- 5.9.21 Electronic Proofs of Claim (EPOC)
- 188.8.131.52 Program Scope and Objectives
- 184.108.40.206.1 Background
- 220.127.116.11.2 Authority
- 18.104.22.168.3 Responsibilities
- 22.214.171.124.4 Program Management and Review
- 126.96.36.199.5 Program Controls
- 188.8.131.52.6 Terms and Acronyms
- 184.108.40.206.7 Related Resources
- 220.127.116.11 Electronic Proofs of Claim (EPOC)
Part 5. Collecting Process
Chapter 9. Bankruptcy and Other Insolvencies
Section 21. Electronic Proofs of Claim (EPOC)
March 22, 2017
(1) This transmits revised IRM 5.9.21, Bankruptcy and Other Insolvencies, Electronic Proofs of Claim (EPOC).
(1) Editorial changes were made throughout this section to add clarity and to update, correct, or add citations.
(2) IRM 18.104.22.168: internal controls subsections 22.214.171.124.1 through 126.96.36.199.7 have been added.
(3) Added additional information regarding Letter 3931 under IRM 188.8.131.52.2 (3), Withdrawing a Claim.
(4) Added additional information regarding Unknown Errors under IRM 184.108.40.206.3 (3) (b) Note.
(5) Added IRM 220.127.116.11.4 (3) (e), Failed Pre-Validation.
(6) Added IRM 18.104.22.168.4.(4) (j) Note.
Kristen Bailey, Director
Purpose. This Internal Revenue Manual (IRM) section describes the process and procedures for operating the Electronic Proofs of Claim (EPOC) system application. These procedures are followed in order to protect the Government's interest in Bankruptcy cases.
Audience. This IRM is designed for use by Centralized Insolvency Operation (CIO) personnel responsible for transmitting proofs of claim to the U.S. Bankruptcy courts using the EPOC system. Field Insolvency personnel submit claims for EPOC processing by CIO personnel.
Policy Owner. The Director of Collection Policy is responsible for issuing policy for the Insolvency program.
Program Owner. The program owner is Collection Policy, Insolvency an organization within the Small Business Self Employed (SB/SE) division.
Primary Stakeholders. SB/SE Collection, Specialty Collection, Insolvency.
Program Goals. The objective of the EPOC program is to efficiently transmit IRS proofs of claim data to the individual U.S. Bankruptcy courts. Following the processes and procedures outlined in this IRM section will ensure that the daily transmission will be successfully completed, and IRS’s proofs of claim will be submitted timely for the Court’s consideration.
The EPOC application is an automated system that collects proofs of claim data from the Automated Insolvency System (AIS), batches the claims by court code designation, and transmits the claim data to the individual U.S. Bankruptcy Courts. A proof of claim is a statement filed with the bankruptcy court listing debts owed by the debtor to a particular creditor.
IRM 5.9, Bankruptcy and Other Insolvencies, contains the Service’s position, procedures, information, instructions, guidance, and references concerning bankruptcy cases, stockbroker insolvencies, receiverships, assignments for the benefit of creditors, corporate dissolutions, and bulk sales.
The EPOC program operates within the guidelines of the Bankruptcy Code (11 USC), the Bankruptcy Reform Act of 1994 (BRA 94), and the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA).
IRM 5.9, Bankruptcy and Other Insolvencies, provides a list of titles and responsibilities with an explanation of their roles and authority.
Field Specialists are responsible for ensuring that proofs of claim for cases assigned to them are submitted timely for EPOC. EPOC Operators are responsible for running the EPOC application daily. CIO management will ensure that daily transmissions have been completed and that transmission errors are resolved. AIS system analysts will monitor the daily transmissions and work to resolve system issues.
Three AIS Reports; Denied EPOC Claims, EPOC Submission Status, and EPOC Status, are used to support program objectives. These reports are described in detail in IRM 22.214.171.124.4, EPOC Reports.
CIO managers and executives will review the Denied EPOC Claims report, EPOC Submission Status report, and EPOC Status report to identify errors and potential program weaknesses.
The Collection Policy, Insolvency program analyst will periodically run the EPOC Submission Status report to ensure that all court’s claims have been processed.
Managers are required to follow program management procedures and controls addressed in IRM 126.96.36.199.2, Reviews, IRM 188.8.131.52, Controls, and IRM 184.108.40.206, Quality.
Operational and Program reviews are conducted on a yearly basis. See IRM 220.127.116.11.2, Operational Reviews, and IRM 18.104.22.168.5, Program Reviews, for more information.
