TIGTA audits provide independent oversight of IRS activities to promote efficiency and effectiveness in administering the nation’s tax system.

TIGTA's Office of Audit strategically evaluates IRS programs, activities, and functions to ensure that resources expended reduce vulnerabilities in the nation’s tax system.

The TIGTA audit process includes the following steps:

TIGTA contacts EAM indicating the scope of work and the anticipated periods involved for the planning and research project. Engagement letters are not required for these TIGTA audit activities which include audit planning, research activities (surveys, information gathering, etc.), and integrity projects.

EAM forwards the information to the Chief, Oversight Liaison.

The SB/SE recipient will forward the information to the Chief, Oversight Liaison, if planning contacts are made through different channels.

The SB/SE audit liaison:

If the planning and research phase results in a formal audit, TIGTA will issue an engagement letter through EAM. The SB/SE audit liaison assigned to the planning and research phase will retain the responsibility for overseeing the audit.

If an audit is not warranted, the planning and research phase is closed by a TIGTA memorandum.

To initiate an audit, TIGTA notifies the IRS through the issuance of an engagement letter. This letter may be addressed to the responsible program executive, business unit head of office, Chief Risk Officer, one of the Deputy Commissioners, or the Commissioner depending on the scope and nature of the audit. EAM is responsible for processing the notification or engagement letter. See IRM 1.29.1.2.5, Audit Initiation and Notification.

The engagement letter is the official notification that TIGTA is conducting a formal audit. Once TIGTA issues the engagement letter, the audit is officially open, whether or not an opening conference is held.

EAM forwards the engagement letter to all of the audit contacts including the Chief, Oversight Liaison. The forwarded information identifies the lead and other BUs or OUs TIGTA expects to contact.

The Chief, Oversight Liaison assigns the audit to an SB/SE audit liaison.

The SB/SE audit liaison will discuss available dates with the lead OU and informs TIGTA of the assignment, establishes a relationship, and requests available dates for an opening conference.

The opening conference is an initial opportunity to discuss background information, provide a perspective on the program or process being audited, set expectations for the audit, including agreeing on a mid-point or other periodic briefings, and establish a positive rapport with the audit team.

If SB/SE is the lead on an audit, the SB/SE audit liaison schedules the opening conference with the SB/SE OUs and other impacted BUs. It is the responsibility of the SB/SE functional coordinator to encourage the executive from their functional area to participate at the opening conference. See IRM 1.29.1.2.6, The Opening/Entrance Conference.

The SB/SE audit liaison will:

The TIGTA fieldwork phase is the research and information gathering phase.

The SB/SE audit liaison will work with the TIGTA audit team to keep up to date with audit activities and to identify significant and sensitive issues before TIGTA issues the Agreement to Facts document.

For SB/SE lead audits, the SB/SE audit liaison will:

When another BU is identified as the lead, the SB/SE audit liaison will:

At the conclusion of their fieldwork, TIGTA may issue an Agreement to Facts (ATF) document or a Findings and Recommendations document to share information about audit findings and recommendations. ATF is not a required part of the TIGTA process so not every TIGTA audit will have an ATF.

TIGTA may request an ATF meeting through the SB/SE audit liaison.

TIGTA will provide a briefing document of the tentative audit findings and recommendations to the SB/SE audit liaison prior to the ATF meeting.

TIGTA will provide the briefing document at least two full business days before the meeting to allow for key audit stakeholder review.

The SB/SE audit Iiaison will review and then distribute the briefing document to the appropriate functional coordinators and impacted BU liaisons for their review and distribution to the key audit stakeholders.

The SB/SE audit liaison sends the briefing document to the SB/SE Research coordinator, before the proposed date of the ATF meeting requesting:

The SB/SE audit liaison will schedule an internal stakeholder meeting to take place prior to the ATF meeting. The internal meeting is particularly essential if the SB/SE audit liaison identifies the potential for negative impact, or if the key audit stakeholders, after their review of the briefing document, raise concerns. The request for the meeting should include:

This internal stakeholder meeting affords SB/SE the opportunity to correct, clarify, or mitigate the document contents prior to the ATF meeting with the TIGTA audit team.

