Self Quality Review Is No Longer Allowed – Here’s How to Handle It
Self quality review is not allowed at VITA tax sites for the upcoming tax season and beyond. This means each tax return must be reviewed by a quality reviewer independent of the tax preparer. Many tax sites will be affected by the policy, which will increase the burden on VITA programs and strain their resources.
Those VITA programs affected must implement a method to complete an acceptable quality review when resources limit the ability to complete a “traditional” face‐to‐face review between the taxpayer and an independent quality reviewer.
NCTC has worked with our members and the IRS on Elimination of Self Quality Review Guidelines. These guidelines provide a list of “acceptable” alternative approaches, summarized below, that programs may employ in the upcoming tax season to complete an appropriate and acceptable quality review of a completed tax return.
- Virtual VITA model – A quality reviewer reviews the tax return from a remote location with the taxpayer on the phone or available through other electronic means (e.g. Skype). After approval from the quality reviewer, the tax return is filed.
- Delayed Quality Review – A quality reviewer at the same location reviews the tax return with the taxpayer on the phone, face-to-face, or by electronic means within a reasonable period of time (since return is not “complete” until quality review has been completed, there is no timeframe related to “stockpiling” that must be considered).
- Off‐site Delayed Quality Review – A quality reviewer at a different location reviews the tax return within a reasonable period of time. Documents are faxed or scanned to the off‐site quality reviewer. Taxpayer contact information is included to ensure that the taxpayer can be included in the review process.
- Drop‐off model – Taxpayer drops off their tax documents for tax return preparation and agrees to return to pick up the completed tax return. Quality review will happen with the taxpayer over the phone or through another form of communication with the taxpayer and quality reviewer.
Due to the nature of the above alternative approaches, the IRS agreed to modify Quality Site Requirement #3, Quality Review Process, to remove the requirement that the quality review must be completed “prior” to the taxpayer leaving the site. The QSR #3 now focuses on the fact that a quality review must be completed and the taxpayer must be engaged in the quality review process.
If none of the above alternative approaches work for you, VITA programs that do not have the capability to complete a peer-to-peer review can propose a workable solution. The workable solution must be approved by the IRS Relationship/Territory Manager before implementation and must consider the following key elements for an acceptable alternative method:
- The tax preparer cannot be the quality reviewer on a return he/she has prepared. It does not matter if QR is done on a separate day or different location – there must be independence between tax preparer and tax reviewer.
- The taxpayer must consent (i.e. signed written consent) to the completion of a Quality Review by another individual if that quality reviewer will not be meeting with the taxpayer face‐to‐face (e.g. QR completed by phone, virtually, through Skype, etc.).
- Taxpayer’s identity must be verified by both the tax preparer and the quality reviewer.
- Taxpayer must participate in the return preparation and in the quality review process in a material manner that allows for dialogue between the taxpayer, the preparer, and the quality reviewer (whether by phone, Skype, etc.).
- All documents critical to tax preparation and direct deposit must be accessible to the quality reviewer.
- Virtual VITA exists when either the taxpayer, return preparer, or quality reviewer are not face‐to-face. The utilization of the Virtual VITA/TCE process requires adherence to all Quality Site Requirements.
This is a change that is sure to cause some headaches. If you’ve got some tips or just want to share how you’re handling it, tell us in the comments section below.
By Catherine Ro, Project Manager