The following chart contains acronyms used through this IRM:
Acronyms Description AIS Automated Insolvency System APOC Automated Proofs of Claim CIO Centralized Insolvency Operation CM/ECF Case Management/Electronic Case Filing EPOC Electronic Proofs of Claim MOTD Message of the Day PACER Public Access to Court Electronic Records POC Proof of Claim
IRS claims may be created manually or systemically by the APOC application and can be viewed in the AIS POC screen.
A proof of claim for a specific case can be transmitted to the court via the EPOC interface. Claims are submitted for EPOC manually by a Field Insolvency employee assigned to a case.
Claims submitted for EPOC will be transmitted to the courts daily by EPOC operators (CIO employees with EPOC Operator privileges.) Claims that are successfully transmitted will get systemically acknowledged on AIS. Claims that error out during EPOC transmissions will be researched, corrected, and re-submitted for EPOC transmission by EPOC operators.
Electronic Filing Required. Some courts require or request electronic filing of proofs of claim through the courts’ CM/ECF websites. Access to the CM/ECF is coordinated locally with the court. Field Insolvency Group Managers are required to submit LOGIN applications to each court for CM/ECF privileges. The courts provide website documentation and training. The AIS court screen provides an indicator for courts requiring electronic filing of claims.
Only an AIS System Analyst with Analyst privileges can update the AIS court screen. The EPOC court indicator must be marked Y to use EPOC functionality.
The court table is located by selecting the Court Information Option in the AIS Support Menu.
EPOC Interface. IRS regulations require additional security measures with EPOC use. IRS claims can only be submitted to CM/ECF websites by a secure EPOC interface. EPOC transmits the AIS claim data to the court websites. EPOC also supplies the PDF claim document required by the court websites.
Access to CM/ECF Sites. The CIO is the only office performing the actual EPOC transmissions. Only select CIO users need access to the EPOC interface. An EPOC button in the AIS Misc. Options menu is used to open and operate the interface. This EPOC button will only be visible and available to employees approved for EPOC access. An EPOC Operator privilege will be granted through the AIS Support Menu Employee Information screen. An OL5081 Modify Profile request is required by the IRS to request EPOC access.
The EPOC Process. From the Proof of Claim menu, the user selects a button to Submit Claim for EPOC. The creditor number assigned for each case must be added to AIS prior to submitting the claim for EPOC transmission. The creditor number is automatically downloaded for cases received through ENS. However, for cases added to AIS manually, the creditor number must also be manually added. Creditor numbers are secured from PACER and CM/ECF. Claims are held in a queue until they are transmitted to a court’s CM/ECF website through the AIS - EPOC interface. The following table illustrates the steps in sending a claim via EPOC.
STEP AIS EPOC CM/ECF Website 1 The Field Insolvency specialist or advisor prepares the Proof of Claim document. After review to ensure the case has an IRS creditor number, the Specialist or Advisor selects a button to Submit Claim for EPOC to send the Proof of Claim to the EPOC court. The EPOC status changes from Not Submitted to Submitted for Processing. 2 At night, AIS selects all claims whose status is Submitted for Processing. This process will prepare the claim for EPOC. Data used for the website fill-in form is added for each claim. The EPOC status on AIS changes to Currently Being Processed. 3 All queued Proof of Claim documents are loaded into EPOC by court designation. 4 Documents are translated to PDF format. 5 The designated EPOC operator selects the EPOC button under the AIS Interfaces menu. 6 A new EPOC window will appear on the user's computer. 7 The EPOC operator will select the Claim Filing button. When the Claim Filing screen appears, the user will enter the court they are assigned to process in the Search Court field. For example; to access Texas West, the user will enter TXW. 8 All of that day's claims for that court will appear on the screen in (P) Processing status. The EPOC operator can either select specific claims to transmit by clicking on the check box next to each claim case number and then click the Submit Selected Claims button, or they can just click on the Select All and Submit button to submit all claims without clicking on each check box. 9 EPOC runs from 7:00am to 7:00pm EST, Monday - Friday. EPOC picks up and transmits submitted claim data every 30 minutes (on the 00 and 30 of every hour). 10 EPOC will connect with the designated court's CM/ECF and will supply the required Login and Password after the claims are submitted for processing. The EPOC operator will not see this action on their screen. 11 The court's CM/ECF website receives case information and the formatted .pdf claim documents from EPOC. The EPOC operator will not see this action on their screen. 12 The court's CM/ECF website sends an acknowledgement (or error message) for each claim submitted to AIS through EPOC. The EPOC operator will not see this action on their screen. 13 EPOC will automatically log off from the court's CM/ECF website after all claims for that court have been transmitted and acknowledged. The EPOC operator will not see this action on their screen. 14 The EPOC operator repeats steps 7 & 8 for each court that is assigned until all claims have been submitted for all assigned courts. 15 The EPOC operator can select the Claim Filing Status button to view the status of each claim for any court. The user must enter the court in the Search Court field. 16 Claims that have been submitted to the court will be designated with an S. Claims that have not been submitted will be designated with a P (Processing). Claims that have been Accepted will be designated with an A. Claims that had errors will be designated with a D (Denied). Claims that could not be transmitted will be designated with a U (Unknown). 17 Claims in D(Denied) and U (Unknown) statuses must be corrected and re-submitted. 18 The EPOC operator selects the Exit button to close the EPOC screen after all claims for all assigned courts have been transmitted. 19 AIS retrieves acknowledgements and errors from EPOC and updates the Proof of Claim and History screens. Claims that are acknowledged will receive a claim number and acknowledgement date. The EPOC Status will change to Accepted by Court.The EPOC Status for Denied claims will change to Rejected by Court . The EPOC Status for Unknown errors will remain as Currently Being Processed.
