1. Introduction: What is Form 13978?

IRS Form 13978, officially titled the Projected Operations VITA Grant Application (and historically referred to as the Projected Operations VITA Grant Program Application Plan), is an administrative operational planning document published by the Internal Revenue Service (IRS). The IRS is a bureau of the United States Department of the Treasury responsible for administering federal tax laws and overseeing community tax assistance grant initiatives.

Rather than being used by everyday wage earners to calculate tax liabilities, Form 13978 is an institutional planning tool. It is administered by the Stakeholder Partnerships, Education and Communication (SPEC) division within the IRS Wage and Investment Division.

Form 13978 is completed by non-profit organizations, municipal agencies, universities, and community coalitions applying for federal grant funding under the Volunteer Income Tax Assistance (VITA) Grant Program. It serves as the applicant’s official operational blueprint, detailing how many tax returns the organization plans to prepare, where sites will be located, how many volunteers will be mobilized, and which underserved populations will be prioritized.

2. Purpose of the Form

Each year, Congress appropriates millions of federal grant dollars to help community organizations provide free tax preparation to low-to-moderate-income families, seniors, individuals with disabilities, and taxpayers with limited English proficiency. When awarding these competitive federal grants, the IRS must verify that applicants have realistic, well-structured operational plans.

While companion Form 13977 details the financial budget and matching funds, Form 13978 captures the operational production targets. It answers vital administrative questions: How many electronic returns will you file? How many physical and mobile clinics will you operate? How many volunteer hours will you recruit? How will returns be quality reviewed?

Form 13978 establishes the official performance baseline for your grant. Reviewers evaluate these operational projections to score your grant application. At the close of the filing season, the IRS compares your actual operational achievements on Form 13980 against the targets you committed to on Form 13978.

3. Who Needs to File This Form

Form 13978 is completed by organizations seeking federal VITA grant funding under Assistance Listing Number 21.009. You need to file this form if you represent any of the following entities:

Non-Profit 501(c)(3) Organizations: Community action agencies, United Way chapters, and charitable coalitions submitting a competitive VITA grant application.
Local & Municipal Government Bodies: City, county, or regional government departments establishing free municipal tax clinics.
Colleges & Universities: Academic institutions sponsoring on-campus or community-based volunteer tax clinics.
Financial Institution Coalitions: Credit unions, community development financial institutions (CDFIs), and banks organizing volunteer tax sites.
Returning Grantees Adjusting Goals: Currently funded organizations submitting revised operational plans during grant award negotiations or post-award site modifications.

The form is prepared and signed by the applicant organization’s executive director, program coordinator, or responsible official. Individual taxpayers and volunteer tax preparers never complete Form 13978.

4. Who Is Exempt / Not Required to File

Because Form 13978 is strictly an operational planning document for federal VITA grant applicants, most organizations and individuals do not need to file it:

Individual Taxpayers: Community members visiting a free tax clinic have no connection to this grant application form.
Individual Tax Volunteers: Volunteer preparers, greeters, and quality reviewers complete Form 13615, not Form 13978.
Non-Grant Sponsoring Partners: Community organizations that operate VITA clinics without receiving federal grant funds register their locations using Form 13715 and do not submit Form 13978.
Tax Counseling for the Elderly (TCE) Applicants: Programs applying exclusively for TCE grant awards submit Form 8653 (TCE Program Application Plan) rather than Form 13978.
Low Income Taxpayer Clinics (LITCs): Legal clinics representing taxpayers in audits are funded under a separate statute and use the Form 13424 series for reporting.

5. When to File

Form 13978 operates on a strict annual grant application calendar governed by IRS Publication 4671:

Annual Application Deadline: Form 13978 is submitted as a mandatory attachment to the VITA grant application package on Grants.gov. The submission window opens annually on May 1 and closes on May 31.
Award Acceptance Revisions: If your organization is awarded a grant around October 1, but the awarded funding level differs from your request, you must submit a revised Form 13978 adjusting your return and site targets within 20 days of notification.
Mid-Season Operational Updates: If significant unforeseen disruptions occur—such as sudden facility closures or major shifts in site locations—grantees must coordinate with their assigned IRS Tax Analyst to update their operational plan.

Federal grant portals strictly enforce deadlines. Submissions uploaded after 11:59 p.m. Eastern Time on May 31 are automatically rejected by Grants.gov.

6. Where and How to File

Form 13978 cannot be submitted through consumer tax preparation software like TurboTax. It is submitted through official federal grant management platforms.

