The Internal Revenue Service Has Opportunities to Provide
Hearing- and Speech-Impaired Taxpayers With Easier Access to Toll-Free
Telephone Services
May 2003
Reference
Number: 2003-30-111
This report has cleared the Treasury
Inspector General for Tax Administration disclosure review process and
information determined to be restricted from public release has been redacted
from this document.
May
30, 2003
MEMORANDUM FOR
COMMISSIONER, SMALL BUSINESS/SELF-EMPLOYED DIVISION
COMMISSIONER, WAGE AND
INVESTMENT DIVISION
FROM: Gordon C. Milbourn III /s/ Gordon C.
Milbourn III
Acting Deputy Inspector
General for Audit
SUBJECT: Final Audit Report - The Internal Revenue Service Has Opportunities to
Provide Hearing- and Speech-Impaired Taxpayers With Easier Access to Toll-Free
Telephone Services (Audit # 200330016)
This
report presents the results of our review of the Internal Revenue Service’s (IRS) ability to provide hearing- and
speech-impaired taxpayers with access to toll-free telephone services. This review was performed as part of our
audit of the IRS’ ability to provide taxpayers with access to the toll-free
telephone system during the 2003 Filing Season. An audit memorandum presenting the results of this review was
issued to the Commissioners, Small Business/Self-Employed and Wage and
Investment Divisions, on February 28, 2003.
The memorandum is included as Appendix IV to this report.
In summary, the IRS has
opportunities to provide hearing- and speech-impaired taxpayers with easier
access to its TTY/TDD service.
Cumulative Fiscal Year 2003 data, through the week ending January 25,
2003, showed there were 69,299 net call attempts to the TTY/TDD line, which is
extremely small call demand in comparison to that on other toll-free lines. Of these 69,299 attempts, only 3,286 calls
were answered while more than 66,000 calls were abandoned. In addition, almost one-third of the call
attempts to the TTY/TDD line resulted in busy signals.
Our analysis and discussions
with IRS management determined that access to the IRS’ TTY/TDD service was
diminished because voice callers were saturating the TTY/TDD line. This may have been attributable, in part, to
the fact that various IRS media that provide instructions for calling the IRS
did not clearly explain that the TTY/TDD number was only for hearing- and
speech-impaired callers. Conversely,
all of the toll-free services advertised by the IRS as being available on the
TTY/TDD number, such as the Taxpayer Advocate Service, cannot be provided to
taxpayers on that line. Further, the
IRS’ TeleTax for Topic #102 (“Tax assistance for individuals with disabilities
and the hearing impaired”) incorrectly announced the hours that the TTY/TDD
service was available. Finally, account
notices sent to taxpayers do not include the TTY/TDD number, although hearing-
and speech-impaired taxpayers with account issues can be helped on this line.
Calls on the TTY/TDD line
were routed to 2 of the IRS’ 29 toll-free facilities. Taxpayers with tax law questions whose TTY/TDD calls were routed
to the Atlanta call site may not have received the same level of assistance as
those taxpayers whose calls were routed to Indianapolis. Because the Atlanta call site has been designated
to handle account calls only, its CSRs have received only limited training on
tax law issues and, therefore, cannot handle the broad spectrum of tax law
calls. In addition, the CSRs that are
trained to handle calls on the TTY/TDD equipment are not capable of providing
TTY/TDD service to Spanish-speaking callers.
In addition, during the 6-day period starting on January 25, 2003, the
Average Speed of Answer on the TTY/TDD line ranged from a low of 28.7 seconds
to a high of 263.2 seconds. This range
may be attributable to the fact that not all
of the TTY/TDD machines are equipped with strobe lights to alert the CSRs to an
incoming call.
We recommended providing
additional trunk lines or obtaining the technology to block voice calls from
entering the TTY/TDD line. To improve
the advertising for the IRS’ TTY/TDD service, we recommended revising the
various taxpayer instructions for calling the IRS to clearly explain that the
TTY/TDD number is for hearing- and speech-impaired taxpayers only and that it
requires special equipment to receive service on this line. Separate TTY/TDD numbers/equipment should be
provided for the Taxpayer Advocate Service and other specialized toll-free
product lines so that hearing- and speech-impaired taxpayers have the same
expectations as voice callers to receive one-stop service. We also recommended revising TeleTax Topic
#102 to announce the correct hours of operation for the TTY/TDD service, and
including the TTY/TDD number on account notices and letters sent to taxpayers,
clearly indicating that it is for hearing- and speech-impaired taxpayers
only. To increase the IRS’ capacity to
provide one-stop service on the TTY/TDD line, we recommended moving the TTY/TDD
equipment from Atlanta to a site with CSRs trained to handle both tax law and
account calls and providing TTY/TDD service to Spanish-speaking taxpayers. Finally, to increase the speed of answer on
the TTY/TDD line, we recommended providing strobe lights on all TTY/TDD
equipment to alert CSRs to incoming calls.
