1.  Volunteer certification

2.  Intake and interview process

3.  Reference materials available

4.  Title VI information provided

5.  Privacy and confidentiality guidelines followed

6.  Quality Review process

7.  Returns timely filed/delivered

8.  Correct SIDN

9.  Correct EFIN

The training suggests that implementing these 9 Quality Site Requirements make a Site a Quality Site.  The rationale is that accurate taxpayer returns are more likely to be produced at a Quality Site.

It is the opinion of this author that while following these 9 QSRs may make a site a Quality Site, as a whole, the 9 together are neither necessary nor sufficient to ensure the creation of accurate returns, satisfied Clients, or contented volunteers.

Let us consider items 4, 5, 8, and 9.  How does the absence of Title VI information displayed on the site, or not following privacy and confidential guidelines, or incorrect SDIN or EFIN affect the accuracy of a return? Title VI information displayed is a compliance requirement to inform taxpayers of their rights, and if someone took the time to read and understand it seriously, will realize that VITA sites technically do not follow the guidelines in Title VI.  VITA sites are to help prepare taxes of low-income, elderly, limited English Speaking and disabled taxpayers.  This suggests that VITA sites discriminate in favor of elderly and disabled taxpayers, and since many limited English Speaking taxpayers have a national origin other than the US, there is discrimination in favor of those.   Not following the privacy and confidential guidelines may be against compliance requirements, but doing so may help the accuracy and correctness of the return in many situations.  An incorrect SIDN or no SIDN does not affect the accuracy or correctness of the return, refund or tax due amount, but simply does not track the quality and productivity of the site, which may be important to the Site Coordinator, volunteers and SPEC.   Likewise, if the EFIN is incorrect or there is no EFIN, the return will not e-file properly.  On a paper return, the EFIN is irrelevant anyway.

Consider requirement #3, Reference Materials available; nothing is said about if or how they are to be used.  At least two trainers in Tax Law classes have proudly stated that they do not remember the tax laws but look it up each time they are faced with any issue.  A Taxpayer went to a site where two such volunteers were very polite, but needed to look up each item in the references, and that inspired no confidence in the taxpayers at all.  The statement also brings into question the value of certification.  If all answers can be found in the reference material or Pub 17, why do we even need to worry about certification?  They can always be looked up.    However, the biggest problem is that given this requirement, the lack of reference materials available caused a major problem.  Orders for publication 4012, the volunteer resource guide made in October were not delivered by the end of January, and with no information provided that they would not be delivered.  On being asked, the Relationship Manager informed us that copies would not be available, which made it difficult to meet this requirement even if it were important.  It took a lot of persuasion to get more copies.

How about requirement #1, Volunteer Certification?  While it is reasonable to require that volunteers who prepare tax returns for taxpayers are certified in Tax Law, let us look in detail at what this requirement says:

Volunteers must be certified to:
Answer tax law questions
Instruct tax law
Prepare or correct tax returns
Conduct quality reviews of returns

One trainer interpreted this to mean that all volunteers at a site must be certified to accomplish these activities which is unreasonable since those who are not certified (e.g. greeters, IT volunteers, or minors helping out with stapling papers) could not help in a site unless they went through this set of certification requirements.  The correct interpretation would be that any, some, or all of the above activities must  be performed by certified volunteers.  It appears to suggest that transmitting returns does not require certification.  A bigger problem is that there is no official way of verifying volunteer certification; scrawled signatures on an illegible form with scores entered in, or an identification badge with certification levels marked brought in as evidence of certification are easy to falsify when there is no process in place to verify that the volunteers are who they claim to be, and that they actually did the exam themselves.  Verification of the certification of a volunteer can best be done by the Relationship Manager keeping and publishing an official list that is referenced by Site Coordinators.  Link and Learn online testing captures that information, but does not provide it for independent verification, relying instead of producing a paper copy of an electronic file which can be modified fairly easily, and then asking for the site coordinator to verify it.

