Federal VITA/TCE Volunteer Standards of Conduct – Ethics Training

VITA/TCE Volunteer Standards of Conduct – Ethics Training
Publication 4961 (Rev. 10-2024)
4961

VITA/TCE Volunteer Standards of Conduct – Ethics Training

Volunteer Income Tax Assistance (VITA) / Tax Counseling for the Elderly (TCE)

2024 RETURNS

Take your VITA/TCE training online at apps.irs.gov/app/vita/. 

Link to the Practice Lab to gain experience using tax software 

and take the certification test online, with immediate scoring
and feedback.
Publication 4961 (Rev. 10-2024) Catalog Number 58618U Department of the Treasury Internal Revenue Service www.irs.gov

How to Get Technical Updates?

Updates to the volunteer training materials will be contained in Publication 4491-X, VITA/TCE Training Supplement. The
most recent version can be downloaded at: www.irs.gov/pub/irs-pdf/p4491x.pdf

Volunteer Standards of Conduct
Volunteer Income Tax Assistance / Tax Counseling for the Elderly (VITA/TCE)
The mission of the VITA/TCE return preparation programs is to assist eligible taxpayers in satisfying their tax
responsibilities by providing free tax return preparation. To establish the greatest degree of public trust, volunteers are
required to maintain the highest standards of ethical conduct and provide quality service.
Annually all VITA/TCE volunteers must pass the Volunteer Standards of Conduct (VSC) certification test and agree that
they will adhere to the VSC by signing and dating Form 13615, Volunteer Standards of Conduct Agreement – VITA/TCE
Programs, prior to volunteering at a VITA/TCE site. In addition, return preparers, quality reviewers, coordinators, client
facilitators, and tax law instructors must certify in Intake/Interview and Quality Review. Volunteers who answer tax law
questions, instruct tax law classes, prepare or correct tax returns, or conduct quality reviews of completed returns must
also certify in tax law prior to signing the form. Form 13615 is not valid until the sponsoring partner’s approving official
(coordinator, instructor, administrator, etc.) or IRS contact confirms the volunteer’s identity, name, and address, using
government-issued photo identification, and signs and dates the form. Volunteers’ names and addresses in Link & Learn
taxes must match their government-issued photo identification. Advise volunteers to update their My Account page in
Link & Learn Taxes with their valid name and address.
As a volunteer in the VITA/TCE programs, you must adhere to the following Volunteer Standards of Conduct:
VSC #1 – Follow all Quality Site Requirements (QSR).
VSC #2 – Do not accept payment, ask for donations, or accept refund payments for federal or state tax return
preparation from customers.
VSC #3 – Do not solicit business from taxpayers you help or use the information you gained about them (taxpayer
information) for any direct or indirect personal benefit for yourself, any other specific individual or organization.
VSC #4 – Do not knowingly prepare false returns.
VSC #5 – Do not engage in criminal, infamous, dishonest, notoriously disgraceful conduct, or any other conduct
considered to have a negative effect on the VITA/TCE programs.
VSC #6 – Treat all taxpayers in a professional, courteous, and respectful manner.
Failure to comply with these standards could result in, but is not limited to, the following:
•
•
•
•
•
•
•

Removal from all VITA/TCE programs
Inclusion in the IRS Volunteer Registry to bar future VITA/TCE activity indefinitely
Deactivation of your sponsoring partner’s site VITA/TCE electronic filing identification number (EFIN)
Removal of all IRS products, supplies, loaned equipment, and taxpayer information from your site
Termination of your sponsoring organization’s partnership with the IRS
Termination of grant funds from the IRS to your sponsoring partner and
Referral of your conduct for potential TIGTA and criminal investigations

TaxSlayer® is a copyrighted software program owned by Rhodes Computer Services. All screen shots that appear
throughout the official Volunteer Income Tax Assistance (VITA) and Tax Counseling for the Elderly (TCE) training
materials are used with the permission of Rhodes Computer Services.
Confidentiality Statement:
All tax information you receive from taxpayers in your volunteer capacity is strictly confidential and should not, under any
circumstances, be disclosed to unauthorized individuals.

4961 Table of Contents

Volunteer Standards of Conduct (Ethics) Training

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Introduction
Objectives

Unethical Defined

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Volunteer Standards of Conduct (VSC)

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Taxpayer Civil Rights
Due Diligence

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Failure to Comply with the Volunteer Standards of Conduct
Volunteer Protection Act

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Instructions for Completing Training, Certifications, and the VSC Agreement
Resolving Problems

Exercise Answers
Form 13615

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Link & Learn Taxes

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Volunteer Standards of Conduct (Ethics) Training

Introduction
The integrity of the Volunteer Income Tax Assistance (VITA) and Tax Counseling for the Elderly (TCE)
programs depends on maintaining public trust. All taxpayers using VITA/TCE services should be confident
they are receiving accurate tax return preparation and quality service.
All volunteers are responsible for providing the highest quality and best service to taxpayers. Along with this
responsibility, all volunteers must sign and date Form 13615, Volunteer Standards of Conduct Agreement –
VITA/TCE Programs, each year, stating they will uphold the highest ethical standards and follow all Quality
Site Requirements (QSR).
Furthermore, all IRS Stakeholder Partnerships, Education and Communication (IRS-SPEC) partners
must sign either Form 13533, Sponsor Agreement or Form 13533-A, FSA Remote Sponsor Agreement,
certifying they will adhere to the strictest standards of ethical conduct. By signing this agreement, the
sponsor agrees to make certain their volunteers are aware of the standards of conduct and the key
principles of privacy and confidentiality.
New volunteers must complete the Volunteer Standards of Conduct (VSC) Training. Returning volunteers
are encouraged to review the VSC Training as a refresher. All VITA/TCE volunteers must pass a VSC
certification test with a score of 80% or higher. The VSC Training will provide:
•