Copies
of this report are also being sent to the IRS managers who are affected by the
report recommendations. Please contact
me at (202) 622-6510 if you have questions or Richard Dagliolo, Acting
Assistant Inspector General for Audit (Small Business and Corporate Programs),
at (631) 654-6028.
Actions
Can Be Taken to Better Meet the Needs of Hearing- and Speech-Impaired Callers
Appendix I – Detailed Objective, Scope, and Methodology
Appendix II – Major Contributors to This Report
Appendix III – Report Distribution List
Appendix V – Management’s Response to Memorandum #1
The Internal Revenue Service’s (IRS) mission is to provide America’s taxpayers with top quality service by helping them understand and meet their tax responsibilities and by applying the tax law with integrity and fairness to all. The IRS provides toll-free telephone numbers that taxpayers may call when seeking answers (in either English or Spanish) to tax law questions, requesting tax forms, or requesting information about their accounts. The IRS’ suite of toll-free numbers also includes several lines for taxpayers that need other specialized services.
More than 34 million Americans are deaf or hearing-impaired, and almost 2.7 million Americans have speech impairments. The Telecommunications Accessibility Enhancement Act of 1998 requires that individuals with hearing and speech impairments be provided with full access to Federal Government telecommunications services and facilities.
The IRS provides a special toll-free line (1-800-829-4059)
to serve those hearing- and speech-impaired taxpayers that require TTY/TDD
service. The term TTY/TDD is an
abbreviation for “Teletype” and “Telecommunications Device for the Deaf.” The TTY/TDD allows the users to communicate by text messages that
each party alternately sends via a keyboard.
Calls
to the IRS’ TTY/TDD line are routed to Customer Service Representatives (CSR)
located in Atlanta, Georgia, or Indianapolis, Indiana. The IRS provides service on its
TTY/TDD line 5 days per week from 7:00 a.m. to 10:00 p.m. (local time for all
taxpayers except those in Alaska and Hawaii).
The IRS also provides service on its TTY/TDD line from 10:00 a.m. to
3:00 p.m. on certain Saturdays during the filing season. These are the same hours of service that the
IRS provides for voice callers on its other customer service toll-free lines.
This review was performed in January and February 2003 at the IRS’ Joint Operations Center and Accounts Management Center in Atlanta, Georgia. The audit was conducted in accordance with Government Auditing Standards. Detailed information on our audit objective, scope, and methodology is presented in Appendix I. Major contributors to the report are listed in Appendix II.
Cumulative Fiscal Year (FY) 2003 data, through the week ending January 25, 2003, showed there were 69,299 net call attempts to the IRS’ TTY/TDD line. Of these, only 3,286 calls were answered, while more than 66,000 were abandoned. Almost one-third of the call attempts to the TTY/TDD line resulted in busy signals. In addition, taxpayers who called the TTY/TDD line with tax law questions may have encountered more difficulty in obtaining assistance than taxpayers who called the TTY/TDD line with account questions.
Although the call demand on the TTY/TDD line is extremely small in comparison to that on other toll-free lines, the IRS has opportunities to provide hearing- and speech-impaired taxpayers with easier access to its service by:
·
Preventing
voice callers from tying up the TTY/TDD line.
·
Improving
the advertising for the TTY/TDD service.
·
Increasing
the capacity to handle TTY/TDD calls.
· Improving the speed of answer on the TTY/TDD line.
Because the TTY/TDD equipment was receiving few actual TTY/TDD calls in comparison with the total call volume, IRS management believed that voice callers may be saturating this line. We were advised that the IRS could not block voice calls from entering the TTY/TDD trunk lines because neither AT&T nor the IRS equipment can differentiate voice calls from TTY/TDD calls.
However, on January 24, 2003, the IRS made some changes to its system to try to limit the amount of time that voice callers tie up the TTY/TDD line. These changes resulted in voice callers receiving a shrill sound as soon as they connect to the line, followed by a recorded message explaining the purpose of this line and the correct telephone number for the voice callers to use. If the voice callers did not hang up prior to these two actions, the system then disconnected them. In addition to these systemic actions, the IRS is now opening the Atlanta call site from 7 a.m. to 1 a.m. Eastern Standard Time (EST), whereas previously it was open only outside of the daytime hours (9 a.m. to 5 p.m. EST) that the Indianapolis call site was open.
