VOTERS WITH 

DISABILITIES

Observations on 

Polling Place 

Accessibility and 

Related Federal 

Guidance

Report to Congressional Requesters

October 2017

GAO-18-4

United States Government Accountability Office

This report was revised on December 4, 2017 to correct page 41, 

Figure 10, the label of the measure we used to determine whether or 

not the height of the voting machine or voting surface was consistent 

with the 2010 ADA Standards for Accessible design criteria.

The corrected label is “44 inches Maximum height to voting machine 

or voting surface.”
United States Government Accountability Office

Highlights of GAO-18-4, a report to 

congressional requesters

October 2017

VOTERS WITH DISABILITIES

Observations on Polling Place Accessibility and 

Related Federal Guidance

What GAO Found

GAO examined a nongeneralizable sample of 178 polling places during early inperson voting and on Election Day 2016. At these polling places, GAO examined 

a number of features outside and inside the voting area. Outside the voting area, 

GAO was able to examine features at all 178 polling places and found that 60 

percent (107) had one or more potential impediments. The most common were 

steep ramps located outside buildings, lack of signs indicating accessible paths, 

and poor parking or path surfaces (see figure).

Of the 178 polling places, GAO was able to fully examine voting stations inside 

the voting area at 137. Of these 137 polling places, 65 percent (89) had a voting 

station with an accessible voting system that could impede the casting of a 

private and independent vote. For example, some voting stations were not set up 

to accommodate people using wheelchairs, which might have required someone 

else to help them vote. GAO was not able to fully examine voting stations at 41 

polling places due to voting area restrictions.

Most states that completed GAO’s survey reported taking actions during the 

2016 general election to facilitate voting access for voters with disabilities,

including having accessibility requirements, providing election worker training,

and conducting oversight. For example, 44 states reported having accessibility 

standards for polling places, and 48 states reported conducting at least one 

oversight activity, such as analyzing accessibility complaints.

The Department of Justice’s (DOJ) guidance does not clearly specify the extent 

to which certain federal accessibility requirements are applicable to early inperson voting, an increasingly common form of voting at a designated location

before Election Day. In this context, GAO found some variation in the extent to 

which accessible voting systems are provided for early in-person voting. GAO 

found one county without accessible voting systems at five of its early in-person

voting locations. Also, officials from four states said that these systems are not 

required by their state laws for in-person voting before Election Day. Given that 

voting has evolved since federal accessibility requirements were enacted, 

studying the implementation of these requirements in the context of early inperson voting could position DOJ to determine the extent to which any changes 

to its guidance are necessary.

View GAO-18-4. For more information, contact 

Barbara Bovbjerg at (202) 512-7215 or 

BovbjergB@gao.gov or Rebecca Gambler at 

(202) 512-8777 or GamblerR@gao.gov.

Why GAO Did This Study

Federal law generally requires all 

polling places for federal elections to 

be accessible to all voters, and each

polling place to have a system for 

casting ballots that is accessible for 

people with disabilities. GAO’s work 

during the 2000 and 2008 general

elections showed mixed results on 

polling place accessibility. GAO was 

asked to examine voting access for 

people with disabilities during the 2016 

general election.

This report examines in-person voting 

before and on Election Day 2016. GAO 

examined (1) the extent to which

selected polling places had features 

that might impede voting access; (2) 

actions states took to facilitate voting 

access; and (3) guidance DOJ 

provided on the extent to which federal 

accessibility requirements apply to 

early in-person voting. GAO examined

features at a nongeneralizable sample 

of 178 polling places, identified by

selecting 21 counties in 12 states and 

the District of Columbia (DC). Counties 

were selected for variation in 

population size, geographic location,

and type of election administration. 

GAO did not assess legal compliance 

with federal or state laws. GAO also 

surveyed state election officials in 50 

states and DC (with 98 percent 

responding); reviewed federal laws and 

guidance; and interviewed local, state,

and federal officials.

What GAO Recommends

GAO recommends that DOJ study the 

implementation of federal accessibility

requirements in the context of early inperson voting and, as necessary, make 

changes to existing guidance. DOJ 

generally agreed with GAO’s 

recommendation.
Page i GAO-18-4 Voters with Disabilities

Letter 1

Background 8

Most Selected Polling Places We Examined Had One or More 

Features Outside or Inside the Voting Area That Could Impede 

Access for Voters with Disabilities 14

Most States Reported Having Accessibility Requirements and 

Conducting Oversight among Other Actions during the 2016 

General Election 22

DOJ Guidance Does Not Clearly Specify the Extent to Which 

Federal Accessibility Requirements Apply to Early In-Person 

Voting 27

Conclusions 34

Recommendation for Executive Action 34

Agency Comments 34

Appendix I Objectives, Scope, and Methodology 36

Appendix II List of Potential Features Outside of the Voting Area That Might 

Impede Access to Voting 46

Appendix III Survey of States Actions to Facilitate Voting Access for People with 

Disabilities 52

Appendix IV Comments from the Department of Justice 64

Appendix V Comments from the Election Assistance Commission 66

Appendix VI GAO Contacts and Staff Acknowledgments 69

Contents
Page ii GAO-18-4 Voters with Disabilities

Tables

Table 1: Selected Federal Laws Related to Voting Accessibility for 

Voters with Disabilities 10

Table 2: Number of Polling Places with Voting Station Features 

That Could Impede Casting a Private and Independent 

Vote on an Accessible Voting System 21

Table 3: Type of Assistance That Polling Place Officials Reported 

They Would Provide to Help People with Disabilities 

Operate the Accessible Voting System 22

Table 4: Selected Features Outside the Voting Area That Might 

Impede Access to Voting: Selected Early In-Person 

Voting Polling Places 46

Table 5: Selected Features Outside the Voting Area That Might 

Impede Access to Voting: Selected Polling Places on 

Election Day 48

Table 6: States’ Responses to GAO 2016 Survey Question: “To 

the best of your knowledge, did your state office take any 

of the following actions to facilitate private and 

independent voting for people with disabilities in 

preparation for Election Day, November 8, 2016?” 52

Table 7: States’ Responses to GAO 2016 Survey Question: “For 

Election Day, November 8, 2016, did your state obligate 

or spend any Help America Vote Act (HAVA), state, 

and/or local funds for any of the following activities to help 

facilitate voting access for people with disabilities?” 53

Table 8: States’ Responses to GAO 2016 Survey Question: “In 

your opinion, for the 2016 general election, how 

challenging, if at all, has it been for your state to ensure 

voting access for people with disabilities in the following 

ways?” 54

Table 9: States’ Responses to GAO 2016 Survey Question: “For 

the 2016 general election, did your state office perform 

any of the following oversight activities to ensure local 

compliance with state and federal requirements for voting 

accessibility and accommodations?” 55

Table 10: States’ Responses to GAO 2016 Survey Question: “For 

the 2016 general election, did your state allow for or 

require jurisdictions to provide early in-person voting?” 55
Page iii GAO-18-4 Voters with Disabilities