The ATF meeting with TIGTA and internal stakeholders will:

When another BU is identified as the lead, the SB/SE audit liaison will coordinate with the impacted OU functional coordinators and the lead BU liaison regarding the ATF meeting and invite participants, as needed.

TIGTA issues a discussion draft report in advance of the closing conference. The IRS has five business days to provide responsive comments. See IRM 1.29.1.2.15, Discussion Draft Report (TIGTA Only).

The discussion draft report identifies findings and recommendations and provides a snapshot of the potential draft report that will require an official response from the IRS.

A meeting may be held during the discussion draft report phase.

The purpose of the discussion draft report meeting is to bring all impacted stakeholders together to discuss the audit findings, recommendations, and issues of concern.

A pre-discussion draft meeting based on the report findings and recommendations is at the discretion of the SB/SE program owner, and potentially other impacted BUs. The purpose of the pre-discussion draft meeting is to discuss and coordinate the agency’s position on the findings, monetary benefits (outcome measures), and recommendations. The meeting should also cover any concerns with monetary benefits, clarification or agreement needed concerning the recommendation ownership, program manager responsibility, identification of an author for developing the report response, or the IRS’s position.

The SB/SE audit liaison will coordinate and provide guidance on the preparation of the audit response to the lead SB/SE functional coordinator immediately after the discussion draft report meeting is held or declined. See IRM 1.29.1.2.16, Draft Report.

The SB/SE audit liaison will provide the SB/SE functional coordinator, for preparation of the response, the following information:

The SB/SE functional coordinator ensures that the response is prepared using the same guidelines identified under IRM 11.53.4.5.2.7, Preparation of the GAO Audit Response.

The SB/SE functional coordinator ensures that the response addresses all monetary benefits (outcome measures).

SB/SE functional coordinators and SB/SE audit liaisons review due dates for corrective actions to ensure established guidelines are followed.

TIGTA issues the final report, which includes the agency’s official response to an audit.

The final report is assigned a report number.

The recommendations and corrective actions included in the final report are added to JAMES.

The SB/SE audit liaison provides a copy of the final report to the impacted SB/SE OUs.

For non-lead SB/SE audits, another BU is the lead and SB/SE is impacted. The lead BU is responsible for scheduling openings, closings, progress update meetings, or for preparing final management responses to draft and final reports (GAO reports).

The lead BU audit liaison is responsible for coordinating, facilitating, and monitoring of the audits that affect their organization.

When impacted SB/SE OUs provide input or comments for a draft report or 180-day letter:

Generally, the GAO Director of Tax Issues sends a Notification Letter to EAM, as the designee of the IRS Commissioner, to notify the IRS of a new audit.

The notification letter is the official notification that GAO will conduct a formal audit. EAM will forward the entrance letter to the Chief, Oversight Liaison and other impacted stakeholders to initiate the opening of an audit. Audits are assigned to a SB/SE audit liaison who serves as the primary POC throughout the audit process.

If the lead BU is not identified or is in question, EAM will coordinate the opening with impacted areas.

The lead organization for the audit schedules GAO meetings and issues the GAO entrance conference invitation. The entrance conference with GAO should be scheduled within 14 calendar days following the request for a meeting. GAO generally will not begin work until the entrance conference has occurred.

The SB/SE audit liaison performs the following tasks to manage the audit:

The SB/SE audit liaison will work with the GAO audit team to keep up to date with audit activities and to identify significant and/or sensitive issues before GAO issues the Statement of Facts.

For SB/SE lead audits, the SB/SE audit liaison will:

When another BU is identified as the lead, the SB/SE audit liaison will:

GAO conducts an exit conference on all audits and provides a Statement of Facts for comment.

