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1991 Report of the Auditor General of Canada
Chapter 16—Department of National Revenue—Taxation—Taxpayer Services
Main Points
Introduction
Audit Objectives and Scope
Understanding and Responding to Expectations
Consultative committees provide user input
The Department needs more feedback on services
The Department does not make the most effective use of complaints as a source of information
Performance standards may not adequately reflect client expectations
Telephone Enquiries
The Department provides automated enquiries services to reduce demand on agents
The target level of service for general enquiries is lower than the Government Telecommunication Agency's guideline
The level of service standard is not met for much of the filing season
The Department focusses on its standard for waiting time
The Department's surveys do not provide an estimate of accuracy of replies to the public
Enquiries agents are courteous
Temporary enquiries agents have little training or experience
Counter Enquiries
A departmental task force recommends a review of the structure and location of NRT offices
The Department recognizes that some service counters are not well designed for confidentiality
Waiting time at service counters is not adequately measured
Correspondence
Systems are in place to ensure correspondence is complete, accurate and timely
Forms and Publications
The Department is taking steps to improve its publications
Publications are becoming easier to read but are still not understandable to a large percentage of the adult population
Some forms and publications are not available on time
Education and Special Services Programs
Determining the Benefits and Costs of Service Activities
Accountability
Performance reporting concentrates on volume data, not on quality
Conclusion
Main Points
16.1 The Department of National Revenue-Taxation has stated its commitment to improving taxpayer services. In recent years it has extensively studied its operations, changed some practices, extended the use of automation, and expanded the range of its services. Still, the quality of some services provided is below the levels desired by the Department.16.2 Information on client expectations is vital to the establishment of service standards. The Department uses consultative committees and focus groups to learn how it can be more responsive to taxpayers' needs. Questionnaires used to obtain taxpayers' views should be supplemented with other information sources. The Department does not make the most effective use of complaints as a source of information (paragraphs 16.20 to 16.33).
16.3 During the 1990 and 1991 filing seasons for personal income tax returns, the Department conducted surveys of telephone enquiries agents in order to monitor various aspects of their performance. One output of the surveys was information indicating that it took an average of 3.8 call attempts to get an agent on the line in 1990 and 3.2 attempts in 1991. This performance does not meet the Department's standard of approximately 1.4 attempts (16.36 to 16.55).
16.4 A large percentage of adults in Canada find the Department's publications difficult to understand. The Department is beginning to address the problem. A "readability team" is helping revise key publications to make them more understandable. In addition, certain members of the Department have received training on how to use plain language when they write. As a result, several of the Department's publications are now easier to read (16.78 to 16.89).
16.5 The Department has not conducted evaluations of its services to determine whether they are contributing to its objectives in a cost-effective manner or whether its resources are optimally employed (16.98 to 16.100).
16.6 Part III of the Estimates reports certain volume data on taxpayer services. It does not contain any information on service standards or quality (16.101 to 16.106).
Introduction
16.7 The Canadian income tax system is based on the principle of self-assessment. Taxpayers are responsible for calculating their obligations or entitlements. Yet, the Income Tax Act is not readily understood by the vast majority of people. To meet their obligations or determine their entitlements, therefore, taxpayers need other sources of information about the tax.16.8 National Revenue - Taxation (NRT) must prepare forms and publications that accurately reflect the law and at the same time are easy for people to use. NRT must provide ways for people to ask for and get answers to their questions. In fact, providing information services can form a part of all NRT's activities.
16.9 A recently completed report by the Service to the Public Task Force (part of the government's PS 2000 initiative) recognizes the importance of employees in providing government services and calls for three major changes:
- The public service must become more client-centred and effective in meeting citizens' needs and expectations;
- Public servants must consult much more actively with clients and other stakeholders in developing and administering programs; and,
- Managers must improve their performance so that public servants feel valued, motivated, informed and challenged to put forth their best efforts.
16.11 One output of the Initiative was a draft mission statement. The following is an excerpt from the draft statement:
We at Revenue Canada - Taxation are responsible to Canadians and their governments for excellence in the operation of the income tax system.
By excellence, we mean that all obligations are understood and honoured, all entitlements are received and all our clients have confidence in our capability and integrity.
To realize this mission, Revenue Canada -Taxation is committed to quality service that is:
- responsive to our clients' needs and built on consultation;
- impartial, fair and respectful of individual rights and the Declaration of Taxpayer Rights;
- open, accessible and understandable;
- efficient and courteous; and
- professional, prompt and willing.
We will achieve our mission through a highly capable work force which is equipped with state-of-the-art technology and dedicated to service.16.12 Service is singled out as a strategy to achieve the mission. This reflects a movement, evident in the Department for some time, towards a "service culture". Another major part of NRT's strategy, the use of enforcement, is implicit in the mission statement.
