Purpose: This IRM provides information and guidance on the post audit process and responsibilities within the Wage and Investment (W&I) Division.

Audience: All W&I executives, managers, and W&I Division/Functional liaisons, audit coordinators and JAMES audit coordinators.

Policy Owner: Director, W&I Operations Support

Program Owner: Director, Business Technology Organization

Program Goals:

Primary Stakeholders: W&I executives and management, W&I functional coordinators and liaisons, Enterprise Audit Management and TIGTA and GAO personnel.

The JAMES Audit Coordinator (JAC) - The JAMES coordinator oversees and manages the post audit process, including PCAs and updates to the JAMES. For more information on JAC responsibilities refer to IRM 1.29.1.1.3.6, JAMES Audit Coordinators (JACs). Additionally, the W&I business division James Coordinator is also responsible for the following post audit activities:

Business Unit Coordinator - Within each W&I business unit, a coordinator works with the division JAMES coordinator to manage the post audit process for their business unit. The business unit coordinators are responsible for the following:

The TIGTA and GAO planned corrective action (PCA) reports tracked in the JAMES are identified by a unique numbering sequence.

The TIGTA and GAO PCA action numbers are comprised of the finding number, the recommendation number, and the corrective action number. The TIGTA report numbers are comprised as shown in Table 1.1 and the GAO report numbers are comprised as shown in Table 1.2.

Business unit codes may not always end in “0.”

PCA plans are assigned to a lead business division identified by the organizational symbols; referred to as the “Responsible Organization” in the JAMES.

PCAs are assigned to a specific business unit to implement; referred to as the “Responsible Employee” in the JAMES.

Organizational codes are extended to the third and fourth level. See Table 1.4. for a partial list of W&I organizations and organizational codes.

At the close of an audit, a corrective action report is entered into the JAMES. For management to comply with EAM reporting requirements, each corrective action within an action plan has an estimated implementation date. The JAMES tracks PCAs for all Treasury Department agencies by the projected implementation date.

A new report number is assigned in the JAMES. This number tracks post GAO and TIGTA audit activity. For the list of codes, see Table 1.3.

To obtain access to the JAMES, the new user’s manager must send a JAMES access request to the W&I headquarters JAMES Coordinator within the Program, Evaluation and Improvement (PEI) Team. If a functional coordinator is requesting access, the manager will first forward to the business unit coordinator to review before submitting to PEI. The manager must include the following information when requesting JAMES access:

Users must read and acknowledge receipt of the "FARS User Responsibility Statement" and the "Rules of Behavior" document online before gaining access to the application.

Accounts with no activity expire after six months. Contact your JAMES W&I Coordinator for reactivation.

A6 Audit Summary Report contains a summary of findings, recommendations and PCA’s including the amount of any potential monetary benefits and root cause. Generally, the information in this report for TIGTA audits is entered into JAMES by TIGTA. EAM enters relevant data from the GAO final reports for GAO corrective actions. For more information regarding how the A6 Report is input, visit IRM 1.29.1.3.6.7, Entering New Audit Reports into JAMES.

When new actions are entered into the JAMES, the EAM Coordinator sends a notification e-mail to the W&I business division JAMES Coordinator and W&I Business Unit Coordinator. See Exhibit 1.55.6-1 for an example. The verification process involves the division and business unit coordinators reviewing the JAMES report (findings, recommendations and corrective action plan(s)) for accuracy and returning a notification of concurrence or non-concurrence.

When a business unit concurs with the report and no outcome measures are identified, an e-mail response can be returned to EAM.

When a redaction request is made to a final audit report, the EAM Coordinator ensures the appropriate boxes are checked in the JAMES report to safeguard sensitive data. These JAMES reports may include redacted text from the final audit report posted on the auditing agency's website. Use caution when distributing JAMES reports containing redacted information by limiting distribution only to those with a need to know.

When there is a major discrepancy with the report and/or outcome measure, the business unit must prepare a memorandum under executive signature. See Exhibit 1.55.6-2 and Exhibit 1.55.6-3 for examples of memorandums. If more than one business unit is identified in a report, each business unit forwards a separate memorandum.

The EAM Coordinator, the W&I business division JAMES Coordinator and the business unit coordinator each play significant roles in ensuring the implementation and timely reporting of PCAs to Congress.

The EAM Coordinator is responsible for:

The W&I business division coordinator is responsible for:

The W&I business unit coordinator is responsible for:

When responding to an audit recommendation, it may be decided that more than one IRS business division or more than one W&I business unit is responsible for implementing a PCA. If this is the case, then duplicate or multiple PCA(s) may be established and tracked in the JAMES. Communication between the affected offices, headquarters, and EAM is important and necessary. See Table 1.5, Duplicate Planned Corrective Action Guidance, for general guidance in recognizing when a duplicate PCA may be established if two or more officials are noted or implied as a responsible official in the final audit response.