An explanation of the six Volunteer Standards of Conduct listed on Form 13615

•

Information on how to report possible violations

•

Consequences of failure to adhere to the program requirements

•

Examples of situations that raise questions on ethical behavior

Why do we have Ethics Training?
During past filing seasons, the Treasury Inspector General for Tax Administration (TIGTA) and IRS-SPEC
discovered unacceptable practices at a few VITA/TCE sites. In response to these issues, IRS-SPEC
enhanced the Volunteer Standards of Conduct. The intent is to provide guidance and a structure for
regulating VITA/TCE volunteers and to protect taxpayers.
When unscrupulous volunteers intentionally ignore the law, it compromises the integrity of the VITA/TCE
program and the public’s trust. Unfortunately, due to the actions of a few, the VITA/TCE programs’ integrity
and trust have been tested. In these cases, IRS-SPEC can and does take appropriate actions against the
partners and volunteers involved.
IRS-SPEC is ultimately responsible for oversight of the VITA/TCE program. The agency often
receives complaints from taxpayers, partners, and congressional members when notices are issued.
IRS-SPEC researches and responds to all inquiries.

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Objectives
At the end of this lesson, you will be able to:
•

List the six Volunteer Standards of Conduct

•

Describe unethical behavior

•

Use the external referral process to report unethical behavior

•

Identify consequences for failing to comply with the standards

•

Explain how volunteers are protected

What do I need?
•

Form 13615, Volunteer
Standards of Conduct
Agreement – VITA/TCE
Programs

•

Publication 5683,
VITA/TCE Handbook
for Partners and Site
Coordinators

•

Publication 4299, Privacy,
Confidentiality, and Civil
Rights – A Public Trust

Unethical Defined
IRS-SPEC defines unethical as not conforming to agreed standards of
moral conduct, especially within a particular profession. In most cases,
unethical behavior is acted upon with the intent to disregard the established
laws, procedures, or set policies.
Do not confuse an unethical action with a lack of knowledge or a simple
mistake.

Mary prepared a return which included a credit the taxpayer did not qualify for. Mary did not understand the law, so she did not act unethically. However, if Mary knowingly allowed a credit for which the
taxpayer did not qualify, Mary committed an unethical act and violated the Volunteer Standards of Conduct.

Volunteer Standards of Conduct (VSC)
Often volunteers face ethical issues, which arise in unexpected situations requiring quick decisions and
good judgment. In many cases, the volunteer will react to unusual situations and not realize until later that it
was, in fact, an ethical dilemma.
The Volunteer Standards of Conduct were developed specifically for the operation of free tax preparation
programs. Form 13615, Volunteer Standards of Conduct Agreement – VITA/TCE Programs, applies to all
conduct and ethical behavior affecting the VITA/TCE programs. Volunteers must agree to adhere to the
standards of conduct prior to working in a VITA/TCE free tax return preparation site.
All participants in the VITA/TCE programs must adhere to these Volunteer Standards of Conduct:
VSC #1 – Follow all Quality Site Requirements (QSR).
VSC #2 – Do not accept payment, ask for donations, or accept refund payments for federal or state tax
return preparation from customers.
VSC #3 – Do not solicit business from taxpayers you help or use the information you gained about them
(taxpayer information) for any direct or indirect personal benefit for yourself, any other specific
individual or organization.
VSC #4 – Do not knowingly prepare false returns.
VSC #5 – Do not engage in criminal, infamous, dishonest, notoriously disgraceful conduct, or any other
conduct considered to have a negative effect on the VITA/TCE programs.
VSC #6 – Treat all taxpayers in a professional, courteous, and respectful manner.

VSC #1 – Follow all Quality Site Requirements (QSR).
The purpose of the Quality Site Requirements (QSR) is to ensure the quality and accuracy of tax return
preparation and consistent operation of sites.
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Non-adherence to any QSR only becomes a violation of the VSC if volunteers refuse to follow the QSR. If
the problem is corrected, it is not a violation of the VSC.
Refer to Publication 5166, VITA/TCE Volunteer Quality Site Requirements, for a full explanation of each
QSR. See a brief description of the ten QSR below:
QSR #1, Certification
Volunteers must complete their certifications using the IRS electronic tests through Link & Learn
Taxes (LLT). Volunteers who prefer to take the Certification Test on paper utilizing Form 6744, VITA/
TCE Volunteer Assistor’s Test or Retest, may continue to complete the test using that method but must
transcribe their answers to the test in LLT. Volunteers’ names and addresses in Link & Learn taxes must
match their government-issued photo identification. SPEC recommends that volunteers update their My
Account page in LLT with their valid name and address.
•

Volunteer training may consist of classroom training, self-study, and/or LLT.

•

Volunteers have two attempts to pass each certification with a passing score of 80% or above on each
certification.

Volunteer Standards of Conduct (VSC) Training
New volunteers must take the VSC Training. The training is available in LLT and in Publication 4961,
VITA/TCE Volunteer Standards of Conduct – Ethics Training. SPEC encourages returning volunteers to
review the VSC training as a refresher. All volunteers must pass the VSC certification using LLT prior to
working at a site.

VITA/TCE Intake/Interview and Quality Review Training
All new and returning volunteer instructors, preparers, coordinators, and quality reviewers must take
Publication 5101, VITA/TCE Intake/Interview and Quality Review Training and pass Intake/Interview and
Quality Review certification. Volunteer greeters, screeners and client facilitators who assist taxpayers with
completing Form 13614-C, Intake/Interview and Quality Review Sheet, must also take Intake/Interview and
Quality Review Training and certify.
•

This training will be offered virtually with a Q&A session via Webcaster. Link is available in Publication
5325, Fact Sheet: Filing Season Training for SPEC Partners and Volunteers.

•	 All

volunteer greeters, screeners and client facilitators who assign tax returns for return preparation must
also take Intake/Interview and Quality Review Training and certify.

