the next action.
Every project follows a basic process of substantive actions:
Issue problem validation;
Determination of issue scope;
Action plan development;
Initial management consultation;
Execution of approve action plan task;
Development of recommendations/issue resolution;
Management consultation and concurrence;
Continuance of the project task;
Preparation of closing documentation; or
A project must be worked following this process with no unnecessary delays or periods of inactivity.
Responsibilities for the project leader and/or team members include:
Monitoring the progress of the project;
Monitoring the progress of the project so that deadlines are met;
Communicating with the project leader and members on the progress of the work; and
Coordinating the activities of team members.
The project lead must ensure that contact is made with a variety of internal partners to seek information and input. These partners may provide informal support to the project or join the project team, with their managers' approval. Document all contacts on SAMS. Internal partners may include:
Portfolio Advisors (PA): The NTA has assigned to each LTA an Advocacy Portfolio or portfolios. The PAs maintain a current understanding of the topic, initiate proactive proposals, assist in resolving identified problems, and monitor the program/process. See IRM 22.214.171.124.2.3, Advocacy role of Portfolio Advisor (PA).
The TAS Director of TAG (or designee);
The LITC Program Director (use email and cc other LITC managers as needed);
Other Appropriate HQ Directors, including the Director, ITAP; and
Attorney Advisor Manager.
The DII will secure and update key contact information quarterly. The list is then distributed to the Directors, AP and FSA to facilitate communication among the TAS program offices.
Analysts should update II project status on SAMS every Thursday by noon, using the "Notes" tab and selecting "Status" as the note type.
Analysts should update AP project status on SAMS by the last working day of each month and when a significant action needs to be brought to management’s attention, using the "Notes" tab and selecting "Status" as the note type.
All project status updates must use the following format;
Issue - LITCs not receiving transcripts when calling the PPS. (Sample verbiage) Causes - Inadequate IRM procedures to help IRS employees understand role of an LITC student representative. LITCs not following instructions when submitting POAs - Representative & Taxpayer signatures more than 45 days apart invalidate the POA. Also, LITC POA is valid only 130 days from the time it is received in the CAF unit. (Sample verbiage) Actions to Date - IRM updates requested for Collections, Exam & Accounts Management that educated IRS employees about role of student representatives. Submitter has gone out to all LITCs asking for the procedures followed in securing a POA so we can determine a root cause and the extent of the issue (i.e., Is this problem limited to academic LITCs or all LITCs?). (Sample verbiage) Actions Remaining - Outreach to LITCs to reinforce submission requirements of POA, and limitations such as 45 day rule and 130 day rule. SERP alert - to all areas dealing with LITCs to alert them of the rights of student representative from LITCs. (Sample verbiage)
Some projects or proposals will not lend themselves to the exact process stated below. This may be due to expediency or the sensitivity of the issue. OSA management will take part in closing out all projects and will advise staff of what steps to take in these situations.
The Project Lead will recommend to management the most appropriate way to resolve the issue during the project completion phase. The project lead must consider the expediency or sensitivity of the issue and proposal when selecting the method. Project analysis and resolution recommendations will be documented within the executive summary. See Exhibit 13.2.2-6, Executive Summary Template.
Examples of methods to resolve projects include:
Informal recommendations to the Operating Division;
Administrative recommendations, including programming change requests;
Published guidance requests;
Advocacy Proposals (issued by the EDSA);
Taxpayer Rights Impact Statement (TRIS) (Issued by the NTA);
Proposed Taxpayer Advocate Directive (Issued by the NTA);
Taxpayer Advocate Directive (TAD) (Issued by the NTA); and
Legislative Recommendation (proposed by the NTA in the Annual Report to Congress).
Informal agreements resolve projects without the need for a written Advocacy Proposal. Examples of these agreements that require no signature are as follows:
Resolution by VMS;
Verbal contact, or
The project lead must document all informal recommendations on SAMS, using the "Recommendations" tab. This allows OSA to track recommendations sent forward for implementation (e.g., requesting a SERP alert, agreed upon changes to the IRM, etc.).