Table 11: States’ Responses to GAO 2016 Survey Question: “For 

early in-person voting, did your state require, allow, 

prohibit, or not address each of the following accessibility 

provisions and at voting locations for people with 

disabilities?” 56

Table 12: States’ Responses to GAO 2016 Survey Question: “For 

early in-person voting for the 2016 general election, which 

of the following statements best describes your state’s 

policy for providing a direct recording electronic (DRE) 

system or other accessible machine at voting locations 

used by jurisdictions?” 56

Table 13: States’ Responses to GAO 2016 Survey Question: “To 

the best of your knowledge, did your state office take any 

of the following actions to facilitate private and 

independent voting for people with disabilities during early 

in-person voting for the 2016 general election?” 57

Table 14: States’ Responses to GAO 2016 Survey Question: “For 

early in-person voting for the 2016 general election, did 

your state obligate or spend any Help America Vote Act

(HAVA), state, and/or local funds for any of the following 

activities to help facilitate voting access for people with 

disabilities?” 57

Table 15: States’ Responses to GAO 2016 Survey Question: “In 

your opinion, how challenging, if at all, has it been to 

implement the following aspects of Help America Vote Act 

(HAVA) during early in-person voting in your state for the 

2016 general election?” 58

Table 16: States’ Responses to GAO 2016 Survey Question: “For 

early in-person voting for the 2016 general election, did 

your state office perform any of the following oversight 

activities to ensure local compliance with state and federal 

requirements for voting accessibility and 

accommodations?” 59

Table 17: States’ Responses to GAO 2016 Survey Question: “In 

your opinion, for the 2016 general election, has it been 

more challenging to ensure accessibility for early inperson voting than for Election Day, more challenging to 

ensure accessibility on Election Day than for early inperson voting, or has there been no difference between 

early in-person voting and Election Day?” 59
Page iv GAO-18-4 Voters with Disabilities

Table 18: States’ Responses to GAO 2016 Survey Question: “In 

your opinion, have the following aspects of the Help 

America Vote Act (HAVA) been more challenging to 

implement for early in-person voting than for Election Day, 

more challenging to implement on Election Day than for 

early in-person voting, or has there been no difference 

between early in-person voting and Election Day?” 61

Table 19: State-Reported Requirements Concerning the 

Accessibility of Polling Places: Election Days 2000, 2008 

and 2016 61

Table 20: States’ Reported Challenges in Implementing Various 

Aspects of the Help America Vote Act (HAVA), 2008 and 

2016 62

Table 21: Accommodations That States Reported Requiring Local 

Jurisdictions to Offer to Voters with Disabilities, as of 

Election Days 2000 2008 and 2016 62

Table 22: State-Reported Provisions Concerning Accessibility of 

Polling Places and Accommodations for Individuals with 

Disabilities, 2008 and 2016 63

Table 23: Reported Changes in State Requirements Concerning 

Alternative Voting Methods from the 2000, 2008 and 2016 63

Figures

Figure 1: Areas and Zones in Selected Polling Places That We 

Examined 5

Figure 2: Trend in the Percentage of Voters Casting a Vote before 

Election Day 8

Figure 3: Total Number of Potential Impediments at Selected 

Polling Places during the 2016 General Election, Outside 

or Inside the Voting Area 15

Figure 4: Number of Selected Polling Places That Had One or 

More Potential Impediments Outside the Voting Area 16

Figure 5: Zones Outside the Voting Area with One or More 

Potential Impediments That Could Impede Access for 

Voters with Disabilities 17

Figure 6: Example of a Polling Place with a Make-shift Ramp 

Constructed from a Folding Table and a Block of Wood 

That Could Pose an Impediment for Voters with 

Disabilities 18
Page v GAO-18-4 Voters with Disabilities

Figure 7: Number of Selected Polling Places with a Voting Station 

with an Accessible Voting System That Could Impede 

Casting a Private and Independent Vote 20

Figure 8: State-Reported Requirements Regarding the 

Accessibility of Polling Places, as of Election Days in 

2000, 2008, and 2016 24

Figure 9: Examples of Items for Observation and Measurements 

from Our Data Collection Instrument That Were Used to 

Train GAO Teams for Polling Place Examinations 39

Figure 10: Measurements Used to Determine If a Voting Station 

Was Set Up to Accommodate People Using Wheelchairs 

Based on Criteria in the Americans with Disabilities Act 41

Abbreviations

ADA Americans with Disabilities Act of 1990

DOJ Department of Justice

DRE direct recording electronic 

EAC Election Assistance Commission

HAVA Help America Vote Act of 2002

MCD minor civil division 

PAVA Protection and Advocacy for Voting Access

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Page 1 GAO-18-4 Voters with Disabilities

441 G St. N.W.

Washington, DC 20548

October 3, 2017

The Honorable Charles Schumer

Minority Leader

United States Senate

The Honorable Roy Blunt

Chairman

Subcommittee on the Departments of Labor, Health 

 and Human Services, Education, and Related Agencies

Committee on Appropriations

United States Senate

The Honorable Robert P. Casey

Ranking Member

Subcommittee on Children and Families

Committee on Health, Education, Labor, and Pensions

United States Senate

Voting is fundamental to America’s representative democracy, and 

federal law generally requires that polling place locations and voting 

methods be accessible to all eligible voters for federal elections. In 

particular, the Americans with Disabilities Act of 1990 (ADA) includes 

requirements to ensure that people with disabilities have access to public 

services, programs, or activities, such as voting.1 Although the ADA does 

not specifically address the accessibility of polling places, Title II of the 

ADA and its implementing regulation—which prohibit discrimination on 

the basis of disability—require public entities to select and use facilities 

for their services, programs, or activities that will not exclude people with 

disabilities and to provide appropriate auxiliary aids and services, where 

necessary, to provide people with disabilities an equal opportunity to 

participate in the service, program, or activity. Additionally, the Help 

America Vote Act of 2002 (HAVA) required that, by January 1, 2006, each 

polling place have at least one voting system that is accessible by people 

with disabilities in federal elections.2 According to HAVA, an accessible 

 1

Pub. L. No. 101-336, 104 Stat. 327 (codified at 42 U.S.C. §§ 12101-12213). 

