Form 8654 – TCE Semi-Annual/Annual Program Report Guide

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Form 8654 is the report that comes after the grant, not the application for it. Once an organization wins a Tax Counseling for the Elderly award, this is how it reports program activity and expenditures back to the IRS. Treating it like the application form, or forgetting it entirely, is how a clean grant turns into an accountability problem at year-end.

There are two filing points. The Semi-Annual Program Report is due June 30, required when the program is still operating after April 30, and the Annual Program Report is due December 31 or within 90 days after program completion, whichever is earlier. Administrative expenses on line 18 may not exceed 30% of the program cost, so build the figures cumulatively so the semi-annual numbers roll forward into the annual report.

Key Takeaways

• Form 8654 is the TCE Semi-Annual/Annual Program Report – the post-award reporting form filed by TCE federal-award recipient organizations to report program activity and expenditures to the IRS. It is not a grant application or a taxpayer-facing return; grant applications themselves are submitted separately through Grants.gov.
• Eligible organizations include non-profits, community organizations, and government entities that can demonstrate the capacity to train and support volunteer tax counselors serving the senior population.
• TCE grants reimburse out-of-pocket program expenses – training materials, volunteer travel, equipment, and direct administrative costs related to running TCE sites.
• The report has two filing points: the Semi-Annual Program Report is due June 30 (required when the program is still operating after April 30), and the Annual Program Report is due December 31, or within 90 days after the program is completed, whichever is earlier.
• TCE volunteers must be certified annually through IRS Link & Learn Taxes. All TCE returns undergo quality review, typically using the same Form 6729-D process as VITA sites.
• Quick rule you can copy into your SOP: Prepare Form 8654 on a cumulative, year-to-date basis so the Semi-Annual figures roll forward into the Annual report and total program cost on line 22 reconciles to the federal award on line 23 the first time.

What Form 8654 Is and When to Use It

Form 8654 is the Tax Counseling for the Elderly Semi-Annual/Annual Program Report – the post-award reporting form filed by TCE federal-award recipient organizations (program sponsors) to report semi-annual and annual program activity and expenditures back to the IRS. It is not the grant application document and not a taxpayer-facing return. Organizations that operate free tax assistance sites for taxpayers aged 60 and older under an IRS TCE federal award use this form to report on program operations to the IRS SPEC (Stakeholder Partnerships, Education, and Communication) function; grant applications themselves are submitted separately through Grants.gov.

The TCE program was established under Section 163 of the Revenue Act of 1978 and is authorized under IRC Section 7526. It authorizes the IRS to make grants to public and private non-profit agencies and organizations to establish programs that provide tax counseling to elderly individuals. The AARP Foundation Tax-Aide program is the largest national TCE grantee, operating thousands of sites across the country each filing season.

Who Should Use Form 8654

The organizations that file Form 8654 are the TCE federal-award recipients (program sponsors): senior centers, community organizations, libraries, faith-based groups, and state and local government agencies that operate free tax preparation sites for seniors under an IRS TCE award. The responsible officer of that organization completes and signs the report; individual volunteers and the taxpayers served do not file it.

Form 8654 vs. the VITA Program

The VITA program and the TCE program are parallel IRS programs with different target populations. VITA focuses on low- to moderate-income individuals generally, while TCE focuses specifically on taxpayers aged 60 and older. An organization that operates both programs maintains separate program operations and reports each separately to its IRS SPEC channel.

The Tax Counseling for the Elderly Program

The TCE program trains and certifies volunteers to provide free tax counseling and return preparation services to taxpayers aged 60 and older, with special emphasis on tax issues relevant to seniors – pension and annuity income, Social Security benefits, retirement account distributions, and age-related credits. TCE sites operate during the filing season (January through April) and in some cases year-round for extended services.

The AARP Foundation Tax-Aide Partnership

AARP Foundation Tax-Aide is the primary national TCE grantee, operating under a cooperative agreement with the IRS. AARP Tax-Aide recruits and trains thousands of volunteers across the country, operates sites in senior centers, libraries, and other community locations, and serves millions of taxpayers each year. New organizations interested in the TCE program may partner with AARP Tax-Aide regionally rather than applying independently, particularly if they lack the infrastructure for a standalone operation.

Who TCE Serves

TCE sites serve taxpayers aged 60 and older, with no income restriction (unlike VITA, which has an income threshold). In practice, most TCE clients are low- to moderate-income seniors on fixed incomes. The program specifically addresses the tax complexity that seniors face – required minimum distributions, pension income taxation, Social Security benefits inclusion calculations, Medicare premium deductions, and property tax credits available in many states.