16.13 While the draft mission statement itself is new, some of its key ideas are not. NRT's Declaration of Taxpayer Rights, published a few years ago, reminds taxpayers that they are entitled to know and insist on certain rights. Particularly relevant to the subject of this chapter are the following concepts:
You are entitled to expect that the Government will make every reasonable effort to provide you with access to full, accurate and timely information about the Income Tax Act, and your rights under it.
You are entitled to courtesy and considerate treatment from National Revenue - Taxation at all times....
Audit Objectives and Scope
16.14 Because of the current interest within government in services to the public, and because NRT is taking steps that reflect its own concern in this area, we felt it would be timely to audit some of the Department's major service activities.16.15 The objectives of the audit were to determine whether NRT's programs for providing general services to the public are managed with due regard for economy and efficiency and whether satisfactory procedures have been established to measure and report on effectiveness. We also wished to determine whether Parliament is kept adequately informed of results.
16.16 We focussed on the most widely used of NRT's services and related products: general enquiries (by telephone, by correspondence, or in person); forms and publications; and taxpayer education and assistance programs. For the most part, these services are aimed at individual, rather than corporate, taxpayers. We also examined hiring, training and supervision of staff, because they have an impact on the quality of services offered. Finally, we looked at how Part III of the Estimates reports on services.
16.17 We excluded services that are ancillary to enforcement, collection or other activities that we audited and reported on in the last three years.
16.18 Exhibit 16.1 shows the program structure in NRT. The service activities examined during this audit were expected to consume 2,270 person-years, or 10 percent of total authorized person-years, and $162 million, or 13 percent of estimated departmental gross expenditures for 1990-91.
16.19 The audit involved work in 10 of 37 district offices, 3 of 7 taxation centres and 2 of 5 regional offices. Our audit also included work in the head office, which provides administrative support and functional guidance in respect to service activities.
Understanding and Responding to Expectations
16.20 An organization that is oriented toward service to the public should conduct research to identify clients and articulate client behaviour and expectations. A service organization needs standards defined in quantifiable terms and measurement of performance against them. Service standards should be set giving due regard to client expectations, program objectives and the feasibility and cost of providing service.
Consultative committees provide user input
16.21 NRT currently meets with numerous interest groups and advisory committees and has plans to extend its contacts. The scope of this communication goes beyond provision of services and includes matters of tax administration and enforcement. The Department has demonstrated that it does act upon the information and advice obtained.16.22 At the district office level, the extent of consultations with outside groups varies. For the most part, meetings take place with local accounting and law associations and deal with technical matters of tax law and administration.
The Department needs more feedback on services
16.23 In early 1991, NRT started a national program to monitor client satisfaction with its services. Questionnaire cards are available to taxpayers at all points of face-to-face contact with NRT employees. Taxpayers are asked the purpose of their contact with NRT, their overall rating of the service (excellent, good, fair or poor), whether service was courteous and explanations were clear, and whether they were served in their official language. Space is provided for additional comments. An appointment with a departmental representative can also be requested on the card.16.24 Also beginning in 1991, clients who call InfoTax (see paragraph 16.39) hear a recorded voice asking three questions: whether they found the information helpful; whether they will contact the Department for more information; and whether they would recommend the service to friends.
16.25 A limitation of the questionnaires is that replies are not obtained in a manner that will allow objective measurement of trends. Because of this, results cannot be correlated with internal performance measures to reveal how changes in these measures affect overall satisfaction ratings.
16.26 Other sources are needed to provide the following data that the questionnaires were not intended to capture:
- information on non-automated general telephone enquiries, which are one of NRT's major services;
- information about aspects of service that create value in the client's eyes and aspects that detract from the value; and
- information from people who might benefit from the services but who do not presently use them.
16.27 The Department should devise ways to obtain ongoing feedback on services not covered by its questionnaires.
Department's response: We have many mechanisms in place to obtain feedback from our clients, questionnaires being but one important vehicle. Other means include, at the national, provincial and local levels, face-to- face meetings, focus groups, advisory committees, and extensive consultations with tax practitioners and representative groups of taxpayers. We use exit survey cards at our district offices to solicit client feedback and we employ problem resolution officers at our offices who both obtain feedback from taxfilers and take action to deal with it.
A major objective of Revenue Canada - Taxation is enhanced client service. Our commitment to service is exemplified by our wide ranging services. Examples include a computerized telephone enquiry service called TIPS, Seasonal Tax Assistance Centres or STACs and FAX machines at our district offices for greater accessibility. In an effort to continue to be responsive to clients' needs, we will use appropriate mechanisms and strategies to obtain feedback on our services.