2

Pub. L. No. 107-252, 116 Stat. 1666 (codified at 52 U.S.C. §§ 20901-21145); see 52 

U.S.C. § 21081(a)(3). 

Letter
Page 2 GAO-18-4 Voters with Disabilities

voting system must provide people with disabilities the same opportunity 

to vote privately and independently that is afforded to other voters.3

HAVA also established the Election Assistance Commission (EAC) to 

serve, among other purposes, as a clearinghouse and information 

resource for the election officials who administer federal elections.4 The 

Department of Justice’s (DOJ) Civil Rights Division is responsible for 

enforcing federal voting laws.

We have previously reported on issues related to the accessibility of 

polling places for people with disabilities. Specifically, our work on voting 

accessibility during the 2000 and 2008 general elections showed that 

although improvements to polling place accessibility had been made 

between the two elections, work remained to ensure that voting was fully 

accessible to people with disabilities.5 Since our previous work that 

described the accessibility of polling places used on Election Day, early 

in-person voting—voting in person at a polling place or other voting 

 3

52 U.S.C. § 21081(a)(3)(A). This requirement can be satisfied through the use of at least 

one direct recording electronic (DRE) voting system or other voting system equipped for 

individuals with disabilities at each polling place. 52 U.S.C. § 21081(a)(3)(B). A direct 

recording electronic voting system allows voters to mark ballots electronically using a 

touch screen or push-button interface, and their ballot selections are stored in the 

machine’s memory.

4

See 52 U.S.C. §§ 20921-30. 

5

GAO, Voters with Disabilities: Access to Polling Places and Alternative Voting Methods, 

GAO-02-107 (Washington, D.C.: Oct. 15, 2001); and Voters with Disabilities: Additional 

Monitoring of Polling Places Could Further Improve Accessibility, GAO-09-941 

(Washington, D.C.: Sept. 30, 2009).
Page 3 GAO-18-4 Voters with Disabilities

location before Election Day without providing an excuse—has expanded 

across the country,6 and is now used in almost three quarters of states.7

You asked us to examine voting access for people with disabilities at 

polling places used during early in-person voting and on Election Day 

(November 8) 2016. This report (1) examines the extent to which polling 

places in selected locations used during the 2016 general election had 

features that might impede access for voters with disabilities; (2) 

describes the actions states took to facilitate voting access during the 

2016 general election; and (3) examines the guidance that DOJ has 

provided on the extent to which federal accessibility requirements apply, if 

at all, to early in-person voting.

To determine the extent to which selected polling places had features that 

might impede access for voters with disabilities, we examined a 

nongeneralizable sample of 178 polling places. These included 45 early 

in-person voting polling places in 11 counties in 6 states and the District 

of Columbia, and 133 Election Day polling places in 21 counties in 12 

states and the District of Columbia. The counties we visited during early 

in-person voting were a subset of the counties visited on Election Day. 

However, we did not examine the same polling places on Election Day 

that we examined during early in-person voting. In each polling place, we 

made observations, took measurements, and interviewed chief polling 

place officials.

To identify polling places to examine, we first selected 21 counties from 

among the 84 randomly selected counties that were part of our study on 

the accessibility of polling places for voters with disabilities during the 

 6

We use this definition of early in-person voting throughout the report. Specifically, to 

examine the accessibility of polling places during the 2016 general election, our definition 

also includes the completion of an absentee or mail ballot in-person at a polling place or 

other voting location. Absentee voting generally is a method of voting offered in some 

states that enables citizens to cast a vote by mail and may require voters to provide an 

excuse explaining why they cannot vote on Election Day; although some states have "no 

excuse" absentee voting in which any validly registered voter may request and cast an 

absentee ballot. 

7

National Conference of State Legislatures, Election Administration website, accessed 

July 6, 2017, 

http://www.ncsl.org/research/elections-and-campaigns/absentee-and-early-voting.aspx.
Page 4 GAO-18-4 Voters with Disabilities

2008 general election.8 We selected these 21 counties based on: (1) 

variation in county population size (ranging from about 80,000 to over 10 

million people), with most counties being larger in population size; (2) 

variation in type of election administration (that is, we selected some 

counties in which the county administers elections, and we selected other 

counties in which elections are administered by other government 

entities, such as cities, townships, or other local government entities); and 

(3) variation in geographic location.

Within these counties, we selected up to seven polling places based on 

the relative proximity of polling places to one another and variation in 

types of facilities used as polling places, such as schools, houses of 

worship, or city halls. Because we selected a nongeneralizable sample of 

polling places for the 2016 general election, our results cannot be used to 

make generalizations about polling places nationwide during the 2016 

general election or to make comparisons with the results from our polling 

place accessibility assessments for the 2000 and 2008 general elections. 

However, our examination of the selected 178 polling places did provide 

important information about voter accessibility in a range of polling places 

in various types of local election jurisdictions across the country during 

the 2016 general election.

At our selected polling places, we examined features outside and inside 

the voting area that could have posed a potential impediment during early 

in-person voting or on Election Day voting.9 Figure 1 shows the zones 

within each area of the polling place where we made observations and 

took measurements. We examined specific features in each zone that 

might pose potential impediments for people with disabilities, many of 

which can primarily affect individuals with mobility impairments, such as 

voters using wheelchairs.

 8

See GAO-09-941. For a description of how we originally selected the 84 counties and the 

two-stage sampling method to select polling places, see appendix I.

9

Our use of the term “potential impediment” in this report is broader than our use of the 

term in our report on the 2008 general election. In our report on the 2008 general election, 

we used the term potential impediments in reference to features outside the voting area. 