Based on the IRS’ Daily Executive Level Summary Reports available since these changes, the actions seem to be successfully preventing voice callers from reaching the TTY/TDD equipment. Managers at both call sites stated that they are no longer receiving voice callers on the TTY/TDD equipment. During the current filing season, however, large numbers of callers continued to attempt to reach the IRS via the TTY/TDD number, and hundreds of callers received busy signals on a daily basis.
Voice callers may have been inadvertently calling the TTY/TDD line for assistance because not all of the various IRS media that provide instructions for calling the IRS clearly explained that the TTY/TDD number is only for hearing- and speech-impaired taxpayers. For example, the section on “Calling the IRS” contained in the instructions for completing individual income tax returns that are provided to millions of taxpayers advised them to “call 1-800-829-1040 (for TTY/TDD help, call 1-800-829-4059).” Many taxpayers may not understand the TTY/TDD abbreviation and, in turn, may not realize that this number should only be used by hearing- and speech-impaired individuals with access to special telecommunications equipment.
Conversely, not all of the toll-free services advertised by the IRS as being available at the TTY/TDD number can be provided to taxpayers on that line. For example, the tax package instructions, various IRS tax publications, and the IRS public web site (www.irs.gov) provided the same TTY/TDD number for contacting the Taxpayer Advocate Service as is provided for asking tax law questions, requesting tax forms, or resolving account issues. Most of the CSRs assigned to receive TTY/TDD calls were not trained to handle this type of call. The IRS has CSRs at other sites that are specifically trained to receive voice calls to the Taxpayer Advocate Service.
In addition, we found that:
· The IRS’ TeleTax line for Topic #102 (“Tax assistance for individuals with disabilities and the hearing impaired”) incorrectly announced that TTY/TDD service was available 24 hours per day. The IRS currently provides TTY/TDD service for only 15 hours per day.
· Account notices sent to taxpayers do not include the TTY/TDD number, although hearing- and speech-impaired taxpayers with account issues can be helped on this line. Consequently, these taxpayers may not know that this number is available to provide assistance to them.
Because large numbers of voice callers are attempting to reach the IRS on the TTY/TDD line, the IRS has no data on the actual number of hearing- and speech-impaired taxpayers using TTY/TDD equipment who may be attempting to access its TTY/TDD line. Consequently, IRS management does not know if the quantity of TTY/TDD machines, the number of trunk lines, and/or the number of CSRs assigned to the TTY/TDD line are sufficient to effectively meet the demand. In addition, we were advised that the CSRs trained to handle calls on the TTY/TDD equipment are not capable of providing TTY/TDD service in Spanish.
The IRS has equipment to receive TTY/TDD calls in only 2 of its 29 toll-free facilities. The IRS initially began offering TTY/TDD service at its Indianapolis, Indiana, call site in 1976. When the IRS expanded its hours of toll-free service to 24 hours per day, 7 days per week, TTY/TDD equipment was added to its Atlanta, Georgia, call site in June 2001 to cover those hours that were not handled by Indianapolis. Both sites have three TTY/TDD machines and three trunk lines each. Given the current capacity, a maximum of only six calls can be in the system at any given time before a new caller would receive a busy signal. The TTY/TDD trunk lines can be tied up for long periods because these calls are considerably longer than voice calls. For example, IRS program analysts advised us that a 45-minute call is not uncommon because of the need to type messages. When all of the TTY/TDD trunk lines are tied up with other callers, there is no way to give hearing- and speech-impaired callers a message that their calls cannot be handled.
Until recently, the TTY/TDD equipment was not in use at the same time by both sites. The Indianapolis lines were used only during normal work hours, while the Atlanta lines were used only during the expanded hours of service. In late January 2003, the IRS began routing calls to the TTY/TDD line to both sites during the day rather than only to the Indianapolis site.
Taxpayers with tax law questions whose TTY/TDD calls were routed to the Atlanta call site may not have received the same level of assistance as those taxpayers whose calls were routed to Indianapolis. Because Atlanta is a call site that has been designated to handle account calls only, its CSRs have received only limited training on tax law issues and, therefore, cannot handle the broad spectrum of tax law calls. Conversely, the majority of the TTY/TDD calls involving tax law questions, account issues, and tax forms requests can be handled at the Indianapolis site, since it is both an account and tax law site.