The purpose of the exit conference is to discuss and resolve findings and questions contained in the Statement of Facts document. Waiving the exit conference is not an option.

GAO provides an estimate of the number of recommendations that may be included in the draft report. Recommendations are not always specifically identified until the draft report is issued.

GAO uses this phase to discuss, clarify, or correct data and significant issues that may be included in the draft report.

The SB/SE audit liaison will:

All SB/SE impacted OUs will:

The SB/SE audit liaison combines all comments into one file and provides the consolidated comment matrix to GAO prior to the conference call.

GAO prepares a draft audit report at the conclusion of an audit, requesting a formal agency response addressing the report’s conclusions and recommendations. See IRM 1.29.1.2.16, Draft Report.

The draft report is assigned a report number that Treasury uses to track corrective actions on JAMES when delivered to EAM.

EAM delivers the draft report to the Chief, Oversight Liaison who forwards it to the SB/SE audit liaison for distribution to the SB/SE Functional Coordinators and contacts for impacted BUs.

The IRS Commissioner generally has 30 calendar days to respond to a draft report. However, the GAO required response due date can be as few as seven calendar days from the date of the draft report if there is a Congressional request for the report. The cover memorandum accompanying the draft report will clearly stipulate the response time required.

SB/SE will provide a response that includes the following:

In limited circumstances, there may not be adequate time for the IRS to properly consider and address the individual recommendations. In that case, the letter will let GAO know whether the IRS generally agrees with the recommendations and that we will provide a detailed response to the recommendations in our letters prepared in response to the GAO final report. This should be used rarely.

If an extension to prepare the response is needed, the SB/SE audit liaison will notify the Chief, Oversight Liaison, who will then contact EAM to request the additional time to respond.

To coordinate the response, the SB/SE audit liaison:

The SB/SE audit liaison will coordinate and provide guidance on the preparation of the audit response to the lead SB/SE functional coordinator. The functional coordinator will return the response to the SB/SE audit liaison after securing the approval and signatures of appropriate officials.

Upon receipt of the completed response, the SB/SE audit liaison will:

The SB/SE audit liaison will forward the approved response to the Chief, Oversight Liaison.

After securing the approved management response from the SB/SE audit liaison, the Chief, Oversight Liaison reviews the package for accuracy and then forwards the signature package to EAM at least six days prior to GAO’s due date. EAM, will prepare the signature package and submit the package to Deputy Commissioner’s office.

The goal of SB/SE is to establish achievable corrective action due dates. For consistency throughout SB/SE, use the 15th of the month as the due date for all corrective actions. Delaying actions should be rare; however, certain delays, such as those relating to funding, IRM clearance and publication, executive steering committee concurrences, and Unified Work Request (UWR) prioritization, may be necessary.

To ensure achievable due dates, the SB/SE audit liaison will advise the SB/SE OUs to:

See IRM 1.29.1.2.23, Developing a Planned Corrective Action.

The final report procedure for GAO audits requires that the IRS respond to the Congress within 180 calendar days of the issuance of a GAO final report with recommendations (180-Day Letter). Legislative Affairs creates e-Trak controls to track the progress of the 180-Day Letter required for the GAO final reports. See IRM 11.5.1, 180-Day Letter Program and the exhibit in IRM 1.29.1-2 180-Day Letter Response.

GAO issues the final report that includes the agency's official 30 day response to the draft report.

The final report number remains the same as the draft report.

The SB/SE audit liaison provides a copy of the final report to the impacted SB/SE OUs.

The SB/SE audit liaison prepares the Form 14074, Action Routing Sheet and forwards it to the lead SB/SE OU and other impacted stakeholders to initiate the clearance and approval process for an audit response.

The SB/SE audit liaison includes the following individuals and information on the Action Routing Sheet for review and approval:

The lead SB/SE OU functional coordinator initiates the clearance process for the response.

The Chief, Oversight Liaison manages clearance up to Legislative Affairs (LA) once package is received from the function.

