WASHINGTON — The IRS Independent Office of Appeals has announced the launch of a two-year pilot program aimed at enhancing Post Appeals Mediation (PAM). This initiative seeks to make mediation a more attractive option for taxpayers by refining the process and encouraging earlier, more efficient resolutions to tax disputes before they reach the courtroom.
Renewed Focus on Alternative Dispute Resolution
“Appeals is committed to offering Alternative Dispute Resolution programs as a cost-effective option for resolving cases, improving the taxpayer’s experience, and making the best use of IRS resources,” said John Hinding, Acting Chief of Appeals.
The pilot program underscores the IRS’s ongoing effort to make tax administration more efficient, fair, and collaborative.
What Is Post Appeals Mediation?
PAM offers taxpayers a final opportunity to resolve their disputes after an unsuccessful Appeals process. Once a request for mediation is accepted, both parties meet in an accelerated session to negotiate a mutually acceptable resolution.
The discussions are confidential, solution-focused, and designed to bridge gaps that remain after formal Appeals consideration.
How the Mediation Process Works
During a typical PAM session, an Appeals mediator—who has no prior connection to the case—facilitates dialogue between the taxpayer and the IRS. These sessions usually last one day and focus on clarifying issues, identifying common ground, and exploring creative settlement options.
Taxpayers may also include a private co-mediator at their own expense to support the process.
What’s Changing Under the New Pilot
The new pilot introduces one key procedural change: cases accepted into the PAM program will now be reassigned to an Appeals team unconnected with the original case. This team will represent Appeals during the mediation session, providing a truly independent perspective. All other aspects of the PAM process will remain the same.
A Fresh Look Without Creating a New Appeal
This adjustment is not intended to create a new appeal but rather to facilitate an expedited “fresh look” at the case. By engaging a new Appeals team and neutral mediators, the program encourages productive discussion and helps both parties explore all possible paths to resolution before proceeding to potential litigation.
Promoting Efficiency and Trust
“PAM proceedings typically have a high level of success, but we are always working with taxpayers, practitioners, and stakeholders to adjust our ADR programs in ways that make them more desirable and effective,” said Michael Baillif, Director of the IRS ADR Program Management Office.
“This small structural change could have a big impact on how efficiently disputes are resolved.”
Benefits for Taxpayers and the IRS
Mediation saves time, reduces costs, and helps taxpayers avoid the stress of prolonged disputes. For the IRS, it frees up resources by limiting the number of cases that move to court.
Both sides benefit from improved communication, transparency, and the opportunity to resolve disagreements cooperatively rather than through litigation.
Building on a Proven Track Record
The PAM program has historically achieved a strong success rate. Many taxpayers who participate are able to reach an agreement within a single day of mediation.
The IRS hopes that by making the process even more accessible and independent, more taxpayers and representatives will view it as a viable option for dispute resolution.
Supporting the Broader ADR Portfolio
The pilot complements the IRS’s broader suite of Alternative Dispute Resolution (ADR) programs, which include:
- Fast Track Settlement (FTS) — enabling taxpayers to resolve disputes while their case is still in Examination.
- Fast Track Mediation Collection (FTMC) — offering a quicker resolution for collection disputes.
- Post Appeals Mediation (PAM) — facilitating resolution after Appeals review.
- Rapid Appeals Process (RAP) — promoting collaboration between Appeals and taxpayers to expedite complex cases.
- Early Referral — allowing certain issues to be referred to Appeals before an entire case is closed by Examination.
A Step Toward a Modern, Accessible Appeals Process
The IRS continues to modernize its Appeals function to better serve taxpayers. This pilot reflects a broader cultural shift within the agency toward collaboration, transparency, and early resolution.
By improving ADR programs, the IRS aims to strengthen taxpayer trust and foster a more balanced, responsive tax system.
Encouraging Participation and Feedback
As the pilot progresses, the IRS will closely monitor outcomes and collect feedback from participants to assess its impact. Insights gathered will help determine whether to make the new approach permanent or introduce additional refinements.
Taxpayers and practitioners are encouraged to share their experiences and suggestions throughout the two-year period.
Looking Ahead
Through the PAM pilot, the IRS Appeals office reaffirms its commitment to resolving tax disputes fairly, efficiently, and collaboratively.
By offering a “fresh look” from an independent Appeals team, the program represents an important step toward strengthening taxpayer confidence in the dispute resolution process—and toward a more modern and accessible IRS for all.
FAQs
What is the IRS Post Appeals Mediation (PAM) program?
The Post Appeals Mediation (PAM) program allows taxpayers to resolve disputes with the IRS after an unsuccessful Appeals proceeding. It provides an opportunity for both parties to reach a mutually acceptable agreement through a one-day mediation session facilitated by a neutral IRS mediator.
What is changing under the new PAM pilot program?
Under the two-year pilot, cases will be reassigned to a new Appeals team not previously involved in the case. This team will represent Appeals during mediation, providing an independent perspective. All other aspects of PAM remain the same.
How long does a PAM session usually take?
Most Post Appeals Mediation sessions last one day. The session is designed to help the taxpayer and IRS representatives identify issues, find common ground, and reach a settlement without going to court.
Can taxpayers bring their own mediator?
Yes. Taxpayers may include a co-mediator at their own expense. This person works alongside the IRS mediator to help facilitate discussions and promote a fair resolution.
Is the new pilot program creating another level of appeal?
No. The PAM pilot does not create a new appeal. It simply offers an expedited, independent review to help both parties resolve disputes before considering litigation.
What other IRS Alternative Dispute Resolution programs are available?
The IRS Appeals Office offers five ADR programs: Fast Track Settlement, Fast Track Mediation Collection, Post Appeals Mediation, Rapid Appeals Process, and Early Referral. Each provides flexible options to resolve disputes efficiently and cost-effectively.
How will the IRS evaluate the PAM pilot program?
The IRS will monitor the pilot over two years, gathering feedback from taxpayers and practitioners to assess its effectiveness and determine whether to make the changes permanent.