The Department does not make the most effective use of complaints as a source of information
16.28 An important aspect of ensuring client satisfaction and detecting opportunities for service improvements is proper complaint handling. There should be a comprehensive complaint handling policy that:
- assigns specific responsibility for registration and routing of complaints from all sources;
- specifies the manner of acknowledgment and response; and,
- prescribes a process for selecting complaints for detailed analysis to determine causes and actions needed to prevent recurrence.
16.30 A complaint is usually handled in the area about which it was made. No procedure is in place to log all complaints. Urgent or sensitive complaints, such as those from Members of Parliament, or complaints needing special attention and co-ordination of activities are referred to the Problem Resolution Program, which operates in each district office and taxation centre. Replies to complaints to the Minister or Deputy Minister are co-ordinated by the Taxpayer Correspondence Section in head office.
16.31 One of the Problem Resolution Program's objectives is to analyze trends in taxpayer complaints referred to it and identify causes so the Department can prevent the recurrence of particular problems. We found that trend analysis is not done.
16.32 The Department's Task Force on Organizational Effectiveness suggested that NRT consider enhancing the existing Problem Resolution Program and setting it up as a new division in district offices with authority and capacity to serve as an ombudsman for clients, politicians and tax preparers. This program would be advertised with a view to improving service, responsiveness and public education.
16.33 The Department should ensure that taxpayers are informed of where and how complaints may be lodged. Complaints should be analyzed, and results reported to senior management, with an explanation of actions taken in response to significant trends.
Department's response: Complaints may be lodged through contact with any departmental representative at any time and at any of our various locations. In addition, exit survey cards at district offices are widely used to solicit both positive and negative feedback on the level of service received. These cards also contain an item offering an opportunity for a face-to-face meeting if the taxfiler so requests. Statistics on 10,000 exit survey cards completed last spring reveal that 74 percent of clients rated our service as excellent and 22 percent said it was good.
To strengthen further our ability to respond to client concerns, two initiatives have been implemented. First, for 1991, both the General and Special Tax Guides contain a description of our Problem Resolution Program and the telephone number of a co-ordinator at each district office and taxation centre. Secondly, we are enhancing our Problem Resolution Program control system to reveal trends more accurately and to ensure more timely reporting of corrective actions initiated. A similar trend analysis is also being introduced in respect of general and ministerial correspondence.
Performance standards may not adequately reflect client expectations
16.34 Following sections of the chapter refer to a variety of service quality indicators and standards that NRT uses. Information and feedback obtained through consultation, questionnaires, surveys, and analysis of complaints could be used to ensure that the Department considers indicators and establishes standards that reflect an understanding of the performance desired by clients as well as program objectives and the feasibility and cost of providing service. At present, the Department has not ensured that its standards can satisfy client expectations to a reasonable extent.16.35 The Department should review its performance standards to determine whether they adequately reflect client expectations of service quality as well as program objectives and the feasibility and cost of providing service.
Department's response: We periodically review our standards and revise them towards improving the quality of service to our clients. We will continue to review our performance standards on an ongoing basis and we will consult extensively to determine and reflect client expectations in any revision to these standards.
Telephone Enquiries
16.36 NRT provides a general enquiries service through 37 district offices across the country. In 1990-91, agents were expected to handle about 7.7 million calls, including general enquiries, questions on the Goods and Services Tax Credit, and pension reform queries. They were also expected to deal with 1.5 million refund and Advance Child Tax Credit enquiries. The Department's automated enquiries services handled a further 835,000 general and tax credit enquiries and 634,000 refund enquiries. (See Exhibit 16.2 ) (See photograph )16.37 Each year the Department hires and trains hundreds of temporary employees to handle telephone calls during the busy season when people prepare and file their individual income tax returns. These temporary agents are expected to respond to all questions about material in the General Tax Guide. This amounts to about 75 percent of questions. For this work they are given three weeks of full-time training. However, students hired to respond to telephone enquiries in the evening are expected to answer a more limited range of questions and receive a lesser amount of training.
16.38 When the agent who first gets a call cannot answer the question, the call is passed on to a more experienced, permanent employee. If the question requires research before an answer can be given, the caller is to be notified within 24 hours.
The Department provides automated enquiries services to reduce demand on agents
16.39 In 1987-88, NRT initiated an automated telephone enquiry service called Telerefund that provides callers with the status of their income tax refunds. Automated service, which is available across Canada, has now been expanded to provide general information (InfoTax) and information on certain tax credits.16.40 NRT feels there are significant advantages to the automated system. The service extends beyond normal office hours. An evaluation of Telerefund showed that calls made to this automated system reduced the calls to the regular refund enquiries agents. Also, a departmental analysis estimated that calls through the automated Goods and Services Tax Credit enquiry system cost, on average, less than calls to agents.
