National Taxpayer Advocate Erin Collins issued a mea culpa admitting to the findings of a recent report faulting the Taxpayer Advocate Service that she runs for slow responsiveness to taxpayers.
In a blog post Thursday, Collins initially seemed to blame the local offices for problems with answering the phones, but then acknowledged wider problems with TAS at the national level. The local phone lines were the subject of a report by the Treasury Inspector General for Tax Administration that found local TAS phone lines were not consistent in giving taxpayers the ability to speak with a TAS representative. TIGTA called all 76 local TAS telephone lines in the United States, including offices in the District of Columbia and Puerto Rico, using the telephone numbers listed on the TAS and IRS websites. The calls found some telephone lines were not in service, voicemail boxes were full, and inconsistent recorded scripted messaging and callback time frames. Only two telephone lines were answered by a TAS representative. Voicemail prompts indicated that callbacks would be received within time frames ranging from one business day to four weeks.
Collins wrote that the problem with the local phone lines was limited in scope because most calls are placed to TAS’s national toll-free number, and TAS immediately took corrective actions to address TIGTA’s findings.
National Taxpayer Advocate Erin Collins speaking at the AICPA & CIMA National Tax and Sophisticated Tax Conference in Washington, D.C.
But she acknowledged a larger issue in the findings. “Although TAS ultimately serves most taxpayers well, we are not starting to work cases and we are not returning telephone calls as quickly as we would like<‘ Collins wrote. “Part of my job is to highlight areas where the IRS is not meeting expectations, so it’s only fair that I be transparent in acknowledging where TAS is falling short.”
She added that TAS is taking actions to improve its level of service to taxpayers, including new technology, as well as hiring and training more personnel. TAS’s workload has grown in recent years and Collins said she hears about the problems when she speaks to practitioners. However, she insisted that TAS resolves the majority of taxpayer problems satisfactorily and she pointed to surveys of thousands of customers, 81% of whom reported they were satisfied overall, compared to 15% who aren’t satisfied.
But she has been receiving negative feedback, at least from tax professionals.
“Having said that, I regularly speak to groups of practitioners and hear more complaints than I would like of unreturned phone calls, delays in providing updates, and delays in resolving cases,” Collins wrote. “In a nutshell, TAS faces three core challenges in case advocacy:
We are receiving more cases;
We have recently hired a considerable number of new case advocates who require training before they can effectively assist taxpayers; and
We are using a functionally limited case management system that is more than two decades old and causes inefficiencies and delays.”
In terms of caseload, she pointed out that TAS has received about 18 percent more cases in fiscal year 2024 than the previous two fiscal years, when it received around 220,000 cases, and TAS case advocates are carrying active inventories of over 100 cases at a time.
In response, TAS has been hiring more new case advocates and improving its case management system, leveraging additional funding from Congress. However, Collins pointed out that it takes months, even years, to train these new hires as they will work on cases involving a wide array of procedural and technical issues, including tax return processing, identity theft, audits, collection matters and appeals.
Approximately 30% of TAS’s case advocates have less than a year of experience, and around 50% have less than two years of experience.
“That means nearly one-third of our case advocate workforce is still receiving training and working limited caseloads or have no caseloads yet, and half are likely to require extra support for complex cases,” Collins wrote. “TAS has never had a year when so many case advocates were new. To compound the challenges, we have to temporarily reassign experienced case advocates to provide training and supervision for the new hires, further straining our resources to work current cases.”
In response, TAS is looking at improving its training processes, for example, by training new hires on the highest volume issues first, so they can start working on those cases faster, while continuing to receive comprehensive training so they can become effective all-around advocates over time.
Like much of the IRS, TAS is also relying on outdated technology, which is finally being upgraded thanks to recent funding boosts. The current case management system, known as the Taxpayer Advocate Management Information System, or TAMIS, is over 20 years old and lacks the kinds of features common in more modern case management systems. That means TAS case advocates need to spend extra time doing work that could be partially or fully automated.
In response, TAS is developing a new customer relationship management system, called “Phoenix,” that it plans to deploy next year. In designing and building the system, TAS is getting feedback from case advocates who use TAMIS to help identify areas where the technology can automate tasks and otherwise improve efficiencies. “The improvements in efficiency will be significant because we will be better able to understand, see and prioritize work across our workforce from both an employee and a management perspective,” said Collins.
The new system will have the flexibility for continuous improvement. Like the IRS’s Where’s My Refund? app or online account, one long-term goal is to allow taxpayers, tax pros and congressional staff to communicate with TAS and receive case updates through a What’s the Status of my TAS Case? portal or online account.