If taxpayers who reach the Atlanta call site on the TTY/TDD line cannot be helped by the CSRs, they will be told to call one of the other regular IRS toll-free telephone numbers using a relay operator or, in the case of a tax law question, given an option to call back between 9 a.m. and 5 p.m. EST (if they called outside of those hours) when they may have a better chance of reaching a CSR who can answer their questions (i.e., potentially reach the Indianapolis call site).
We received a video from Gallaudet University that documented the experience of its Technology Access Program staff with trying to communicate with the IRS using TTY/TDD equipment. The video showed that if callers attempt to use a relay operator to communicate with the IRS, they may be unsuccessful in obtaining assistance because of the complex routing scripts and the speed of the recorded messages. For example, the relay operator must type the recorded information into the TTY/TDD equipment for the taxpayer who must then type an answer (e.g., which menu item he or she would like to select). By the time these actions are completed, the IRS’ system may have timed out and hung up on the caller. In addition, we were advised that it is difficult or impossible for a relay operator to type fast enough to include all of the menu selections due to the speed of the spoken word versus the speed of the typed word.
Not all of the IRS’ TTY/TDD machines were equipped with strobe lights. At the Atlanta site, only one of the three TTY/TDD machines was equipped with a strobe light to alert the CSR to an incoming call. The other two machines relied upon the CSR to notice a computer screen image of a ringing phone. None of the three TTY/TDD machines at the Indianapolis site were equipped with strobe lights. Instead, a screen image of a ringing phone was used along with very small lights on the top of the machines. Because the CSRs assigned to the TTY/TDD line worked paper inventory while waiting for incoming calls, they may not immediately notice that a call is waiting.
During the 6-day period starting on January 25, 2003, the Average Speed of Answer on the TTY/TDD line ranged from a low of 28.7 seconds to a high of 263.2 seconds. Since there is no call queue beyond that of the six trunk lines for the six TTY/TDD machines, the waits at the higher end of the range may be attributable, at least in part, to the CSRs being unaware of the incoming calls. Management at the Atlanta site informed us that they had requested strobe lights for all three machines but had received no response to this request.
The Directors, Customer Account Services, of the Wage and Investment (W&I) and Small Business/Self-Employed Divisions, have opportunities to ensure that hearing- and speech-impaired taxpayers are provided easier access to the IRS’ toll-free telephone system by:
1. Providing additional trunk lines or determining if the technology exists that would distinguish voice calls from TTY/TDD calls and, if so, obtaining this enhancement to enable the IRS to block voice calls from entering the TTY/TDD line.
Management’s Response: The Commissioner,
W&I Division, stated that a Request for Information Services was initiated
on February 7, 2003, to implement a technical solution to provide equal access
to TTY/TDD users and sufficient capacity for one call site to handle all of the
demand, if necessary.
2. Revising the various taxpayer instructions for calling the IRS to clearly explain that the TTY/TDD number is for hearing- and speech-impaired taxpayers only and that it requires special equipment to receive service on this line.
Management’s Response: The Commissioner, W&I Division, does not believe that changing the instructions is necessary. The instructions and the listing that the IRS uses are consistent with the standard format that other Government agencies and private organizations use.
3. Providing separate TTY/TDD numbers/equipment for the Taxpayer Advocate Service and other specialized toll-free product lines so that hearing- and speech-impaired taxpayers have the same expectations as voice callers to receive one-stop service.
Management’s Response: The Commissioner,
W&I Division, has consulted with members of the Taxpayer Advocate Service,
and they are not aware of any complaints or problems with the current
service. Representatives from the
Taxpayer Advocate Service and the other product lines will be invited to
participate in the W&I Division’s review of services. The W&I Division will examine all of its
documents and publications for taxpayers to ensure that they carry a message
consistent with the service the IRS provides.
4. Revising TeleTax Topic #102 to announce the correct hours of operation for the TTY/TDD service.
Management’s Response: The W&I
Division has revised TeleTax Topic #102 to announce the correct hours of
operation.
5. Including the TTY/TDD number on account notices and letters sent to taxpayers and clearly indicating that it is for hearing- and speech-impaired taxpayers only.