In this report, the term refers to features both outside and inside the voting area.
Page 5 GAO-18-4 Voters with Disabilities

Figure 1: Areas and Zones in Selected Polling Places That We Examined

Outside the voting area of the polling place, we examined four zones: (1) 

parking, (2) the path from parking to the building entrance, (3) the 

entrance, and (4) the path from the entrance to the voting area. Inside the 

voting area, we assessed whether (1) an accessible voting system was 

provided, and (2) aspects of the voting station that could enable the 

casting of a private and independent vote by a person with a disability. To 

make these observations, we sent teams of two GAO staff to each 

selected county in our nongeneralizable sample during early in-person 

voting from October 26, 2016, through November 6, 2016, and separately 

on Election Day, November 8, 2016. Each team was equipped with a tape 

measure and a digital level,10 as well as a structured data collection 

instrument with which to document their observations and measurements. 

The teams used a data collection instrument similar to the one we used to 

document observations and measurements of features at polling places in 

the 2008 general election, as well as to document the responses of chief 

polling place officials to our interview questions. We revised the 2008 

data collection instrument to reflect changes made in the Americans with 

Disabilities Act: ADA Checklist for Polling Places 2016—issued by DOJ—

and in the 2010 ADA Standards for Accessible Design.

11 Additionally, 

 10The digital levels were used to measure potential structural impediments in buildings 

and on walkways. We tested the reliability of the digital levels based on the consistency of 

readings from all digital levels, by reviewing the manufacturer’s specifications, and talking 

with a representative of the manufacturer. We determined that the levels were sufficiently 

reliable for our purposes.

11Our updated data collection instrument, used to document observations and 

measurements, was based on the Americans with Disabilities Act: ADA Checklist for 

Polling Places 2016 as well as the ADA Standards for Accessible Design, and was 

reviewed by officials at DOJ and EAC. In particular, the data collection instrument was 

updated to include the cross-slope measurement of ramps or curb cuts. See 2010 ADA 

Standards for Accessible Design §§403.3, 405.3.
Page 6 GAO-18-4 Voters with Disabilities

officials at DOJ, EAC, and disability advocates reviewed a draft version of 

our data collection instrument, and we incorporated their comments 

where appropriate. We also pretested the data collection instrument at 

polling places during one state’s congressional primary in September 

2016.

For our observations and measurements both outside and inside the 

voting area, we did not differentiate the severity of potential impediments 

because accessibility is dependent on numerous factors, including the 

nature of an individual’s disability. In addition, we did not assess polling 

places for legal compliance with HAVA accessible voting system 

requirements or other federal or state laws, but as described more fully 

below, we examined features that might impede access to voting for 

people with disabilities.

We visited 178 polling places. However, in some instances our examiners 

were not able to complete all measurements inside the voting area 

because of voting area restrictions.

• Of the 178 polling places, we examined features outside the voting 

area at all 178.

• Of the 178 polling places, we observed whether or not the polling 

place had an accessible voting system at 167 polling places, although 

we were not able to observe every measurable aspect of the voting 

station.12 At the remaining 11 polling places, we were unable to 

observe if an accessible system was available. Further, for these 

polling places, we were able to determine potential impediments both 

outside and inside the voting area. 

• Of the 178 polling places, we determined whether or not the polling 

place had a voting station inside the voting area that could facilitate or 

impede the casting of a private and independent vote at 137 polling 

places. At the remaining 41 polling places we were not able to

observe if voting stations with accessible voting systems could 

impede private and independent voting.

 12We define “voting station” as the location within a polling place where voters may record 

their votes, including the area around and the actual voting booth or enclosure where 

voting takes place as well as the voting system. “Voting system” refers to the voting 

equipment that was used to cast a ballot, such as a DRE, a ballot-marking device, or 

another type of machine or technology. 
Page 7 GAO-18-4 Voters with Disabilities

To identify the actions states took to facilitate voting for people with 

disabilities during the 2016 general election, we administered a webbased survey to state election officials in all 50 states and the District of 

the Columbia from January 2017 to May 2017. We obtained a 98 percent 

response, as one state did not submit a survey response. We did not 

verify survey responses or other information provided by state officials, 

and some states did not respond to all survey questions. In general, we 

also did not analyze states’ laws to determine their voting access 

requirements, but instead relied on the states’ responses to our survey. 

However, in several cases, we conducted a limited review of state laws or 

other related information (such as type of early in-person voting provided) 

to understand the context of a state’s survey response.

To address all three objectives, we reviewed relevant federal laws and 

regulations as well as other relevant documentation, including (1) DOJ’s 

publicly available guidance on HAVA and ADA implementation, and (2) 

EAC’s 2007 advisory guidance regarding the HAVA accessible voting 

system requirement.13 We also interviewed election administration 

experts; officials at EAC, DOJ, and national organizations that represent 

election officials; local and state election officials; and, disability advocacy 

organizations. We also compared DOJ’s guidance against Standards for 

Internal Control in the Federal Government.14 Additional information about 

our objectives, scope, and methodology is provided in appendix I.

We conducted this performance audit from May 2016 to October 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 13Department of Justice, Civil Rights Division, Disability Rights Section, The Americans 

with Disabilities Act and Other Federal Laws Protecting the Rights of Voters with 

Disabilities. (Washington, D.C.: Sept. 2014); Americans with Disabilities Act: ADA 

Checklist for Polling Places 2016; and Election Assistance Commission, 2007 Guidance 

on Accessible Voting System Requirements (Washington, D.C.: Jan. 24, 2007).

14GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014). Internal control is a process effected by an entity’s 

oversight body, management, and other personnel that provides reasonable assurance 

that the objectives of an entity will be achieved.
Page 8 GAO-18-4 Voters with Disabilities

During the 2016 general election, approximately 137 million voters cast 

ballots in schools, libraries, churches, government buildings, recreation 

centers, senior centers, and other locations.15 According to the Census 

Bureau, over 51 million voters—about one of every three—cast their 

ballots before Election Day 2016, a number which has grown since 2000 

(see fig. 2).16

Figure 2: Trend in the Percentage of Voters Casting a Vote before Election Day

Note: Estimates come from independent analyses of data that includes the U.S. Census Bureau’s 

Current Population Survey. Discrepancies between these analyses and estimates from Census’s 

Current Population Survey data alone could arise from a number of potential factors, including the 

timing of this analyses and the incorporation of multiple data sources with different collection 

methodologies.

