TIGTA: IRS Video Review Processes Effective, Could Be Improved

Video Review Processes Have Been Implemented; However, Those Processes Can Be Strengthened

June 28, 2019

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.

Highlights

Final Report issued on June 28, 2019

Highlights of Reference Number: 2019-10-037 to the Commissioner of Internal Revenue.

IMPACT ON TAXPAYERS

The IRS Communications and Liaison Division connects the IRS to the American taxpayer by working with external audiences to enhance the public's understanding of the IRS and its mission, programs, and policies. The Division's services allow the IRS to reach a wide variety of audiences through social media engagements, the IRS Video Portal, and YouTube video content.

WHY TIGTA DID THE AUDIT

In February 2013, the IRS created the Service-Wide Video Editorial Board (SVEB) to review and approve all video projects planned throughout the IRS. In addition, each appropriations law from Fiscal Years 2014 through 2018 states that no IRS funds may be used to make a video unless the SVEB determines in advance that making the video is appropriate, taking into account the cost, topic, tone, and purpose of the video.

This audit was initiated to evaluate the costs and impact of IRS video projects, and determine if the policies for reviewing content and requesting prior approval are being followed.

WHAT TIGTA FOUND

The IRS implemented controls to ensure that no funds made available to the IRS are spent on video productions unless the SVEB, administered by the Communications and Liaison's Visual Education Communications Branch, determines in advance that making the video is appropriate.

TIGTA determined that IRS business units are adhering to the SVEB review process and are not producing videos outside established procedures. In addition, approval processes take into account the projects' estimated cost, topic, tone, and purpose. From October 1, 2015, through March 31, 2018, the SVEB reviewed 366 video project requests with estimated production costs of $873,200.

In addition, TIGTA determined that IRS video projects reach a significant number of employees and taxpayers. For example, videos available to employees and taxpayers have been viewed more than 5 million times. Additionally, the videos posted on IRS YouTube channels have more than 13 million views, and these channels have almost 30,000 subscribers.

However, TIGTA's review of a judgmental sample of 36 approved video requests and associated documentation found that documentation of SVEB approvals and actual production costs could be strengthened. Of the 36 video projects reviewed, three did not have documentation of all required approvals, and the IRS could provide documentation of actual production costs for only 17 of the video projects. In addition, TIGTA was unable to determine whether six projects were approved by the SVEB prior to production because the actual production dates were not documented.

WHAT TIGTA RECOMMENDED

TIGTA recommended that the Chief, Communications and Liaison, ensure that sufficient documentation related to approvals, actual production dates, and actual costs is maintained for each approved video project request.

In their response, IRS management agreed with the recommendations and plans to automate the request process to ensure that proper supporting documentation is maintained.

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June 28, 2019

MEMORANDUM FOR
COMMISSIONER OF INTERNAL REVENUE

FROM:
Michael E. McKenney
Deputy Inspector General for Audit

SUBJECT:
Final Audit Report — Video Review Processes Have Been Implemented; However, Those Processes Can Be Strengthened (Audit # 201810011)

This report presents the result of our review to evaluate the costs and impact of Internal Revenue Service (IRS) video projects, and determine if the policies for reviewing content and requesting prior approval are being followed. This review is included in the Treasury Inspector General for Tax Administration's Fiscal Year 2019 Annual Audit Plan and addresses the major management challenge of Achieving Program Efficiencies and Cost Savings.

Management's complete response is included as Appendix V.

Copies of this report are also being sent to the IRS managers affected by the report recommendations. If you have any questions, please contact me or Heather Hill, Acting Assistant Inspector General for Audit (Management Services and Exempt Organizations).

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Table of Contents

Background

Results of Review

Appendices

Appendix I — Detailed Objective, Scope, and Methodology

Appendix II — Major Contributors to This Report

Appendix III — Report Distribution List

Appendix IV — Video Request Submission Form

Appendix V — Management's Response to the Draft Report

Abbreviations

IRS	Internal Revenue Service
SVEB	Service-Wide Video Editorial Board
TIGTA	Treasury Inspector General for Tax Administration
VEC	Visual Education and Communication

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Background

In May 2013, the Treasury Inspector General for Tax Administration (TIGTA) recommended that the Internal Revenue Service (IRS) Chief Financial Officer establish procedures to clearly outline the need for and value provided by any conference videos for future conferences.¹ TIGTA also recommended that the purpose and use of videos be clearly detailed in any request for a conference and include the applicable costs in the approval request. The IRS agreed with TIGTA's recommendations. In February 2013, the IRS created the Service-Wide Video Editorial Board (SVEB) to review and approve all video projects² planned throughout the IRS. In addition, Congress included language in each appropriations bill from Fiscal Years³ 2014 through 2018,⁴ stating that none of the funds made available to the IRS may be used to make a video unless the SVEB determines in advance that making the video is appropriate, taking into account the cost, topic, tone, and purpose of the video.