Informal agreements will require a closing date, closing recommendation, closing contact information for the contact responsible for implementing agreed upon actions, implementation date; and, if necessary, a follow-up date and contact name. Informal agreements should be considered for TAS-wide communication by C&L. See Exhibit 13.2.2-4, TAS Communications Assistance Request.
Any informal agreement should always be discussed with management to determine whether it represents an appropriate resolution to the problem.
When the Project Lead or team completes research, collects, interprets and analyzes the data, and interacts with the OD or function to resolve the issue at the appropriate level but is unsuccessful, it is appropriate to draft an Advocacy Proposal setting forth the recommended solution(s) or corrective action(s) for the problem. The draft proposal should include:
Introduction -- a separate section one to two pages long, prepared after the proposal is complete, with summary statements from each of the proposal's major headings, which will become the front page of the final report.
Problem Statement -- a brief explanation of the issues and/or problem along with analysis of relevant laws, regulations or procedures.
Agreements Reached -- a detailed description of any agreements reached with the OD or function, to date.
Agreements Needed -- a detailed description of agreements needed with an explanation as to how these agreements will resolve the problem(s).
Requested Action -- a detailed explanation as to what next steps the OD or function should take to resolve the problem.
TAS Contacts -- the names and contact information for the EDSA, the DII or the DAP, as applicable, and the project lead.
The project lead will provide to management a draft of the Advocacy Proposal along with an Executive Summary and pertinent attachments, such as memoranda, letters or other document(s).
If the proposed remedy requires a change to an IRM, the TAS SPOC must be added as a team member so he/she will be aware of the proposal and can monitor the IRM correction request.
Forward advocacy proposals through management channels to the DII or DAP. The DII or DAP, if they agree, will work with the appropriate OD or function program manager to resolve the issue.
If the DII or DAP cannot resolve the issue, forward the advocacy proposal to the EDSA who will work at the executive level for agreement to implement the proposal.
At a minimum, the following major headings should be used in preparing an Advocacy Proposal:
Agreements reached (if any);
TAS contacts; and
See Exhibit 13.2.2-2, Advocacy Proposal Template.
A Technical or Advocacy Analyst may recommend that published guidance be issued or that existing guidance be revised. When the analyst determines that such action is needed to address the advocacy issue being worked, he or she should take the following steps:
Discuss the issue with management for concurrence;
Upon management's concurrence, the analyst will prepare a memorandum to the Special Counsel to the National Taxpayer Advocate (CNTA); and
Forward, through management, to the EDSA for signature. See Exhibit 132.2–5, Memorandum to Request a Counsel Legal Opinion.
Do not be overly concerned about the form the guidance takes. It could be a Revenue Ruling, Revenue Procedure, Notice, etc. The important thing is to highlight the problem and state why the IRS should change its position or issue guidance in areas where there is none.
Legislative proposals are warranted when changes may be necessary to improve equity or fairness in the tax code, improve service to taxpayers, or reduce taxpayer burden. While the IRS may change its own administrative policies or procedures, only Congress may enact or amend laws. All TAS legislative proposals are submitted to the NTA for potential inclusion in the ARC, which is the only means of transmitting proposed legislation from TAS to Congress. The NTA may also initiate legislative recommendations outside OSA.
TAS Administrative Process for Legislative Issues: The project lead or team may determine that a legislative proposal that would change an existing tax law or enact a new one is an appropriate solution to the issues or problems raised by a project. Legislative action is warranted when current law prevents problems from being resolved, or when change might improve service or reduce burden. A legislative proposal is not appropriate for changing IRS operational procedures or processes, revenue procedures, revenue rulings, or existing regulations.
The ARC is the only vehicle for transmitting legislative proposals generated by Systemic Advocacy. These proposals are presented as Legislative Recommendations (LRs).