Authority to regulate elections is shared by federal, state, and local 

officials in the United States. The responsibility for the administration of 

federal and state elections resides at the state level, and states regulate 

various aspects of elections, including, for example, absentee and early 

voting requirements and Election Day procedures. Within each state, 

 15U.S. Federal Election Commission, Official 2016 Presidential General Election Results: 

November 8, 2016; (Washington, D.C.: Jan. 30, 2017).

16Michael P. McDonald, 2016 November General Election Early Voting, United States 

Elections Project (July 13, 2017), http://www.electproject.org/early_2016.

Background
Page 9 GAO-18-4 Voters with Disabilities

primary responsibility for planning, managing, and conducting elections 

largely resides with local officials at the county level or in minor civil 

divisions like cities and towns. These localities implement both Election 

Day processes as well as any voting processes that occur before Election 

Day, such as absentee and early in-person voting.

While federal elections are generally conducted under state laws and 

policies, several federal laws apply to voting and some provisions 

specifically address accessibility issues for voters with disabilities. These 

federal laws collectively address two issues that are essential to ensuring 

that voters with disabilities have the same opportunity as voters without 

disabilities to access and cast their ballots at a polling place: (1) physical 

access to the polling place, and (2) voting systems that enable people 

with disabilities to cast a private and independent vote. Table 1 shows 

selected federal laws addressing accessibility issues for voters with 

disabilities.

Federal Laws Relating to 

Voting and Accessibility
Page 10 GAO-18-4 Voters with Disabilities

Table 1: Selected Federal Laws Related to Voting Accessibility for Voters with Disabilities

Selected Law Highlights of Accessibility Requirements in Selected Laws

The Voting Rights Act of 1965

Pub. L. No. 89-110, 79 Stat. 437 

(codified as amended at

52 U.S.C. §§ 10101-702). 

• Authorizes voters who require assistance to vote (by reason of blindness, disability, or 

inability to read or write) to be assisted by a person of their choice, provided the assistant is 

not the voter’s employer or an agent of the voter’s employer or union.

Voting Accessibility for the Elderly 

and Handicapped Act (VAEHA)

Pub. L. No. 98-435, 98 Stat. 1678 

(codified as amended at 52 U.S.C. 

§§ 20101-07).

• Requires political subdivisions responsible for conducting elections to assure that all polling 

places for federal elections are accessible to elderly voters and voters with disabilities.

a

• One such exception occurs when the chief election officer of the state determines that no 

accessible polling places are available (or temporarily available) and the officer ensures that 

elderly voters and those with disabilities who are assigned to inaccessible polling places be, 

upon advance request, either reassigned to an accessible polling place or provided another 

means for voting on Election Day.

• Requires election administrators to provide registration and voting aids (such as instructions 

printed in large type) to the elderly and people with disabilities.

The Americans with Disabilities Act 

of 1990

Pub. L. No. 101-336,104 Stat. 327 

(codified as amended at 42 U.S.C. 

§§ 12101-213). See also 28 C.F.R. 

pt. 35. 

• Title II and its implementing regulation require that people with disabilities have access to 

public services, programs, or activities, including the right to vote.

• Does not specifically address the accessibility of polling places. Instead, public entities are 

required to select and use facilities for their services, programs, or activities that will not 

exclude people with disabilities.

b

Help America Vote Act of 2002

Pub. L. No. 107-252, 116 Stat. 

1666 (codified at 52 U.S.C. §§ 

20901-21145).

• Vests enforcement authority with the U.S. Attorney General to bring a civil action against any 

state or jurisdiction as may be necessary to carry out specified uniform and 

nondiscriminatory election technology and administration requirements under HAVA.

• Outlines minimum standards for voting systems for federal elections, stating that the voting 

system must be accessible for people with disabilities, including the blind and visually 

impaired, in a manner that provides the same opportunity for access and participation as for 

other voters.

• This requirement may be satisfied through the use of at least one direct recording electronic 

device or other voting system equipped for people with disabilities at each polling place.

Source: GAO analysis of federal laws. | GAO-18-4

a

Under the VAEHA, the definition of “accessible” is determined under guidelines established by the 

state’s chief election officer, but the law does not specify standards or minimum requirements for 

those guidelines. 52 U.S.C. § 20107(1).

b

However, public entities are not required to take any action that they can demonstrate would result in 

a fundamental alteration in the nature of a service, program, or activity or in undue financial and 

administrative burdens. 28 C.F.R. § 35.164.

In 2010, DOJ promulgated revised regulations for Title II and Title III of 

the ADA, which included the adoption of the 2004 ADA Standards for 

Accessible Design updated accessibility standards as part of the 2010 

ADA Standards for Accessible Design (2010 Standards).

17 The 2010 

Standards—which became effective in March 2012—revised the

 17See 75 Fed. Reg. 56,164 (Sept. 15, 2010) and 75 Fed. Reg. 56,236 (Sept. 15, 2010). 
Page 11 GAO-18-4 Voters with Disabilities

minimum accessibility requirements, such as specifications for sloped

surfaces, new construction or construction modifications to state and local 

government facilities, public accommodations, and commercial buildings, 

that had been established in the 1991 ADA Standards for Accessible 

Design.

DOJ helps ensure state and local compliance with federal laws and 

regulations designed to provide voters with disabilities physical access to 

polling places and voting systems through a number of actions. For 

example:

• DOJ’s Civil Rights Division is responsible for enforcing Title II of the 

ADA (which prohibits discrimination on the basis of disability in public 

services), and Section 301 of HAVA (which requires each polling 

place in a federal election to have a voting system that is accessible 

to individuals with disabilities).

• DOJ separately investigates allegations of program access violations, 

including within polling places, under its Title II enforcement 

authority.

18

• DOJ also provides educational outreach and technical assistance to 

states and localities. Specifically, based on the 2010 Standards for 

Accessible Design, in 2016 DOJ updated technical guidance for 

polling place accessibility, known as the DOJ ADA Checklist for 

Polling Places (ADA Checklist). The ADA Checklist mainly focuses on 

ADA accessibility requirements for polling places and offers guidance 

for temporary measures that can be used to facilitate access for 

people with disabilities. The ADA Checklist is also used by DOJ 

officials and state and local election administrators to evaluate the 

accessibility of current and potential polling places.