VITA/TCE Tax Law Training
Volunteers who answer tax law questions, instruct tax law classes, prepare, or correct tax returns, and/or
conduct quality reviews of completed tax returns, must certify in tax law prior to conducting tax law related
tasks. Screeners and client facilitators who answer tax law questions must also certify in tax law. Tax law
certification is an annual requirement. Volunteers who do not help with tax law related issues (for example,
greeters, receptionists, equipment coordinators) do not have to certify in tax law but must still complete
the VSC certification test via LLT.
IRS tax law certified volunteer preparers must prepare tax returns that are within scope of the VITA/ TCE
program. Volunteers must spot out-of-scope returns early in the tax return preparation process. Refer all
out-of-scope tax returns to a professional tax return preparer. Scope refers to VITA/TCE tax law topics
applied to a volunteer prepared tax return. Scope does not refer to income levels. A Scope of Service Chart
is in Publication 4012, VITA/TCE Volunteer Resource Guide.
•	 Tax

law instructors must certify in tax law at the Advanced level or higher.

•	 IRS

tax law certified volunteer preparers can only prepare returns with tax issues that fall within their
certification level. If the site is preparing tax returns above the Basic certification level, the volunteer
preparer must certify to the level needed to prepare these returns.
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•	 Designated

and peer-to-peer quality reviewers can only quality review returns with tax issues that fall
within their certification levels. If the site is preparing tax returns above the Basic certification level, the
quality reviewers must certify to the level needed to quality review these returns.

Specialty Certifications
•

Volunteers may take other specialty certifications.
◦

Volunteers must first certify in Volunteer Standards of Conduct before taking Over the Phone Interpreter
(OPI) certification

◦

Volunteers must first certify at either Basic or Advanced level before taking the specialty certification for
Puerto Rico.

◦

Volunteers must first certify at the Advanced level before taking the Military and International specialty
certifications.

•

Federal Tax Law Update Test for Circular 230 Professionals (C230) - SPEC offers a tax law certification
test that allows VITA/TCE volunteers who have the professional designation of attorney, Certified Public
Accountant (CPA), or Enrolled Agent (EA) to certify on new provisions and tax law changes. Volunteers with
professional designations must have an active license and be in good standing. In addition, the volunteers
must first certify in Volunteer Standards of Conduct and Intake/ Interview and Quality Review. The C230 test
is an optional certification. Volunteers who want more training can choose the traditional certification paths
available to all volunteers.

•

Volunteers who successfully pass the C230 test can prepare all tax returns within the scope of the VITA/
TCE program. SPEC created the minimum certification requirements for volunteers who are authorized
under Circular 230; however, partners may establish additional certification requirements for their
volunteers. Volunteers and coordinators should check with the sponsoring SPEC partner.
Volunteers who certify only in C230 for tax law are not eligible for Continuing Education (CE) credits.

SPEC requirements may be different from partner requirements. Partners may require a higher level of
training. However, partner requirements can never be lower than IRS requirements. For example, some
partners require their coordinators to be certified at the Advanced tax law certification level, even if they do not
give tax law advice, prepare, or correct tax returns. For example, AARP Foundation Tax-Aide (Tax-Aide)
requires tax counselors to certify at the Advanced level. This is an acceptable practice.
Coordinators and alternate coordinators must complete site coordinator training annually. There are several
options for completing site coordinator training:
•

Attend local territory training sessions scheduled between October and December.

•

Attend partner-provided training on the topics covered in Publication 5088, VITA/TCE Site Coordinator
Training or

•

Review Publication 5088, which is available on Link & Learn Taxes (LLT) or IRS.gov.

QSR #2, Intake/Interview and Quality Review Process
All taxpayers using the services offered through the VITA/TCE programs should be confident they are
receiving accurate return preparation and quality service. Three vital processes that result in accurate returns
and quality service are: effective intake, thorough taxpayer interview and quality review of the tax return. All
sites must use Form 13614-C, Intake/Interview and Quality Review Sheet, for every tax return prepared by an
IRS-certified volunteer. Form 13614-C guides the IRS-certified volunteer preparer through the interview with
the taxpayer and allows them to gather all necessary information to prepare an accurate return.
Every site must use a complete quality review process for all returns prepared to ensure accuracy. A tax
return is considered accurate when tax law is applied correctly, and the completed return is free from error
based on the completed Form 13614-C, Intake/Interview and Quality Review Sheet (or Form 13614-NR),
the taxpayer's interview and the taxpayer’s supporting documentation. All returns must be quality reviewed
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and discussed with the taxpayer using the designated or peer-to-peer review. Self Review is not allowed. All
returns must be quality reviewed by another volunteer certified to the level required for the return.
Form 13614-NR, Nonresident Alien Intake and Interview sheet is also available for use at sites
serving nonresident alien taxpayers. Volunteers are required to be certified in Foreign Student and
Scholar to use this form to prepare Form 1040-NR, US Nonresident Alien Income Tax Return.
QSR#2 requires a volunteer to have a complete Form 13614-C before preparing each tax return.
Volunteers must verify each answer on pages 1 through 3. On pages 2 and 3, confirm each checked
box is accurate. If a taxpayer incorrectly checked a box, erase or cross out the box and put your initials.
Use the gray shaded column on the right side of pages 2 and 3 to leave notes or clarify answers. There is
additional space for preparer notes on page 5.
QSR #3, Confirming Photo Identification and Taxpayer Identification Numbers (TIN)
Coordinators must have a process in place to confirm taxpayers’ identities and taxpayer identification
numbers (TIN). All volunteers must follow the site's process prior to tax return preparation. In addition, the
quality reviewer must perform the verification procedures again during quality review before taxpayer signs
and receives a copy of the prepared tax return.
This process must include using acceptable documents to confirm taxpayers’ identities and TIN by
reviewing:
•

Original photo identification (ID) for the taxpayer (and spouse, if married filing jointly); and

•

Social Security numbers (SSN) and individual taxpayer identification numbers (ITIN) for everyone listed
on the tax return and

•

Correct spelling of names for everyone listed on the tax return

Please refer to Publication 4299 for more information about acceptable documents for photo identification
and to confirm a TIN. Publication 4299 provides exceptions for validating taxpayer identities subject to
coordinator approval.
QSR #4, Reference Materials
All sites must have, in paper or electronic form, the following reference materials available for use by IRS tax
law certified volunteers:
•