The target level of service for general enquiries is lower than the Government Telecommunication Agency's guideline
16.41 The Department needs to provide readily accessible service delivery systems. Accordingly, it has set the following service standards for access to general enquiries agents:
- Not more than 30 percent of calls will get a busy signal. This level of service is referred to as "P30." Another way to express this standard is to say that, on average, it should take a caller no more than approximately 1.4 attempts to get an agent on the line.
- On average, a caller will not be put on hold in the call queue for more than 180 seconds before an agent comes on the line.
- Not more than 10 percent of calls in the call queue will be abandoned by the caller.
16.42 A Government Telecommunications Agency guideline recommends that toll-free (1-800) telephone numbers provided through the Government Shared Network deliver a level of service such that only 10 percent of calls will receive a busy signal. The guideline does not apply to service provided through regular local telephone numbers.
16.43 An opinion survey of NRT district office managers conducted by head office showed that complaints about accessibility rise sharply when upwards of 20 percent of callers get a busy signal.
The level of service standard is not met for much of the filing season
16.44 As noted above, the current objective of the Department is to provide a P30 level of service. National surveys of accuracy of responses to telephone enquiries performed during the 1990 and 1991 filing seasons indicate that the Department did not meet its standard for level of service in the 12-week period of each survey. The consultants who performed the surveys reported that, on average, it took 3.8 call attempts to get an agent on the line in 1990 and 3.2 attempts in 1991. This means that, on average, in 1990, over 73 percent of calls attempted by the consultants resulted in a busy signal. In 1991, the figure was over 68 percent.16.45 The Department does not have a reliable measure of levels of service for the part of the year not covered by the survey. The statistical method used by NRT to estimate levels of service is unreliable at levels poorer than P10. Telephone companies that use similar statistical estimates verify them by actual measurement of all calls attempted and calls connected. NRT does not verify its estimates by this or any other means.
16.46 The Department should develop reliable measures of levels of service that can be used throughout the year.
Department's response: The Department is committed to the pursuit of the most reliable measures available. We do this to the extent possible using statistical estimation techniques. Such measures tell us that we generally do meet our level of service standard except for the busiest hours of the filing season.
We will continue to use all methods available to us and to explore new measurement techniques as they become available.
The Department focusses on its standard for waiting time
16.47 NRT's use of several performance standards that support each other is consistent with the practice of other organizations that provide telephone enquiry services.16.48 An improvement of one measure used by NRT may be accompanied by a deterioration in another. In view of this, the Department focusses its attention on the standard for waiting time and manages its telephone systems accordingly.
16.49 To illustrate, when the number of calls to a district office increases to the point where the waiting time is excessive, NRT practice is to reduce the number of incoming telephone lines. Accordingly, callers will get a busy signal rather than being put on hold and having to wait for an extended period of time. (See Exhibit 16.3 .) For toll-free lines, this practice reduces the long-distance charges incurred by the Department.
16.50 Departmental statistics for the 1990 filing season show that the standard for abandonments was not met during busy hours in about 45 percent of the district offices. The 180-second standard for waiting time was generally met.
The Department's surveys do not provide an estimate of accuracy of replies to the public
16.51 According to the Declaration of Taxpayer Rights, the Department should provide full and accurate information. NRT takes this to imply a standard of 100 percent accuracy all the time.16.52 For the 1990 and 1991 tax return filing seasons, NRT hired a consulting firm to pose a series of test questions to telephone enquiries agents. The purpose of these surveys was to identify questions that were answered incorrectly and feed back the results to district offices so that managers and supervisors could take remedial action to improve accuracy. This supplements other means used by supervisors to improve agents' job performance.
16.53 The surveys of general enquiries were carried out over periods of 12 weeks and consisted of about 2,000 calls in 1990 and about 3,800 calls in 1991. Callers asked questions from a series of test questions covering a range of subjects. The responses were recorded, compared to the recommended answers, and analyzed by the consultants.
16.54 The survey for the 1990 filing season showed that 68 percent of answers to test questions were correct. For the 1991 survey, 80 percent were correct. During the surveys, whenever a question was answered incorrectly, the district office was promptly informed of the question and the correct response. The consultants cautioned that, because this feedback was given while the survey was in progress, the overall survey results may not be representative of the accuracy rate achieved in replies given to the general public. We noted that there are no other indicators to measure the accuracy of responses to public queries.
