GAO reviewed two Internal Revenue Service (IRS) year 2000 business
continuity and contingency plans for their consistency and completeness
on the basis of IRS' guidance for such plans.
GAO noted that: (1) two IRS business continuity and contingency
plans--one for processing paper tax returns that result in a refund
(refund plan) and the other for receiving paper submissions (paper
submissions plan)--were inconsistent and incomplete in two key areas
included in IRS' guidance: (a) performance goals; and (b) mitigating
actions; (2) these weaknesses raise questions about whether these two
plans provide sufficient assurance that IRS has taken all the necessary
steps to reduce the impact of a potential year 2000 failure; (3) IRS'
guidance requires that plans specify a desirable performance goal; (4)
the performance goal for the refund plan was inconsistent with the
plan's contingency actions; (5) this inconsistency raises questions
about the goal that IRS is trying to achieve with the refund plan; (6)
the paper submissions plan did not include a performance goal; (7)
without appropriate performance goals, IRS has little assurance that the
contingency actions specified in the plan are appropriate for reducing
the impact of a potential year 2000 failure; (8) in addition, neither
plan specified the completion dates for the mitigating actions, which
IRS' guidance defines as the steps that are to be completed in advance
of a potential year 2000-related failure, to help reduce its impact; (9)
moreover, neither plan specified which individuals were to be
responsible for completing the mitigating actions; (10) IRS' guidance
requires that the plans include mitigating actions and completion dates,
but does not require that responsible individuals be identified for
completing mitigating actions; (11) however, without assigning actions
to specific individuals and identifying completion dates, IRS has little
assurance that these actions will be completed before a potential year
2000 failure; (12) in June 1999, GAO informed IRS officials of its
concerns regarding these two plans; (13) GAO also told them that its
concerns raise questions about the extent to which other plans may have
similar weaknesses; (14) in response to GAO's concerns, IRS officials
agreed to make changes to improve the completeness and consistency of
these two plans; (15) they also said they have designated an individual
that is to determine the extent to which other plans may have similar
weaknesses and revise the plans as needed; and (16) in addition, IRS
assigned one of its year 2000 contractors to set up a mechanism by which
IRS could track the implementation of business continuity and
contingency plan actions.
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