The Office of Communications within the IRS Communications and Liaison Division is the focal point for planning, coordinating, and producing IRS-wide communications. The office works through a variety of communications channels including national and local media as well as social media, to enhance the public's understanding of the IRS and its mission, programs, and policies; manages national media campaigns to help the IRS meet its goals and business objectives; produces interactive video training; and provides video services to IRS employees nationwide. The IRS Visual Education and Communications (VEC) Branch, formerly known as the IRS “TV Studio,” operates within the Office of Communications. The VEC Branch develops and designs instructional and informational multimedia products. The VEC Branch staff includes producer/directors, engineers, program analysts, a staff assistant, and a general manager. In some instances, they contract with production crews and editors. The VEC Branch is also responsible for the administration of the SVEB review process. The VEC Branch receives requests for video projects, coordinates the SVEB review process, and notifies the requestors of the final decision of the SVEB and Deputy Commissioner for Operations Support. Figure 1 provides a high-level organizational view of the IRS Communications and Liaison Division.

The SVEB consists of three members⁵ who oversee the development and standards for video projects throughout the IRS. Specifically, the SVEB is responsible for:

• Developing and approving a concept of operations for video projects.

• Looking at resource sharing and opportunities to maximize efficiencies.

• Establishing an oversight process.

• Reviewing all video projects planned throughout the IRS for external and internal use, considering cost, topic, and tone.

All videos developed for internal and external audiences must be approved by the SVEB (unless noted as an exception)⁶ and must be closed captioned. To request approval for a video project, the requestor must submit a request form for SVEB consideration and approval. Appendix IV includes the template for video project requests. The request form documents key information surrounding the video project, e.g., topic and purpose of the video, format and delivery method, target audience, estimated cost, estimated production dates, and use of contractors. The SVEB reviews requests on a weekly basis and forwards any recommendations to the Deputy Commissioner for Operations Support for final approval or denial of the request. Once a decision has been made, the VEC Branch notifies the requestor in writing whether the video project was approved or denied. According to Internal Revenue Manual requirements,⁷ it is the responsibility of the requesting party to obtain additional approvals if, during production, the cost of the video project increases. Figure 2 outlines the SVEB video project request and approval process.

The Division's services allow the IRS to reach a wide variety of audiences through social media engagements, the IRS Video Portal, and YouTube video content. The following are examples of video content available for public audiences on the IRS Video Portal⁸ and the associated number of views:⁹

• Small Business Taxes: The Virtual Workshop | 501,679 views.

• Payment Alternatives When You Owe the IRS | 10,268 views.

• Safeguards Security Awareness Training | 76,745 views.

• Online Payment Agreement Introduction | 131,318 views.

The following are examples of YouTube videos¹⁰ posted for taxpayer use and the associated number of views:

• IRS Withholding Calculator Tips | 33,102 views.¹¹

• Paycheck Checkup | 45,178 views.

• Tax Return Errors — Tips to Avoid Them | 47,180 views.

• Missing W-2 | 39,000 views.

This review was performed at the IRS Communications and Liaison, VEC Branch, in Lanham, Maryland, during the period of May 2018 through March 2019. We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objective. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objective. Detailed information on our audit objective, scope, and methodology is presented in Appendix I. Major contributors to the report are listed in Appendix II.

Results of Review

Processes Were Developed to Preapprove Video Projects, but Documentation of Approvals, Production Dates, and Actual Costs Can Be Strengthened

According to the IRS, the use of video is an important tool to maintain training while reducing travel and training costs for IRS employees. Additionally, the IRS states that the use of video (including social media) has provided a key educational and outreach tool for the IRS to reach taxpayers. The IRS has developed processes to review and approve video projects. Our review found that business units are appropriately submitting video requests for approval to the SVEB, and the SVEB is generally adhering to its review and approval procedures. We also found that IRS video projects reach a significant number of employees and taxpayers. However, the IRS can strengthen these processes to more fully comply with appropriations law and SVEB requirements. Specifically, we found that documentation of the video requests and actions taken during the SVEB review process could be strengthened. As a result, the IRS is unable to determine whether program requirements are being met.