Submit the legislative change proposal to the Senior Advisor to the NTA through OSA management in a brief document that should include the following sections:
Problem - A short description of the problem that the legislative recommendation is designed to solve.
Example - One or more examples illustrating how this problem affects individual or business taxpayers.
Recommendations - A brief explanation of our proposed solution(s) to the problem.
Present Law - An objective, unbiased description of the legal provisions the NTA is proposing to change.
An advocacy project or immediate intervention will be closed when:
Project work is complete;
The data analysis supports the conclusion and recommendations; and
The DII or DAP approves the closure.
Project leads or Technical Analysts will prepare an Executive Summary containing the elements described in the Executive Summary Template for every project, unless instructed by management not to prepare one. See Exhibit 13.2.2-6. Upon closure to the manager the analyst will update SAMS status to "Submit for closure."
The Executive Summary can be interim or final. A final Executive Summary demonstrates how the project lead reached the proposed resolution of the project. An interim Executive Summary sets forth the research and analysis performed to date and seeks direction from the FSA manager, FSA Director, the DII, or the DAP on how to proceed.
Before submitting a project for closing, the project lead will review the documentation to ensure that:
Data analysis supports the conclusion;
Tax law and IRM procedures were applied and interpreted correctly;
All related issues were correctly addressed; (Issues that arise that are found to be related to the project must be addressed. There are no requirements to resolve all related issues. It is important that the related issues are forwarded to the individual who can address them).
All necessary internal and external contacts have been made (Attorney Advisors, LITC, TAP, CNTA, Sr. Advisor to NTA, PA, BA, TAG, V&S, C&L, and TAS research. This is not an all inclusive list).
Submitter contacts are made appropriately. Telephone contact should be attempted first, as follows: Immediately upon telephone contact, tell the taxpayer or representative your name, your job title and your unique employee identification number. If you do not make telephone contact, your initial letter to the customer must contain the above identifying information. This will satisfy the requirements of RRA98 § 3705. See IRM 126.96.36.199, RRA98 § 3705, Identify Yourself.
Written communications as per IRM 1.10.1, IRS Correspondence Manual, are grammatically correct and free from spelling errors.
Appropriate actions have been taken to educate or communicate changes and clarifications to various stakeholders. (Educating the submitter via a closing letter is not considered for this purpose. Resolution of a project may require that TAS deliver education 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).
Project closure files should include all SAMS prints, documentation, signed closing letters, and executive summaries. Upon closure of the project, the project file will be forwarded to the centralized location below:
Internal Revenue Service
Taxpayer Advocate Service
1111 Constitution Ave, N.W., Room 7704
Washington, D.C. 20224
Attn.: (Name needed)
Once the project is closed, the project lead, through OSA, will notify the submitter of the result of his or her advocacy submission.
A closing letter is the expected method of notification, and the DII or DAP must approve any other method. Closing letters are signed by the DII and DAP if the originator is an IRS employee. Closing letters on projects initiated by submitters outside the IRS, are signed by the EDSA. See IRM 188.8.131.52, RRA 98 § 3705, Identify Yourself.
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.
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 184.108.40.206, Processing Advocacy Issues, Taxpayer Advocate Directives, and IRM 13.1.4, TAS Authorities.
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.
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.
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.
The Executive Summary is divided into the following sections:
Summary of research;
Summary of contacts;
Analysis of data findings;
Formal Advocacy Proposal submitted; and
Recommendations (date made, date accepted and date implemented).
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).
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.
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).
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. "
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
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.
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.
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.
The approval path of the letter is:
The Project Lead or Technical Analyst prepares the letter and sends it to his or her manager or Director as appropriate.
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.
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.
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.
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.
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.
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.
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.
See Exhibit 13.2.2-9. , Advocacy Closing Letter.
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.
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.
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.
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.
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.
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:
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.
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.
