IRS Form 15722 Guide: Grant Program Administrative Review

Introduction: What Is IRS Form 15722?

IRS Form 15722, officially titled Grant Program Office – Administrative Review, is a specialized compliance and monitoring document issued by the Internal Revenue Service (IRS). Governed by the Department of the Treasury, this form is administered through the Grant Program Office (GPO) within the Stakeholder Partnerships, Education, and Communication (SPEC) organization of the Taxpayer Services Division.

Each year, the IRS awards millions of dollars in federal grants to non-profit organizations, universities, and local government agencies. These funds support the Volunteer Income Tax Assistance (VITA) and Tax Counseling for the Elderly (TCE) programs, which provide free tax return preparation to low-to-moderate-income families, elderly filers, and individuals with disabilities.

Form 15722 serves as the official evaluation instrument used by IRS grant specialists during formal administrative and financial monitoring reviews. Paired with its companion document, Form 15723 (Administrative Review Preparation Checklist), Form 15722 evaluates whether grant recipients manage federal awards in strict compliance with federal grant regulations, Office of Management and Budget (OMB) Uniform Guidance, and program performance goals.

Purpose of the Form: Why Does Form 15722 Exist?

Under Title 2 of the Code of Federal Regulations (2 CFR 200), known as the Uniform Guidance, federal agencies that award grants are legally required to monitor recipients to ensure taxpayer funds are used efficiently, lawfully, and solely for approved grant activities.

VITA and TCE grant programs involve complex financial requirements. Grantees must maintain separate accounting ledgers, track allowable versus unallowable costs, document required non-federal matching contributions, and oversee capital assets such as laptops and printers deployed across community tax clinics.

Form 15722 provides a structured, objective framework for IRS reviewers to examine these operational areas. By documenting findings, verifying internal controls, and establishing Corrective Action Plans (CAPs) when deficiencies arise, the form ensures that community partners maintain high operational standards while safeguarding federal funds.

Who Needs to Use or Undergo Review With Form 15722?

Form 15722 is an institutional evaluation tool utilized by IRS personnel and recipient organizations in the federal grant ecosystem:

• IRS Grant Program Office (GPO) Analysts: Federal grant specialists who conduct scheduled administrative and financial monitoring reviews of active grantees.
• VITA and TCE Grant Recipients: Non-profit agencies, charitable foundations, community action coalitions, and academic institutions that have received federal matching awards.
• Coalition Lead Agencies and Fiscal Sponsors: Umbrella organizations that administer grant funding and pass portions of the award through to partner tax clinics.
• Grant Program Directors and Financial Officers: Executive leadership and accounting personnel responsible for preparing records and participating in the administrative review conference.

Who Is Exempt or Not Required to Use This Form?

Because Form 15722 is restricted to formal federal grant oversight, several types of organizations and filers are exempt from its scope:

• Non-Grantee Volunteer Tax Sites: Community organizations that operate VITA or TCE clinics using only local volunteer resources without receiving federal grant awards from the IRS GPO.
• Low Income Taxpayer Clinic (LITC) Grantees: Legal clinics receiving funding under the LITC program operate under the National Taxpayer Advocate and follow separate administrative review protocols.
• Individual Taxpayers: Everyday citizens who receive free tax filing services at volunteer clinics never complete or interact with Form 15722.
• Commercial Tax Preparation Businesses: For-profit accounting firms and retail tax franchises are ineligible for IRS volunteer grants and are not governed by GPO reviews.

When to File and Implement: Timing and Review Frequency

Form 15722 follows an administrative monitoring schedule rather than an annual tax filing deadline:

• Periodic Multi-Year Reviews: The Grant Program Office conducts administrative reviews periodically throughout an organization’s multi-year grant cycle or during the active performance period.
• Advance Notice and Scheduling: The GPO contacts the recipient organization in advance, providing Form 15723 to outline the specific records that must be compiled prior to the review meeting.
• Post-Review Corrective Windows: If the completed Form 15722 identifies compliance deficiencies, the grantee is typically given 30 to 60 calendar days to complete a formal Corrective Action Plan.

Where and How to Transmit Review Records

The administrative review process combines digital documentation reviews with formal conferences:

Electronic Document Submission: Prior to the review, the grantee transmits requested financial ledgers, policies, and payroll files electronically via secure IRS email or authorized federal grant management portals as directed by the assigned GPO analyst.

Virtual or On-Site Conferences: Reviewers examine documentation and conduct interviews either through secure virtual videoconferencing platforms or through on-site visits to the grantee’s administrative headquarters.