Processes were implemented to provide reasonable assurance that videos are preapproved and the topic, estimated cost, and tone are appropriate

The IRS implemented controls over video projects to provide reasonable assurance that no funds made available to the IRS are spent on videos unless the SVEB determines in advance that making the video is appropriate, taking into account estimated cost, topic, tone, and purpose of the video, as required by appropriations law.¹² From October 1, 2015, through March 31, 2018, the SVEB reviewed 366 requests for video projects with estimated production costs of $873,200. This includes 78 requests totaling $129,536 for videos to be produced and posted to the IRS's YouTube channels.

The SVEB approved 336 (92 percent) out of the 366 video requests during this time; and denied eight requests due to factors such as inappropriate content, tone, or cost.¹³ SVEB documentation shows that these videos were denied for reasons related to copyright permissions, Section 508 compliance,¹⁴ inappropriate use of character animation, questionable cost expenditures, and use of external video content that was not appropriate for IRS purposes.

Our review of video project records obtained from four IRS business units found that the business units are adhering to the SVEB review process and are not producing videos outside established procedures. In addition, our review of a randomly selected sample of 36 videos posted on IRS YouTube channels found that the SVEB reviewed and approved all 36 YouTube videos prior to the IRS posting the videos on YouTube.

We also found that IRS video projects reach a significant number of employees and taxpayers. The IRS measures the impact and performance of its video projects through viewership. From October 1, 2015, to March 31, 2018, the IRS Video Portal housed 1,099 videos available for internal and external audiences. There were 751 videos available to employees and 348 videos available to the public. These videos received 1.6 million views between October 1, 2015, and March 31, 2018, and have been viewed 5.3 million times from the time they were posted to the IRS Video Portal through October 1, 2018. Additionally, IRS YouTube channels have almost 30,000 subscribers and contain videos that had been viewed more than 13 million times, as of March 31, 2018.¹⁵

Documentation maintained by the SVEB could be strengthened to improve program compliance

Our review of the documentation maintained by the SVEB for a judgmental sample¹⁶ of 36 of the 366 video requests between October 1, 2015, and March 31, 2018, found that documentation could be strengthened to improve program compliance with appropriations law and SVEB requirements. According to the Standards for Internal Control in the Federal Government,¹⁷ documentation is a necessary control in determining if a program is operating effectively, which ultimately aides management in determining if the activity is an effective use of public resources. Specifically, we found that the SVEB did not always maintain documentation of SVEB or Deputy Commissioner for Operations Support approval. In addition, we found that the current SVEB process does not include collecting or maintaining documentation on actual production costs and dates at the close of each approved video project.

Documentation of SVEB and Deputy Commissioner approval

A video project must be approved by a majority (two-thirds) of the SVEB members and the Deputy Commissioner for Operations Support. We found documentation supporting SVEB approvals in 33 (92 percent) of the 36 sampled video projects. However, for the remaining three video projects, the SVEB could not provide appropriate documentation to support that a two-thirds majority approved the request. Additionally, the SVEB was unable to provide documentation that the Deputy Commissioner for Operations Support approved one of the three video requests.

The SVEB manually tracks the approval of video projects. The request form is a Microsoft® Word document that is filled out and submitted to the VEC Branch via e-mail. It does not include signature lines for approval. Instead, approvals by each SVEB member and the Deputy Commissioner for Operations Support are documented via e-mail. The VEC Branch maintains the e-mail records supporting the SVEB and Deputy Commissioner approvals.

Documentation of approval prior to production

Business units are required to obtain project approval prior to production. We identified six (18 percent) of 34¹⁸ sampled video projects where the approval from the SVEB or Deputy Commissioner for Operations Support came either on the same day as the estimated production date in the request form or subsequent to the estimated production date. It is possible that the actual production dates occurred later than the estimated production date listed in the request; however, because the process does not require documentation to support the actual production time frames, we could not determine if these six videos were produced subsequent to SVEB approval. Maintaining records on when a video project is produced would help ensure that business units are not producing videos prior to obtaining approvals.

Documentation of actual production costs

The SVEB does not know the actual production costs of approved video projects. The SVEB approves video projects based on estimated production costs. IRS guidance states¹⁹ that, if there are any changes or cost increases on production needs and services at any time during the production process, a final budget must be re-submitted to the SVEB for review and approval. When the SVEB approves a request, it includes a disclaimer in its approval stating that if during the production, the cost increases, please notify the SVEB. SVEB approval will be needed for additional funds. Despite this disclaimer, the SVEB does not have a process to track the actual cost of the videos approved for production. IRS video projects are paid for either by the Communications and Liaison Division (primarily the VEC Branch) or by an IRS business unit. However, the business units and the VEC Branch could provide records of the actual production costs for only 17 (47 percent) of the 36 sampled video projects. Further, we found that the actual production costs for five of the 17²⁰ video projects exceeded the estimated cost approved by the SVEB and the SVEB had not approved the cost increase.

