IRS Should Ensure Customer Service Enhancements Are Accessible for Taxpayers with Disabilities

The IRS is in the midst of reinventing itself by offering taxpayers several new customer service options, including:

• Expanding document digitalization;
• Implementing chatbots to assist taxpayers;
• Adding more customer service representatives;
• Expanding the use of online taxpayer accounts; and
• Conducting a direct file pilot program.

These enhancements will undoubtedly provide better customer service to taxpayers, but the IRS must design them so they will be accessible to all, including the 42 million Americans with a reported disability as of the 2021 census. It is critical that the IRS ensure that these millions of taxpayers with disabilities can easily comply with their tax obligations and receive the refunds to which they are entitled, especially since this group struggles with financial stability at a higher rate than their non-disabled counterparts.

According to an August 2023 report published by the Financial Health Network, only 51 percent of working-age people with disabilities said they were able to pay all of their bills on time, compared with 71 percent of working-age people without disabilities. Thus, taxpayers with disabilities may be eligible to claim on their returns – and greatly benefit from – refundable credits such as the Earned Income Tax Credit and Child Tax Credit, which can generate significant refunds. But taxpayers with disabilities can only claim these credits if IRS systems are accessible and the information is readily available.

Despite mentioning several times in the IRS Strategic Operating Plan that customer service enhancements will be usable by all taxpayers, including those with disabilities, the plan offers few details on how the IRS intends to make this statement a reality. The IRS should ensure these new customer service enhancements are accessible by strengthening its communication with disability organizations and seeking their feedback regarding accessibility.

The IRS Is Making Strides in Accessibility Improvements, But It Can Do More

The IRS has made some accessibility improvements over the last few years and is working closer with the disability community. For example, as I discussed in a previous blog, the IRS recently made changes to better accommodate visually impaired taxpayers. Specifically, beginning in January 2022, the IRS implemented a new alternative media process where visually impaired taxpayers can elect to receive certain types of written correspondence in:

• Large print,
• Braille,
• Audio (MP3),
• Plain Text File (TXT), or a
• Braille Ready File (BRF).

Recently the IRS introduced the Direct File program just in time for the 2024 filing season. When developing Direct File, the IRS collaborated with both organizations representing disabled individuals and individual taxpayers with disabilities to ensure the final product would be accessible. These individuals and representatives from the organizations tested the product in return for a small stipend; volunteers identified several minor issues, which the Direct File Team took immediate steps to remedy. This approach serves as a model for the IRS in developing and implementing other customer service tools.

The IRS Should Build on These Successes

The IRS should replicate the process used to develop the Direct File program in its efforts to develop new technology for all taxpayers. As in the development of Direct File, the IRS should discuss accessibility of new customer service tools with disability organizations at the beginning of the design process and not wait until it has implemented the systems. When taxpayers with disabilities discover problems after the IRS has implemented a system, developers must then create patches or workarounds, which may result in an inferior product and time delays.

The IRS recently held a roundtable event on accessibility with several disability organizations. Although this was a good first step to improve communication, the roundtable only included organizations representing the visually impaired. TAS encourages the IRS to continue these roundtable events, and include a variety of disability organizations, where accessibility and other relevant issues can be discussed. Additionally, the IRS should consider creating a disability council it can consult with regarding issues facing taxpayers with disabilities. Other federal government agencies have successfully utilized such councils.

By implementing an approach similar to that of the Direct File program when designing new customer service tools, the IRS can ensure that services such as online accounts, chatbots, and document upload tools are fully accessible to taxpayers with disabilities and also comply with Sections 504 and 508 of the Rehabilitation Act of 1973.

Recommendations

To achieve the objective of optimal accessibility and comply with relevant provisions of the Rehabilitation Act of 1973, the IRS should take the following actions:

1. The IRS should establish a disability council made up of both internal and external stakeholders to advise the IRS on issues and concerns facing taxpayers with disabilities, and how the IRS can best address those issues.
2. The IRS should work with individuals with disabilities to test the usability of its digital products. The IRS can contract with organizations that specialize in testing webpages and online services to ensure maximum accessibility. These testers will use several accessibility software products such as JAWS^®, Dragon^® or ZoomText^®, and will have different levels of competency in using the software to more accurately simulate the public’s experience.

Conclusion

As the IRS moves forward with modernization and digitalization of its services, it needs to ensure that it prioritizes accessibility along the way. I have no doubt the IRS sees the value and importance of creating equally accessible products that all taxpayers can use easily, but it needs to develop a specific plan for ensuring accessibility as it develops these enhancements and provide details to the public. IRS communication is a key aspect to ensuring that any customer service enhancements are accessible to all taxpayers. Thus, the IRS should open lines of communication with the disability community and seek their input every step of the way. By doing so, organizations will have an easy and clear means of raising any concerns to the IRS. Additionally, the IRS should work with disability experts to test and guarantee that its newly developed customer service products are fully accessible and should begin this process early in the development stage, ensuring that it is not an afterthought.

I look forward to continuing to work with disability organizations, including the National Council on Disability, the National Disability Institute, and the National Federation of the Blind, to ensure accessibility is a key component of IRS’s mission.

Resources

• Additional help is now available for visually impaired and other taxpayers with disabilities
• Accessible tax forms and language options
• IRS resources and services for visually impaired taxpayers
• Information About the Alternative Media Center
• IRS to Implement Process to Provide Accessible Tax Notices to the Blind