The Best-kept Secret Federal Feedback Loop Model

An ode to the Taxpayer Advocate Service

BY ANNE MEEKER

In my particular slice of the para-Congress/”democracy space” world, there are two constant drumbeats:

  1. We have to figure out how to address state capacity: this means improving the implementability of legislation at the drafting/passage phase, improving the mechanisms for oversight and collaboration between the Executive and Legislative branches (including funding), investing in agency technology, staffing, etc.

  2. We have to figure out how to address civic/public/constituent engagement: we need to make the levers of policymaking more accountable and accessible to people, find the right tools and practices for people to share their opinions, experiences, and expectations of government (at the points in which they can be used for greatest leverage), close the loop by showing people what their input does, rebuild trust in government and democracy to achieve the expressed will of the people, etc.

With those two things in mind: let me tell you a story about the most elegant, demonstrably effective, relatively low-cost, and criminally overlooked model we have for achieving both of these goals at once: the unassumingly-named Taxpayer Advocate Service (TAS).

If you’ve known me at any point in the last ten years, you know that having a massive crush on the Taxpayer Advocate Service is more or less my personality — so buckle up for a real fangirl post, y’all.


Ode to the Taxpayer Advocate Service

When I was a casework manager for a House office, we sent a survey to every constituent whose case we closed, positive or negative. The survey asked how our team did, of course, but it also asked the constituent to reflect on their experience with the federal agency their case involved. To the best of their recollection or understanding — what went wrong that was so egregious, so unsolvable, that they lobbed a Hail Mary pass to their local Congressional office? And when we were able to get it resolved, how did they feel about that resolution? Was it satisfying? Was it what they expected? Did it feel fair?

We watched the data come in, monitored our own numbers — and then I noticed something weird.

Our IRS casework consistently blew all other agencies out of the water on constituent satisfaction.

And when we pulled back and looked at why, the answer was clear: the Taxpayer Advocate Service.

The Taxpayer Advocate Service, helmed by the National Taxpayer Advocate, is an independent agency within but separate from the IRS, reporting directly to Congress. TAS does three key things:

  1. Enforce the Taxpayer Bill of Rights (TBOR) by working directly with individual taxpayers to resolve problems with tax collection; and using data gathered in the course of that enforcement,

  2. Report to the IRS, and

  3. Report to Congress

It’s this combination of things that differentiate it from entities like Inspector Generals.

Enforcing TBOR

When taxpayers run into problems with the IRS that they are unable to resolve through normal customer service channels, TAS is an extra level of support: TAS staff are recruited from the IRS and tax prep/advocacy world, so they are true subject-matter experts on tax code and administration, able to go toe-to-toe with the IRS on the finer points of tax law and administration with an insider’s perspective.

The legislative code that makes TAS work is the Taxpayer Bill of Rights (TBOR). TBOR is a codification of basic expectations for how taxpayers must be treated by the IRS. The list is short and straightforward: taxpayers have…

  1. The Right to Be Informed

  2. The Right to Quality Service

  3. The Right to Pay No More than the Correct Amount of Tax

  4. The Right to Challenge the IRS’s Position and Be Heard

  5. The Right to Appeal an IRS Decision in an Independent Forum

  6. The Right to Finality

  7. The Right to Privacy

  8. The Right to Confidentiality

  9. The Right to Retain Representation

  10. The Right to a Fair and Just Tax System

These rights (which, by the way, were developed through an interesting semi-deliberative process) are what give Taxpayer Advocates the legal basis for their advocacy on behalf of individual taxpayers. And these have teeth: in extreme circumstances where a taxpayer would suffer irrevocable harm due to an IRS action, TAS can issue a Taxpayer Assistance Order to the agency to halt that action.

Reporting to the IRS

What this work creates (beyond the general moral justice of it all) is data: TAS treats its taxpayer-facing work as data-gathering.

This data surfaces problem areas with the IRS’s internal practices, regulatory landscape, enforcement practices, staff training and quality control, technology, and more — all of which TAS delivers back to the IRS in targeted recommendations for administrative fixes that the agency can and should make unilaterally.

Reporting to Congress

And, last but not least, TAS also delivers its annual report to Congress, including “the Purple Book” of recommendations for challenges with the IRS that require legislative fixes — and possibly additional appropriations — to address. And this is not just a doorstop of recommendations that TAS drops on Congress and walks away from. Every year, my team in our district office and our team in DC sat down separately with TAS staff to review the list of cases we had sent to them, and the legislative recommendations that would fix the problems we’d seen.

As an advocacy strategy — *chef’s kiss.*

More importantly, these legislative recommendations frequently go into law: this year alone, multiple bills have passed (via “Secret Congress”) addressing open TAS recommendations around correcting math errors, straightening out conflicting filing deadlines for disaster survivors, and the Senate Finance Committee is at work on a bipartisan bill that would tackle another broad swath of recommendations.

TAS is so effective that there is constantly some low-level chatter about how to replicate its approach for other agencies; most notably SSA and the VA.¹ And given TAS’ impact on constituent satisfaction in our casework, I think there’s a clear case to be made that these efforts count as investment in the Legislative branch as well — it was even part of the inspiration behind the House’s efforts to develop an aggregation tool for casework data.


What “Opinion” Engagement Can Learn from “Service” Practices

I raise TAS here in part because I think it’s a phenomenal example of a clear, institutionalized, functional feedback loop connecting constituent voices, the Legislative branch, and the Executive branch together. Everyone working in the state capacity and civic engagement worlds — as well as in Congressional constituent services trying to figure out what solutions already exist to solve casework-related problems — should be aware of it as a citable case study. We do service journalism newsletter-ing here, folks.

But more than that, the TAS example also demonstrates how state capacity and public engagement are not separate conversations.

When I’m thinking about constituent engagement, I think about the constituent-initiated side as kind of a Venn diagram: there is “opinion,” or spontaneous/prompted expressions of constituents’ views on things, and then there is “request,” or “service” — the moments where constituents reach out to the government because they need something. A lot of constituent engagement-focused work really focuses on that first bucket, and finding ways to streamline the process of structuring, delivering, or processing opinions on stuff. This is clearly important, and we haven’t cracked how to do it right.

But TAS’s approach to turning service requests into data into policy recommendations actually helps us think through what elements of public input make that input usable for policy. Public input works when…

  1. The stakes are concrete and personal. Someone dealing with an IRS problem isn’t expressing an abstract preference — they’re experiencing the actual consequences of how policy works in practice.

  2. The feedback is specific and actionable. “This regulation created this problem for this type of taxpayer” is a way more useful signal than “I support/oppose this bill.”

  3. There’s a natural accountability loop. The resolution (or lack thereof) of individual cases creates pressure and evidence for systemic fixes in a way that submitted opinions often don’t.

  4. It’s already happening. You don’t have to convince people to participate — they’re already reaching out because there is a clear incentive for them to do so. The question is whether you’re treating that contact as data or just as transactions to close.

So yes, let’s replicate TAS at SSA and VA — and continue to fund TAS and the legislative liaison/Congressional affairs staff at other agencies who handle casework as investments in legislative capacity.

But more than that, let's keep TAS close to hand as a reference example for everyone working on constituent engagement and state capacity — because what it demonstrates isn't just that feedback loops can work, but the engagement design choices that make them work. We can learn from what works in handling “service” requests to figure out what makes an “opinion” solicitation/management system work or not work. TAS is the proof of concept that shows that this is achievable.


¹ When I had the chance to testify alongside former Taxpayer Advocate Nina Olson before the House Select Committee on the Modernization of Congress, this was Nina’s primary recommendation.

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