16.55 The Department should develop measures of performance for telephone enquiries that are representative of the accuracy rate of replies given to the general public.
Department's response: Our approach to improving accuracy includes after-the-fact measurement as well as building self-corrective measures directly into our programs. With regard to the latter, we continue to incorporate quality assurance, training and monitoring activities to obtain immediate feedback for corrective action. We are experimenting with expert systems technology towards improving accuracy.
Respecting measurement, we annually carry out a survey of telephone enquiries for the purpose of providing immediate feedback to our enquiries staff so improvements can be made. This was supplemented in 1989 with an independent survey conducted by a firm of chartered accountants, selected through a competitive process, to produce statistically valid results. We will repeat the independent survey from time to time to monitor our progress.
Enquiries agents are courteous
16.56 The Declaration of Taxpayer Rights indicates that NRT is to provide courteous and considerate treatment. NRT takes this to mean that staff are to be courteous all the time. The consultants who carried out the above- mentioned surveys also rated NRT agents on their courtesy. In 1990, the consultants found that agents were courteous in handling enquiries 97 percent of the time. In 1991, the consultants found that agents were courteous 95 percent of the time.
Temporary enquiries agents have little training or experience
16.57 In a service organization, the need for resources and skills should be based on the organization's service standards.16.58 The departmental Task Force on Organizational Effectiveness expressed concern that during the busiest time of the year, from February to April, the Department uses temporary employees having little experience or training as enquiries agents. Yet, NRT expects these employees to meet its high standard for accuracy as implied in the Declaration of Taxpayer Rights. The Task Force cites expert opinion that in such situations there is a high risk that service standards will not be met.
16.59 Each year NRT invites applications for jobs as enquiries agents. The qualifications demanded of applicants vary among district offices. Some applicants will have served as enquiries agents in prior years.
16.60 Applicants are given tests to evaluate technical ability, personal suitability, oral communication skills, tact and courtesy, and the ability to plan and organize. Each district office develops its own selection tests with little or no guidance from head office.
16.61 Temporary employees hired to answer general telephone enquiries take three weeks of training, or less in the case of students who are hired to work in the evenings and are expected to answer a more limited range of questions.
16.62 Permanent staff involved in the same work take more training. Training profiles are used to determine which courses a person has to take to be able to do the job. At the time of our audit, training profiles for enquiries agents were out of date and listed some courses that no longer existed. By May 1991, updated training profiles had been sent out to district offices.
16.63 Temporary and permanent enquiries staff complete training exercises but are usually not tested after completing courses. In some district offices that give a final test, persons who do not pass it are not retained as enquiries agents.
16.64 NRT may be able to improve its accuracy by using more permanent enquiries agents, training its temporary agents better, and/or hiring only those applicants who pass a test to demonstrate acceptable knowledge of the subject matter. However, the Department does not have the data available to determine whether these alternatives would be more cost-effective than its current way of doing business. NRT needs to conduct pilot studies to evaluate these and other possibilities.
16.65 The Department developed computerized expert systems for non-resident and source deductions enquiries activities. It plans to have an expert system available for general enquiries agents in 1993. If successful, the new system could help enquiries agents provide accurate responses.
16.66 The Department should consider performing pilot projects to test how using a higher ratio of permanent to temporary staff, modifying training programs for temporary staff, conducting qualifying technical examinations, or other alternatives would affect accuracy.
Department's response: The Department considers employment of temporary staff during peak periods to be the most efficient utilization of available resources and their use does not, in any way, compromise our desire for accuracy. To assist these employees, we introduced an electronic information bank which enquiries officers draw on as a key source of expertise in responding to questions from the public.
Many of our temporary enquiries people return year after year and thus require less new training. For new personnel, however, we carefully monitor their performance throughout the training period. Enquiries agents, including temporary staff, are trained to answer questions of the complexity ordinarily encountered. More complex enquiries are referred to more expert permanent staff.
In our pursuit of service excellence, we will analyze new approaches, including some of the pilot projects suggested by the Auditor General.
Counter Enquiries
16.67 District offices provide full counter services for taxpayers who wish to make enquiries in person. Taxation centres provide at least minimum counter services. The number of counter enquiries has been growing each year. (See photograph )16.68 NRT also provides extended counter service for those who need help to complete their returns. In several district offices, taxpayers are given guidance to complete their own returns. The number of taxpayers using this service is increasing.
16.69 During peak periods, Seasonal Tax Assistance Centres provide counter services similar to those of district offices. These centres do not have on-line access to taxpayer information, but they do carry forms and publications that are in high demand. They are open anywhere from one day to several weeks each year, depending on the size and location of the community being served. The centres are located primarily in portable work stations in shopping malls.