The EAC—an independent federal commission established by HAVA—

has wide-ranging duties that help improve state and local administration 

of federal elections. Among other things, the EAC is responsible for (1) 

periodically conducting and making publicly available studies regarding 

methods of ensuring accessibility of voting, polling places, and voting 

equipment; (2) serving as a national clearinghouse of and resource for 

 18Under “Project Civic Access,” for example, DOJ has reached agreements with a number 

of cities and towns to open up civic life, including voting, to people with disabilities. Some 

agreements require altering polling places and providing curbside or absentee balloting.

DOJ’s and EAC’s Roles in 

Federal Elections
Page 12 GAO-18-4 Voters with Disabilities

federal election-related information; (3) providing for the certification of 

voting systems; and (4) providing voluntary guidance to states 

implementing certain HAVA provisions. EAC does not have legal authority 

to enforce implementation of the ADA or HAVA.

The responsibility for the administration of federal elections resides at the 

state level, and states regulate various aspects of elections including, for 

example, registration procedures, absentee and early voting 

requirements, and Election Day procedures. States also establish policies 

for how voters can cast their ballots—including opportunities to vote in 

person on Election Day, in person before Election Day (e.g., early inperson voting), by mail under certain circumstances (absentee voting), by 

mail under any circumstances (no-excuse absentee or all vote-by-mail)—

and states can choose to implement a combination of such policies.19

Within states, implementing federal and state election policies is largely a 

local responsibility, residing with about 10,500 local election jurisdictions 

nationwide. Local election officials make a number of planning and 

management decisions that determine the day-to-day operations of 

polling places. For example, they can designate any of the variety of 

locations mentioned earlier as a polling place. Local election officials also 

recruit and train poll workers.

Some states have implemented voting methods aimed at increasing voter 

convenience by offering citizens an alternative to voting on Election Day, 

which may benefit people with disabilities. These methods include inperson voting before Election Day—also referred to as early in-person 

voting—which has been gaining popularity in federal elections in recent 

years.20 In general, this form of voting affords an eligible voter the 

opportunity to cast a ballot in person prior to Election Day. The provision 

and implementation of voting before Election Day is governed by state 

 19For more information about state laws regarding registration and voting on or before 

Election Day, see GAO, Elections: State Laws Addressing Voter Registration and Voting 

on or before Election Day, GAO-13-90R (Washington, D.C.: Oct. 4, 2012).

20We have previously reported that for the 2010 general election, 33 states and the 

District of Columbia required or allowed for early in-person voting, which increased from 

24 states and the District of Columbia during the 2004 general election. See GAO, 

Elections: Views on Implementing Federal Elections on a Weekend, GAO-12-69 

(Washington, D.C.: Jan.12, 2012). 

State and Local Election 

Jurisdictions and Methods 

of Voting
Page 13 GAO-18-4 Voters with Disabilities

law and varies from state to state; consequently, there is no national 

definition of early voting.

Methods for in-person voting before Election Day and the extent to which 

they are used vary across states and localities. Some states or 

jurisdictions allow voters who have obtained an absentee ballot to cast 

their vote in-person at a designated location prior to Election Day in a 

process known as in-person absentee voting. Others allow voters to cast 

their ballots in the same manner as they would on Election Day during 

early voting. While both of these forms of in-person voting before Election 

Day might offer similar experiences for voters, the state laws governing 

them—such as in the dates, times, and locations that these options are 

offered—can vary widely as can local procedures for handling these preElection Day ballots. For example, ballots cast before Election Day at a 

clerk’s office might be counted at a central location on Election Day 

versus being counted at the precinct. Local election administrators may 

also exercise discretion in determining the number and location of early 

voting sites as well as their hours of operation.

Providing an accessible voting system encompasses both the voting 

method and the operation of the system. In terms of the voting method, 

HAVA requires the use of a direct recording electronic (DRE) voting 

system or other voting system equipped for individuals with disabilities to 

facilitate voting for people with disabilities. These accessible voting 

systems are primarily electronic machines or devices equipped with 

features to assist voters with disabilities.

• DRE devices capture votes electronically. These devices come in 

both push button or touch screen models, and mark ballots when a 

voter presses a button or touches a screen that highlights the selected 

ballot option (such as a candidate’s name). Voters can change their 

selections until they touch the final vote location that indicates a 

completion of all choices, and their vote is officially cast. These 

devices can be equipped with features such as an audio ballot and 

audio voting instructions for the blind.

• Ballot marking devices use electronic technology to mark an optical 

scan ballot at voter direction, interpret ballot selections, communicate 

the interpretation for voter verification, and print a voter-verified ballot. 

Voters use a device’s accessible interface to record their choices on a 

paper or digital ballot. These devices can accommodate voters who 

Accessible Voting 

Systems for People with 

Disabilities
Page 14 GAO-18-4 Voters with Disabilities

prefer to vote in an alternate language or require use of a foot-pedal 

or a sip-and-puff device.21

In terms of the operation of the system, HAVA specifies that the 

accessible voting system must provide the same opportunity for access 

and participation, including privacy and independence, as provided to 

other voters.22

We visited 178 selected polling places during either early in-person voting 

or on Election Day 2016. At these polling places, we examined a number 

of features both outside and inside the voting area. Of the 178 polling 

places, we were able to examine features across both areas at 167.23 A 

minority of these 167 polling places were free of potential impediments.24

Outside the voting area only—where we were able to measure features at 

all 178 polling places—most had one or more potential impediments 

anywhere from (1) parking, (2) the path to the building entrance, (3) the 

entrance, or (4) the path from the entrance to the voting area. Inside the 

voting area only—where we were able to observe whether or not the 

polling place had an accessible voting system at 167 of the 178 polling 

places—almost all had accessible voting systems. Further, of the 178 

polling places, we were able to determine whether or not the polling place 

had a voting station inside the voting area that could facilitate or impede 

the casting of a private and independent vote at 137 polling places. Of 

these 137 polling places, most were set up in a way that could impede 

casting a private and independent vote.

 21A sip-and-puff device is a straw-like accessory that allows a voter to make selections by 

either blowing or sucking into the device. 

2252 U.S.C. § 21081(a)(3)(A). 

23Throughout this report, we characterize the number of selected polling places with 

potential impediments with modifiers defined as follows: “almost all” represents 90 percent 

or more of selected polling places; “most” represents 60 percent or more of selected 

polling places; “the majority” represents 51 percent or more of selected polling places; 

“many” represents 40 percent or more of selected polling places; and a “minority” 

represents 20 percent or fewer of selected polling places.