Publication 17, Your Federal Income Tax (For Individuals)

•

Publication 4012, VITA/TCE Volunteer Resource Guide

•

Publication 4299, Privacy, Confidentiality, and Civil Rights – A Public Trust

•

Volunteer Tax Alerts (VTA) and Quality Site Requirement Alerts (QSRA) or CyberTax Alerts issued by TaxAide

QSR #5, Volunteer Agreement

Form 13615, Volunteer Standards of Conduct Agreement - VITA/TCE Programs.
Annually, all volunteers (coordinators, return preparers, quality reviewers, greeters, screeners, client
facilitators, etc.) must complete the Volunteer Standards of Conduct (VSC) certification. In addition they
must agree to follow the VSC by signing and dating Form 13615.
The partner’s approving official must also certify (sign and date) Form 13615. This confirms that the
partner’s approving official has verified the volunteer’s identity, name, and address, using governmentissued photo identification. The partner must also confirm the volunteer has passed the required IRS
training certification test(s), and the volunteer has signed and dated Form 13615. Every volunteer’s Form
13615 must be certified prior to their volunteering at a VITA/TCE site. This approving official can be the
coordinator, sponsoring partner official, instructor, or IRS contact, as appointed by the partner.
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The approving official must confirm volunteers’ identities, names, and addresses using government-issued
photo identification (ID), when reviewing and signing Forms 13615. SPEC partners and coordinators can
review volunteers’ government-issued photo ID electronically. Government-issued photo identification
(ID) includes valid driver’s license (U.S.), state ID (U.S.), Military ID, national ID, visa, Global Entry ID, or
passport. Coordinators can make exceptions to use official high school identification for students taking part
as volunteers in an official VITA/TCE High School program. The name on Form 13615 must match both
the name on the government-issued photo ID and the volunteer’s name added to TaxSlayer or other tax
preparation software. SPEC does not allow the use of volunteer nicknames in the tax preparation software.
Volunteers’ names and addresses in LLT must match their government-issued photo ID. Advise
volunteers to update their My Account page in LLT with their valid name and address.
Coordinators must exercise due diligence and have a method to verify training certification the day
the volunteer reports to the site.
The approving official must confirm volunteers’ identities, names, and addresses using government-issued
photo identification (ID), when reviewing and signing Forms 13615. SPEC partners and coordinators can
review volunteers’ government-issued photo ID electronically. Government-issued photo identification
(ID) includes valid driver’s license (U.S.), state ID (U.S.), Military ID, national ID, visa, Global Entry ID, or
passport. Coordinators can make exceptions to use official high school identification for students taking part
as volunteers in an official VITA/TCE High School program. The name on Form 13615 must match both
the name on the government-issued photo ID and the volunteer’s name added to TaxSlayer or other tax
preparation software. SPEC does not allow the use of volunteer nicknames in the tax preparation software.
Coordinators who prepare tax returns, provide tax law assistance, correct rejected returns, or quality
review tax returns must certify in tax law to the level required for the complexity of the returns. If they
do NOT perform any of these duties, they are not required to certify in tax law, as shown by the dotted line
in the certification paths chart.
Tax Preparers

Instructors, Quality
Reviewers

Coordinators

Circular 230
Volunteers

All Other Volunteers

Volunteer Standards of Conduct Training & Certification
Intake/Interview and Quality Review Certification
Site Coordinator
Certification
Tax Law Certification

*Federal Tax Law Update Test for Circular 230 Professionals
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Circular 230
Certification*

SPEC Over-thePhone Interpreter
(SPEC OPI, optional
certification)

QSR #6, Timely Filing of Tax Returns
All coordinators must have a process in place to ensure every tax return is timely electronically filed or
delivered to the taxpayer. Refer to Publication 1345, Handbook for Authorized IRS e-file Providers of
Individual Income Tax Returns, for guidance on e-filing returns, stockpiling of returns and resolving rejects.

E-filing Returns and Stockpiling of Returns
Stockpiling is waiting more than three calendar days to submit the return once the site has all necessary
tax documents. Tax returns must be e-filed no more than three calendar days after the site has secured all
necessary information from the taxpayer and completed all necessary tax preparation steps required to file
the taxpayers return electronically.
This means the taxpayer has completed the intake/interview process, provided all necessary tax
documents, completed the Quality Review and has provided consent to the site to e-file the return by
signing Form 8879. Once these steps have been completed, the VITA/TCE site has three calendar days to
e-file the return.
Returns must be completed within a reasonable timeframe. If due to lack of response, delays with
resolving rejects, signing Form 8879 or volunteer staffing, sites must notify taxpayers that the return
has been deactivated in the tax preparation software and to return to the site to pick up their tax
documents. If the taxpayer does not return to the site, per Publication 4299, Privacy, Confidentiality, and
Civil Rights, sites must properly dispose of tax documents including burning or shredding the data.

Extension to File Returns
Sites can assist taxpayers with filing Form 4868, Application for Automatic Extension to File US Individual
Income Tax Return, with the consent of the taxpayer and when the facts and circumstances of the
taxpayer’s situation indicate filing an extension to file their return is the correct tax determination for the
taxpayer.
In order to e-file the Form 4868 on behalf of the taxpayer, the Form 8878, IRS E-file Signature Authorization
for the Form 4868 or Form 2350 MUST be signed by the taxpayer prior to the e-filing of the Form 4868.
QSR #7, Civil Rights
All VITA/TCE sites must make available to all taxpayers who seek services at the site information on Title
VI of the Civil Rights Act of 1964 by providing the current Publication 4053 (en-sp), Your Civil Rights are
Protected Poster for IRS Assisted Programs (VITA/TCE/LITC) (English & Spanish), or a current D143,
AARP Foundation Tax-Aide (poster).
These posters provide volunteers and taxpayers with contact information to report discriminatory treatment.
If a taxpayer or volunteer has a civil rights complaint, refer them to the contact information on Publication
4053 (en-sp). If taxpayers request the information in writing, offer Publication 4454, Your Civil Rights are
Protected. Publication 4454 is an optional brochure designed to notify taxpayers of their civil rights when
the site cannot provide tax preparation services (for example, lack of information to prepare the return, the
return is not within scope of the VITA/ TCE program).
Taxpayers must have access to the civil rights information even if they do not have a tax return 

prepared. At a traditional site, the poster must be visible at the first point of contact between the 

taxpayer and volunteer. For virtual sites, the poster must be sent or made available to all seeking services.