Who Files Form 8654

Form 8654 is filed by the TCE federal-award recipient organization (the program sponsor), not by the taxpayers it serves and not by individual volunteers. The responsible officer of the recipient organization signs the report. The form identifies the recipient on line 3 by legal name, address, and Employer Identification Number (EIN), which is the account/identifying number used on the form.

Semi-Annual vs. Annual Report

Line 1 sets the report type: Semi-Annual or Annual. A Semi-Annual report is required when the program is still in operation after April 30 (a typical report period runs from October 1 through May 31). The Annual report covers the full program period. The recipient enters the fiscal year on line 2 and the report period on line 4.

Cumulative, Year-to-Date Basis

Both reports are prepared on a cumulative, year-to-date basis rather than period-only. The Semi-Annual totals roll forward into the Annual report instead of restarting at zero, so the December 31 figures tie back to the program's cumulative draws and the federal award reported on line 23.

How to Complete Form 8654

Key Sections of the Report

Section	Lines	What to Report
Recipient and Report Identification	Lines 1–4	Report type, fiscal year, recipient name/address/EIN, and report period
Volunteer Reimbursements	Lines 5–8	Reimbursements to volunteer tax assistors/reviewers, instructors, and coordinators; line 8 totals lines 5 through 7
Administrative Expenses	Lines 9–18	Salaries/benefits, supplies and volunteer recognition, rent/utilities, and other admin costs; line 18 totals lines 9 through 17 and may not exceed 30% of line 19
Program Cost and Award Reconciliation	Lines 19–25	Program cost (line 19), total program cost (line 22), federal award (line 23), unexpended balance (line 24), and refund to IRS on the Annual report (line 25)
Program Output	Lines 26–32	Returns prepared (lines 26–28), taxpayers assisted (lines 29–30), number of sites (line 31), and the site listing attachment with SIDN, EFIN, and site type (line 32)

Where the Report Goes

Form 8654 is submitted to the IRS SPEC (Stakeholder Partnerships, Education, and Communication) function that administers the TCE program, not to a federal grant portal. Confirm the current submission method and contact with your IRS SPEC relationship manager before the due date.

Form 8654 Reporting Deadlines

Report	Trigger	Due Date
Semi-Annual Program Report	Required when the program is still in operation after April 30	June 30
Annual Program Report	Covers the full program period	December 31, or within 90 days after the program is completed, whichever is earlier

A typical report period starts October 1; the Semi-Annual report “To” date is often May 31 when the program is still operating after April 30. Build the workbook on a cumulative basis so the Semi-Annual figures roll forward and the Annual report reconciles to the federal award. Confirm the current-year due dates against the Form 8654 instructions (Rev. March 2026) and your IRS SPEC relationship manager.

What TCE Grants Cover

TCE grant funds reimburse organizations for reasonable costs directly related to operating TCE sites. Allowable costs include:

• Volunteer training materials and certification costs
• Volunteer travel and mileage reimbursement for site operations
• Tax preparation equipment (computers, printers, scanners) – may be subject to procurement and ownership rules, and computers and printers purchased with grant funds may not exceed a unit cost of $1,000 per the Form 8654 line 21 instructions
• Site-related supplies (paper, toner, forms)
• Direct administrative costs of managing the TCE program (not general organizational overhead, and total administrative expenses reported on line 18 may not exceed 30% of program cost on line 19)
• Interpreter and accessibility services for sites serving non-English-speaking or disabled seniors

What Grants Do Not Cover

General organizational overhead, fundraising activities, lobbying, political activities, and costs unrelated to the TCE program are not allowable grant expenditures. Volunteers may be reimbursed using actual expenses, stipends, or both methods simultaneously – records must be kept on both, totals are reported under lines 5 through 8, and stipends must be designated based on expected out-of-pocket expenses (not on time engaged in volunteer service). Organizations that attempt to use grant funds for organizational salaries not directly tied to TCE administration, or that pay stipends based on hours of service rather than out-of-pocket expenses, risk grant clawback and disqualification from future awards.

Volunteer Certification Requirements for TCE Sites

All TCE volunteers must be certified by the IRS each year before preparing or reviewing returns. Certification is completed through Link & Learn Taxes (L&LT), the IRS online training platform. TCE-specific training modules cover the additional topics relevant to senior taxpayers.