The HOLD feature was instituted in 2017 as a result of IRS senior leadership concerns about committing to corrective action(s) when budgetary or other constraints were likely to inhibit implementation. However, beginning March 31, 2022, Interim Guidance Memo (IGM) OCRO-01-0322-0002 was issued to remove the process for placing recommendations on hold as this process has become obsolete with the agreement of the Chief Risk Officer, the Deputy Commissioner for Services and Enforcement and the Deputy Commissioner for Operations Support. This IGM has since been incorporated into IRM 1.29.1.3.8, Extending Planned Corrective Actions, and business units are to take the following actions:

For any existing Hold recommendations, if a business unit decides to close the Hold as unimplemented, they must schedule a meeting with the applicable oversight authority to:

If the oversight authority concurs with an unimplemented closure, a formal request memorandum to the oversight authority is prepared by the requesting business unit and routed through PEI for the signature of the W&I Commissioner.

Recommendations that W&I agreed to but lacked the funding and/or resources for implementation before February 03, 2021, were placed on hold.

The Recommendation Hold Category, which lists why a recommendation was placed on hold, is tracked in the JAMES. Generally, the responsible business organization determines the reason for a recommendation hold. The following are typical recommendation hold category reasons:

Status updates for W&I recommendations placed on HOLD are requested twice during the year (e.g., February and September).

Recommendations on HOLD are reported to W&I executive board monthly.

For more information regarding PCA Holds, see IRM 1.29.1.3.8, Guidance for Recommendations on Hold.

When a recommendation on HOLD has been fully implemented, the business unit’s primary coordinator works with PEI and the EAM JAMES coordinators to update and close the PCA in JAMES.

Before closing recommendations on HOLD a Form 13872, Planned Corrective Action (PCA) Status Update for TIGTA/GAO/MW/SD/TAS/REM Reports, must be prepared to release the HOLD in JAMES. In box 4a of Form 13872, select HOLD Release/Add PCA from the status drop down menu. Form 13872 must state the corrective action, the responsible official, and the planned implementation date.

After the recommendation has been taken out of Hold status and the PCA created, another Form 13872, along with the supporting documentation will be uploaded to JAMES by the business unit coordinator to close the newly-created PCA.

Activities in a planned corrective action (PCA) report are updated to record actions taken to implement, delay, cancel or supersede an action. The following table provides steps for updating PCA Reports:

The Form 13872,Planned Corrective Action (PCA) Status Update for TIGTA/GAO/MW/SD/TAS/REM Reports, is used to document the status change of the PCA. The Form 13872 is uploaded into the JAMES and used by EAM to validate the status update. See IRM 1.29.1.3.1(3), Closing Planned Corrective Actions for more information.

The Form 13872 requires an executive signature. The contact person listed on Form 13872 in section eight (a - c) must be a subject-matter expert able to clarify activities related to the corrective action plan if requested by EAM, TIGTA, GAO, or other management official. The signature of the responsible business unit JAMES coordinator in section nine (a - d) is required. Return for correction any documentation that does not reflect the appropriate signatures or contain the required information.

If ownership of a PCA must be reassigned to another W&I business unit, first obtain concurrence and documentation. A formal memorandum of concurrence is not necessary. However, an e-mail from the accepting executive is required. See IRM 1.29.1.3.9(6)(a), Managing Unique PCA Activities.

If ownership of a PCA must be reassigned to another business division, concurrence is needed from the accepting official. Prepare a formal memorandum from the transferring business division head to the reassigned business division head. See Exhibit 1.55.6-7.

Correspondence must clearly identify the report number, the PCA number, and the reason for transfer.

Forward the signed memorandum and/or other communications supporting the reassignment to EAM to complete the reassignment in the JAMES.

The activities implementing PCAs must be completed by the due date in order to be considered timely implemented. Update in JAMES the status of a PCA on or before the controlled due date for it to be considered implemented timely. Enterprise Audit Management requires all status changes (implementations, cancellations, and extensions) to be updated in the JAMES on or before the due date. See Table 1.6, Table 1.7, and Table 1.8 for criteria on timely implementing and extending all PCAs and updating the JAMES.

Consider various factors when setting the initial PCA due date. PCA implementation timeliness can extend for multiple years. For appropriate guidance on Managing Long-term PCAs or Long-term extensions. See IRM 1.29.1.3.9(1), Managing Unique PCA Activities.

PCAs with longer completions timeliness, warrant greater attention. PCAs are considered long-term as follows:

In September 2010, the Department of Treasury enhanced the Joint Audit Management Enterprise System (JAMES) to store documentation in support of a PCA status change.

Effective January 2016, when the PCA status is set to "Implemented" , "Cancelled" , or "Replaced" a message box appears on the JAMES screen stating – "At least one supporting document is required to be uploaded before the Status field can be changed."