When a claim is added to AIS, either by the APOC system or manually, the Proof Prepared date is blank, and the Proof Required field on the Taxpayer Screen should be "Yes." The case will be on the Bar Date report, but not on the POC F/U Report.
To file claims to an EPOC court, use the Submit Claim for EPOC button on the Proof of Claim screen. When the claim is picked up for overnight processing, the status changes to Currently Being Processed and the Proof Prepared date is filled in. The Proof Required field on the Taxpayer Screen is not changed. The case will be on the Proof of Claim Follow-up report. The case will be on the EPOC Status report.
After EPOC files the claim, AIS is updated with the information from the court and the EPOC status is updated. If the claim is successfully filed, the Proof Acknowledgement date is filled in and the Proof Required field on the Taxpayer Screen is changed to "F." The case will not be on a Bar Date or POC F/U report. If the claim is rejected, the Proof Acknowledgement date is NOT filled in, the Proof Required field on the Taxpayer Screen is changed to "R." The case remains on the Bar Date report. See IRM 22.214.171.124.4.
Amending a Claim. A claim number is systemically input to the "original claim #" field on the proof of claim screen. EPOC adds the court's claim number at the same time it inputs the court's acknowledgment date.
When a claim is amended, the caseworker must ensure the court's claim number is shown on the AIS Proof of Claim screen prior to submitting the amended claim to EPOC.
If a claim appears on the claim registry with a zero claim number, the caseworker must contact the court to have it assigned a valid claim number.
Amended claims without an original claim number and/or an amended claim number on AIS will be rejected by AIS. An error message will appear when the user attempts to submit the claim for EPOC instructing the user to enter the appropriate claim numbers.
Withdrawing a Claim. To withdraw a claim filed through EPOC, it must be amended to $0.00 and submitted by clicking on the "Submit Claim for EPOC" button on the Proof of Claim Screen. If a court does not accept this method of withdrawing a claim, the specialist can send a letter instructing the court to remove a specific claim from the claims register. For those courts, caseworkers can generate Letter 3931, Request to Withdraw Administrative Proof Claim, on AIS for mailing to the court.
Using the EPOC Interface. To access the EPOC interface, the designated EPOC operator selects the EPOC button located in the AIS Interfaces menu.
EPOC Message of the Day (MOTD).
When an authorized EPOC operator selects the EPOC button, a new window will appear displaying the EPOC Message of the Day (MOTD).
The following navigation buttons will be visible: Claim Filing, Claim Filing Status, Refresh, and Exit.
Claim Filing. Select the Claim Filing button from the Navigation menu. The Claim Filing screen allows the user to display the pending Proofs of Claim for a specific court jurisdiction.
The EPOC operator next selects their assigned court to process by typing the court initials in the Search Court box. For example, to load claims to transmit to the Arizona court, the user must type "AZ."
As an EPOC operator types alpha characters, all related courts for those alpha characters will be displayed in a drop down menu box. For example, when typing "AL" for the Alabama courts, the Search Court menu box will display the Alabama Middle, Alabama North, and Alabama South courts as ALM, ALN, ALS. The user can point and click on the court that they want to process.