QSR #8, Correct Site Identification Number (SIDN)
All tax returns prepared by VITA/TCE sites must include the correct site identification number (SIDN). E-file
administrators must set tax software defaults to make sure the correct SIDN automatically appears on each
tax return. Partners or coordinators should work with their local SPEC territory office to make sure they are
using the correct SIDN.

7

QSR #9, Correct Electronic Filing Identification Number (EFIN)
All tax returns prepared by VITA/TCE sites must include the correct electronic filing identification number
(EFIN). All partners must use the online IRS e-file application process found in E-Services on IRS.gov to
apply for an EFIN or update an application. A separate EFIN is required for each physical location. E-file
administrators should set the tax software defaults to ensure the correct EFIN automatically appears on
Form 8879, IRS e-file Signature Authorization.
QSR #10, Security, Privacy, and Confidentiality
Publication 4299, Privacy, Confidentiality, and Civil Rights - A Public Trust, is the resource document
for guidance on securing and protecting personally identifiable information (PII) shared by taxpayers,
volunteers, and partners. A copy (paper or electronic) must be available at the site. Sites must follow all
security, privacy, and confidentiality guidelines as outlined in Publication 4299.
All coordinators must have security procedures in place as described in Publication 4299 for the following
processes:
•	 Preparing

an annual security plan to safeguard taxpayer data. Sites can use Form 15272, VITA/ TCE
Security Plan, or a similar document that captures the same information. See note below for more
information on Form 15272.

•

Protecting all computers with passwords.

•

Using a hard-wired internet connection or encrypted and password protected wireless internet connection.

•

Securing computers, printers, and all equipment.

•

Safeguarding PII at the site by safely storing and/or properly disposing of the information.

•

Properly securing signatures on IRC Section 7216 required consent notices.

•

Limiting volunteer access privileges to the tax software based on assigned roles.

•

Generally restricting volunteer access to the tax software.

•

Deactivating usernames in the tax software when volunteers quit, resign, or are no longer working at the
site.
For additional information on Quality Site Requirements, refer to Publication 5166, VITA/TCE
Volunteer Quality Site Requirements.

VSC #2 – Do not accept payment, ask for donations, or accept refund payments for federal
or state tax return preparation from customers.
“Free” means we do not accept payment for our services from the clients we serve. We do not want to
confuse the taxpayer by asking for donations. Donation or tip jars located in the return preparation or
taxpayer waiting area are a violation of this standard. Donation or tip jars can be placed in another area
at the site as long as that area does not give the impression that the site is collecting the funds for return
preparation. Donation or tip jars cannot be in the entry, waiting, tax preparation, or quality review areas.
A client may offer payment, but always refuse with a smile and say something like, “Thank you, but
we cannot accept payment for our services.” If someone insists, recommend cookies or donuts for the
site. Taxpayers can make cash donations to the sponsoring organization, but not in the tax preparation
area. Refer taxpayers who are interested in making cash donations to the appropriate website or to the
coordinator for more information.
Having fee-based preparation at the VITA site location while the VITA site is open is like tip jars within
the preparation space. This causes confusion to the taxpayer as VITA is advertised as a free service.
You finish a time-consuming return and the client is very grateful. On her way out, the client stops by
and tries to sneak a $20 bill in your pocket, saying, “I would have paid ten times that at the preparer
across the street.” Return the money and explain that you cannot accept money for doing taxes.
8

Taxpayers’ federal or state refunds must not be deposited into VITA/TCE volunteers', partners' or any
associated organizations' personal or business bank/debit card accounts. VITA/TCE sites must only
request direct deposit of a taxpayer’s refund into accounts bearing the taxpayer’s name.
Some VITA/TCE sites use employees of the sponsoring organization to prepare tax returns as a part
of their work duties. This is not considered receiving payment from the customer and is not a violation
to this VSC.

VSC #3 – Do not solicit business from taxpayers you help or use the information gained
about them (taxpayer information) for any direct or indirect personal benefit for yourself,
any other specific individual or organization.
Volunteers must properly use and safeguard taxpayers’ personal information. Volunteers may not use
confidential or nonpublic information to engage in financial transactions. They cannot allow improper use of
taxpayer information to further their own, another persons' or organizations' private interests.
SPEC encourages partnering with banks or credit unions to promote unbanked taxpayers to open bank
accounts. However, sites and volunteers cannot offer clients refund anticipation loans (RAL) or refund
anticipation checks (RAC) when preparing federal or state tax returns.
Below is guidance for banks or credits unions who partner with VITA/TCE:
•	 VITA/TCE

coalitions and partners must take steps, so taxpayers clearly understand tax services remain
free of cost regardless of whether they sign up for a bank or credit union membership or a refund
anticipation loan.

•

Bank or credit union information/enrollment tables must remain in a separate space from tax return
preparation.

•	 Bank

or credit union offerings must be announced using general terms to potential customers separate
from tax return preparation.

•	 Volunteers

must not promote bank or credit union services by using information provided by the taxpayer
to prepare a tax return (such as the taxpayer not having a bank account or the amount of the tax refund).

•

SPEC encourages VITA/TCE coalitions and partners to reach out and find additional financial institutions
to offer services at VITA/TCE sites. To avoid the appearance of endorsement or preferential treatment,
SPEC recommends giving other financial institutions with similar products with the same or similar terms
to be present at the location separate from tax return preparation.