Certification Level	Relevance to TCE
Basic	Minimum for all TCE preparers and reviewers
Advanced	Required for returns with rental income, Schedule C, retirement distributions
Social Security and Retirement Income	Specialized module critical for TCE sites serving seniors
Military	Relevant for TCE sites near military bases serving veteran seniors

TCE Reporting and Grant Accountability

TCE grantees are required to submit periodic performance reports to IRS SPEC documenting site activity, returns prepared, volunteer hours, and grant expenditures. Annual financial reports confirm that grant funds were spent on allowable expenses and within the grant period; the Form 8654 Annual Report itself is due by December 31 or 90 days after the completion of the program, whichever is earlier. Grantees that fail to submit required reports, misuse grant funds, or fail to meet performance targets may be placed on a corrective action plan or lose eligibility for future grants.

Record Retention

Federal grant recipients must retain financial records, supporting documentation, and program records for at least three years after the end of the grant performance period (or longer if litigation, claims, or audit findings are pending). Maintain organized records of all grant expenditures, volunteer rosters, training certifications, and site operational logs.

Common Mistakes That Slow Things Down

Form 8654 looks like a short report, but the same six errors come back every cycle and slow grant close-out for TCE sponsors. Catching them before the responsible officer signs saves a round of IRS clarification.

Practical Checklists You Can Reuse

Pull these into your TCE grant SOP folder. They cover the three points in the cycle where Form 8654 errors compound: mid-year, year-end, and the line 32 attachment.

Keep 8654 Season From Stalling

TCE grant close-out lands in two pressure points: the June 30 Semi-Annual filing for programs that operate past April 30, and the December 31 Annual report (or 90 days after program completion, whichever is earlier). Sponsors who run multiple sites with all-volunteer rosters often hit October and realize the cumulative reporting requirement (per IRS Form 8654 instructions, Rev. March 2026) means assembling workpapers from October 1 of the prior year, not from June 30.

The fix is not more hours during close-out. It is moving the controls earlier in the grant cycle so the report assembles itself from already-clean records.

• Stand up a cumulative expenditure workbook on October 1 of the fiscal year, with separate tabs for lines 5 through 7 volunteer reimbursements and lines 9 through 17 administrative expenses.
• Run a mid-year line 18 versus line 19 test in March or April – if admin is trending above 25%, reclass or trim before the 30% ceiling is breached.
• Maintain a single volunteer roster with a primary role flag so the column (a) count on lines 5(a), 6(a), and 7(a) never double-counts a coordinator who also prepares returns.
• Track recognition-item purchases against the $10 per-item cap on line 10 and food spend against the $500 program-wide cap on line 17 in real time, not at year-end.
• Keep the line 32 site listing live – update SIDN, EFIN, site type, and actual volunteer hours weekly so the attachment is ready when the final report is signed.

Sponsors who want production discipline without adding internal headcount lean on outsourced grant-accounting and review capacity. Accountably's tax and accounting delivery teams work inside your workpapers, run the cumulative reconciliation, and prepare the line 32 attachment so the responsible officer signs a report that ties out the first time.

FAQs

What is Form 8654 used for?

Form 8654 is the Tax Counseling for the Elderly Semi-Annual/Annual Program Report (OMB 1545-2222) – the post-award reporting form filed by TCE federal-award recipient organizations (program sponsors) to report semi-annual and annual program activity and expenditures to the IRS. It is not a taxpayer-facing return and not a grant application form. Organizations that receive IRS TCE funding to operate free tax assistance sites for taxpayers aged 60 and older use this form to report on program operations after the grant has been awarded.

When is Form 8654 due?

The Semi-Annual Program Report is due June 30 and is required when the program is still in operation after April 30. The Annual Program Report is due December 31, or within 90 days after the program is completed, whichever comes first. These are the due dates for the report itself, not for any application.

What does Form 8654 report?

Form 8654 reports the TCE program's activity and expenditures back to the IRS. It captures volunteer reimbursements on lines 5 through 8, administrative expenses on lines 9 through 17 (totaled on line 18), program cost on line 19, total program cost on line 22, the federal award and unexpended balance on lines 23 and 24, and program output: returns prepared (lines 26 through 28), taxpayers assisted (lines 29 and 30), and tax preparation sites (line 31).

What is the 30% administrative expense cap on Form 8654?

Total administrative expenses on line 18 (the sum of lines 9 through 17, column (b)) may not exceed 30% of program cost on line 19. If administrative expenses run above that limit, the report will not balance and the IRS SPEC function will flag it during review.

How are TCE grants different from VITA grants?

TCE grants specifically fund tax counseling services for taxpayers aged 60 and older, with specialized training on retirement income, Social Security, and pension issues. VITA grants fund free tax preparation services for low- to moderate-income individuals of any age. An organization may apply for both programs if it qualifies for each separately and can demonstrate the capacity to serve both populations.