Programs Submission Response: AGI Verification

ISSUE:
AGI forms sent to IRS for verification and update.

FACTS:
County Offices are spending numerous man hours sending AGI forms to IRS 3 and sometimes 4 times before they are processed. This is also resulting in increased and unnecessary postage costs for FSA to keep resending these documents to the IRS.

SOLUTION:
Why wouldn’t it be possible for the IRS to provide a fax number for FSA to fax the AGI forms to? There could be a separate fax number set up for each AGI year. Fax reports would provide verification to FSA that the documents were received by the IRS, and the result would be a savings in postage. 

NATIONAL OFFICE RESPONSE:
What we have found is that forms successfully reach the IRS processing facility. Copies of the Form 3210 are being provided to the COF’s as required in acknowledgement of the receipt of the AGI certification statements. Also, the number of resubmissions over the past 12 months have been and continue in a downward trend. 

Faxing the AGI certification and disclosure statements, even just the ones being re-submitted, may be a reasonable means for FSA to achieve an instant economic saving on postage costs. Please keep in mind that this is entirely dependent upon the IRS and its ability to timely acquire and make available for use multiple machines and phone lines, each dedicated to a specific year. Such an arrangement is not currently part of the MOU and reimbursable agreement between FSA and IRS for the verification of the $900K AGI amount. The consideration of the request for an additional forms submission and handling capability would first require FSA to submit revisions to the business rules for the AGI verification process and then in response, the completion of an extensive cost analysis by the IRS before any preliminary agreement and approval by both FSA and IRS could become a reality. The development and implementation would require the commitment of significant monetary and personnel resources for both Agencies, and which neither currently has to devote to such a project.

There may be no real savings with this convenience. The overall costs for IRS, and subsequently FSA, for this proposal may be greater than the current postage costs for resubmissions via the postal service. Nonetheless, this represents an idea worthy of consideration, at least the availability to FAX an AGI certification and disclosure statement – only for a very limited or restrictive basis.