A complete, executive approved and dated, Form 13872 and any supporting documentation must be uploaded into the JAMES at the time the PCA Status is updated in the JAMES.

As of April 1, 2017, PCAs reported as “Implemented” in management’s response to an audit report requires sufficient supporting documentation be provided. Refer to IRM 1.29.1.3.3, Requirements for Form 13872 and Supporting Documentation, for more information on the requirements for the supporting documentation.

EAM or the CFO assigns the initial due date in the JAMES for these PCAs to be updated. For TIGTA actions the assigned due date is 60 days following the issuance of the final report and for GAO actions, with the exception of those from the financial statement audit, the assigned due date is 30 days from the issuance of the 180-day letter. The supporting documentation must be uploaded into the JAMES in order to consider a PCA accurately closed in the JAMES.

All due dates are set for the 15th day of the month.

If sufficient supporting documentation is not uploaded into the JAMES on or before the due date, a request to extend the initial due date must be processed using the Form 13872. See IRM 1.55.6.11.5, Extending Planned Corrective Actions, for guidance.

Support documents containing sensitive information must be redacted before uploading.

Examples of support documentation include:

Due to the significance of the GAO/TIGTA audit program, coordinators must ensure the information entered into the JAMES is accurate, grammatically correct, executive approved, and entered timely.

Documents, once uploaded into the JAMES, cannot be edited. However, they can be deleted and an edited version can be re-uploaded.

A statistical sample of closed PCAs are reviewed monthly by the Servicewide oversight office.

PCAs found to not have sufficient documentation to support closure uploaded in the JAMES are documented and the results are sent to the business division headquarters and the responsible organization. See Form 14668, CFO Corporate Planning and Internal Control Closed Planned Corrective Action (PCA) Quality Assurance Review Notification, and IRM 1.29.1.3.5.2, Monthly Closed Sample Quality Reviews, for additional guidance.

Coordinate the submission, review and approval of new or additional documents through PEI before uploading into the JAMES.

The business unit coordinator thoroughly reviews the Form 13872 before obtaining executive signature.

The business unit coordinator forwards the Form 13872 and supporting documentation to the W&I business division JAMES Coordinator for complete review and approval for the business unit to route to the executive for signature and then upload to JAMES. For more information see IRM 1.29.1.3.3, Requirements for Form 13872 and Supporting Documentation. Also, for more information on Evidentiary Documentation Examples, see IRM Exhibit 1.29.1-4

Include all support documentation with the Form 13872 when forwarding to the executive for certification.

The EAM Coordinator performs a final review and validation of all PCAs updated in the JAMES.

If additional information is needed, the EAM Coordinator must communicate through the W&I business division primary JAMES coordinator or designated point of contact to resolve.

A variety of reports are used to manage the GAO/TIGTA PCA inventory and communicate related information about management controls data. Monthly, quarterly, and annual reports are prepared to capture the number of actions opened, closed, delayed, and the performance rating of timely responses. See Table 1.9 for a list of frequently used reports.

Division headquarters offices must maintain an official record of a GAO or TIGTA audit in accordance with Title 44, USC 3102.

The IRS established a records management program to ensure the economical and efficient management of its records. The program provides for the application, on a continuing basis, of sound management practices and techniques in the creation, maintenance, retrieval, preservation and disposition of records. See IRM 1.15.1, Records and Information Management Program, for additional information. All Federal employees are required by law to preserve records containing adequate and proper documentation of the organization, functions, policies, decisions, procedures and essential transactions of the agency. See IRM 1.15.3.1.2,Authority to Destroy Records, IRM 1.15.6.7, Managing Electronic e-mail Records, for additional information.

GAO audit records must be retired from the JAMES ten years after closing, and destroyed when 20 years old.

TIGTA records must be prepared for retirement from the JAMES ten years after closing and destroyed after ten years.

For the above, the EAM issues a data call e-mail and advises PEI of the dates in which the information will be retired or purged.

From the audit report Additional Security Is Needed For Access To The Registered User Portal 2020-XX-XXX (Audit 2013XXXXX), PCAs 1-5-1 and 1-6-1 will be transferred to the Office of Online Services; and PCAs 1-1-1 and 1-3-1 will be transferred to the Return Preparers Office.

From the audit report Systems Validations Are Insufficient To Prevent The Unauthorized Use of Electronic Filing Identification Numbers 2019-XX-XXX (Audit # 2019XXXXX), PCAs 1-1-1, 1-2-1, 1-3-1, and 1-6-1 will be transferred to the Return Preparers Office. (3) From the audit report Individuals Who Are Not Authorized To Work In The United States Were Paid $4.2 Billion in Refundable Credits 2016-XX-XXX (Audit 20148XXXXX), PCA 4-1-3 will be transferred to the Return Preparers Office.