“We know our taxpayers want more secure digital communication options and faster service,” Collins wrote. “We envision providing more real-time information and updates using system capabilities, while also allowing our case advocates to spend more of their time on case resolution. The data security concerns of allowing direct access to a portal are significant, so this functionality is probably several years away. But we are actively planning toward that goal to improve the taxpayer experience while we advocate on their behalf.”
I recently took my family and some clients to the Cayman Islands for a spring break vacation. The five-star resort where we stayed was very nice, as expected. But several of us came away feeling a little underwhelmed. Everyone had a good time and nothing went wrong. In fact, if we hadn’t known it was a five-star resort, we would have said, “Great service and great experience” in our reviews. But because it was a five-star resort, we were expecting exceptional service, and from that perspective, the resort fell short.
If we’d stayed at a three-star hotel, we probably would’ve praised it as exceptional. But at five-star prices, you don’t just expect “good” — you expect extraordinary. You expect the staff to greet you by name (with a smile). You expect thoughtful gestures for your kids. You expect the staff to anticipate your needs without being asked. At the five-star level, details aren’t just nice touches; they’re essential.
I bring this up because in these inflationary times, everyone’s talking about raising prices. Accounting firms are no different. I’m not against raising prices, but I don’t care how high the inflation rate is. If you raise prices without delivering more tangible to the client, your value goes down in the client’s mind. If you want to charge three-star prices and deliver a three-star experience to clients, that’s OK. But, if you want to start charging five-star prices, your client’s expectations will adjust accordingly.
The good news is, it’s not that hard to deliver more value for clients in terms of providing better communication, more proactive response time and better tools for clients, etc. But you must make sure clients are well aware of what you will be doing differently to deliver more proactive communication and advice, faster response time and better tools for them to use. If you don’t, clients will just see a higher invoice than last year for the same level of service. Expectations will go up and satisfaction will go down.
Just like hotels and restaurants, when you move up the price ladder, you move up the expectations ladder. Your level of professionalism must go up. Your client response time must be faster. You must increase the level of proactive advice given to clients. When you’re thinking about what kind of firm you want to be — i.e., a firm serving fewer clients at higher prices — you can’t just deliver a tax return without any advice, feedback or recommendations like you did before. The tax return itself is a commodity. Most of the fee you add on top of it is service. More on that in a minute.
If you want to increase prices and serve fewer clients, think carefully about what you’re going to do for them in order to be their most trusted advisor. All the levers you have at your disposal — tools, resources, proactive advice, response time, etc. — will have to move when prices move.
Think about the last time you researched a vacation. When you Googled hotels, did you notice the little box where you could filter for three-star resorts, four-star resorts, five-star resorts, etc.? The expectations you had for each type of resort was different based on the price point. Clients make the same mental calculation based on your pricing when deciding whether to stay with you or move up or down market for an alternative accounting firm. Again, you must align your prices with the expectations that come with those prices.
As accounting firms, we are essentially luxury service providers. Most of our clients are very intelligent, and if they had to, they could probably figure out how to do their own taxes. The luxury we provide them is saving them the headache of filling in endless rows and boxes, providing expert counsel on how to save money or buy more time, and most importantly, dealing directly with the IRS so they don’t have to.
Again, you must align your prices with the expectations that come with those prices.
When my firm recently raised its fees, we told clients very clearly: “Here is our updated pricing model. We want to be more meaningful to you. We want to focus on the clients we work best with. This is your new, updated fee structure, and here are the additional things you will be getting from us.” A few clients pushed back, but most did not.
Price is an automatic market positioner. If you want to charge $350 for a tax return, you are positioning yourself as a low-cost provider. Clients are not expecting much, and you don’t have to provide much in the way of service or advice. But if you want to move up market and charge $2,000 for a simple return, people aren’t really paying you $2,000 for the return itself. They’re paying for access to a high-end professional who knows their situation intimately. No more than $400 of that $2,000 fee is for the tax return itself. Everything else is for the implied service you provide.
In a highly competitive market like professional services, you can’t charge Ritz prices for Holiday Inn service. Don’t get me wrong. There’s nothing wrong with Holiday Inns. They’re a great brand and a well-run operation just like Ritz. Both types of hotels are very intentional about what they charge and what you can expect when you stay there. They build well-honed systems and processes around what they can afford to deliver at their relative price points. No one’s mad when they book a Holiday Inn. No one’s mad when they book a Ritz. The friction only comes when their relative expectations aren’t met.
What is your firm doing to deliver more value to clients? I’d love to hear more.