#2 appears to be a reasonable request, except that what is called an intake and interview process is another name of a mandatory form to be filled.  In 2007 (for 2006 tax year) and prior years, this sheet included questions which were not relevant, required detailed explanation of something irrelevant to the taxpayer.  One year, the wordy questions asked taxpayers for permission to receive junk mail.  In 2007, use of the intake and interview sheet actually introduced new errors by the way the questions were asked that resulted in many taxpayers qualifying as HH who had their returns filed as Single.  The other big problem is to require that the intake and interview sheet at all times reflect the current state of knowledge about the taxpayer information.  The 2008 intake and interview sheet is a vast improvement from those in the past, but requiring it to accurately capture all the known taxpayer information before entering data into the computer defeats its purpose as a guide or a checklist.  A more useful checklist is the electronic list provided in TaxWise, where the checking of various boxes results in introducing special forms and schedules into the return which could not be removed without unchecking the boxes.  By the time the TP has filled the form with the information, it may have been more productive having them fill in a 1040A or 1040-EZ with the basic information of name, address and SSN, and have volunteers fill in and compute only the income, tax and refunds.  The form in prior years used TaxSpeak, and over the years has moved towards PeopleSpeak, but requiring the paper form to be the document of record is getting into the way of it being useful.

#6 is an interesting activity.  The Quality review process as currently defined means 100% inspection.  In manufacturing and other processes, Quality is a process that results in fewer and fewer defects with less and less inspection.  Statistical sampling is used to check that the quality is under control.  On the other hand, it reasonable to expect responsible adult information workers to stand behind the quality of their work, a standard that is expected of most paid preparers.  This practice may or may not have created the situation where volunteers do not have the self confidence to create an accurate return, but must be treated like kindergarten children whose every piece of work must be inspected by the teacher.  Relationship managers have come in and asked to see paper copies of electronic returns, and it is was surprising to note that they are inspecting whether the SIDN and the EFIN were correct.  To improve efficiency, these two pieces of information are entered in to the Tax Form Defaults so they appear on every return that is started from those Tax Form Default, so the review is in essence checking if the computer fills in default information correctly.   Furthermore, it is neither necessary or a requirement for volunteers to remember the EFIN or the address of the site.  One approach  that works is to let the preparer who made the mistake contact the taxpayer for correction; that way, volunteers become more careful of their work instead of counting on other people to catch errors in their sloppy work.  Additional analysis of the effect of quality process on return accuracy is discussed in more detail in a different section of this document.

#7 is determined by asking the Site Coordinator about representative statistics.  Much of this information can be obtained objectively by using the appropriate reporting tools in TaxWise which reflects actual results instead of the wishful thinking on the part of the coordinator.

To improve accuracy of returns,  here are some suggestions for thought and discussion:

1. Review return jointly with taxpayer. Enlist the taxpayer's help in inspecting the names, addresses and SSN of taxpayer(s) and dependents, informing them that if incorrect, not only will their returns be delayed, but that they will have to come back with the correct information.  Taxpayers who feel it is not their jobs to check this, but the job of the volunteer should be told that if they are not interested in the correctness of the return which gives them their refund, there is even less reason for the volunteer to be interested in it.

2. Require correctly entering W-2 forms as a minimum competency for new volunteers.   For two years in a row, SPEC sent out a Quality Alert at the beginning of the Tax Season to distribute to all partners and volunteers on the importance of correctly completing W-2 information.  The fact that it had to be sent out at the beginning of the second year indicates that lessons had not been learnt in the first year, and no attention had been paid to better training.  Even though the memo was widely distributed, it does not offer anything new to returning volunteers, whereas new volunteers are overwhelmed by so many messages that this is not likely to be read by them.  This minimum competency for filling the state information without assistance should be a mandatory requirement for volunteers using Taxwise to prepare returns.  A part of the TaxWise training should be devoted to independent data entry of all the information on a W-2 in the state, including the quirky ways that the numbers and boxes are sometimes treated.  In particular, at one site, 3 first year volunteers who had undergone TaxWise training did not know how to fill the information in the correct boxes.

3. Train volunteers to recognize limits of their certification.  Volunteers need to recognize if the scope of the return is beyond their certification level before they start entering the data for the return.  There is nothing wrong in not doing a return.  It is worse to start a return and then ask someone else questions every step of the way.  There are those volunteers who are willing to take on the challenge of researching new situations - this should be encouraged so long as the Site Coordinator is aware of it, and willing to review such returns with the preparer before filing the return.

