IRS Safeguards and 1075 Update
DEAR COLLEAGUE LETTER
DATE: March 28, 2008
TO: ALL STATE AND TRIBAL IV-D DIRECTORS
RE: IRS Safeguards and 1075 Update
This correspondence is a follow up to the email sent to State IV-D Directors on February 7, 2008 providing the internet link to the newly revised IRS Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies and Entities. As a reminder, the publication is located on the IRS website. In an effort to improve and increase safeguarding of Federal Tax Information (FTI), the revised version of the IRS 1075 includes guidance on encryption of FTI and new computer security requirements that became effective in December 2007.
The IRS is aware that the new computer security requirements will take time to implement. In a session on March 18 at the National Child Support Systems Symposium, representatives from IRS discussed the new safeguarding procedures outlined in the IRS 1075. The following information and recommendations were presented by IRS during the session:
Your State should perform a gap analysis to determine the gaps between your current security implementation and the new requirements in the IRS 1075, and develop a plan to address identified gaps. You are not required to submit your gap analysis and plan to the IRS; however, they will be happy to review it for you. Send an email with “1075 Implementation Plan” in the subject line to firstname.lastname@example.org.
The Safeguard Activity Report (SAR) and Safeguard Procedures Report (SPR) will be submitted by your State using approved templates developed by the Office of the Safeguards at IRS. You will continue to submit your SAR annually. The IRS has extended the due date for the SAR from January 31 to March 31. The SPR is now required every six years. In order to prevent a processing backlog at IRS, please do not submit your SPR until requested by the Office of Safeguards.
States can request either of the approved templates from the IRS by sending an email with “Need SAR (or SPR) template” in the subject line to email@example.com. Within two business days the IRS will provide the template along with instructions for returning reports using the IRS-approved encryption method. You will also receive the password for SAR/SPR transmission. Information on this process and the safeguards program is available online on the IRS website.
In collaboration with OCSE, the Office of the Safeguards will provide teleconference briefings in the near future to discuss safeguard review issues and address your concerns about the new rules. Our common goal is to protect the personal data of the individuals that we serve.
If you have concerns about the safeguard review process or the findings from your IRS review exit interview, please contact Scott Hale at (202) 401-5745 or email firstname.lastname@example.org.
Office of Child Support Enforcement
cc: Regional Program Managers