24For the purposes of this study, we treated all of the potential impediments with equal 

significance, although we recognize that, in practice, the effect of any one impediment 

may depend on the nature of an individual’s disability. For example, the width of a door 

would not necessarily affect an individual who is blind and without mobility impairments, 

but it could prevent a person using a wheelchair from entering a polling place.

Most Selected Polling 

Places We Examined 

Had One or More 

Features Outside or 

Inside the Voting Area 

That Could Impede 

Access for Voters 

with Disabilities
Page 15 GAO-18-4 Voters with Disabilities

Of the 167 polling places where we could examine features outside and 

inside the voting area, 17 percent of polling places (29 of 167) were free 

of any potential impediments across both areas during early in-person 

voting or on Election Day 2016. That is, 83 percent (138 of 167) of polling 

places had one or more potential impediments. Figure 3 provides 

additional details about the number and location of these potential 

impediments.

Figure 3: Total Number of Potential Impediments at Selected Polling Places during 

the 2016 General Election, Outside or Inside the Voting Area

Note: We made observations and measurements outside of the voting area at all 178 selected polling 

places, which include early in-person and Election Day polling places. However, we observed and 

measured inside the voting area at 167 polling places, and were able to make full observations and 

measurements of both areas (including at the voting station) at 137 polling places with accessible 

voting systems. Also, for inside the voting area, none of the 89 polling places with potential 

impediments had voting stations with accessible voting systems with more than 3 potential 

impediments to casting a private and independent vote.

A Minority of Polling 

Places We Examined 

Were Free of Any Potential 

Impediments 
Page 16 GAO-18-4 Voters with Disabilities

Most polling places (107 of 178, or 60 percent) we examined during early 

in-person voting and on Election Day had one or more potential 

impediments from parking to the voting area. Of these 107 polling places, 

43 had one potential impediment, 53 had two to four potential 

impediments, and 11 had five or more potential impediments (see fig. 4). 

Examples of potential impediments included poor or unpaved parking 

surfaces and doors that would be difficult for a person using a wheelchair 

to open. Forty percent of all polling places we examined (71 of 178) had 

no potential impediments outside of the voting area.

Figure 4: Number of Selected Polling Places That Had One or More Potential 

Impediments Outside the Voting Area

Note: 71 of the 178 polling places we examined had no potential impediments.

At a majority of the polling places with one or more potential impediments 

outside the voting area, polling place officials we interviewed said that 

they offered curbside voting to assist voters who may have had difficulty 

getting to or making their way through a polling place.25 Specifically, of 

the 107 polling places that had one or more potential impediments, 63 

offered curbside voting, while the remaining 44 did not.

 25According to DOJ guidance, curbside voting cannot replace in-person voting except in 

rare circumstances. Specifically, “in some circumstances, when a public entity is unable to 

identify or create an accessible polling place...election administrators may instead use an 

alternative method of voting at the polling place. While absentee balloting can be offered 

to voters with disabilities, it cannot take the place of in-person voting for those who prefer 

to vote at the polls on Election Day. Any alternative method of voting must offer voters 

with disabilities an equally effective opportunity to cast their votes in person. For example, 

the only suitable polling site in a precinct might be an inaccessible building. In this rare 

circumstance, election administrators may provide “curbside voting” to allow persons with 

disabilities to vote outside the polling place or in their cars.” See Department of Justice, 

Civil Rights Division, Disability Rights Section, The Americans with Disabilities Act and 

Other Federal Laws Protecting the Rights of Voters with Disabilities (Washington, D.C.: 

September 2014).

Most Polling Places We 

Examined Had One or 

More Potential 

Impediments Outside the 

Voting Area
Page 17 GAO-18-4 Voters with Disabilities

Outside the voting area, we found differences between the polling places 

we examined during early in-person voting and those we examined on 

Election Day 2016. Specifically, we found that outside the voting area 64 

percent (29 of 45) of the early in-person polling places had one or more 

potential impediments compared with 59 percent (78 of 133) of the 

Election Day polling places. In addition, 38 percent (11 of 29) of the 

polling places used for early in-person voting with one or more potential 

impediments offered curbside voting while 67 percent (52 of 78) of the 

Election Day polling places with one or more potential impediments 

offered it.26

Of the four zones we examined outside the voting area at all 178 polling 

places, the path from parking to the building entrance was the zone that 

most commonly had one or more potential impediments, followed by the 

building entrance (see fig. 5). Specifically, 33 percent (58 of 178) of all 

polling places we examined had at least one potential impediment on the 

path to the building, such as an unsafe or poor ramp surface. (See figure 

6 for an example of a ramp we observed that was constructed from a 

folding table and a block of wood.) None of the selected polling places 

had a potential impediment in all four zones.

Figure 5: Zones Outside the Voting Area with One or More Potential Impediments 

That Could Impede Access for Voters with Disabilities

 26Furthermore, 42 percent (19 of 45) of all polling places used for early in-person voting 

that we examined offered curbside voting compared with 62 percent (83 of 133) of the 

Election Day polling places.
Page 18 GAO-18-4 Voters with Disabilities

Figure 6: Example of a Polling Place with a Make-shift Ramp Constructed from a 

Folding Table and a Block of Wood That Could Pose an Impediment for Voters with 

Disabilities

In addition, we observed that a higher percentage of polling places we 

examined during early in-person voting than on Election Day had one or 

more potential impediments across three of the four zones outside the 

voting area: (1) the path to the building entrance (17 of 45 polling places 

during early in-person versus 41 of 133 polling places on Election Day); 

(2) the building entrance (13 of 45 versus 26 of 133); and (3) the path 

from the building entrance to the voting area (14 of 45 versus 21 of 133).

Across the polling places we examined during the 2016 general election, 

the most common potential impediments outside the voting area were 

steep ramps or curb cuts located outside the building; entrance door 

thresholds exceeding 1⁄2 inch in height; poor parking, pathway, or ramp 

surfaces; and, a lack of signs clearly indicating accessible paths from 

parking to the voting area. See appendix II for a full listing of each 

potential impediment we observed at polling places used for early inperson voting and separately on Election Day 2016.
Page 19 GAO-18-4 Voters with Disabilities

Of the polling places in which we made observations and measurements 

inside the voting area, almost all (158 of 167, or 95 percent) had at least 

one accessible voting system. The most common brands of accessible 

voting systems used at these polling places were ballot marking devices. 