Initial applicants must download Form 13978 as part of the electronic application package on Grants.gov and upload it as a mandatory attachment to the Standard Form 424 (Application for Federal Assistance). Grantees submitting post-award revisions can upload the updated form through the mobile-friendly web portal on IRS.gov or email it directly to their assigned IRS VITA Grant Tax Analyst.

Before submitting, your organization must maintain an active registration in the federal System for Award Management (SAM.gov) and possess a valid Unique Entity Identifier (UEI). If physical verification documents or audit samplings are requested, deliver materials to the specific IRS address as per instructions outlined in Publication 4671.

7. Step-by-Step Instructions to Fill the Form

Form 13978 is structured into five distinct operational sections covering return volume, site logistics, quality review protocols, volunteer staffing, and underserved populations. Review the table below for a section-by-section walkthrough.

Section / Line Range	Operational Category	Required Information & Instructions
Lines 1–3	Return Volumes	Enter projected low-income federal returns filed electronically (Line 1), paper returns (Line 2), and total returns prepared (Line 3).
Lines 4–8	Preparation Sites	Record established sites (fixed and ad hoc) and proposed new sites (fixed and ad hoc). Line 8 is the sum of Lines 4 through 7.
Lines 9–11	Filing Capabilities	Report sites offering paper-only preparation, sites offering electronic filing, and the total IRS software licenses needed.
Lines 12–13	Quality Review Method	Indicate the number of sites using peer review (preparers reviewing each other) versus designated review (dedicated quality reviewers).
Lines 14–18	Volunteer Staffing	Estimate the total number of volunteers and total volunteer hours by position: Tax Assistors, Support Staff, Coordinators, Instructors, and Administrators.
Lines 19–24	Underserved Populations	Forecast returns for specific groups (elderly, rural, disabled, limited English, Native American). Select ONE primary and ONE secondary focus.
Signature Block	Official Certification	The organization’s responsible official signs and dates the form, affirming that operational plans are accurate and achievable.

Understanding Key Operational Definitions

When completing Form 13978, site coordinators must understand how the IRS defines clinical operations:

Fixed vs. Ad Hoc Sites: A fixed site is a permanent location open throughout the tax season with regularly scheduled days and hours (such as a public library or university clinic). An ad hoc site is a temporary, short-term, or mobile clinic open only for specific days (such as a weekend pop-up clinic at a community center).
Peer Review vs. Designated Review: Under IRS Quality Site Requirements, 100% of returns must be quality reviewed before filing. Peer review means volunteer preparers review each other’s work. Designated review means a dedicated, experienced volunteer or coordinator conducts all quality reviews.
Underserved Population Focus: Lines 19 through 24 require you to estimate returns prepared for specialized demographics. You must designate only one population as your primary focus and only one population as your secondary focus.

8. Required Documents/Information Needed Before Filling

Before completing Form 13978, assemble the following operational data and background records:

Historical Production Data: Prior-year tax return preparation counts and site statistics to ensure your projections are grounded in realistic historical trends.
Facility Agreements: Confirmed building use agreements, library room reservations, or lease contracts detailing how many fixed and ad hoc sites will operate.
Companion Form 13977: The VITA Grant Budget Plan, ensuring that your volunteer hour projections on Form 13978 match the in-kind volunteer matching figures budgeted on Form 13977.
Volunteer Recruitment Targets: Rosters or recruitment estimates detailing how many certified tax preparers, screeners, and site coordinators you will mobilize.
Local Demographic Data: Census data and community poverty statistics identifying local underserved populations (such as rural areas or non-English speaking communities).

9. Common Mistakes to Avoid

Operational inconsistencies can lower your application’s technical evaluation score. Avoid these frequent mistakes when completing Form 13978:

Unrealistic Return Projections: Projecting massive return increases without a corresponding increase in volunteer recruitment or site capacity is a common red flag for grant reviewers.
Mathematical Imbalances: Ensure Line 1 plus Line 2 equals Line 3, and Lines 4 through 7 sum correctly to Line 8. Mathematical errors lead to administrative delays.
Selecting Multiple Primary Populations: Checking more than one primary or secondary underserved population violates form instructions and causes scoring deductions.
Underestimating Software Licenses: Failing to request enough software licenses on Line 11 limits how many volunteer workstations your sites can operate simultaneously.
Disconnect with the Financial Budget: The volunteer hours reported in Lines 14 through 18 must align with the volunteer valuation figures entered in Line 2 of Form 13977.
Missing the May 31 Cutoff: Waiting until the final hours on May 31 risks technical transmission errors on Grants.gov.