A departmental task force recommends a review of the structure and location of NRT offices
16.70 An important aspect of accessibility is the location of NRT offices. The last full-scale review of office locations was carried out in 1970. Since that time, a network of regional taxation centres has been set up and the former Montreal and Toronto District Offices have been split into several smaller district offices. A departmental Task Force on Organizational Effectiveness recommended that a full-scale review of office structure and location be carried out.
The Department recognizes that some service counters are not well designed for confidentiality
16.71 The Declaration of Taxpayer Rights states that taxpayers are entitled to considerate treatment. One way to show consideration is to respect the taxpayers' wishes for confidentiality.16.72 The Department has a variety of counter designs ranging from sit-down interview booths to stand-up counters. Private interview rooms are available upon request. A departmental study of counter designs concluded that side-by-side stand-up counters provide moderate confidentiality while other designs, with proper sound masking, provide higher confidentiality. The study recommended that new counter designs providing improved confidentiality be phased in over time, as district offices request renovations to their counter enquiries areas.
Waiting time at service counters is not adequately measured
16.73 The Department has a standard of 20 minutes for the average time a taxpayer should have to wait before being served at the counter. Of the 10 district offices we visited, only one gathers and reports relevant performance data.16.74 Managers assess the accuracy of answers given to counter enquiries by listening to conversations, noting employees' questions to supervisors and reviewing written material that arises from enquiries. There is no measurement of the accuracy of replies to counter enquiries similar to that done for telephone enquiries.
16.75 The Department should collect information on waiting times for comparison to existing standards. The Department should determine whether it is feasible to obtain an objective measurement of accuracy of replies to counter enquiries.
Department's response: Although we do not measure waiting times, it is routine practice to augment our counter staff in light of demand. Nevertheless, we recognize the importance of counter service to our clientele and we will explore other ways of measuring the accuracy of this service including enhancing the use of our exit survey cards.
Correspondence
16.76 General correspondence is handled mainly in NRT's seven taxation centres and, to a lesser extent, in district offices. Letters include questions about income tax publications or forms, taxpayers' accounts or their income tax returns. NRT's objective is to provide an accurate written answer within 30 days of receipt of a taxpayer's letter.
Systems are in place to ensure correspondence is complete, accurate and timely
16.77 In taxation centres, a computer system is used to monitor correspondence received, replies sent, response time, and the length of time each unanswered letter has been in inventory. In district offices, a register is usually kept that records taxpayer name, type of request, and the date a request is received. The completeness, accuracy and timeliness of replies to taxpayers are reviewed regularly by local management and periodically by Internal Audit and Quality Review of district offices and taxation centres.
Forms and Publications
16.78 NRT makes available to the public approximately 960 forms, 510 interpretation bulletins and information circulars, and 90 guides and pamphlets. In total, more than 175 million copies of these were printed during 1990. The number of forms and publications is increasing each year.
The Department is taking steps to improve its publications
16.79 NRT must prepare forms and publications that use simple language to accurately explain complex points of law and provide other information needed by its clients.16.80 Documents can be rated according to the level of education a person would need to read and understand them. This is referred to as a "readability" rating. For example, a document with a readability level of grade 8 should be understood by a person with at least that level of education.
16.81 NRT has not set readability targets for its authors or editors. Rather, it tries to tailor each publication according to the anticipated audience. However, in all cases, the philosophy is "the simpler the better".
16.82 NRT has recently taken a number of initiatives towards this goal:
- A readability team has been established to review and help simplify some newly written or updated publications.
- Writers and editors attend a course to teach them how to write in plain language.
- Readability guidelines for authors are being developed.
- Focus groups, comprising cross-sections of people who would use a particular form or publication, are brought together to review existing or new material. A number of external groups are also asked to assess publications. Comments from all sources are considered, and changes are made as appropriate.
- Some publications are being written in both official languages rather than being written in one and translated into the other.
Publications are becoming easier to read but are still not understandable to a large percentage of the adult population
16.83 Readability studies recently carried out by consultants for NRT on three of its tax guides showed that, on average, they fall in the grades 11 to 13 range. Using similar methodology, we examined four other popular departmental tax guides, including the General Tax Guide. Three of the guides had been reviewed by the NRT readability team. We found that, on average, readability scores fell in the grades 9 to 10 range. The guides were easier to read than earlier versions. Readability scores varied considerably in passages from different parts of the same guide. Scores in individual passages from guides examined by NRT's consultants and ourselves ranged from grades 7 to 16. (In this scoring system, grade 16 is equivalent to three or four years of university training.)16.84 The formulae used to measure readability look only at such things as word, sentence and paragraph length. The formulae do not consider other important features that have an impact on readability, such as content, organization and development of ideas, and layout of material. In our examination, we looked at these other features and concluded that here, too, much improvement was evident.