SPEC determined having a representative of a bank or credit union present at the same location as a
VITA/TCE site but separate from the tax return preparation space is not a violation of VSC #3 even if
that bank provides RACs/RALs as part of its overall business.
The partner operates a paid tax service in addition to having a VITA site in the same facility. The
volunteer reviews the income documents and determine the taxpayer’s total income is above the VITA
income limit. The volunteer then directs customers to their paid service for taxpayer convenience, so they do
not have to seek services elsewhere. You explain that this is a violation of VSC #3. Partner used taxpayer
information gained during the Intake/Interview process for direct personal benefit to their organization.
Your primary business includes selling health insurance policies. During the interview, you find out the
taxpayer lost access to health insurance in January of the current year. You cannot offer to sell the
taxpayer health insurance through your business.
You are a volunteer preparer and an accountant. You cannot solicit business from the taxpayer.
You are the site’s greeter. Your daughter asks you to take candy orders at the site for her school
fundraiser. You explain to her that as a VITA/TCE volunteer you cannot solicit personal business.

9

Securing consent
There will be some instances when taxpayers will allow the use of their personal information other than for
return preparation. Under Internal Revenue Code § 7216, all volunteer sites using or disclosing taxpayer
data for purposes other than current, prior, or subsequent year tax return preparation must secure a consent
from the taxpayer. There are several types of consents: Global Carry Forward Consent, Relational EFIN
Consent, and Use and Disclosure Consents. The coordinator will have a process in place if consents are
required at your VITA/TCE site.
Exceptions to required consents
Volunteer sites that use or disclose the total number of returns (refunds or credits) prepared for their
taxpayers at their site (aggregate data) for fundraising, marketing, and publicity are not required to secure
taxpayers’ consent. This information cannot include any Personally Identifiable Information (PII), such as
the taxpayer’s name, SSN/ITIN, address or other personal information, and does not disclose information
containing data from fewer than ten tax returns.
This exception does not apply to the use or disclosure in marketing or advertising of statistical compilations
containing or reflecting dollar amounts of refunds, credits, rebates, or related percentages.
IRC 7216(a) – Imposes criminal penalties on tax return preparers who knowingly or recklessly make
unauthorized disclosures or uses of information furnished in connection with the preparation of an
income tax return. A violation of IRC 7216 is a misdemeanor, with a maximum penalty of up to one year
imprisonment or a fine of not more than $1,000, or both, together with the cost of prosecution.
For additional information on IRC 7216 required consents, refer to Publication 4299, Privacy, Confidentiality,
and Civil Rights – A Public Trust.

VSC #4 – Do not knowingly prepare false returns.
It is imperative that volunteers correctly apply tax law to the taxpayer’s situation. While it can be a
temptation for a volunteer to bend the law to help taxpayers, this will cause problems down the road for the
taxpayers. Volunteers must not knowingly prepare false returns.
Trust in the IRS and the local sponsoring organization is jeopardized when ethical standards are not
followed. Fraudulent returns can result in unwanted taxpayer interaction with the IRS. The taxpayer may be
required to pay additional tax, plus interest and penalties, resulting in an extreme burden. In addition, the
taxpayer may seek damages under state or local law from the SPEC partner for the volunteer’s fraudulent
actions. Even so, the IRS would still seek payment of the additional taxes, interest, and penalties from the
taxpayer.
To report suspected violations or concerns which you have by emailing SPEC Headquarters at
[email protected]. The email should include your name, contact number, site name, and a detailed
description of the incident including the individual's full name, date the incident occurred, and the number of
taxpayers affected by the violation.
A volunteer preparer told the taxpayer that cash income does not need to be reported. The return was
completed without the cash income. The volunteer preparer has violated this standard. The quality
reviewer simply missed this omission and the return was printed, signed, and e-filed.
The quality reviewer missed this omission and the return was printed, signed, and e-filed. Since the quality
reviewer did not knowingly allow this return to be e-filed incorrectly, the quality reviewer did not violate this
standard. Do not to confuse an unethical action with a lack of knowledge or a simple mistake.
A volunteer prepares a fraudulent return by knowingly claiming an ineligible dependent. The taxpayer
received a notice from IRS disallowing the dependent and assessing additional taxes, interest, and
penalties. The taxpayer may seek money from the SPEC partner, but must still pay the IRS the additional
taxes, interest, and penalties.
10

A volunteer prepares a fraudulent return by adding Household Employee Wages that the taxpayer did
not earn. The taxpayer received a notice from IRS for additional information needed about the
earnings that the taxpayer did not have so the IRS corrected the tax return and began assessing additional
taxes, interest, and penalties.
Hardship on the taxpayer
For a low-income taxpayer, it could be impossible to make full payment and recover from return fraud. If
full payment is not received, the taxpayer will receive several collection notices. If full payment is still not
received, the taxpayer will be sent through the IRS collection process. This could also involve the filing of a
tax lien or a levy (garnishment) on their bank accounts and/or wages. The taxpayer may be eligible for an
installment agreement, but it could take several years to pay the IRS debt.
A taxpayer’s return fraudulently contains the Earned Income Credit (EIC). The taxpayer has already
received the refund when an audit notice is issued. During the audit, the taxpayer cannot provide
documentation to support the EIC claim.
The taxpayer is disallowed $3,000 in EIC and now has a balance due of over $4,000, including penalties
and interest. This amount reflects only the EIC disallowance. An additional disallowance of the Head of
Household (HOH) filing status and Child Tax Credit (CTC) could generate a balance of over $6,000.
Identity Theft
Nationwide, identity theft continues to grow at an alarming rate. Unfortunately, there are instances of
unscrupulous volunteers using information they have obtained at a VITA/TCE site to steal the identity
of taxpayers. For example, using a stolen SSN to file a false tax return to obtain a refund is a form of
identity theft. Any suspicion of identity theft occurring at a VITA/TCE site must be reported to IRS Criminal
Investigation (CI) and Treasury Inspector General for Tax Administration (TIGTA).
The IRS considers this a very serious crime and put measures in place to detect possible identity theft
situations at VITA/TCE sites. The IRS is continually implementing: new processes for handling returns,
new filters to detect fraud, new initiatives to partner with stakeholders, and a continuing commitment to
investigate the criminals who commit these crimes.
Jane, an IRS tax law-certified volunteer, is working at a VITA site on the first day the site is open. She
has volunteered to electronically file the tax returns for the site to help out the coordinator. Therefore,
she is given the needed permission level in the tax preparation software.
That day, Joe, the coordinator, opens the locked VITA file cabinet and discovers an e-file acceptance report
he forgot to destroy from the previous year. He asks Jane to take the report down the hall to the shredder
because it has several SSNs listed. Jane puts the report in her purse without Joe’s knowledge.
Later that night at home, Jane opens the VITA tax preparation software and prepares falsified tax returns
for the eight SSNs listed on the report she took from the VITA site that morning. She makes sure the
returns all have large refunds. Jane puts her own bank account information in the direct deposit fields and
electronically files the returns.
Jane stole the identity of these eight taxpayers by preparing false federal tax returns to steal the refunds.
SPEC has a system that extracts information pertaining to tax returns filed through the VITA/TCE program
where multiple tax refunds are being deposited into a single bank account. Jane’s actions were reported to
IRS CI and TIGTA.

