TAP 04-022

Forms Testing

Statement of Issue:

There has been very little focus group testing of IRS individual income tax forms or instructions during the last seven years.

Proposal:

The Area 5 Committee recommended that the number of forms and instructions that are tested with focus groups be increased to a greater extent than is currently being planned.

The Committee endorses all the recommendations made by the GAO and urges their implementation by the IRS. These recommendations and the Committee’s comments are:

• Develop written criteria for determining which changes to tax forms and instructions should be tested with taxpayers before publication.
  
  Criteria should include the potential for error and the number of taxpayers affected. Data regarding potential for error could be gleaned from the “top 20” list of errors, statistics from call-in centers, the audit process, and surveys of tax preparers.

• Develop official written guidance that incorporates those criteria and ensure that the guidance requires staff that develop new or revised forms and instructions to document which changes would merit testing and why.
  
  This is a logical extension of the previous recommendation. Acting Commissioner Bob Wenzel stated that these first two recommendations would be implemented in 2004.
  
• Clarify procedures by designating when in the annual forms development process that a draft version of forms and instructions should be available for testing with taxpayers.
  
  It should be possible to have testing done before the document is submitted to legal staff and well ahead of a last minute time crunch. Written procedures should be in place to ensure this.

• Ensure that an appropriate range of evaluations are conducted of tests that are performed to better establish the costs and benefits of performing tests and to refine IRS’s approach to testing.
  
  In the years 1997-2002 only five forms and instructions were tested. A larger sample needs to be tested and evaluated to determine the costs and benefits of testing.

• Use information gained from documenting when changes to forms or instructions likely would be beneficial and from evaluations of tests to reassess an appropriate level of resources to perform testing.
  
  The benefits are hard to quantify and occur over the long run. The IRS should seek more resources on the basis of the long run benefits.

Response Notes:

After this recommendation was approved by the Joint Committee, Area 5 was advised that a comprehensive set of criteria for “Selecting New/Revised/Redesigned TAS Forms and Instructions for Forms Testing” had been developed. Proposal was sent forward and acknowledged.