16.85 The fact that NRT's guides are written, on average, at the grades 9 to 13 level implies that they are still not understandable to a large percentage of the adult population. Statistics Canada reported in 1990 that 63 percent of adult Canadians can handle most everyday reading demands; 22 percent have limited reading abilities and can use only material that is simple and clearly laid out and involves tasks that are not too complex; and 15 percent are unable to deal with even simple materials. Almost 6.5 million adults fall inside the second and third categories. Of these, over 2 million have completed at least secondary schooling.
16.86 While it seems unrealistic to expect NRT to be able to reach the 15 percent of adults who are unable to deal with even simple materials, it may be able to reach those with limited reading ability. If NRT's publications are now more difficult than the materials Statistics Canada considered to represent "everyday reading demands", then even some of the 63 percent of adults who are most literate will be unable to understand them. This conclusion seems very likely when one considers that certain passages score at a grade 16 (see paragraph 16.83) readability level. The Department would need to simplify its publications further and to make the readability level consistent within each of them to be assured of reaching this group. (See Exhibit 16.4 )
16.87 By the end of our audit, the Department's readability team had been able to work on only 12 publications, but had plans to do more.
16.88 The benefit of having more easily understandable guides may accrue to the Department as well as to taxpayers. Since the answers to 75 percent of questions posed to general enquiries agents can be found in the General Tax Guide, further improvements to the Guide may have the effect of reducing general enquiries. This would free resources to be used for other purposes. Improved guides may also result in fewer taxpayer errors on returns, which could result in reducing resources used for processing returns.
16.89 The Department should perform a study to estimate the benefits that would result from making its publications easier to read and understand. The Department should ascertain, from the findings of the study, whether improvements to publications are being given appropriate priority and adequate resources.
Department's response: Further study is not required. Improved readability is a long-standing departmental priority and is a major consideration in the writing of departmental publications. While recognizing the complexity of the subject matter, all new publications are written in consideration of the target audience.
The Department has a readability program in place which includes a Readability Team and a training course on writing in plain language for employees working on publications. In addition to those initiatives referenced in paragraph 16.94 of this report, the new TI 65 Plus and TI No-Cal returns permit many individuals to complete their returns with little or no reference to the guide.
We supplement our written publications with a public enquiries service, small business seminars, videos, and other activities geared towards public education. For many years, the Volunteer Program and the tax preparation session have assisted those individuals who are unable to make use of our other information services. Our goal is to reach all Canadians through the best means available.
Some forms and publications are not available on time
16.90 Forms and publications should be available to taxpayers when needed. Distribution of forms and publications is a major task for the Department. For example, 24 million T1 returns are printed and distributed annually.16.91 In many instances, forms and publications were provided to district offices after the scheduled date. We found that some forms and publications were not available when requested or were made available to the public only days before they were due to be filed. Certain forms and publications were held up due to delays in the passage of related legislation. Many thousands of back orders were being held in district offices pending receipt of required material.
16.92 The fact that materials are not available when needed causes inconvenience and aggravation to the taxpayer and additional workload and mailing costs to the Department.
Education and Special Services Programs
16.93 NRT's education programs give current and potential taxpayers a better understanding of their rights and obligations under tax law and show them how to complete their income tax returns. They are meant to make it easier for taxpayers to comply with the law. (See photograph )16.94 The program entitled Teaching Taxes has been offered by NRT for about 20 years. Four more recent programs are: Small Business Tax Seminars, Tax Preparation Sessions, Distance Education, and a video, Stepping Through Your Tax Return. (Distance Education is noteworthy for its innovative use of communications technology: Taxpayers in remote communities can gather to receive help completing their returns via television monitors from an NRT employee located in an urban centre.)
16.95 NRT has various programs to help taxpayers complete their income tax returns, including the Community Volunteers Program and the Native Peoples Outreach Program.
16.96 Certain NRT initiatives are meant to help taxpayers with very simple tax situations. For example, the Department recently introduced T1 65 Plus and T1 Short returns, which have easy-to-read large print with only 11 and 32 lines respectively and require no calculations. NRT also issued a special three-year Federal Sales Tax Credit return for senior citizens to apply for unclaimed tax credits.
16.97 Besides the taxpayer assistance programs described earlier, NRT gives help to people with special needs:
- Hearing and visually impaired individuals are served through toll-free, bilingual enquiry services.
- Guides and other publications are available in braille, in large print or on audio cassette.
- Services are advertised in foreign language newspapers.