VSC #5 – Do not engage in criminal, infamous, dishonest, notoriously disgraceful conduct,
or any other conduct considered to have a negative effect on the VITA/TCE program.
SPEC can prohibit volunteers from participating in the VITA/TCE program if they engage in criminal,
infamous, dishonest, or notoriously disgraceful conduct, or any other conduct prejudicial to the government.
11

Volunteers must take care to avoid interactions that discredit the program. A taxpayer may look to state or
local law to seek money from the SPEC partner for a volunteer’s fraudulent actions.
If you have information indicating that another volunteer has engaged in criminal conduct or violated
any of the Volunteer Standards of Conduct, immediately report such information to your coordinator
and email SPEC headquarters at [email protected] and copy the partner and the local SPEC territory
office as appropriate. The email notification should include your name, contact number, site name, and a
detailed description of the incident including the individual's full name, date the incident occurred and the
number of taxpayers affected by the violation.
Consequences
Volunteers performing egregious activities are barred from volunteering for the VITA/TCE program and may
be added to a registry of barred volunteers.
Allowing an unauthorized alien to volunteer at a VITA/TCE site is prohibited. An “unauthorized alien”
is defined as a person not lawfully admitted into the United States for either permanent residence or
employment. All volunteers participating in the VITA/TCE program must legally reside in the United States.
Coordinators are required to ask for proof of identity with a government-issued photo ID for each volunteer.
However, coordinators or partners are not required to validate the legal status of volunteers. Therefore, by
signing Form 13615, volunteers are certifying that they are legal residents of the United States.
A partner’s program director was convicted of embezzling funds from an unrelated organization. The
program director’s criminal conduct created negative publicity for the partner. The partner was
removed from the VITA/TCE program.
A taxpayer’s refund was stolen by a volunteer return preparer at a VITA site. The taxpayer sought
monetary damages from the SPEC partner for the volunteer’s fraudulent actions. The volunteer
preparer was banned from volunteering in the VITA/TCE program.

VSC #6 – Treat all taxpayers in a professional, courteous, and respectful manner.
To safeguard public trust, Internal Revenue Service employees, partners, and volunteers must maintain the
confidence and respect of the people we serve. All volunteers must conduct themselves professionally in a
courteous, businesslike, and diplomatic manner.
Volunteers take pride in assisting individuals who come to VITA/TCE sites for return preparation. Taxpayers
are often under a lot of stress and may wait extended periods for assistance. Volunteers may also
experience stress due to the volume of taxpayers needing service. This situation can make patience run
short. It is important to remain calm and create a peaceful and friendly atmosphere.
You finish a difficult return for Millie, who has self-employment income, several expenses, and very
few records. In addition, her son turned 25 and moved out early in the year. She owes the IRS about
$50. After you carefully explain the return, Millie sputters, “You don’t know what you’re doing. I always get a
refund! My neighbor is self-employed and she got $1,900 back.” In this situation, you should take a deep
breath and courteously explain that every return is different. If necessary, involve the coordinator.

12

Taxpayer Civil Rights

In accordance with federal law and the Department of the Treasury – Internal Revenue Service policy,
discrimination against taxpayers on the basis of race, color, national origin (including Limited English
Proficiency), disability, sex (in education programs or activities), age or reprisal is prohibited in programs
and activities receiving federal financial assistance.
Persons with disabilities and/or limited English proficiency should be able to participate in or benefit
from programs and services that IRS supports. Taxpayers with a disability may request a reasonable
accommodation and taxpayers with limited English proficiency may request language assistance to
access services. For additional information refer to Publication 4053, Your Civil Rights Are Protected, for
reasonable accommodations.
Coordinators at federally assisted sites are responsible for ensuring that reasonable requests for
accommodation are granted when the requests are made by qualified individuals with disabilities and
that reasonable steps are taken to ensure that LEP persons have meaningful access to its programs or
activities. For additional guidance, please visit the Site Coordinator Corner on IRS.gov and review the
Fact Sheets on Reasonable Accommodation and Limited English Proficiency.
If a taxpayer believes he or she has been discriminated against, a written complaint should be sent to:
Internal Revenue Service

Civil Rights Unit

111 Constitution Avenue, NW, Room 2413
Washington DC 20224
For all inquiries concerning taxpayer civil rights, contact the Civil Rights Division at the address
referenced above, or email: [email protected]

Do not send returns, payments or other non-civil rights information to this address.

