Administrative Burden

Administrative Burden

Policymaking by Other Means

Pamela Herd, Donald P. Moynihan

A basic truism of public administration is that different organizations with different histories, different expertise, and different professional backgrounds will approach the same problem in different ways. The IRS did not approach EITC compliance in the same way that traditional welfare agencies would, seeking more documentation before providing benefits. Instead, it approached EITC compliance as another form of tax compliance, which could be best addressed postpayment via cross-checks with other sources of information. The professional culture of the IRS led it to deal with a large population of tax filers by placing much of the verification burden on the government rather than on the individual. As compliance problems were identified, the IRS continued with this approach, with more aggressive cross-checks and use of administrative data to verify participant eligibility. The IRS also sought to change the rules in ways that favored simplification rather than complexity. Such rules both made verification checks easier and reflected an assumption that errors in reporting were at least partly because of confusion arising from the complexity of reporting requirements. Simplified child qualifying criteria were adopted in 1990, and the IRS was given authority by Congress to use Social Security numbers to cross-check dependent claims.

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