The claims to be processed for the specified court will appear in a column format showing important claim data, such as AIS case number, court, form, creditor number, status, date created, claim number, amended number, and the various claim amount data. None of the claims will be selected for processing as a default. Claims in this screen will be in the "P" (Need to be Processed by EPOC) or "U" (Unknown Error) status.
For quick submission of all claims to the court – the EPOC operator should select the Select All and Submit button. The EPOC operator can also submit individual claims by selecting them one at a time and then selecting the Submit Selected Claims button.
When claims are submitted for EPOC transmission, the Claim Filing screen will display the total number of claims that were submitted.
EPOC will take the following actions, which the EPOC operator will not see:
- Determine whether the court uses the single claim upload or multi-claim zip upload process.
- Log into the court's CM/ECF website.
- Provide the creditor number and claim amount data for each claim submitted.
- Attach the .pdf proofs of claim documents.
- Capture the acknowledgement data and update the AIS POC and History screens.
Claim Filing Status. To review the status of claims submitted that day, the EPOC operator can review the Claim Filing Status screen. The EPOC operator must select the Claim Filing Status button in the top navigation menu while in the Claim Filing or MOTD screens.
The EPOC operator must enter the court initials of the court that they want to review in the Search Court box and Enter.
The Claim Filing Status screen will display all claims for that court for that day listing the court case number, court, form, creditor number, date created, claim number, amended number, status, and a message.
The Status Codes include:
- P = Process (Claims received from AIS that still need to be “processed” by EPOC – the EPOC operator still needs to submit these to the court).
- S = Submitted (Claims that have been Submitted to the court by EPOC and are waiting on the court’s response).
- A = Accepted (by the court).
- D = Denied (by the court – the message column will explain why it’s denied – these claims will appear on the Denied EPOC Claims and EPOC Status reports in AIS).
- U = Unknown (will appear when there is an internet transmission interruption – these claims will appear on the EPOC Submission Status report in AIS. They also will appear in the Claim Filing screen. They must be submitted again to the court either the same day or the following day.
Exiting EPOC. When an EPOC operator has completed submitting the claims for each assigned court jurisdiction, they must first click the Exit button located in the top Navigation menu and then close their browser window to completely close EPOC.
The AIS Reports Menu contains three important EPOC Reports that must be reviewed and worked to ensure that all claims are correctly transmitted, accepted, and acknowledged. The Denied EPOC Claims report, EPOC Submission Status report, and the EPOC Status report will identify rejected claims and claims that still need processing.
Identifying Rejected Claims. The court's rejection of an original claim is indicated in the "EPOC Status" field of the Proof Screen with the annotation "Rejected by Court," and the F in the "Proof Req'd" field on the Taxpayer Screen changes to an R. Rejected claims also appear on the bar date report and are systemically annotated in the AIS case history. When the claim is resubmitted and subsequently accepted, the R in the AIS Proof Req'd field reverts to an F for original claims, and the EPOC Status field shows "Accepted by Court." If for some reason the R does not revert to an F systemically, the case must be referred to a manager to input the F manually.
Systemic Histories. EPOC creates four systemic AIS histories for rejected claims:
Incorrect Creditor Number. This indicates the claim is not filed. The EPOC operator must research the creditor number on CM/ECF using the generic login and password. Then the EPOC operator must update AIS with the correct creditor number and resubmit the claim by clicking the "Submit Claim for EPOC" button on the AIS Proof of Claim screen.
Incorrect Case Number. This indicates the claim is not filed. The EPOC operator must verify the docket number and court key, update the docket number and/or court key on AIS if needed, and resubmit the claim by selecting the "Submit Claim for EPOC" button on the Proof of Claim screen.
Invalid Amendment Number. This indicates the amended claim may not be filed. The EPOC operator should check PACER to determine if the claim was accepted. If not, the amended claim number must be updated and then should be resubmitted by clicking the "Submit Claim for EPOC" button on the AIS Proof of Claim screen.
No Confirmation Stamp. This rejection message is triggered by systemic interruptions in the court's website. The EPOC operator must check PACER to determine if the claim was accepted. If it was accepted, the EPOC operator must update the acknowledgement date and document the history screen. If the claim was not accepted, the EPOC operator must resubmit the claim by clicking the "Submit Claim for EPOC" button on the Proof of Claim screen.
Failed Pre-Validation. This error occurs with courts running the zip upload process. The case that errors out may have an issue with its docket number or docket format, the creditor number, the court code, the judge’s initials, the chapter, or the address. The EPOC operator must research the case on PACER, make any necessary changes to AIS, and resubmit the claim by clicking the "Submit Claim for EPOC" button on the Proof of Claim screen.