10. Penalties for Non-Filing or Errors

Because Form 13978 is a competitive grant application document rather than a tax return, there are no civil tax penalties or personal fines for failing to file it. However, the operational and financial consequences for the organization are substantial:

Application Ineligibility: Submitting an incomplete, mathematically flawed, or late Form 13978 results in the immediate disqualification of your grant proposal.
Lower Competitive Scoring: Unrealistic projections or poorly defined quality review plans lower your technical evaluation score, reducing the likelihood of receiving an award.
Corrective Action Placement: Grantees that fall significantly short of their approved Form 13978 return goals (typically below 90% of projections) may be placed on administrative probation or face reduced funding in future grant cycles.
Grant Recoupment Risks: If failure to achieve operational goals causes budgeted matching funds to fall below statutory ratios, the organization may be required to refund federal grant dollars to the U.S. Treasury.
False Claims Act Liability: Intentionally inflating past return counts or fabricating volunteer participation numbers on federal grant applications violates 18 U.S.C. Section 1001, carrying criminal fines and civil fraud penalties.

11. Related Forms or Schedules

Form 13978 operates within a comprehensive suite of IRS volunteer tax preparation grant documents:

Standard Form 424: Application for Federal Assistance
Form 13977: VITA Grant Budget Plan
Form 13979: VITA Grant Final Expense Report
Form 13980: VITA Grant Performance Measures Report
Form 13981: VITA Grant Agreement
Form 13715: Volunteer Site Information Sheet
Form 13614-C: Intake/Interview and Quality Review Sheet
Form 13615: Volunteer Standards of Conduct Agreement – VITA/TCE Programs
Publication 4671: VITA Grant Program Overview and Application Instructions
Publication 5683: VITA/TCE Handbook for Partners and Site Coordinators

12. Frequently Asked Questions

What is the difference between Form 13977 and Form 13978?

Form 13977 is the financial budget plan where you detail estimated dollar expenses and matching funds. Form 13978 is the operational plan where you forecast return volumes, site locations, volunteer hours, and target populations.

What is the difference between a fixed site and an ad hoc site on Form 13978?

A fixed site operates on a continuous, predictable schedule throughout the tax season (such as an established clinic open every Saturday). An ad hoc site operates on a temporary or intermittent basis, such as a one-day mobile clinic at a rural senior center.

What is the difference between peer review and designated review?

Peer review occurs when volunteer tax preparers review and check each other’s completed returns. Designated review occurs when a specific, experienced volunteer or site coordinator is assigned to perform all quality reviews exclusively.

Can an organization choose more than one primary underserved population?

No. You must choose exactly one primary focus and one secondary focus on Lines 19 through 24. Selecting multiple primary populations violates application guidelines.

How does the IRS evaluate volunteer hours reported on Lines 14–18?

The IRS reviews volunteer staffing to ensure you have enough certified preparers and quality reviewers to support your projected return volume. The volunteer hours must also reconcile with the in-kind volunteer matching funds budgeted on Form 13977.

Can an organization adjust its projected numbers after receiving a grant award?

Yes. If the IRS awards a funding amount different from your initial request, you will submit an updated Form 13978 during the award acceptance process to align your return and site targets with your approved funding level.

13. Conclusion: Key Takeaways Summarized

IRS Form 13978 provides the operational foundation for any successful VITA grant application. Setting realistic, data-backed goals ensures your program remains competitive and compliant. Keep these essential practices in mind:

Operational Production Blueprint: Use Form 13978 to project your annual return volumes, site operations, volunteer hours, and underserved population targets.
Verify Mathematical Balance: Ensure that all return lines and site totals sum correctly throughout the document.
Align with Your Budget: Confirm that your volunteer staffing numbers and site plans match the financial expenditures on Form 13977.
Select Only One Primary Focus: Choose exactly one primary and one secondary underserved population from the demographic options.
Submit via Grants.gov: Upload your completed operational plan as part of your primary VITA application package between May 1 and May 31.
Deliver Revisions to SPEC: Submit post-award operational revisions through the mobile-friendly web portal on IRS.gov or directly to your assigned IRS Tax Analyst as per instructions in Publication 4671.

IRS Form 13978: Projected Operations VITA Grant Application