Determining the Benefits and Costs of Service Activities
16.98 NRT needs to know whether its service activities are achieving their objectives and contributing to the accomplishment of the Department's mission. It needs to know whether the benefits obtained from service activities are worth the cost. Such information would help NRT to determine whether any new activities should be introduced or whether existing activities should be expanded, cut back or discontinued.16.99 The Department has not performed program evaluations or other analyses that provide answers to these questions. In the absence of such information, it cannot demonstrate that its resources are optimally deployed between service and enforcement activities or among service activities.
16.100 The Department should evaluate the costs of its service programs in relation to their contributions to stated objectives and determine the appropriate allocation of resources.
Department's response: Because the Department is committed to the highest possible level of service quality, new service programs are piloted and tested while existing programs are periodically examined to determine their current appropriateness and cost effectiveness. Two examples where such evaluations were conducted are the Seasonal Tax Assistance Centre and the Telerefund programs.
As we begin implementing measures designed to improve our service, we intend to build in evaluation mechanisms to provide feedback on the progress achieved.
Accountability
Performance reporting concentrates on volume data, not on quality
16.101 The government's White Paper, Public Service 2000: The Renewal of the Public Service of Canada, states that: "Deputy Ministers will establish clear standards of service, and will be accountable both for the reasonableness of those standards and for the quality of the service provided to the public." In a similar vein, we believe that Part III of the Estimates should report to Parliament on the quality of services provided compared to service standards that the Department can justify as reasonable in relation to client expectations.16.102 NRT's Part III of the Estimates for 1991-92 contains only information on service volumes over time, such as the number of telephone enquiries received, letters answered, and certain publications printed. Other significant information relating to the quality of the Department's services should be developed and included in Part III of the Estimates to provide a clearer and more complete picture of NRT's performance.
16.103 The following measures are illustrative, but have not yet been proven to be representative of the quality factors that clients find important. Nor has it yet been shown how those measures that are internally focussed correlate with overall indices of client satisfaction.
- Telephone enquiries: Percentage of calls that get a busy signal; average time that taxpayers have to wait in the call queue before reaching an agent; percentage of calls in the queue that are abandoned before reaching an agent; and percentage of questions answered correctly.
- Counter service: Average time that taxpayers have to wait before being served.
- Written enquiries: Average time to reply to a taxpayer request and percentage of questions answered correctly.
- Forms and publications: Number of readability reviews performed and readability levels achieved compared to target levels.
16.105 In December 1990, the Treasury Board approved NRT's new Operational Planning Framework. In its submission to the Treasury Board, the Department listed several proposed performance measures, some of which are the same or similar to those suggested above. NRT's 1991-92 Part III of the Estimates notes the Department's intention to expand its reporting of performance information in Part III based on the new Framework.
16.106 The Department should develop and report in Part III of the Estimates measures of the quality of its services to accompany volume measures. Relevant standards should also be reported as a basis for comparison.
Department's response: As the Auditor General's report notes, the Department is developing performance indicators that will deal with the quality of service to our clients. Many of these measures are similar to those listed by the Auditor General. In fact, we noted in our 1991-92 Part III of the Estimates that we will expand performance reporting and thus measure the quality of service. The 1992-93 Part III will reflect this.
As our information measurement systems mature, we hope to develop increasingly accurate indicators of performance. As a matter of course, such measures will be included in Part III of the Estimates.
Conclusion
16.107 As stated earlier, our audit objective was to determine whether National Revenue -Taxation's programs for providing general services to the public are managed with due regard for economy and efficiency, and whether satisfactory procedures have been established to measure and report on effectiveness. We also wished to determine whether Parliament is kept adequately informed of results.16.108 Our findings show that there is some variation in the extent to which NRT has demonstrated due regard for economy and efficiency. The Department has devoted much effort to studying its operations with a view to identifying and correcting problems. This chapter notes many departmental initiatives aimed at enhancing economy, efficiency and effectiveness. Some improvements are already evident. However, there remain further opportunities for improvement.
16.109 In our view, a necessary step toward realizing these opportunities is setting up a full range of service quality standards based on knowledge of client expectations. NRT has standards, but they may not reflect client expectations to a reasonable extent. A natural corollary to this is the measurement and reporting of performance in relation to the standards. Another vital step is to perform evaluations to determine whether all of the Department's activities, and this need not be restricted to service activities, are contributing to its ultimate aims and whether the Department is appropriately allocating its resources to various activities.
16.110 With respect to accountability, we conclude that, because NRT's Part III of the Estimates focusses on service volume rather than service quality, Parliament has not been kept adequately informed of results, even in those areas where performance information presently exists.