Denied EPOC Claims Report. The Denied EPOC Claims report is generated using the AIS Reports menu. The Denied EPOC Claims report will list Rejected and Unacknowledged claims on open AIS cases. A Denied EPOC Claims report must be generated daily for each EPOC court.
Select "Reports" from the left side AIS Menu options.
Select the "Denied EPOC Claims" button.
Run the report for a specific court (for example: ALN or AL% for all Alabama courts).
The Org1, Org2, Site, Group, SEID, and Name fields must list "0" .
AIS will generate a .pdf report for the court(s) selected listing all claims with a Rejected or Unacknowledged status.
The report will give the reason a claim is rejected. Some examples include Creditor Not Found, Invalid Claim Number, No Confirmation Stamp, etc.
Research each case listed on both AIS and PACER.
The reject will determine the user's course of action – updating the creditor number, claim numbers, or case number on AIS. After a claim has been corrected on AIS – the user must resubmit the claim on AIS for EPOC.
Unacknowledged claims and No Confirmation Stamp rejects must also be researched on both AIS and PACER. If the claim has posted to PACER, then the EPOC Status on the AIS Proof of Claim screen must be updated to "Accepted" . If the case has not posted on PACER, then the claim must be resubmitted on AIS for EPOC.
Update the case history on all claim/case updates using the appropriate canned EPOC History item.
When researching reject errors on PACER and a case displays a "Warning - Do not enter Claims on this case - Claims are being handled by a Claims Noticing Agent" message. The EPOC operator should notate in the AIS History that a claim will not process through EPOC for this specific case due to the warning message on PACER. The bankruptcy specialist assigned to the case should be notified. The specialist will need to contact the Claims Noticing Agent regarding how the claim should be filed. In most cases, a paper claim will need to be generated by the specialist and mailed to the Claims Noticing Agent.
EPOC Submission Status Report. The EPOC Submission Status Report is generated using the AIS Reports menu. This report focuses on the transmission status of claims within EPOC, not AIS. It can list all claims for a specified date range within a specified category, such as Accepted, Rejected, Submission Cancelled, Submission Re-queued, Selected for Court Upload, Currently Being Processed, and Unknown. Analysts and managers will use this report to review the daily EPOC transmissions.
Select "Reports" from the left side AIS Menu options.
Select the "EPOC Submission Status" button.
In the AIS Reports menu – check the "Selected for Court Upload" , "Currently being Processed" , and "Unknown" boxes.
The report can be run for all courts ("All " will be listed as default)
The report can be run for a selected court – type the court (AZ for example) in the Jurisdiction field.
Enter specific Begin and Finish dates.
The Org1, Org2, Site, Group, SEID, and Name fields must list "0."
AIS will generate a spreadsheet listing of claims.
Unknown error claims can be resubmitted within EPOC.
Claims found in Processed status must be submitted within EPOC to the courts.
Older claims found in Submitted status may mean there is a problem with the court's CM/ECF website, or the court is "locked" within the AIS EPOC Jurisdiction table. Elevate this issue to the appropriate analyst.
EPOC Status Report. The EPOC Status report is generated using the AIS Reports menu. The EPOC Status report will list all AIS claims with an open EPOC status: Rejected, Processing, or Submitted. This report can also list all Accepted cases within a specified date range. Analysts and managers will use this report to focus on specific EPOC data when reviewing the EPOC inventory.
Select "Reports" from the left side AIS menu options.
Select the "EPOC Status" button.
In the Parameters menu, check the "Currently Being Processed" box and the "Rejected By Court" box.
Run the report for all courts (Leave the courts box blank), or for a specific court. For example, enter TXN% for all Texas North courts.
The Org1, Org2, Site, Group, SEID, and Name fields must list "0."
AIS will generate a spreadsheet listing of claims.
Claims listed as Rejected or Currently Processing will also be found on the Denied EPOC Claims report.
If CIO receives a call from an Field Insolvency specialist, advisor, or manager stating that a claim should not be transmitted to the court, the CIO EPOC Operator Manager/Lead/System Analyst should take the following steps:
Make sure the claim is not selected when transmitting the rest of the claims to the court that day.
Go to the AIS Proof of Claim screen and change the EPOC Status from "Currently being Processed" to "Not Submitted" and add a history item.
This will remove the claim from the EPOC Claim Filing queue.
Click the "Refresh" button in EPOC, to refresh the list of claims ready for EPOC Filing, to ensure that the claim has been removed.