TREASURY
INSPECTOR GENERAL FOR TAX ADMINISTRATION
The Background Investigation Process Needs Improvements to Ensure Investigations Are Completed Timely and Effectively
March 28, 2007
Reference Number: 2007-20-059
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.
Phone Number |
202-927-7037
Email Address | Bonnie.Heald@tigta.treas.gov
Web Site
| http://www.tigta.gov
March 28, 2007
MEMORANDUM FOR CHIEF, MISSION ASSURANCE AND SECURITY SERVICES
FROM: Michael R. Phillips /s/ Michael R. Phillips
Deputy Inspector General for Audit
SUBJECT: Final Audit Report – The Background Investigation Process Needs Improvements to Ensure Investigations Are Completed Timely and Effectively (Audit # 200520033)
This report presents the results of our review of the Internal Revenue Service’s (IRS) Background Investigation Process. The overall objective of this review was to determine whether the IRS’ current background investigation process ensures investigations are completed timely and effectively and assures management that IRS and contractor employees are suitable for employment. This audit was part of the statutory audit coverage under the Information Systems Programs and is included in the Treasury Inspector General for Tax Administration Fiscal Year 2006 Annual Audit Plan.
Impact on the Taxpayer
The IRS maintains sensitive financial information for more
than 226 million taxpayers. Because many
IRS and contractor employees must have access to sensitive taxpayer information
to administer the nation’s tax system, the IRS must be particularly cognizant
of hiring only those applicants with the highest integrity. Unsuitable IRS and contractor employees could
gain access to sensitive taxpayer information for unauthorized purposes,
including identity theft.
Synopsis
Background
investigations are the initial step in the process of ensuring the highest
standards of honesty, integrity, and security are met. We analyzed the timeliness and effectiveness
of IRS, contractor, bank lockbox,[1] and contract
cleaning crew employee background investigations.
The IRS’ process for prescreening its employees prior to conducting the background investigations on employees was appropriate and effective. IRS employees were fingerprinted, and preliminary checks were completed prior to the employees gaining access to IRS facilities and systems. Also, IRS employee background investigations were appropriate for the level of risk associated with the positions.
However, background investigations were not completed timely
for IRS and contractor employees. The
IRS did not complete 77 percent of the IRS employee investigations and 72
percent of the contractor employee investigations we sampled within established
IRS baselines. In addition, business unit managers authorized some
contractor employees to gain access to IRS computer systems before fingerprint
analyses had been received by the IRS. The lack of documentation in the case files for
IRS and contractor employee background investigations precluded us from
identifying the causes of the delays. Delays
in processing background investigations increase the risk that the IRS may be
hiring unsuitable IRS and contractor employees that could compromise sensitive
taxpayer information, physically harm employees, and disrupt operations.
Furthermore, temporary bank (lockbox) employees who assist
lockbox sites in handling more than $360 billion in taxpayer remittances per
year receive only an annual fingerprint check.
In 2005, 54 remittances totaling
approximately $2.8 million were stolen from 1 of the lockbox sites. Foreign nationals[2] were responsible for the majority of the
theft. The IRS is currently
working with the Department of the Treasury Financial Management Service to
revise the requirements for hiring temporary lockbox employees. At a minimum, temporary lockbox employees
shall be legal permanent residents who have resided in the
Also, background investigations were not always required for
cleaning contractor employees who had access to IRS office space. Of
the 19 contracts we reviewed, 8 (42 percent) did not require background
investigations on cleaning contractor employees. In another review conducted in 9 locations,
the Treasury Inspector General for Tax Administration Office of Investigations
found that 17 cleaning contractor employees were given access to IRS facilities
without having had background investigations.
Three of these 17 employees were using stolen Social Security Numbers,
and their true identities are unknown.
Hiring cleaning contractor employees without performing background
investigations increases the risk that unsuitable individuals can gain access
to IRS facilities where taxpayer information is vulnerable. Unsuitable cleaning contractor employees could
harm IRS employees, steal taxpayer identities and Federal Government assets,
and obtain unauthorized sensitive tax information. Compliance with recent requirements from the
Office of Management and Budget will reduce this risk.
Recommendations
We recommended the Chief, Mission Assurance and Security Services, ensure the Automated Background Investigation System[3] is programmed to track the time expended to process background investigations. Alerts and reports to management should be developed to enable management to determine when and where delays occur and ensure investigations are completed within established baselines. The Chief, Mission Assurance and Security Services, should also periodically remind business unit managers, contracting officials, and system administrators to review documentation verifying that contractor employees have been prescreened before they are given access to computer systems. Because actions are underway to improve background investigations of temporary bank employees and cleaning contractor employees, we made no additional recommendations.