Physical Mail Deliveries: If original signed certifications, formal single audit reports, or official correspondence must be mailed, packets should be sent to the official IRS address as per instructions provided by the Grant Program Office.

Step-by-Step Overview of Form 15722 Review Areas

Form 15722 is structured into specialized evaluation categories that assess every aspect of federal grant governance.

Review Section	Compliance Category	Required Documentation & Evaluation Focus
Part 1	Grantee & Award Identification	Records legal organization name, EIN, Unique Entity Identifier (UEI), Award Number, program type (VITA or TCE), and performance period.
Part 2	Governance & Internal Controls	Evaluates board oversight, written financial policies, segregation of accounting duties, and conflict-of-interest policies.
Part 3	Financial Management & General Ledger	Verifies that accounting systems track federal funds separately from general operating revenue and other federal awards.
Part 4	Allowable Costs & Payroll Documentation	Inspects time-and-effort logs, staff timesheets, and sample invoices to ensure expenditures align with 2 CFR 200 cost principles.
Part 5	Matching Funds Verification	Audits non-federal cash and in-kind matching contributions to confirm statutory 1:1 matching requirements for VITA grants.
Part 6	Equipment & Inventory Management	Reviews inventory logs for grant-funded property (laptops, printers, scanners) to verify tracking, serial numbers, and physical security.
Part 7	Sub-recipient & Coalition Monitoring	Assesses how the lead agency oversees sub-awards, monitors partner clinics, and verifies performance metrics.
Part 8	Programmatic Performance & Production	Compares actual tax returns prepared and electronic filing rates against the projections outlined in the original grant application.
Part 9	Findings, Corrective Actions, & Signatures	Summarizes compliance status, details required corrective measures, sets deadlines, and records official sign-offs.

Detailed Walkthrough of Major Review Components

1. Financial Accounting and Cost Principles. The GPO reviewer examines sample general ledger transactions to confirm that costs charged to the grant are allowable, allocable, and reasonable. Grant funds cannot be used for unallowable expenses, such as general fundraising, lobbying, entertainment, or alcoholic beverages.

2. Time-and-Effort Payroll Substantiation. When employee salaries are paid or matched using federal grant dollars, federal rules require verifiable documentation. Grantees must show contemporaneous timesheets signed by employees and supervisors that clearly distinguish time dedicated to the grant program from other organizational activities.

3. Tracking Non-Federal Matching Contributions. VITA grants require matching funds from non-federal sources. Reviewers inspect bank statements for cash matches and audit valuation methodologies for in-kind contributions, such as donated office space or professional services, ensuring that valuations follow fair market standards.

4. Equipment Safeguarding. Grant-funded technology—particularly laptops used to prepare confidential taxpayer returns—must be tracked meticulously. The reviewer checks the grantee’s equipment inventory log for serial numbers, acquisition dates, funding percentages, and current physical locations.

5. Performance Targets vs. Actual Results. Reviewers evaluate whether the grantee achieved its proposed target for the number of federal tax returns filed. If production fell significantly below projections, the reviewer explores whether external factors (such as severe weather or site closures) contributed and evaluates the organization’s mitigation plan.

Required Documents Needed Before the Review

Grant recipient organizations should use Form 15723 (Checklist) to assemble the following operational files before the administrative review begins:

• Notice of Award (NOA): The official grant award letter and approved budget narrative governing the current performance period.
• Chart of Accounts & General Ledger: Detailed financial transaction ledgers showing all grant debits, credits, and budget-to-actual comparisons.
• Payroll and Personnel Records: Time-and-effort logs, employee timesheets, and payroll registers supporting all salary allocations.
• Invoices and Disbursement Records: Paid invoices, vendor contracts, canceled checks, and credit card receipts for supplies, software, and travel.
• Matching Funds Records: Award letters from non-federal funders, donor letters, and detailed spreadsheets substantiating in-kind valuations.
• Equipment Inventory Register: A comprehensive list of all capital property and electronic hardware purchased with grant funds.
• Single Audit or Financial Statements: The organization’s most recent independent financial audit conducted under 2 CFR 200 Subpart F (if expending $750,000 or more in federal awards).