Click the "Search for Issues" tab. The results will display in the "Search" field at the bottom of the screen.
If there is a related issue on SAMS, submit the issue and reference the related SAMS issue number in the description field.
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.
Any IRS or TAS employee may submit a new systemic advocacy issue by using the following procedure:
From the SAMS Dashboard click on "Issues" under the "Create" tab on the left navigation bar.
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.
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.
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.
Do not include any taxpayer information in submissions.
Do not paste text from Microsoft Word into SAMS. This imports hidden characters that seriously impact the system. Plain text is acceptable.
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."
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.
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.
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.
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 220.127.116.11.5(4).
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.
All issues received are reviewed to determine if they meet established criteria and are individually ranked to prioritize them for project consideration.
Not all issues become projects. However, all issues remain in the database for trend analysis and potential future projects. See IRM 18.104.22.168, Advocacy Submission Processing.
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.
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.
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" .
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.
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.
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).
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.
To be considered acceptable by the ESP, an employee's suggestion must:
Be a constructive proposal;
Contribute to economy;
Contribute to efficiency;
Directly increase the effectiveness of Government operations; and
Be an original idea.
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.
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.
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.
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.
TAP suggestions not accepted as projects will be discussed between the NTA, EDSA, and National TAP Program Manager to determine alternative courses of action.
This section describes different ways to make corrections, submit suggestions, or raise issues and concerns to the appropriate process owner:
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).
These reviews could result in the creation of virtual technical teams or recommendations for change. See IRM 22.214.171.124.1.6 for information on virtual technical teams.
TAS has new procedures for submitting all changes, suggestions, and recommendations concerning new or revised IRMs and internal IRS forms, notices and publications.
All TAS employees should submit forms/letters/notices/pubs change requests through the TAS IMD/SPOC.
External requests for TAS review of these documents will be handled by the TAS IMD/SPOC using procedures outlined in IRM 126.96.36.199, Reviewing Internal Management Documents (IMDs) For Systemic Issues.
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.
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.
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.
Employees use Form 5391, System Change Request, to suggest technical corrections to IRM procedures and instructions.
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 188.8.131.52, Reviewing Internal Management Documents (IMDs) For Systemic Issues.
A statement of the problem and a statement of the impact must accompany the request. Access this form at http://publish.no.irs.gov.
Use Form 9345, Editorial Change Request, to make editorial, i.e., typographical or printing corrections to the IRM.
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.
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.
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.
If received on SAMS, these suggestions will be closed and transferred to the appropriate office.
Employees use this form to advise the National Office of systemic programming and operational problems that result in work stoppages.
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.
The TAS SPOC is responsible for coordinating the IMD reviews for TAS. For further information on this process see IRM 184.108.40.206, Reviewing Internal Management Documents (IMDs) for Systemic Issues.
Systemic Advocacy analysts are at times asked to participate on cross-functional task forces. See IRM 220.127.116.11.2.5 , Proactive Advocacy Assignments.
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.
The task force activity will be documented on SAMS.
The time spent on task force activity will also be documented on SAMS following the procedures for documenting project time.
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.
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.
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.
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.
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
Time charged to outreach program codes require the completion and forwarding of an outreach event report. See IRM 18.104.22.168.7, Outreach Effectiveness.
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.
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.
Other Function Codes used by SA include:
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.
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 22.214.171.124, 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.
Systemic Advocacy has established a series of organizational measurements to address program effectiveness.
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.
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.
The standards fall within the following categories, timeliness, accuracy and communication with assigned attributes. See Exhibit 13.2.2-10, SA Quality Attributes
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.
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.
|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|
|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).|
|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.|
|Describe the proposed next steps (i.e., a management-level meeting to discuss the agreements needed).|
|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).|
|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.
|TAMIS Research Request|
|Telephone:||Requested Due Date:|
|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)|
This exhibit includes the Quality Review Standards for Systemic Advocacy.
|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
|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:
• 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.|