4. Focus on quality and production of site rather than individuals. Do not focus on the production number of individual volunteers.  This encourages volunteers to become risk averse, and focus only on simple returns.  There are volunteers who are willing to explain to an elderly taxpayer in excruciating detail all the entries in the tax form, even if it is more time-consuming out of respect for his or her seniority; the preparer may not get the highest scores for productivity, but gains high marks in improving the quality of the customer experience by showing them the details of their calculation rather than saying "Trust me".   As an example of quality consciousness in a production line, in a watch factory in the lobby was a jar of all the defects made in that factory as a constant reminder of the fact that defects occur, and it is everyone's problem to avoid them.

5. Provide separate class sequences for Basic, Intermediate, Advanced and Refresher Training at different speeds. Do not try to have tax law in class training for beginner, intermediate and advance all in the same season; Let first year tax preparers, take the basic and spend the rest of the time becoming proficient in the TaxWise, and the non tax-law related procedures for completing the tax return (e.g. the various forms of electronic signatures accepted, entry of direct deposit information).  There should be intermediate level tracts and advance level tracks, each reviewing changes to the previous level, and then spending more on the current track.  The current training regimen is 4 x 8 hr classroom sessions + time for individual study and time for TaxWise, which is roughly 40 hours, and the total time spent volunteering in a season would be about 44 hours, which appears to be a very high overhead endeavor.

6. Use TaxWise to Tax Law, instead of as an afterthought. The current approach to tax law is designed for the days when returns were filled by hand and using a calculator.  While this may be good training to gain deep familiarity with the tax laws, the number of rules and exceptions that must be remembered which the computer can easily be programmed to do takes away from the basic principles and purpose of each Tax Law.  The crowds appear to be highest at the beginning of the tax season, and it is at that time that the volunteers are least trained and need the most practice.  To mitigate this effect, volunteers should be given more computer time on TaxWise during training so they can make their mistakes on practice rather than real returns.

7. Set relevant Site Defaults in the Tax Defaults page.  Do not permit volunteers to change the defaults or override entries.  Only the Admin account should have the ability to override entries.

8. Require volunteers to correct rejects of the returns they complete.

9. Disable override capability in TaxWise for most users.

10. Require volunteers to generate Federal and State e-files and assigning a DCNs prior to considering it complete.

11. Reduce the number of broad based communication only to the people who are affected by it.  Forwarding every message that comes out of SPEC headquarters blindly does not help solve the problem, and after a while, further messages are ignored.  It is not clear that these important messages are read and understood by Relationship managers, and if that is the case, then it does appear that the purpose of the messages are to cover certain parts of someone's anatomy.

12. Timely guidance for unforeseen circumstances.  Many times questions arise in the field which require an immediate answer or response.  In the absence of official guidance, volunteers and coordinators are required to come up with ad hoc solutions which may not be consistent with later decisions.

13. Create an official position of designated reviewer at each site.  This is a job requiring experience that not many volunteers have; it has however been our observation that relationship managers on site visits are very thorough at this.  Some suggestions: (a) get relationship managers to show how reviews are to be done at sites (b) let this be part of the official duties of relationship managers so that the quality and accuracy of the returns at the Site are up to IRS standards.

14. Proper training in using TaxWise.  Some specific actions  (a) require any information to be entered not directly into the forms or schedules, but have everything picked up from worksheets and scratch pages (b) discourage use of calculators when adding numbers - instead, enter the information in the scratch pad and let the computer do the addition (c) Whenever there is a doubt about whether a particular form applies, to fill the form and determine that it is not necessary rather than debating the issue,

15. Transparent process on what help or support sites can expect from IRS in resolving problems with returns that go beyond the scope of emails and phone calls.  Phone calls and voicemail seem reasonable, except that many volunteers prefer to not get calls from the taxpayer after the season or for other tax return related issues beyond the communication of the problem at hand.  This requires a mechanism for getting communication to the relationship manager that is printed out and sent to the taxpayer in a timely fashion.