Common Mistakes to Avoid

Administrative reviews frequently reveal compliance weaknesses that can jeopardize grant standing. Watch out for these common missteps:

• Commingling Grant Revenue: Depositing grant payments into general operating accounts without distinct sub-accounting makes it impossible to verify how federal dollars were disbursed.
• Weak In-Kind Match Documentation: Claiming volunteer hours or donated facilities without maintaining signed attendance logs, fair market rent appraisals, or donor acknowledgment letters.
• Missing Equipment Logs: Failing to maintain an updated hardware registry with serial numbers and assigned site locations for computers purchased with federal funds.
• Estimated Payroll Allocations: Using fixed percentage budget estimates rather than actual, contemporaneous timesheets to document staff time dedicated to the grant.
• Failing to Monitor Sub-Recipients: Passing grant funds to local coalition partners without executing formal sub-award agreements or reviewing their financial ledgers.
• Lacking Written Procurement Policies: Making purchases without documented bidding procedures that satisfy federal micro-purchase and small-purchase thresholds.

Consequences and Penalties for Administrative Non-Compliance

Because Form 15722 is a federal grant monitoring instrument rather than a tax return, statutory tax penalties (such as late-filing fees) do not apply. However, administrative sanctions under federal grant regulations are serious:

• Mandatory Corrective Action Plans (CAP): Grantees with documented deficiencies must draft and execute a corrective plan within a strict timeframe to retain their funding.
• Payment Management System (PMS) Holds: The IRS may place a hold on the organization’s account, preventing electronic drawdowns of grant funds until compliance is demonstrated.
• Cost Disallowance and Repayment: The IRS can disallow expenses that lack adequate documentation or violate cost principles, requiring the grantee to repay those funds to the U.S. Treasury.
• Grant Reduction or Termination: Severe or uncorrected violations can lead to immediate termination of the grant agreement.
• Federal Debarment: Serious mismanagement or intentional misuse of funds can result in government-wide debarment, prohibiting the organization from receiving any federal grants in the future.

Related Forms and Publications

Form 15722 functions alongside several critical IRS volunteer program publications and grant guidelines:

• Form 15723: Administrative Review Preparation Checklist (the preparation companion to Form 15722).
• Publication 1101: Application Package and Guidelines for Managing a TCE Program.
• Publication 4671: VITA Grant Program Overview and Application Instructions.
• Publication 5683: VITA/TCE Handbook for Partners and Site Coordinators.
• Publication 5166: VITA/TCE Volunteer Quality Site Requirements.
• Publication 4299: Privacy, Confidentiality, and Civil Rights – A Public Trust.
• Form 13614-C: Intake/Interview & Quality Review Sheet.
• Form 13715: Volunteer Site Information Sheet.

Frequently Asked Questions (FAQs)

What is the difference between Form 15722 and Form 15723?

Form 15723 is the preparation checklist provided to the grantee ahead of time to help them gather required financial ledgers, policies, and equipment logs. Form 15722 is the official review document used by the IRS Grant Program Office analyst to conduct the review and record formal findings.

How often does an organization undergo an administrative review?

The IRS Grant Program Office conducts reviews periodically across the active grantee network. Reviews may occur once during a multi-year grant cycle, or more frequently if a grantee manages large sub-awards or if previous monitoring identified reporting issues.

Can an organization lose its VITA grant because of an administrative review?

Yes. While the primary goal of the review is educational and corrective, systemic financial mismanagement, fraudulent reporting, or failure to complete a mandatory Corrective Action Plan can result in grant termination and demand for repayment.

What are matching funds in a VITA grant program?

VITA grants require non-federal matching funds, typically on a dollar-for-dollar (1:1) basis. Grantees must prove that for every dollar of federal money received, they contributed an equal amount from non-federal cash sources or allowable third-party in-kind contributions.

Does Form 15722 evaluate tax return accuracy?

Form 15722 focuses primarily on administrative, financial, and organizational compliance. However, it also reviews programmatic production figures. Technical return accuracy is separately evaluated through IRS Quality Site Reviews conducted under Publication 5166.

Who from the grantee organization should attend the review meeting?

The review typically involves the Grant Project Director, the Chief Financial Officer or lead accountant, and key staff members responsible for volunteer coordination and equipment inventory management.

Conclusion: Key Takeaways

IRS Form 15722, Grant Program Office – Administrative Review, is an essential tool for maintaining accountability across federal free tax preparation initiatives. By systematically reviewing internal controls, financial records, time-and-effort logs, and equipment inventories, it ensures that VITA and TCE grant programs remain transparent and legally compliant.

For grant recipients, successful administrative reviews depend on proactive preparation. By maintaining distinct financial ledgers, rigorously documenting non-federal matching funds, and utilizing companion Form 15723 to organize records in advance, organizations can demonstrate strong fiduciary stewardship and protect vital community tax assistance funding for years to come.