Management’s Response: The Commissioner, W&I Division, did not agree with this recommendation because the community of TTY/TDD users is very small in relation to the volume of notices that the IRS sends each year. He stated that this community of customers is aware of the availability of both the Federal Government relay service and the IRS’ own TTY/TDD service number, and added that the IRS believes listing these numbers on notices could be counterproductive because it would increase the probability that voice callers would attempt to use these numbers. However, the IRS will modify the listing of TTY/TDD service in the tax instructions and publications to reflect that assistance is also available for resolving account-related issues.
6. Increasing the capacity of the TTY/TDD line to provide one-stop service by moving the TTY/TDD equipment from Atlanta to a site with CSRs that are trained to handle both tax law and account calls.
Management’s Response: The Commissioner, W&I Division, did not agree with this recommendation. He advised that CSRs assigned to staff the TTY/TDD line should have sufficient training to address these customers’ needs and that moving the equipment is only one option the IRS can use to improve service in this area. The IRS will explore all areas before taking corrective action.
7. Providing TTY/TDD service to Spanish-speaking taxpayers.
Management’s Response: The Commissioner, W&I Division, does not believe that a sufficient number of Spanish-speaking taxpayers who would need IRS-provided TTY/TDD service exists to justify the cost of hiring and training for that service. He advised that the Spanish language is available through the telecommunications relay service, and he does not believe there is a need to duplicate this service at this time. The IRS will examine all of its documents and publications for taxpayers to ensure that they carry a message consistent with the service the IRS provides.
8. Providing strobe lights on all TTY/TDD equipment to alert CSRs to incoming calls.
Management’s Response: The Commissioner,
W&I Division, agreed with this recommendation and will follow up on the
request that was submitted to provide this signaling for the Atlanta site. He advised that the Indianapolis site has a
signaling system. The W&I Division
will review the need for a different method in this site and request the
appropriate service if needed.
Appendix I
Detailed Objective, Scope, and Methodology
Our objective was to
evaluate the Internal Revenue Service’s (IRS) ability to provide hearing- and
speech-impaired taxpayers with access to toll-free telephone services. We performed this review as part of our audit of the IRS’ ability to
provide taxpayers with access to the toll-free telephone system during the 2003
Filing Season.
To accomplish this
objective, we:
I.
Reviewed the
IRS’ performance results for the TTY/TDD toll-free product line provided for
hearing- and speech-impaired taxpayers.
II.
Interviewed
various IRS management officials and program analysts with responsibility for
the TTY/TDD line.
III.
Visited the Atlanta Accounts Management Center to
observe the TTY/TDD operations.
IV.
Performed
Internet research to determine the potential number of hearing- and speech-impaired
individuals.
V.
Contacted Gallaudet University to determine the
potential number of hearing- and speech-impaired individuals that use TTY/TDD
equipment to communicate.
VI.
Reviewed a video made by Gallaudet University that
documented the experience of its Technology Access Program staff with trying to
communicate with the IRS using TTY/TDD equipment.
VII.
Reviewed the accuracy and consistency of the various
instructions provided to taxpayers by the IRS through various media on using
the toll-free telephone system to contact the IRS.
Appendix II
Major Contributors to This Report
Richard Dagliolo, Acting Assistant Inspector
General for Audit (Small Business and Corporate Programs)
Philip Shropshire, Director
Frank J. Dunleavy, Acting Director
William E. Stewart, Audit Manager
Karen J. Stafford, Senior Auditor
Denise Gladson, Auditor
Carol A. Rowland, Auditor
Appendix III
Commissioner N:C
Deputy
Commissioner N:DC
Acting Deputy Commissioner, Small Business/Self-Employed Division S
Deputy Commissioner, Wage and Investment Division W
Director, Customer Account Services, Small Business/Self-Employed Division S:CAS
Director, Customer Account Services, Wage and Investment Division W:CAS
Director, Joint Operations Center W:CAS:JOC
Chief Counsel CC
National Taxpayer Advocate TA
Director, Legislative Affairs CL:LA
Director, Office of Program Evaluation and Risk Analysis N:ADC:R:O
Office of Management Controls N:CFO:AR:M
Audit Liaisons:
Commissioner, Small
Business/Self-Employed Division S
Commissioner, Wage and Investment Division W
Director, Customer Account Services, Small Business/Self-Employed Division S:CAS
Director, Customer Account Services, Wage and Investment Division W:CAS
Appendix IV
Memorandum #1 was removed due to its size. To see the Memorandum, please go to the Adobe PDF version of the report on the TIGTA Public Web Page.
Appendix V
Management’s Response to Memorandum #1
The response
was removed due to its size. To see the
complete response, please go to the Adobe PDF version of the report on the
TIGTA Public Web Page.