If actual production costs were centrally tracked, the SVEB would be able to better review and approve video requests, considering cost as a key factor, as required by appropriations law. By tracking actual production costs, the IRS could compare actual costs to estimated costs and use this knowledge in deciding whether to approve future video projects. For example, the collection of cost data would help the SVEB determine if costs submitted by business units are reasonable when compared to other similar projects.

Recommendations

The Chief, Communications and Liaison, should:

Recommendation 1: Establish processes to ensure that sufficient documentation is maintained by the SVEB for each approved video project request. This should include documentation of the approval by the majority of the SVEB members and the Deputy Commissioner for Operations Support.

Recommendation 2: Establish processes to collect and maintain documentation that supports the actual production date and actual cost of approved video projects. This information should be used to compare (a) actual production dates against video project approval dates to determine if preapproval requirements are being met and (b) actual costs against estimated costs to improve cost estimates for future video projects.

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Appendix I
Detailed Objective, Scope, and Methodology

The overall objective of this review was to evaluate the costs and impact of IRS video projects, and determine if the policies for reviewing content and requesting prior approval are being followed. To accomplish this objective, we:

Internal controls methodology

Internal controls relate to management's plans, methods, and procedures used to meet their mission, goals, and objectives. Internal controls include the processes and procedures for planning, organizing, directing, and controlling program operations. They include the systems for measuring, reporting, and monitoring program performance. We determined that the following internal controls were relevant to our audit objective: public law and IRS policies, procedures, and practices of the SVEB. We evaluated these controls by interviewing IRS personnel responsible for the administration of the SVEB request and approval process, reviewing applicable documentation, testing the effectiveness of the process, and analyzing select video projects to ensure compliance with the established process.

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Appendix II
Major Contributors to This Report

Deann Baiza, Acting Assistant Inspector General for Audit (Management Services and Exempt Organizations)

Troy Paterson, Director

LaToya Penn, Audit Manager

Antonina Hill, Lead Auditor

Meghann Noon-Miller, Senior Auditor

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Appendix III
Report Distribution List

Deputy Commissioner for Operations Support

Chief, Communications and Liaison

Director, Office of Communications

Director, Office of Audit Coordination

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Appendix IV
Video Request Submission Form

Name of project:
Topic: What topics will the project cover, whom will make the presentation, where will the presentation be held and date of event.
Contact person and Phone number:
Approving Executive (SES1 level): (Please provide name & title)
Communications Director/L&E2 Coordinator:
Format: Is it a Video, Webinar, SABA Meeting (formerly named Centra), OCS,3 MS OC4 Live Meeting, Webinterpoint, Phone Forum, town hall, meeting,Captivate presentation? Please specify.
Target Audience: Is the project for External or Internal audience (IRS employees, tax practitioner Community, etc.)? Please specify. Expected Audience size:
Cost: Provide Total Cost for the project and include a breakdown of all the expenses (including Travel cost, if any). NOTE: Travel expenses must be approved by your BU5 and Training Review Board before submitting to the SVEB.
Key Production Dates: When do you plan to Produce the project? When do you plan to Deliver the project to your audience? Has filming started yet?
Are there any outside contractors involved? (i.e., Onstream Media, Booz Allen Hamilton)
Is the video for: Training CPE6 Town Hall or meeting Informational Educational Other/Misc.
Does the project contain: An outside Speaker, Presenter or instructor (not an IRS employee)? Animation or cartoons? Special Effects? Extensive production work? Potentially questionable or sensitive content? Role Plays or Vignettes? Comedy, Satire or Parody? Stock footage, video clips, photographs? Off-Site Location filming (i.e., Travel/Field Office./Campus/Outside-Government Facility)? Hired Talent (SAG-AFTRA7)? Video created by, or with the assistance of, outside vendors; or edited outside the IRS corporate studios? If yes, please explain.
What method do you plan to use to deliver the project (DVD8 distribution, Web cast, upload to SBSE9 video Portal, IRS YouTube channels, etc.)?
What could happen if the project is cancelled or delayed?
Source: IRS Video Request Submission Form.

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Appendix V
Managements Response to the Draft Report