IRM Interim Guidance: The Rules That Change Before the Manual Does

A published IRM section can be accurate on the day it is printed and wrong a month later. The IRS changes procedure faster than it rewrites the manual, and it does that through interim guidance.

If you are reading the IRM to understand what an IRS employee should be doing on your case, you have to check the interim guidance too. Otherwise you are arguing from an outdated rulebook while the employee is reading the current one.

What interim guidance is

IRM 1.11.10 (rev. 2025-07-28) governs the process. It defines interim guidance as an official communication conveyed through memorandums or IRM Procedural Updates used to immediately issue emergency, pilot, deviation or temporary changes to operations or IRM procedures for a defined effective period not to exceed two years.

The background subsection, IRM 1.11.10.1.1, explains why it exists. The IRM is the official source of IRS policies and procedures, and the interim guidance process allows quick communication of new or revised instructions to staff before business units can update the affected IRM sections. It is also used for temporary and pilot procedures.

In practice that means a new collection threshold, a changed form or a pandemic-style emergency procedure can reach employees in days rather than waiting for a full IRM revision.

The two formats

Interim guidance comes in two forms. The first is the Interim Guidance Memorandum, or IGM. IRM 1.11.10 describes it as guidance conveyed by memorandum to issue emergency, pilot, deviation or temporary changes, effective until its expiration date, not to exceed two years.

The second is the IRM Procedural Update, or IPU. An IPU is used to issue an interim procedural change to an IRM section hosted on SERP, the Servicewide Electronic Research Program employees use. IRM 1.11.10 says the change is effective for up to two years, and program owners must use the IPU format to make interim changes to SERP-hosted IRMs.

IRM 1.11.6.4.7 (rev. 2025-09-02) adds a detail that matters if you ever see an employee's screen. When an IPU is posted to SERP, the changed content appears highlighted in yellow so employees can find it, and the revised subsection date reflects the IPU date.

The two year clock

Interim guidance is temporary by design. IRM 1.11.10 says it remains effective until its expiration date, not to exceed two years, and if no expiration date is stated, it is in effect for two years from issuance.

Permanent changes have to be folded into the manual. The same section says business units must incorporate permanent interim guidance into the next revision of the published IRM section within two years from the issuance date. Staff in the Office of Servicewide Policy, Directives and Electronic Resources, called SPDER, periodically review expiration dates and notify business units of imminent expirations.

So when you read a manual transmittal, look at the Effect on Other Documents line. IRM 1.11.6.3.2.1 says it lists any incorporated IGM or IPU. That line tells you which interim guidance has now become part of the permanent text.

Deviations: when a local office is allowed to do it differently

Sometimes an office is not following the national procedure because it has been authorized not to. IRM 1.11.2.2.3 explains that national program guidance may not apply to work in all offices because of special circumstances, and deviation from IRM procedures may be necessary.

There are guardrails. A deviation must be approved under Delegation Order 1-69, must be issued through an interim guidance memorandum to affected employees, must be reviewed by affected program offices, must be reviewed annually and must specify a time frame not longer than two years. If the IRM is on SERP, an IPU referencing the deviation must also be issued.

That matters when an employee says the local office does it differently. The right response is polite and specific: is there a deviation memo, and when does it expire? A real deviation has a paper trail. An informal habit does not.

Who has to sign off

Interim guidance is not a supervisor's email. IRM 1.11.10 says procedural guidance is issued to employees from management in their chain of command. An originating policy office may not give direct instructions to employees in another business unit without the agreement and approval of that unit's chief, director or head of office, and the memo must then carry signatures from both.

It also goes through review. Proposed memos and procedural updates are sent to affected program offices and specialized reviewers for concurrence, and IRM 1.11.10 sets a review window of at least three and not more than ten business days when substantial changes are made during clearance. Emergency guidance can be issued immediately, but the reason for immediate issuance has to be stated.

Employees are told where to look. IRM 1.11.6.6.2 says IRM Online displays a notice when interim guidance exists for a section, and SERP lists all IPUs and SERP Alerts issued for the day on its home page. An IRS employee has no good excuse for missing current guidance on the procedure they are applying.

Why the public can see it

The Freedom of Information Act requires agencies to make available administrative staff manuals and instructions to staff that affect a member of the public. IRM 1.11.10.1.2 cites 5 U.S.C. 552(a)(2)(C) for that rule and notes that the 1996 electronic FOIA amendments require these records in electronic form.

IRM 1.11.10 says guidance meets the electronic FOIA criteria when it affects how a member of the public files, pays and complies with tax requirements, or interacts with the IRS. Business units must post all interim guidance memorandums, and those IPUs that meet the electronic FOIA criteria, to the IMD Tracking System. Qualifying guidance is posted to the FOIA Library on IRS.gov.

IRM 1.11.6.4.1 tells employees where to find it publicly: under Admin Manuals and Instructions in the FOIA Library, in the links for recent delegation orders and policy statements and recent interim guidance to staff. Those links are where you look too.

How to check for interim guidance on your issue

Start with the IRM section that governs your stage of the case. Note its revision date and the Effect on Other Documents line in the transmittal.

Next, search the IRS.gov FOIA Library's interim guidance listings for that IRM number. IRM 1.11.10 requires every interim guidance memorandum to carry a unique control number built from the business unit, the IRM part number, the month and year, and a sequence number, and to name the primary IRM section it affects first.

Then read the memo's expiration date. Expired guidance no longer governs. If it was permanent, it should have been incorporated into a later IRM revision, which you can confirm in that revision's transmittal.

Finally, read the effective dates against your own timeline. If the IRS took an action in March and the guidance changed in June, the March procedure is the one that applied to you.

Why this matters for your case

Collection procedure changes regularly. Thresholds move, forms change and workflows are piloted. An argument built on a superseded procedure is easy for an IRS employee or an Appeals officer to dismiss. An argument built on the current text, with the interim guidance included, is not.

It also works in your favor. When the IRS issues interim guidance that loosens a requirement or creates temporary relief, the employee on your case is supposed to apply it. Not every employee reads every memo on the day it is issued. Knowing it exists lets you raise it.

Read the manual. Then read what changed since the manual. That is the full rulebook. For how the manual itself is organized, start with How to Read the Internal Revenue Manual Like an IRS Employee.