Response
IRS management agreed with both of our recommendations. The Automated Background Investigation System tracks the amount of time it takes to process an investigation and managers have the ability to use inventory reports to track case actions and case delays. In addition, an alert will be deployed that will warn Investigative Analysts 90 days prior to employees’ probationary periods ending. The Program Manager, Personnel Security and Investigations, will also work with the Mission Assurance and Security Services organization’s communications liaison to post periodic notices reminding business unit managers, contracting officials, and system administrators of their responsibilities prior to adding contractor employees to computer systems. Management’s complete response to the draft report is included as Appendix VIII.
Copies of this report are also being sent to
the IRS managers affected by the report recommendations. Please contact me at (202) 622-6510 if you
have questions or Margaret E. Begg, Assistant Inspector General for
Audit (Information Systems Programs) at (202) 622-8510.
Appendices
Appendix I – Detailed Objective, Scope, and
Methodology
Appendix II – Major Contributors to This
Report
Appendix III – Report Distribution List
Appendix IV – Internal Revenue Service
Employee Background Investigation Process
Appendix V – Contractor Employee Background
Investigation Process
Appendix VII – Types of Background
Investigations Identified in Contractor Employee Case Reviews
Appendix VIII – Management’s Response to
the Draft Report
Abbreviations
|
GSA |
General Services Administration |
|
HSPD-12 |
Homeland Security Presidential Directive-12 |
|
IRS |
Internal Revenue Service |
|
NAC |
National Agency Check |
|
NACI |
National Agency Check and Inquiry |
|
OPM |
Office of Personnel Management |
|
PS&I |
Personnel Security and Investigations |
Background investigations provide some assurance that IRS and contractor employees can be trusted with sensitive taxpayer information.
The Internal Revenue Service
(IRS) maintains sensitive financial information for more than 226 million
taxpayers. Because many IRS employees
and contractors must have access to sensitive taxpayer information to
administer the nation’s tax system, the IRS must be particularly cognizant of
hiring only those applicants with the highest integrity. The IRS uses several controls to deter and
detect abuse of sensitive information, but conducting background investigations
is the initial step in the process of ensuring the highest standards of
honesty, integrity, and security are met.
The background investigation process provides at least some assurance
that IRS and contractor employees can be trusted with sensitive taxpayer
information.
The IRS mandates that all applicants accepted for positions be prescreened prior to their entry into the IRS workplace. During prescreening, the IRS fingerprints the applicant, checks for compliance with Federal tax laws, and performs other checks that must be evaluated prior to allowing unescorted access into IRS facilities. If the prescreening results are favorable, and the applicant becomes an employee, the IRS initiates a more thorough background investigation. The background investigation process for employees involves several IRS functions, each with a different role for completing the investigation. Appendix IV outlines the current IRS employee background investigation process. The scope of an employee background investigation varies based on the risks associated with the employee’s position. Appendix VI outlines the different types of IRS employee background investigations for the various risk levels.
Contractor employees must also be prescreened prior to being provided access to IRS facilities and sensitive tax systems. If a contractor employee is expected to be working for more than 30 calendar days, several prescreening checks are required, including fingerprint results and Federal tax compliance. All of the prescreening must be evaluated prior to allowing a contractor employee entry into IRS facilities. If only positive information is found, the IRS provides the contractor employee access to the facilities and systems needed to complete the given task and initiates a more thorough background investigation. Each contractor employee is required to have a background investigation appropriate to the risks associated with the job that he or she will perform. Appendix V outlines the steps involved in the contractor employee background investigation process. Appendix VII outlines the different types of contractor employee background investigations for the various risk levels.
This review was performed at the office of Mission Assurance
and Security Services in the IRS National Headquarters and the
Applicants Were Appropriately Prescreened;
However, Employee Background Investigations Were Not Completed Timely
The IRS
appropriately prescreened applicants for IRS positions before granting them
access to its facilities and systems.
The prescreening test results included fingerprints and the applicants’
compliance with Federal tax laws along with other requirements. Our review of a judgmental sample of 54 IRS
employees determined these steps were taken for all 54 (100 percent) of the
employees. This control is an important
step to reduce the IRS’ risk of providing access to sensitive data to
unsuitable persons. Also, all 54 of the
IRS employees had received the appropriate type of background investigation for
the risk level of their positions.
Employee background investigations were
not completed timely
Because
IRS employees are given access to systems and facilities while their background
investigations are being conducted, it is essential that the investigations be
completed as quickly as possible. Prior
to our review, the IRS had established specific timeliness goals for completing
IRS employee background investigations based on the risk of the employee’s
position. For example, it required investigations for high-risk positions to be
completed within 105 calendar days and investigations for moderate-risk
positions to be completed within 180 calendar days from the employees’
enter-on-duty date. In March 2004, the
IRS stated these baselines were not feasible and subsequently revised its
managers’ performance plans to require that all IRS employee background
investigations be completed within 200 calendar days from the employees’
enter-on-duty date.
IRS
employee background investigations were untimely in 77 percent of the cases we
reviewed.
We reviewed 51 of
the 54[4] IRS employee background investigations
previously mentioned to determine whether the investigations were completed
timely. Due to limited resources, the
IRS sometimes contracts with the Office of Personnel Management (OPM) to
complete background investigations. In
our sample, 7 of the 51 background investigations were performed by the OPM;
the IRS performed the other 44 investigations.
Of the 44 background investigations completed
by the IRS, 34 (77 percent) were not completed within established IRS baselines
and 28 (64 percent) did not meet managers’ performance plan expectations. On average, the IRS took 278 calendar
days to complete investigations for high-risk positions and 249 calendar days
to complete investigations for moderate-risk positions.
In Fiscal Year 2005, the OPM averaged 562 calendar
days to complete 92 background investigations.
In our sample, the OPM conducted 7 background investigations, averaging 366
calendar days for 5 moderate-risk investigations and 305 calendar days for 2 low-risk
investigations. Of the 7 investigations,
3 (43 percent) took more than 1 year to complete.
The background investigation process involves
several IRS functions and various outside agencies. The lack of documentation in the case files
precluded us from identifying the causes of the delays. While the IRS recently put budget codes into
its management information system to track costs for background investigations,
it currently does not monitor and track case processing delays in completing
background investigations. Delays in
processing background investigations increase the risk that the IRS may be hiring
unsuitable employees who could compromise sensitive taxpayer information,
physically harm employees, and disrupt operations.
Recommendation
Recommendation
1: The Chief, Mission Assurance and
Security Services, should ensure the Automated Background Investigation System[5] is programmed to track the time
expended to process background investigations.
Alerts and reports to management should be developed to enable
management to determine when and where delays occur and ensure investigations
are completed within established baselines.
Analyses of this information will also help identify resource
requirements.
Management’s
Response: IRS management agreed with this
recommendation. The Automated
Background Investigation System tracks the amount of time it takes to process
an investigation and managers have the ability to use inventory reports to
track case actions and case delays. In
addition, an alert will be deployed that will warn Investigative Analysts 90
days prior to the ending of employees’ probationary periods.
The IRS granted contractor employees access to its computer
systems prior to receiving their prescreening results. Contractor
employees had the appropriate background investigations for the risk level of
their positions; however, background investigations were not completed
timely. Granting contractor employees
access to sensitive systems without prescreening and delays in processing
background investigations increase the IRS’ risk that unsuitable
contractor employees may gain access to
sensitive data.
Some contractor
employees were provided access to IRS systems before their prescreening tests
were completed
Before contractor employees are allowed access to computer systems, business unit managers must request the PS&I office to conduct fingerprint tests. If results are positive, the PS&I office forwards a letter to the business unit manager, through the Contracting Officer’s Technical Representative,[6] stating that the contractor employee has qualified for access. The business unit manager is required to attach this letter to the system access request form and forward the documents to the appropriate system administrator before a contractor employee is granted access to an IRS system.
We selected a judgmental sample of 48 contractor employees to determine if they had been given access to computer systems prior to completion of their prescreening tests. The IRS provided the dates on which the contractor employees had been granted access to systems for only 11 (23 percent) of the 48 contractor employees in our sample. Business unit managers gave 5 (45 percent) of these 11 contractor employees access to IRS computer systems before they had received the prescreening test results from the PS&I office.
IRS business unit managers did not ensure contractors had been prescreened prior to requesting that they be given access to IRS systems. In addition, system administrators may have added contractors to the systems without receipt of proper documentation verifying that all prescreening tests had been completed. We were unable to determine if the other 37 contractor employees in our sample had been given access to sensitive systems prior to completion of their prescreening tests because the IRS could not provide the documentation.
Contractor
employee background investigations were not completed timely
Because
contractor employees are given access to systems and facilities while their
background investigations are being conducted, the investigations must be
completed as quickly as possible. The
IRS’ baselines for completing contractor employee background investigations
require that investigations for
high-risk positions be completed within 105 calendar days, investigations for
moderate-risk positions within 75 calendar days, and investigations for
low-risk positions within 30 calendar days from the contractor employees’
enter-on-duty date. As with IRS employee
background investigations, the IRS stated the original baselines were not
feasible and revised its managers’ performance plans to require a baseline of
200 calendar days for completion for all contractor employee background
investigations from the enter-on-duty date.
We selected and
reviewed another judgmental sample of 50 IRS contractor employee background
investigations. On average, the IRS took
183 calendar days to complete investigations for high-risk positions, 106
calendar days to complete investigations for moderate-risk positions, and 53
calendar days to complete investigations for low-risk positions. In our sample, 36 (72 percent) of the 50
investigations were not completed within established IRS baselines. However, only 6 (12 percent) exceeded the
managers’ performance plan expectations.
We could not determine the cause of the delays in contractor employee background investigations because actions taken were not sufficiently documented in the case files. As with IRS employees, the IRS is currently defining budget codes to track the time and cost of the background investigation process to enable it to monitor and compute the costs associated with contractor employee investigations. Enabling the Automated Background Investigation System to track the time it takes to complete individual processes for background investigations will help the PS&I office determine where delays occur. Processing delays increase the risk that the IRS is hiring unsuitable contractor employees who could gain access to sensitive tax systems or taxpayer information.
Recommendation
Recommendation 2: The Chief, Mission Assurance and Security Services, should periodically remind business unit managers, Contracting Officer’s Technical Representatives, and system administrators to review documentation verifying that contractors have been prescreened before they are given access to computer systems.
Management’s Response:
IRS management agreed
with this recommendation. The Program
Manager, PS&I office, will coordinate with the Mission Assurance and
Security Services organization’s communications liaison to post periodic
notices to remind business unit managers, Contracting Officer’s Technical Representatives,
and system administrators of their responsibilities in ensuring investigations
have been conducted on contractors prior to their being granted access to
computer systems.
Homeland Security Presidential Directive-12 (HSPD-12)[8] guidelines require the IRS to conduct a background investigation on all IRS employees and contractor employees who need access to its facilities and systems for more than 6 months. In addition, short-term contractor employees (less than 6 months) need a fingerprint check and a Federal Bureau of Investigation criminal check; however, a full background investigation is not required. We determined that the background investigation requirements for lockbox employees and cleaning contractor employees were insufficient to protect taxpayer remittances and safeguard IRS employees and facilities.
Background
investigations for lockbox employees were insufficient
The Department of the Treasury Financial Management Service enters into agreements with qualified financial institutions to perform lockbox collection services on behalf of the IRS. The financial institutions employ lockbox employees at 8 locations to process more than $360 billion in taxpayer remittances annually. In 2005, 54 remittances totaling approximately $2.8 million were stolen from 1 of the sites. Foreign nationals[9] were responsible for the majority of the theft. In addition to the lost revenue, thefts cause undue burden for the taxpaying public. For example, a stolen remittance will generate a balance-due notice to the taxpayer, requiring the taxpayer to provide evidence and proof that the payment was timely made.
Under these
agreements, the IRS sets guidelines for hiring and security at the lockbox
sites. The only type of screening
required for temporary lockbox employees is an annual fingerprint check from
the Federal Bureau of Investigation.
This type of check is insufficient for foreign nationals living in the
Background
investigations on lockbox employees were insufficient. Many of these employees are from foreign
countries, and the annual fingerprint check is not adequate.
An August 5, 2005, memorandum issued by the Office of
Management and Budget[10] to all Federal Government agencies provided guidance on
implementing HSPD-12 and acknowledged that foreign national employees and
contractor employees may not have lived in the United States long enough for a
limited background investigation to be meaningful. The Office of Management and Budget is in the
process of establishing an interagency working group to explore whether
guidance is necessary with respect to background investigations on foreign
national employees and contractor employees. One recommendation under consideration is to
give the OPM access to State Department databases to determine foreign criminal
activity of the applicant.
The Financial
Management Service is currently negotiating its lockbox agreements with banks
for 2007. During peak processing
periods, the work performed at lockbox sites is typically accomplished
using temporary staff. The IRS is currently working with the Financial Management Service to revise
the requirements for hiring temporary lockbox employees. At a minimum, temporary lockbox employees
shall be legal permanent residents who have resided in the
Background investigations for cleaning
service employees were not conducted
Hiring cleaning
contractor employees without performing background investigations increases the
risk that unsuitable individuals can gain access to IRS facilities where
taxpayer information is vulnerable.
Unsuitable cleaning contractor employees could harm IRS employees, steal
taxpayer identities and Federal Government assets, and obtain unauthorized
sensitive tax information.
The General Services
Administration (GSA) manages Federal Government buildings and is responsible
for contracting for cleaning services.
The GSA is also responsible for contracting for cleaning services when
the IRS leases space from third parties.
We requested 20 GSA cleaning contracts for IRS space to determine if
background investigations were required on the cleaning contractor employees
entering IRS facilities. We received 19
of the 20 contracts from the GSA (1 of the contracts had expired). Five of the IRS facilities were Federal
Government buildings controlled by the GSA; the other 14 were leased buildings
controlled by the lessor. Of the 19
contracts we reviewed, 8 (42 percent) did not require background investigations
on cleaning contractor employees.
Although the other 11 (58 percent) contracts had specific language
requiring background investigations, we were unable to confirm that background
investigations had been conducted for cleaning contractor employees because the
GSA was not willing to provide their names due to privacy concerns.
Cleaning
contractor employees were using stolen Social Security Numbers, and their true
identities are unknown.
In another review
conducted by the Treasury Inspector General for Tax Administration Office of
Investigations, all facilities in the state of
The IRS did not
ensure the GSA included specific language in contracts to require background
investigations for the cleaning contractor employees. The GSA is aware of the new requirements of
HSPD-12 and stated it will have background investigations completed for all new
and current janitorial employees by the required HSPD-12 implementation
deadline of October 27, 2007. The IRS
and the GSA are in the process of initiating, identifying, and requesting that
these background investigations be completed.
Because actions are underway to improve background investigations of temporary bank employees and cleaning contractor employees, we are making no additional recommendations.
Appendix I
Detailed Objective,
Scope, and Methodology
The overall objective of this review was to determine whether the IRS’ current background investigation process ensures investigations are completed timely and effectively and assures management that IRS and contractor employees are suitable for employment. To accomplish this objective, we:
I. Reviewed current Department of the Treasury and IRS policies and procedures for processing and conducting background investigations on IRS and contractor employees and obtained the criteria PS&I office employees follow to process and conduct background investigations.
II. Determined whether background investigations for IRS employees, IRS contractor employees, GSA cleaning contractor employees, and bank lockbox[11] employees were completed timely.
A. Determined whether background investigations for IRS employees and IRS contractor employees were completed timely.
1. Obtained a download of Fiscal Years 2004 and 2005 Security Entry and Tracking System[12] data with a population of 22,559 IRS employees and 6,844 contractor employees and the Automated Background Investigation System[13] data with 13,552 IRS employees and 8,285 contractor employees to determine the populations of IRS employees and contractor employees that were required to have background investigations. We determined the Automated Background Investigation System had multiple records for some of the people while the Security Entry and Tracking System data only had one record for each person. This was due to the Automated Background Investigation System recording multiple investigations on the same person where the Security Entry and Tracking System only records a person only once. Further validations of these downloads were unwarranted because we only used the information to select our samples of employees and contractors.
2. From the download, selected judgmental samples of 54 IRS employees and 50 contractor employees and reviewed Security Entry and Tracking System data, Personnel Office data, and case files to determine whether IRS and contractor employees’ fingerprints were processed timely. Judgmental samples were used because we were not projecting the results.
3. Reviewed database information and case files to determine whether the entry-on-duty dates for the IRS and contractor employees in the samples were within the past 1 year to 2 years and the investigations were completed within a 1-year time period from the enter-on-duty date.
B. Determined whether background investigations for GSA cleaning contractor employees working within IRS facilities were completed timely.
1. Reviewed IRS contracts with the GSA to determine whether the contracts require the GSA to conduct a background investigation or fingerprint test prior to hiring a cleaning contractor employee.
2. Selected a judgmental sample of 20 IRS facilities from a population of 750 with the highest risk of not having background investigations completed on cleaning contractor employees. A judgmental sample was used because we were not projecting the results.
C. Determined whether background investigations for bank lockbox employees were completed timely.
1. Contacted the Financial Management Service and obtained one IRS lockbox contract out of eight to determine whether background investigations were required. The lockbox contracts all contained the same wording (i.e., adopting the same lockbox regulations).
2. Selected a judgmental sample of 63 of 2,189 bank lockbox employees from the Automated Background Investigation System. A judgmental sample was used because we were not projecting the results.
III. Determined whether background investigations for IRS employees, IRS contractor employees, GSA cleaning contractor employees, and bank lockbox employees were effective.
A. Determined whether background investigations for IRS employees and IRS contractor employees were effective.
1. Reviewed case files for the samples in Step II.A.2. to determine the average length of time spent on the background investigation process before the IRS employees or contractor employees were approved or terminated.
2. Reviewed system access forms to determine the dates on which the IRS employees or contractor employees were given access to IRS systems before completion of their background investigations.
B. Determined whether background investigations for GSA cleaning contractor employees working within IRS facilities were effective. We contacted the GSA to obtain contractor and cleaning crew names, Social Security Numbers, addresses, and any other information to determine the number of employees and their identities. We were unable to determine whether a prudent decision was made in hiring the employees to clean IRS facilities because the GSA was reluctant to give us the information regarding cleaning contractor employees selected.
C. Determined whether background investigations for bank lockbox employees were effective.
Appendix II
Major Contributors
to This Report
Margaret
E. Begg, Assistant Inspector General for Audit (Information Systems Programs)
Stephen
Mullins, Director
Thomas
Polsfoot, Audit Manager
Cari
Fogle, Lead Auditor
George
Franklin, Senior Auditor
Bret
Hunter, Senior Auditor
Jimmie
Johnson, Senior Auditor
Appendix III
Commissioner C
Office of the Commissioner – Attn: Chief of Staff C
Deputy
Commissioner for Operations Support OS
Commissioner, Wage and Investment Division SE:W
Chief, Agency-Wide Shared Services OS:A
Chief Human Capital Officer OS:HC
Director,
Real Estate and Facilities Management
OS:A:RE
Chief Counsel CC
National Taxpayer Advocate TA
Director,
Office of Legislative Affairs CL:LA
Director, Office of
Program Evaluation and Risk Analysis
RAS:O
Office of Internal
Control OS:CFO:CPIC:IC
Audit Liaisons
Chief, Agency-Wide Shared Services OS:A:F
Chief Human Capital Officer OS:HC
Chief,
Appendix IV
Internal Revenue Service Employee Background Investigation Process
The chart was removed due to its size. To see the chart, please go to the Adobe PDF
version of the report on the TIGTA Public Web Page.
Appendix V
Contractor Employee Background Investigation Process
The chart was removed due to its size. To see the chart, please go to the Adobe PDF
version of the report on the TIGTA Public Web Page.
Appendix VI
Types of Background Investigations Identified in Internal Revenue
Service Employee Case Reviews
Figure 1: Suitability
Background Investigations for Public Trust Positions
|
Risk Level |
Type of Background Investigation |
Investigation Description |
Example of Position |
Job Duties |
|
High |
Background Investigation |
The National Background
Investigations Center and/or OPM conducts NACs[14] and initiates a personal subject
interview, written inquiries, and/or personal contacts to educational
institutions, employers, personal references, credit reporting agencies, and
law enforcement agencies in regard to the applicant or employee. The depth of coverage goes back 5 years. |
Special Agent |
Investigates potential criminal
violations and related financial crimes of the Internal Revenue Code. |
|
Moderate |
Limited Background Investigation |
The National Background
Investigations Center and/or OPM conducts NACs and initiates a personal
subject interview, written inquiries, and/or personal contacts to educational
institutions, employers, personal references, credit reporting agencies, and
law enforcement agencies in regard to the applicant or employee. The depth of coverage goes back 3 years. |
Revenue Agent |
Meets with taxpayers and collects
delinquent taxes from them. |
|
Low |
NACI[15] |
The OPM conducts checks of national
agencies and initiates written inquiries to educational institutions,
employers, personal references, and law enforcement agencies about the
applicant or employee. The results are
sent to the |
Mail Clerk |
Extracts and sorts mail received at
the IRS locations. |
Source: The
NACIs are performed by the OPM. The high- and moderate-risk investigations
are performed by the
Appendix VII
Types of Background
Investigations Identified in Contactor Employee Case Reviews
Figure 1: IRS Contractor Employee Background
Investigations
|
Risk Level |
Type of Background Investigation |
Investigation Description |
Example of Position |
Job Duties |
|
High |
Background Investigation |
The National Background
Investigations Center and/or OPM conducts NACs and initiates a personal
subject interview, written inquiries, and/or personal contacts to educational
institutions, employers, personal references, credit reporting agencies, and
law enforcement agencies in regard to the applicant or employee. The depth of coverage goes back 5 years. |
System Administrator |
Responsible for the daily
operations and users of a particular computer system. |
|
Moderate |
NAC with Law and Credit[16] |
This type of investigation serves
as the complete background investigation for IRS contractor employees in moderate-risk
positions. The scope of the
investigation is 5 years.
Investigative information may be obtained by personal, written, and/or
telephone inquiry. Unfavorable
information requires follow-up by personal contact. |
Systems Engineer |
Usually responsible for building
part of an IRS computer system. |
|
Low |
Basic |
This type of investigation serves
as the complete background investigation for contractor employees in low-risk
positions and as the basis for interim access approval for the contractor
employees in moderate- and high-risk positions awaiting completion of a NAC
With Law and Credit or background investigation. |
Custodial Employee |
Responsible for cleaning IRS work
areas. |
Source: The IRS PS&I Office.
On October 27, 2005, HSPD-12 required Federal Government agencies to be compliant with new security standards for background investigations. The IRS is currently compliant with HSPD-12 and has upgraded its investigations for these risk levels as follows:
· Low-risk positions require a NACI.
· Moderate-risk positions require a NACI and a credit check.
NACIs and NACIs with credit checks are traditionally contracted to the OPM. The background investigations may be conducted by the IRS or contracted to the OPM.
Appendix VIII
Management’s Response to the Draft Report
The response was
removed due to its size. To see the
response, please go to the Adobe PDF version of the report on the TIGTA Public
Web Page.
[1] The IRS lockbox program consists of commercial banks that have contracted with the Financial Management Service to process tax payments. This program was designed to accelerate the deposit of tax payments by having taxpayers send their payments to commercial banks rather than to the IRS.
[2] Any
person who is not a citizen or a permanent resident alien of the
[3] The Automated Background Investigation System is used by the IRS to track and monitor background investigations while they are being conducted. Employees manually update the system.
[4] Three of the 54 cases were excluded because the employees had resigned and their investigations were not completed.
[5] The Automated Background Investigation System is used by the IRS to track and monitor background investigations while they are being conducted. Employees manually update the system.
[6] Contracting Officer’s Technical Representatives are responsible for the contract award and administration process; they must ensure all terms and conditions of the contracts they manage are met and taxpayer dollars are prudently spent.
[7] The IRS lockbox program consists of commercial banks that have contracted with the Financial Management Service to process tax payments. This program was designed to accelerate the deposit of tax payments by having taxpayers send their payments to commercial banks rather than to the IRS.
[8] HSPD-12 (dated October 27, 2005) requires agency implementation of secure and reliable Federal Governmentwide forms of identification of employees and contractors; it also mandates when background investigations should be completed on new and current employees.
[9] Any
person who is not a citizen or a permanent resident alien of the
[10] The
Office of Management and Budget is a division of the Executive Office of the
President of the
[11] The IRS lockbox program consists of commercial banks that have contracted with the Financial Management Service to process tax payments. This program was designed to accelerate the deposit of tax payments by having taxpayers send their payments to commercial banks rather than to the IRS.
[12] The
Security Entry and Tracking System is a Department of the Treasury subsystem of
the
[13] The Automated Background Investigation System is used by the IRS to track and monitor background investigations while they are being conducted. Employees manually update the system.
[14] NACs are investigations where the subject’s name is compared against multiple databases to determine if any derogatory information exists from their history.
[15] NACIs are investigations performed by the OPM. They consist of two parts: NACs and inquiries/interviews (I) with various references the subject provided that are conducted by an investigator.
[16] NAC with Law and Credit is for moderate risk investigations for contractor employees. The NAC is where the applicant is checked against databases for derogatory information. The Law and Credit portion is where the applicant’s law enforcement records are checked in the areas where he or she lived for the last 5 years and a credit check is made to ensure the applicant does not have bad credit.