LA continues the clearance process for the response through the Deputy Commissioner to obtain the IRS Commissioner’s approval and signature.

GAO audits the financial statements of the IRS annually with the objective of rendering an opinion, evaluating internal controls, and reporting IRS’s compliance.

At the conclusion of the audit, GAO issues an opinion on the financial statements. The final report is issued annually by November 15.

The opinion rendered is one of the following:

In the spring of the following year, GAO issues two related management reports:

The following table shows the timeline of events for IRS financial statement audit:

The SB/SE JAMES coordinator (JAC) is the primary point of contact between the Chief Risk Officer, EAM and SB/SE for tracking and reporting on TIGTA and GAO audit corrective actions. The SB/SE JAC is responsible for monitoring the implementation of planned corrective actions (PCAs) in response to TIGTA and GAO audit recommendations. The JAC will maintain records on JAMES audit verification memoranda, management updates to corrective actions, and related documents for each of the audit reports and corrective actions. See IRM 1.29.1.1.3.6 , JAMES Audit Coordinators (JACs).

The JAC’s internal process in SB/SE includes:

The following sections explain the tracking of the implementation of corrective actions addressing audit recommendations to ensure that the SB/SE Division implements planned actions timely and as stated in the management responses to audit reports.

Once TIGTA or GAO issues a final report, EAM prepares the JAMES A6 abstract and the Audit Verification transmittal memorandum. The abstract contains a summary of findings, recommendations, PCAs, root cause category, monetary benefits, if applicable, due dates, and the responsible official. See IRM 1.29.1.3.6.7 ,Entering New Audit Reports into JAMES and IRM 1.29.1.3.7 Root Cause. For GAO final reports, initial abstracts prepared after receipt of the final reports show only findings and recommendations because, unlike responses to TIGTA draft audit reports, the management responses to GAO draft reports do not include specific corrective actions, due dates, or responsible officials. Once the 180-day letter to Congress is completed, EAM adds the corrective actions, due dates and responsible officials to JAMES and issues another verification memorandum.

EAM forwards the JAMES audit verification memorandum transmitting the final report abstracts to the SB/SE JAC requesting verification that the information shown in the abstract is correct, and, if not already provided, the specific corrective actions and original due dates for each audit recommendation (for the GAO report abstracts).The SB/SE JAC reviews the A6 report audit finding, recommendations, corrective action descriptions, implementation dates, and responsible officials for each of the PCAs and compares them to the Final Report and Management Response for accuracy. The SB/SE JAC then forwards the verification memorandum to the SB/SE functional coordinators to review and identify any items that require a revision and confirm the correct root cause category. The SB/SE JAC will respond to EAM by the requested due date with verification of the information in JAMES or requested changes.

EAM assigns three-digit numbers (e.g., 1-2-3) to corrective actions when developing the final report abstracts in the JAMES tracking system. The first digit represents the finding, the second the recommendation, and the third the particular corrective action number under the recommendation.

The SB/SE JAC contacts the responsible SB/SE functional coordinators to resolve any discrepancies or request information on corrective actions. In case of discrepancies in the JAMES abstracts, the SB/SE JAC prepares a draft response to the JAMES verification memorandum for submission by the responsible SB/SE director(s). If no changes are necessary, the JAC verifies and notifies EAM that the abstracts are correct. A concurrence memorandum, signed by a responsible official at the executive level, is only required if there is substantial disagreement or if monetary benefits have been identified.

The JAC enters all new corrective actions on the individual function spreadsheets and prepares the monthly communications for each SB/SE director for tracking and reporting purposes.

SB/SE directors are responsible for implementing the agreed upon corrective actions in the management responses to draft audit reports. The JAC is responsible for monitoring the status of all open SB/SE audit corrective actions and prepares excel spreadsheets to share with SB/SE leaders their function’s corrective action inventory by the 25th day of each month. See IRM 1.29.1.3 , Monitoring Planned Corrective Actions and IRM 1.29.1.3.1 , Closing Planned Corrective Actions.