Due Diligence
By law, tax return preparers must exercise due diligence in preparing or assisting in the preparation of
tax returns. IRS defines due diligence as the degree of care and caution reasonably expected from, and
ordinarily exercised by, a volunteer in the VITA/TCE program. This means, as a volunteer, you must do your
part when preparing or quality reviewing a tax return to ensure the information on the return is correct and
complete. Doing your part includes confirming a taxpayer’s (and/or spouse, if married filing jointly) identity
and providing top-quality service by helping them understand and meet their tax responsibilities.
Generally, IRS tax law certified volunteers may rely in good faith on information from a taxpayer without
requiring documentation as verification. However, part of due diligence requires volunteers to ask
a taxpayer to clarify information that may appear to be inconsistent or incomplete. When reviewing
information for its accuracy, volunteers need to ask themselves if the information is unusual or
questionable.
If at any time a volunteer becomes uncomfortable with the information provided by the taxpayer, the
volunteer should not prepare the tax return. If necessary, ask the coordinator for assistance.

When in doubt, make an effort to find the answer
•

Seek assistance from the coordinator

•

Seek assistance from a tax preparer with more experience

•

Reschedule or suggest the taxpayer come back when a more experienced tax preparer is available
13

•

Reference or research publications (i.e. Publication 17, Publication 4012, Publication 596, etc.)

•

Research www.irs.gov

•

Call the VITA/TCE Hotline at 1-800-829-VITA (8482)

•

Research the Interactive Tax Assistance (ITA) on www.irs.gov to address tax law issues

•

Advise taxpayers to seek assistance from a professional tax preparer

Failure to Comply with the Volunteer Standards of Conduct
Who enforces the standards?
The U.S. tax system is based on voluntary compliance. Most taxpayers compute their tax accurately, but at
times unscrupulous taxpayers and preparers evade the system by filing fraudulent returns. For this reason,
some sponsoring organizations may perform background checks on their volunteers.
The VITA/TCE program is operated by sponsoring partners and/or coalitions outside the IRS. However, IRS
is responsible for providing oversight to protect the VITA/TCE programs’ integrity and to maintain taxpayer
confidence. IRS recognizes the hard work volunteers contribute to the programs and does not want that
overshadowed by a volunteer’s lapse in judgment.

How are the standards enforced?
IRS-SPEC continues to revise Form 13615, Volunteer Standards of Conduct Agreement, to provide
guidance to volunteers and a structure for regulating ethical standards. By signing and dating Form 13615,
Volunteer Standards of Conduct Agreement, volunteers agree that they will adhere to the VSC.
If conduct violating the standards occurs at a VITA/TCE site, IRS-SPEC will recommend corrective actions.
If the site cannot or will not remedy the conduct, then IRS-SPEC will discontinue its relationship and
remove any government property from the site.
In cases of wrongdoing, illegal conduct, and/or management practices that violate the VSC, IRS-SPEC
may terminate a VITA/TCE grant. A volunteer’s conduct could put a site or partner in jeopardy of losing its
government funding.

What if an unethical situation is discovered at a site?
If volunteers, coordinators, or taxpayers identify potential problems at the partner, site, or volunteer level
that may require independent scrutiny, they must report these issues using the external referral process
(VolTax) by emailing SPEC headquarters at [email protected]. Copy the partner and the local SPEC
territory office as appropriate.
In general, the coordinator is the first point of contact for resolving any problems that a volunteer may
encounter. If a volunteer feels an ethical issue can’t be handled by the coordinator, the volunteer
should e-mail SPEC headquarters at [email protected] and copy the partner and the local SPEC territory
office as appropriate.

Volunteer’s role in reporting questionable activity
Honest taxpayers and tax preparers preserve the tax system’s integrity. To sustain confidence in the VITA/
TCE program, you must report violations that raise substantial questions about another volunteer’s honesty,
trustworthiness, or fitness as a tax preparer.
Taxpayers and tax preparers who violate tax law are subject to civil and criminal penalties. Any person who
knowingly aids, assists, procures, counsels, or advises in the preparation or presentation of a materially false
or fraudulent return is subject to criminal punishment. IRS-SPEC will refer violations to the IRS CI or TIGTA.

14

Coordinator’s Responsibility
If a coordinator determines a volunteer has violated the Volunteer Standards of Conduct, the coordinator
needs to immediately remove the volunteer from all site activities and deactivate their access to tax
preparation software. In addition, notify both the partner and IRS-SPEC with the details of the violation. The
coordinator can notify IRS-SPEC by either contacting their local SPEC territory office or using the external
referral process (VolTax). If the coordinator contacts the territory, the territory will use the internal referral
process to elevate the referral to headquarters.
It is critical that SPEC headquarters be notified as quickly as possible of any potential misconduct by any
volunteers to preserve the integrity of the VITA/TCE programs.
While reading the newspaper, Violet, the coordinator at Pecan Public Library, learns that one of her
volunteers, Dale, was arrested for identity theft. The article indicates Dale has been using other
people’s identities to apply for credit cards and then using these cards for unauthorized purchases. Violet
sends an email to [email protected] with the details from the news article and deactivates Dale’s access
to the tax preparation software. When the site opens the next day, Violet pulls Dale aside and advises him
that he cannot work at the site due to his arrest on identity theft charges.
External Referral Process
If an unethical situation is discovered the external referral process (VolTax) provides taxpayers, volunteers,
coordinators, and others an avenue to report potential unethical problems encountered at VITA/TCE sites.
Volunteers and taxpayers can send an email to SPEC headquarters [email protected] and copy the
partner and the local SPEC territory office as appropriate. The email notification should include your name,
contact number, site name, and a detailed description of the incident including the individual's full name,
date the incident occurred and the number of taxpayers affected by the violation if applicable.
The email address is available in:
•

Publication 4836 (en-sp), VITA/TCE Free Tax Programs (English & Spanish)

•

Form 13614-C, Intake/Interview and Quality Review Sheet

•

Publication 730 (en-sp), Important Tax Records-Envelope (English & Spanish Version)

All VITA and TCE sites are required to display Publication 4836 (en-sp), or D-143 for AARP sites, in a
visible location to ensure taxpayer awareness of the abili