Effective Date: January 1, 2014

Previous Policy

IRS Income Match data must NOT be recorded or stored in any place where unauthorized persons may have access to it. Make sure there is NO information in the case that can be identified as IRS data.

To comply with the extra safeguards for IRS data, do not include it in the case record and keep all data which is clearly linked to IRS in locked storage.

NEVER include items in the case record that can form a direct link with the IRS match. Do not refer to IRS in the case record. This includes both notices and the case notes. Use general statements in both. The pre printed request for verification was designed to meet the safeguard rules. If it is completed as designed, it can be filed in the case record. If any extra information is added, it may no longer comply with the rules. Keep case notes entries general. Use "Checked unearned income" or "Cleared Match report." Any information that can be identified specifically as IRS data must be kept in locked storage separate from the case record including the pre-printed request form if it is changes to include any IRS specific information.

The pre-printed request for verification is designed to meet the safeguard rules. When completed as designed, it can be filed in the case record. If extra information is added to the form such as a reference to "Form 1099-R" or "IRS," it may no longer comply with the rules. Such a change would make clear the link between the request and the IRS match. Any information that can be identified specifically as IRS data must be kept in locked storage separate from the case record including the pre-printed request form if it is changed to include any IRS specific information.