February 9, 2022
Commissioner Charles P. Rettig
Internal Revenue Service
1111 Constitutional Ave NW
Washington DC 20224
Re: Accounts Management Inventory Surge Team
Dear Commissioner Rettig:
On behalf of the Professional Managers Association (PMA) – the non-profit professional association that has, since 1981, represented professional managers, management officials, and non-bargaining unit employees at the Internal Revenue Service (IRS) – I write regarding the recent Inventory Surge Team notice sent to all IRS employees.
While PMA understands the pressing need to allocate additional personnel and resources to Accounts Management (AM), we are concerned about the lack of engagement with PMA and feedback from management on the impact of this decision across the Service. When PMA and the IRS signed a Part 251 Consultative Agreement in August 2021, the IRS committed to including “supervisors and managers in the decision-making process, and [to] notify them of executive-level decisions on a timely basis.” The purpose of this agreement and the continued collaboration between PMA and the Service is to improve IRS operations, personnel management, and employee effectiveness to ensure policies are developed that best serve the public interest in accomplishing the important mission of the IRS.
PMA was informed of the Inventory Surge Team a little more than an hour before the rest of the IRS workforce and was not provided an opportunity to relay questions or feedback regarding implementation. Worse, we learned additional details, such as the number of employees impacted, from members of the press. As the nation looks to the IRS during the 2022 Filing Season with many concerns and frustrations, it is imperative the IRS use every resource at its disposal to ensure its decisions are effective and do not create embarrassing situations for the Service or unforeseen consequences for our members or the taxpayers they serve. PMA is one of those resources. While we have incredible trust in IRS leadership to make well-reasoned decisions with the public in mind, the very purpose of our consultative agreement is to ensure the perspective of front-line managers is accessible to agency leadership when making decisions just like this one.
To that end, PMA now writes to relay several questions and concerns regarding the Inventory Surge Team notice:
1. Detailed employees are performing work in their current roles which will now not be performed. How will that impact customer service? Will we be able to balance our statutory obligations with the sudden reduction in bandwidth?
· While the AM backlog is getting a lot of attention in the media and from Congress, there are significant case inventories across the Service, for example in Collections, Examination, the Independent Office of Appeals, and the Taxpayer Advocate Service. We are concerned the singular focus on one backlog will exacerbate other backlogs.
2. Managers are held to performance commitments that are set at the start of each fiscal year. Will the agency be revising those goals so that our members are not penalized for missing targets now that they are losing staff to this project?
3. We understand that a number of these workers will come from the IRS’s quality review function, which means that the Service may be creating a situation where it will close cases at a faster pace while reducing internal oversight. Managers are rated based upon these quality analyses, so it is crucial that they are accurate and sampled in statistically valid manner. What is being done to ensure that the Joint Operations Center remains fully staffed?
4. The communication made it clear that managers themselves will not be detailed, so who will be managing these additional workers in AM? Are we overburdening existing AM managers with tranches of additional employees? Are we asking managers outside of AM to monitor an unfamiliar work stream?
5. When receiving a new employee or joining a new team, our members frequently report that departure ratings are missing and that employee files are difficult to find and missing important data. What training, guidance, and support will the Human Capital Office provide to managers to ensure that the departure rating process is performed and that employee records are correctly transferred?
6. Has the IRS developed a servicewide strategy to transition these employees? Has IT been consulted to ensure they can manage this while simultaneously providing service to the rest of the IRS, so employees remain working effectively?
· IRS technology systems are complex and antiquated. It can take a great amount of effort to get the correct systems installed, obtain software licenses, etc. to be sure these employees are ready to work when they arrive on their detail.
7. Some of the former AM workers were hired in cohorts to other functions. We are hearing from members who are concerned that employees assigned to the Inventory Surge Team will fall behind their peers in on-the-job experience. Are plans in place for “refresher” training or some other form of knowledge transfer when these workers return?
· Being away from their new jobs for six or more months will likely have a short-term negative impact on their productivity when they return but, more significantly, may hamper their long-term competitiveness for details and special assignments.
8. Does the IRS have an approved exception to its detail authority from the Office of Personnel Management? It is PMA’s understanding that workers are limited to 180 days on a detail assignment, in every rolling calendar year. If these details end on September 30th, then they could not begin until early April. could not begin until early April.
9. AM can be a challenging environment for frontline employees, and some seek roles elsewhere in the Service to improve their workplace experience. Is this detail assignment optional?
10. Why was such a profound, novel reassignment of duties executed without consulting management?
Again, PMA fully supports the need to allocate additional personnel and resources to AM. We believe this is the Service’s best chance at improving the taxpayer experience in AM. We only wish to ensure this decision is not done at the detriment of taxpayer services in other areas, which will inevitably create a new, additional backlog once the AM inventory backlog is reduced. Further, PMA wants to be a resource for the IRS and assist in resolving our questions and concerns. This can only be done with effective communication.
For the reasons outlined above, PMA requests a meeting with the Deputy Commissioner for Services and Enforcement to discuss these matters and to work together on solutions.