Each director through their functional coordinators must provide the current status of all corrective actions due within six months in the "Current Status" column on the spreadsheet. Form 13872, Planned Corrective Action (PCA) Status Update for TIGTA/GAO/MW/SD/TAS/REM Reports, is required for each action that is completed or rescheduled. For completed actions, Form 13872 must include specific information about actions taken, completion dates, and any documentation showing implementation of the recommendation. TIGTA or GAO does not consider a recommendation closed simply because the JAMES report says IRS closed it. The auditors may request documentation as evidence of the implemented corrective actions. When preparing status updates, managers should look closely at the JAMES abstracts or the final report to ensure their updates address the recommendations and planned corrective actions in the abstracts. Identified monetary benefits should be addressed in the status update, whether realized or not.

For extensions of due dates, Form 13872 should include specific reasons for delays in implementing actions. A revised date should be set to the 15th of the month following the anticipated completion of the action to allow time to provide a response to EAM and entry into JAMES. The appropriate director must sign the Form 13872. The form must list a contact person who is a senior manager with subject-matter expertise who can answer questions from EAM, TIGTA, GAO, or high-level manager.

All updated spreadsheets and approved Forms 13872 are due to the Chief, Oversight Liaison with a copy to the JAC by the 10th day of the following month.

EAM will inform the audit liaison of any pending actions because the status narratives were not satisfactory to either change, close, or delay the actions. Actions involving a Unified Work Request (UWR) or revisions to the IRM require full implementation of the programming changes and the actual IRM updates, in order to close them in the JAMES tracking system.

To request approval to revise planned audit corrective actions or to close audit corrective actions SB/SE could not implement as planned (e.g., programming changes could not be implemented because the UWR was not approved or because a planned project was canceled), the OU must prepare a concurrence memorandum for the signature of their director. Include a courtesy copy to the EAM. If the Chief Information Officer function rejects a UWR (prepared in response to an audit recommendation), the impacted OU must ask IT to provide the denial in writing, including the specific reasons. See IRM 1.29.1.3.9 ,Managing Unique PCA Activities.

Once signed by the Director, the functional coordinator will send the concurrence memorandum to the JAC who is responsible for transmitting the memorandum to TIGTA or GAO. The JAC is also responsible for following up on these memoranda. TIGTA and GAO send their responses to the EAM who then forwards them to the SB/SE JAC.

The impacted OU should request extensions of due dates for corrective actions pending responses from TIGTA or GAO on memoranda requesting approval to close or change their planned corrective actions.

Transfers of corrective actions to another BU require the concurrence memoranda, with attached abstracts of the corrective actions involved, signed by the directors responsible for the audit recommendations and corrective actions, asking for concurrence signature from the appropriate directors in the receiving BU. See IRM 1.29.1.3.9 (6), Transfer of Ownership for Audit Recommendations.

The SB/SE JAC forwards copies of the signed memoranda to EAM and the appropriate JAMES coordinators in the receiving BU.

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

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

For Long-Term PCAs, provide a status update every 12 months in JAMES. EAM will establish an initial milestone date. Systemic notifications from JAMES are issued 30 days prior to the milestone date prompting a progress update. Updates must include the following information:

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

EAM 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.

The SB/SE Legislative Proposals/Guidance Request Database allows designated users to:

The SB/SE Legislative Proposal/Guidance Request Database Administrator and Chief, Oversight Liaison has the authority to add and remove users from the database and to assign permissions.

Executing changes to the data contained in the database is limited to Oversight Liaison team members and SB/SE Legislative Proposal/Guidance Request Database Administrator.

The OUs must advise the Chief, Oversight Liaison when a change in personnel requires an addition or deletion of user’s read-only authorization.

The SB/SE Legislative Proposal/Guidance Request Database home page provides a series of menu boxes that allows users to:

The SB/SE Legislative Proposal/Guidance Request Database contains the following information on submitted legislative proposals and guidance requests: