The Security and Performance of Electronic Tax
Return Processing Should Be Improved to Meet Future Goals
June 2000
Reference Number: 2000-20-095
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.
June 14, 2000
MEMORANDUM FOR COMMISSIONER ROSSOTTI
FROM: Pamela
J. Gardiner /s/ Pamela J. Gardiner
Deputy Inspector General for
Audit
SUBJECT: Final
Audit Report - The Security and Performance of Electronic Tax Return Processing
Should Be Improved to Meet Future Goals
This report
presents the results of our review of the receipt and
processing of electronic tax returns for the 2000 Filing Season, which was
consolidated at two locations. In
addition, we evaluated the Internal Revenue Service’s (IRS) corrective actions
on selected issues that were included in a previous audit report.
In summary, we
found that the Electronic Management System (EMS) had
sufficient communications and processing capacity to receive and store expected
tax return volumes during the 2000 Filing Season. However, the Chief Information Officer (CIO) should
implement performance and capacity
management planning to determine the processing efficiency and future capacity needed
to achieve the IRS’ goal of receiving 80 percent of tax returns electronically
by 2007. In addition, the CIO
needs to implement adequate
We
issued a draft of this report to IRS management on May 1, 2000, with a May 31,
2000, response period. However,
management’s response was not available as of the date this report was
released.
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 your staff
may call Scott E. Wilson, Associate Inspector General for Audit (Information
Systems Programs), at (202) 622-8510.
Electronic Management System Processing Should Be Evaluated
and Changes Planned
Security Administration Procedures for Electronic Tax Information
Can Be Improved
Electronic Management System Project Management Controls Can
Be Improved
Appendix I – Detailed Objective, Scope, and Methodology
Appendix II – Major Contributors to This Report
Appendix III – Report Distribution
List
The Electronic Management System
(EMS) is the Internal Revenue Service’s (IRS) primary system for receiving
electronic tax returns from trading partners.[1] Through April 17,
2000, the
The overall objective of this
review was to evaluate the
During 1999, the IRS assigned a
new Project Manager to the EMSPO, acquired
hardware and telecommunication links, and revised
Electronic Management System Processing Should Be Evaluated
and Changes Planned
The IRS’ Modernization Blueprint is currently being revised, but how and
when the current
The EMSPO did
not have a performance and capacity management plan to determine whether the
existing
In addition,
the
Most electronic tax returns are
transmitted over public telephone and data communication lines between trading
partners and the IRS, but the IRS has
not implemented encryption procedures for these transmissions. Improved security
for electronic tax return transmissions would help protect over 41 million tax
returns from being read or altered by unauthorized users.
Security Administration Procedures for Electronic Tax
Information Can Be Improved
An EMS security risk assessment report and our audit results showed that the
The EMSPO
did not effectively use project management techniques to ensure timely and
effective testing of all system components, and there is no evidence that
problems which could have affected the filing season were raised to the IRS
Filing Season Readiness Executive Steering Committee.[5]
For example, high capacity telecommunication lines needed for the 2000
Filing Season were not installed timely, but this matter was not raised to the IRS Filing Season Readiness Executive Steering Committee. In
addition, the EMSPO had assigned a contractor the task of maintaining project
planning documentation. However, the
EMSPO did not have copies of this documentation, which would have assisted its
oversight of the project.
The Electronic
Management System Disaster Recovery Plan Should Be Completed and a Recovery
Exercise Conducted
The
The Chief Information Officer (CIO) should implement
performance and capacity management planning and evaluate processing efficiency
to determine future
Management’s
Response: We
issued a draft of this report to IRS management on May 1, 2000, with a May 31,
2000, response period. However,
management’s response was not available as of the date this report was
released.
The overall objective of this review was to evaluate the
The overall objective of this
review was to evaluate the Electronic Management System’s (
Audit work was performed between
December 1999 and January 2000 at the IRS National Office in New Carrollton,
Maryland and the Tennessee Computing Center (TCC)
[6] in
Details of our audit objective,
scope, and methodology are presented in Appendix I. Major contributors to this report are listed
in Appendix II.
The
Through April 17, 2000, the
Through April 17, 2000, the
The IRS
Restructuring and Reform Act of 1998 (RRA 98), Pub. L. No. 105-206, 112 Stat
685, requires the IRS to receive 80 percent of all tax returns and information
electronically by 2007. The IRS’
Electronic Tax Administration (ETA) strategic plan, A Strategy for Growth, proposes to improve electronic tax
processing by consolidating processing operations at fewer sites.
In November 1999, the IRS reduced the number of locations
that receive electronic tax returns from five service centers to the AUSC and
TCC
Until November 1999, trading
partners electronically transmitted tax returns to five IRS service centers.[8] Since then, the
In March 1999, the IRS initiated
efforts to consolidate the receipt of all electronic tax returns on the
·
Acquired
and installed additional hardware and telecommunication lines.
·
Revised
the existing
·
Revised
the EMS Help Desk computer process and procedures previously used only at the
AUSC and expanded their use to all locations.
The
The consolidated
·
The performance
capabilities of the
·
Electronic tax return
and tax information transmissions are not encrypted and could result in
unauthorized disclosures.
·
Security
administration procedures that could prevent and detect unauthorized
·
Project management
controls did not timely identify and effectively correct performance problems
that could delay tax return processing and allow unauthorized access to the IRS
mainframe computers.
·
The
The follow-up review of the prior audit report
recommendations determined that the previously reported non-compliance with the
IRS’ remote access security policy was corrected in the current IRS security
procedures. The IRS’ corrective actions
on the previously reported security administration weaknesses included
improving the audit trails to record all required information about events,
establishing a control to ensure that the audit trail files did not exceed the
capacity of the tapes, and locking out users who had not accessed the
Early in the 2000 Filing Season, we discussed the issues we identified with representatives of the EMS
Project Office (EMSPO) so that corrective actions could begin.
Electronic
Management System Processing Should Be Evaluated and Changes Planned
The IRS’ Modernization Blueprint is currently being revised, but how and
when the current
The EMSPO has not initiated performance and capacity
testing to determine whether the
The IRS has
established a capacity planning and management function to assess the ability
of systems such as the
Locating the
In addition,
locating the
If performance
and capacity tests determine that the
The Chief Information Officer (CIO) should:
1.
Evaluate
the EMS’ performance capability to determine whether it can securely, reliably,
and timely process expected future volumes until the EMS completes transition
to the modernized computer environment and ensure that interim
Management’s Response: We issued a draft of this report to IRS
management on May 1, 2000, with a May 31, 2000, response period. However, management’s response was not
available as of the date this report was released.
Electronic Transmissions of Tax Returns and Related Tax Information
Can Be Better Protected From Unauthorized Disclosure
The IRS requires trading partners to ensure the security of all
transmitted data. However, it does not
require them to encrypt tax return and acknowledgment transmissions.
The ETA strategic plan, A Strategy for Growth, indicates that
the security of the IRS’ electronic systems and the confidentiality of taxpayer
information are among the most important responsibilities of the IRS. The IRS issued two Revenue Procedures and
other administrative documents to provide guidance to trading partners for
electronic filing. The instructions
state that trading partners must secure all
data transmitted to the IRS but do not
provide guidance on how to secure the tax return and acknowledgment
transmissions.
Based on opinions from the IRS Office of the Chief Counsel,
IRS management has taken the position that the IRS is not legally obligated to
protect tax returns until it receives them and, therefore, has not required
trading partners to encrypt tax returns being transmitted to the IRS. However, the IRS has mandated other
transmission standards that trading partners are required to follow. Since most
electronic tax returns are grouped and transmitted in batches over public
telephone and leased data communication lines, there is a risk that
unauthorized disclosure of tax information could occur during transmissions
between trading partners and the IRS.
Encryption is an accepted technique that would prevent sensitive
information from being read or altered by unauthorized users. The IRS uses encryption for internal
transmissions of tax information but has not implemented it for similar
transmissions between trading partners, the IRS, and state tax agencies.
To improve security over the 41 million electronic federal and state
tax returns that are transmitted to the IRS and to increase taxpayers’
confidence that their tax returns are adequately secured during transmission,
additional procedures, including encryption, should be developed and
implemented. These procedures would help
provide the same level of security over transmissions of returns from trading
partners to the IRS as is provided by the IRS in transmitting returns between
IRS locations.
The CIO
should:
2.
Develop and implement improved
security standards and procedures, such as encryption, for all electronic tax
return transmissions.
3.
Integrate
the improved procedures for the electronic transmission of tax returns from
trading partners into the future IRS modernization architecture.
Security
Administration Procedures for Electronic Tax Information Can Be Improved
An EMS security risk assessment and our audit results show that the
The
IRS has established security administration procedures for computer systems
that contain tax-related information.
These procedures are designed to
prevent and detect unauthorized accesses and disclosures. They include:
1) authorized personnel who remotely access IRS systems must use
appropriate user authentication and encrypt all transmitted information, 2)
access to authentication devices and encryption programs must be controlled, 3)
security administration duties must be separated from computer programming and
operations duties, and 4) audit trail reports and logs must be reviewed and
questionable actions reported to management.
Our audit results showed that the
Remote access
authentication and encryption procedures (smartcards) were not properly
implemented.
·
Selected contractor
employees access the
¨
The EMS security
settings did not deny system administrator access to employees who did not use
a smartcard to access the
¨
The EMSPO had not
established a procedure to manage and control access to the smartcards. The smartcards must be accounted for because
they contain the
¨
Another contractor
maintained physical custody of the unissued smartcards and also maintained
The IRS did not
effectively implement the procedures that would detect unauthorized accesses so
that they can be investigated.
·
Security
administration procedures were established to collect and review system access
reports and audit trail information.
However, the IRS did not effectively implement the procedures that would
detect unauthorized accesses so that they could be investigated. Security administrators did not review the
As of January 2000, IRS management had not corrected the
weaknesses identified in the security risk assessment. Without strong security controls, there is an increased risk of
unauthorized accesses to the
The CIO
should:
4.
Ensure that the
5.
Ensure that EMS
security administrators appropriately restrict access to audit trail
information and review
Electronic Management System Project Management Controls
Can Be Improved
The IRS’
system development life cycle guidelines require that project planning
documents be prepared and updated to track the status of all planned
tasks. These documents serve as a basis
for ensuring that all required work is identified, planned for, and completed
before new computer systems are implemented.
These guidelines also require that all aspects of the system be tested
to determine whether the system is functioning as intended and that any
problems be corrected before the system is implemented. Problems that cannot be effectively dealt
with at the Project Office level should be elevated to senior IRS management,
including multi-functional groups such as the IRS
Filing Season Readiness Executive Steering Committee, to assure proper
resolution.
EMSPO project oversight did not ensure timely testing of all system
components.
The EMSPO properly prepared a project
plan and issued Statements of Work[10] to contractors to develop, document,
and test the computer hardware and programming changes needed for the 2000
Filing Season.
However, EMSPO project
oversight did not ensure timely testing of all system components. Also, there is no evidence that problems
which could have affected the filing season were raised to the IRS Filing
Season Readiness Executive Steering Committee.
Centralization of all electronic tax
return receipts at two locations during 1999 required the IRS
Telecommunications function to obtain high capacity telecommunication lines
between the AUSC EMS and the
The EMSPO did not have copies of all project planning documentation and
did not elevate problems that could have affected the 2000 Filing Season to the
Filing Season Readiness Executive Steering Committee.
These problems occurred, in part,
because EMSPO personnel had assigned one contractor the task of maintaining
overall project planning documentation, but the EMSPO did not have copies of
all of this documentation to assist its management oversight of the
project. In addition, each contractor
prepared periodic status reports for its tasks and held meetings with EMSPO
personnel, but the reports and meetings did
not identify the performance problems discussed above, determine their cause,
or initiate changes to effectively correct the problems. In addition, Information Systems management did not elevate the delayed telecommunication
link delivery and testing as a concern to the IRS Filing Season Readiness Executive
Steering Committee.
Closer monitoring of project
management documentation and tasks to assure all critical items are timely
completed and prompt involvement of upper level management in problem areas
would help prevent critical delays in the project development and testing
process.
The CIO should:
6.
Ensure that
7.
Assure that critical development or
testing delays (e.g., computer program or equipment installation) that could
affect tax processing are timely raised to the IRS Filing Season Readiness Executive Steering Committee
for resolution.
The Electronic Management System Disaster
Recovery Plan Should Be Completed and a Recovery Exercise Conducted
IRS personnel did not complete the
IRS information systems security
guidelines require disaster recovery plans to be developed, tested,
implemented, and maintained for major computer systems. The plans should be routinely reviewed,
tested, and updated to provide for reasonable continuity of information system
support and to reduce downtime.
Since 1997,
The full disaster recovery exercise
was not conducted because the EMSPO, contractor, AUSC, and TCC personnel needed
to conduct it were assigned to develop, test, and implement the
There is a significant risk that a disaster recovery effort could delay
tax return processing.
There is a significant risk that a
disaster recovery effort could delay tax return processing as the
The CIO should:
8.
Ensure
that the
The
Appendix I
Detailed
Objective, Scope, and Methodology
The overall objective of our
review was to evaluate the Electronic Management System’s (
I.
To determine whether
the EMS Project Office (EMSPO) management’s oversight activities ensured that
the consolidated EMS was effectively tested and critical problems identified by
the tests were resolved, we:
A.
Reviewed the
B.
Reviewed the
C.
Determined whether the
EMSPO management’s oversight of the completed tests included their
certification that the
II.
To determine whether
EMSPO management’s oversight activities ensured that disaster recovery plans
were developed and effectively tested and critical problems were resolved, we:
A.
Reviewed the
B.
Reviewed the EMSPO
communications and processing capacity assessments and determined whether the
C.
Reviewed the disaster
recovery test plans and results and determined whether the tests were conducted
in a simulated production environment and used the production systems and
whether any problems encountered during testing were effectively corrected.
III.
To determine whether
the EMSPO management’s oversight activities ensured that the necessary steps
were completed to certify the consolidated EMS’ compliance with IRS security
requirements and follow-up on the IRS’ corrective actions on previous audit
recommendations, we:
A.
Determined whether the
EMSPO completed the necessary security certification documentation required to
obtain Interim Authority to Operate and whether the documentation complied with
security certification guidelines.
B.
Reviewed the security
certification documentation prepared for the consolidated EMS and determined
whether the IRS’ corrective actions on previous audit recommendations brought
the
1.
The IRS’ and
Department of the Treasury’s security requirements for access to computer
systems containing sensitive information.
2.
The IRS’ Secure
Dial-In Policy for access to IRS computer systems from remote locations.
Appendix II
Scott E. Wilson, Associate Inspector General for Audit
(Information Systems Programs)
Gary Hinkle, Director
Danny Verneuille, Audit Manager
Nelva
Blassingame, Senior Auditor
Frank
Greene, Senior Auditor
Steven Gibson, Auditor
Olivia Jasper, Auditor
Chief Information Officer
IS
Chief Operations Officer
OP
Deputy Chief Information Officer, Operations IS
Deputy Chief Information Officer, Systems IS
Director,
Director, Systems Development IS:S
Assistant Commissioner (Electronic Tax Administration) OP:ETA
[1]
For purposes of this report, a “trading partner” is anyone who transmits
electronic tax returns to the IRS. This
includes tax return preparers and Online Service Providers who provide
taxpayers a subscription service to prepare and file their own electronic tax
returns.
[2] Service centers are the data input arm of the IRS. Service center personnel input paper tax returns and related tax information, correct errors on paper and electronic tax returns and documents, and forward the data to the computing centers for analysis and posting to taxpayer accounts.
[3] Computing centers house the mainframe tax processing computers that validate tax returns and post the information to taxpayer accounts.
[4] A “smartcard” is a small electronic device about the
size of a credit card that verifies the user’s identification (authentication)
and encrypts the user’s transmission.
[5] The Filing Season Readiness Executive Steering Committee consists of senior IRS management and is chartered to oversee preparations for future tax filing seasons.
[6] Computing centers house the IRS’ mainframe computers that validate tax returns and post the information to taxpayer accounts.
[7] For purposes of this report, a “trading partner” is anyone who transmits electronic tax returns to the IRS. This includes tax return preparers and Online Service Providers who provide taxpayers a subscription service to prepare and file their own electronic tax returns.
[8] Service centers are the data input arm of the IRS. Service center personnel input paper tax returns and related tax information, correct errors on paper and electronic tax returns and documents, and forward the data to the computing centers for analysis and posting to taxpayer accounts.
[9] A “smartcard” is a small electronic device about the
size of a credit card that verifies the user’s identification (authentication)
and encrypts the user’s transmission.
[10] A Statement of Work provides requirements and specifications to the contractor about a service or product that the IRS needs and establishes due dates for deliverables (documents or products) and milestones (critical actions).
[11] Until
the IRS’ mainframe computer consolidation project is completed in 2000,
mainframe processing of electronic tax returns will also be conducted at the
[12] An Interim Authority to Operate is a memorandum signed by senior IRS managers that permits a system to process tax information while security testing and the certification process are ongoing.