Comments on coordinated examination program: evaluation of agent performance and the IRS's ethics initiative, December 20, 1989.

• Author: Burk, William M.

Comments on Coordinated Examination Program: Evaluation for Agent Performance and the IRS's Ethics Initiative

December 20, 1989

Earlier this year representatives of Tax Executives Institute met with Larry M. Phillips, you, and other members of the Internal Revenue Service's Quality Improvement Project on the Coordinated Examination Program to discuss the IRS's review of the CEP program as well as its efforts to refine an ethics initiative for the IRS.

In October, Mr. Phillips participated in the Institute's 1989 Annual Conference, which was held in Toronto, and shared his views as the chair of CEP-QIP team; at that time, members of the Institute's IRS Administrative Affairs Committee reacted to Mr. Phillips's presentation and summarized TEI's concerns and recommendations with respect to two aspects of the IRS's CEP program: evaluation of agent and case manager performance, and the application of the IRS's ethics initiative to large case agents.

As we have already advised Mr. Phillips, his presentation to the Institute's Annual Conference was very well received. TEI members were generally heartened by his comments and the direction in which the QIP team is heading. The purpose of this letter is to follow-up on Mr. Phillips's request that the Institute provide its views on measuring performance and the IRS's ethics initiative. In light of Mr. Phillips's subsequent retirement, we have been advised to submit our comments to you, with copies to Commissioner Goldberg, Assistant Commissioner (Examination) Blattner, and Mr. Phillips.

Overview: A Commitment

to Quality

The development of a meaningful program of measuring performance by members of the CEP examination team is essential to the long-term success of a quality improvement program. In this regard, Tax Executives Institute affirms its general belief that a clear line does not exist between the criteria for evaluating agent performance and ethics. An evaluation procedure that serves to identify, develop, and support the retention of IRS employees who demonstrate superior technical skills and the desired level of professionalism should also single out those employees with integrity, a strong values system, and high ethics.

In other words, good agents or case managers -- or Appeals Officers for that matter (1) -- will not only have the requisite technical skills but will, almost by definition, be professional and ethical in their conduct. Thus, an understandably symbiotic relationship exists between the two concerns. Measuring "good" or "bad" performance, however, is not something that is easily accomplished. Consequently, in addition to soliciting the views of professional associations such as TEI, we recommend that the IRS consider, to the extent it has not done so already, retaining the services of professional management consultants to assist it in refining its evaluation program.

As TEI's previous submissions on the CEP program make clear, the Coordinated Examination Program operates to the mutual benefit of the IRS and taxpayers. We applaud the IRS's initiative in seeking to improve the program, for though the CEP program is operating well, there is truth in the quality axiom, "if it's not broken, it may soon be." Improving techniques and procedures for evaluating agents and case managers should be an integral part of the IRS's CEP quality initiative.

Following the Institute's meeting with the CEP-QIP team this summer, we solicited comments from our various chapters about agent performance and the IRS's ethics initiative. I am pleased to report that our request generated a considerable number of thoughtful responses from all regions of the country. Although taxpayer perceptions of the CEP program in general and the measurement of agent performance and ethics in particular are understandably colored by taxpayers experiences (good or bad) with specific IRS personnel, we believe certain generalizations may properly be drawn. Thus, even if particular conclusions are based on anecdotal evidence and are of limited applicability to the CEP program as a whole, we trust they will be of benefit to the IRS.

Taxpayer or Other Evaluation

A...