Ballot marking devices are accessible voting systems that use electronic 

technology to mark an optical scan ballot. However, 5 percent (9 of the 

167 polling places) did not have any accessible voting systems. Of these 

9 polling places without an accessible voting system, 6 were located at 

polling places used for early in-person voting. Further, 5 of these 6 polling 

places without an accessible voting system were located in one local 

jurisdiction.

Of the selected polling places in which we were able to make full 

observations of the voting station, most (89 of 137, or 65 percent) had at 

least one station with an accessible voting system that could impede 

casting a private and independent vote.27 To determine if voting stations 

with accessible voting systems could impede private and independent 

voting, we assessed four aspects of the voting station: (1) whether the 

voting system was set up and powered on; (2) whether earphones were 

available for audio functions; (3) whether the voting station was set up to 

accommodate people using wheelchairs; and (4) whether the accessible 

voting station provided the same level of privacy for casting a ballot as the 

level of privacy for voters using a standard voting station.28

Of the 137 polling places in which we were able to measure aspects of 

private and independent voting in full, 62 polling places did not have a 

station that met one of these four aspects, 24 did not have one that met 

two aspects, and 3 did not have one that met three aspects. The 

remaining 48 polling places we examined—among the 137 which we 

 27We define “voting station” as the location within a polling place where voters may record 

their votes, including the area around and the actual voting booth or enclosure where 

voting takes place as well as the voting system. For the purposes of this report, we define 

“voting system” to be the voting equipment that is used to cast a ballot, such as a DRE, a 

ballot-marking device, or another type of machine or technology.

28If a polling place had more than one station with an accessible voting system, we 

measured the voting station that seemed to be best configured for voting in a chair or 

wheelchair. If any aspect was not met, we assessed any other stations with an accessible 

voting system to determine if one station met all four aspects for facilitating private and 

independent voting. If we found that all voting stations with an accessible voting system 

could impede casting a private and independent vote, we reported that the polling place 

did not have a voting station with an accessible voting system that met one or more of the 

four aspects we assessed.

Almost All Polling Places 

We Examined Had 

Accessible Voting 

Systems, but Most Had 

Voting Stations with 

Aspects That Could 

Impede Private and 

Independent Voting
Page 20 GAO-18-4 Voters with Disabilities

were able to measure in full—had a voting station with an accessible 

voting system that met all aspects (see fig. 7).

Figure 7: Number of Selected Polling Places with a Voting Station with an 

Accessible Voting System That Could Impede Casting a Private and Independent 

Vote

Note: To determine if voting stations with accessible system could impede private and independent 

voting, we assessed four aspects of the voting station: (1) whether the voting system was set up and 

powered on; (2) whether earphones were available for audio functions; (3) whether the voting station 

was set up to accommodate people using wheelchairs; and (4) whether the accessible voting station 

provided the same level of privacy for casting a ballot as the level of privacy for voters using a 

standard voting station. None of the 89 polling places observed had all four aspects unmet.

As shown in table 2, the aspect of the voting station that most commonly 

posed a potential impediment to casting a private and independent vote 

was a setup that would not accommodate wheelchairs. A voting station 

not set up to accommodate people using wheelchairs might require 

someone else to help a person with a disability vote, which might not 

provide the same level of privacy for a voter with a disability as offered to 

other voters.
Page 21 GAO-18-4 Voters with Disabilities

Table 2: Number of Polling Places with Voting Station Features That Could Impede Casting a Private and Independent Vote on 

an Accessible Voting System

Accessible voting station features that could

potentially impede casting a private and independent vote

Number of polling places

with potential impediment

Percentage of polling places 

with potential impedimenta

Voting system is not set up or powered on 9 7%

Earphones are not attached or prominently visible 13 9%

Voting station is not set up to accommodate voters using a 

wheelchair 58 42%

Voting station does not provide the same level of privacy for 

voters with disabilities that is afforded other voters 39 28%

Source: GAO analysis of polling place data collected during the 2016 general election. | GAO-18-4

a

Percentages are based on the 137 polling places with accessible voting stations that GAO was able 

to fully observe and measure. To determine if voting stations with accessible systems could impede 

private and independent voting, we assessed four aspects of the voting station: (1) whether the voting 

system was set up and powered on, (2) whether earphones were available for audio functions,(3) 

whether the voting station was set up to accommodate people using wheelchairs, and (4) whether the 

accessible voting station provided the same level of privacy for casting a ballot as the level of privacy 

for voters using a standard voting station.

A higher percentage of the polling places we observed on Election Day 

had a voting station with an accessible voting system that could impede 

casting a private and independent vote compared with the early in-person 

voting polling places we examined. Specifically, 67 percent (73 of 109) of 

the Election Day polling places versus 57 percent (16 of 28) of the early 

in-person polling places had a voting station with an accessible voting 

system that could impede casting a private and independent vote.

Almost all of the chief polling place officials said that they would allow a 

friend or relative of a voter with a disability to assist with voting, and most 

said that they themselves would provide various types of assistance to 

help people with disabilities who encountered difficulties while using an 

accessible voting system (see table 3). In addition, officials in 75 percent 

(126 of 167) of the polling places said that their training provided them 

with hands-on practice on how to operate the accessible voting system.29

However, officials in 8 percent (14 of 167) of the polling places we 

examined said that they did not receive any training on accessible voting 

systems.

 29Not all polling place officials answered every question in our data collection instrument. 

Each percentage is based on the number of polling places where officials answered the 

question and not on 178.
Page 22 GAO-18-4 Voters with Disabilities

Table 3: Type of Assistance That Polling Place Officials Reported They Would Provide to Help People with Disabilities 

Operate the Accessible Voting System

Type of assistance polling place officials would 

provide

Number of polling

places where officials

would provide assistance

Percentage of polling places where 

officials would provide assistancea

Explain how to operate the accessible voting system 157 96%

If asked, talk the person through operations while they are 

voting 151 92%

Demonstrate how to operate the accessible voting system 126 80%

Operate the machine for the person if having difficulties 

voting 121 75%

Let the person practice on the machine before voting 53 33%

Source: GAO analysis of polling place data collected during the 2016 general election. | GAO-18-4

a

Not all polling place officials answered every question in our data collection instrument. Each 

percentage is based on the number of polling places where officials answered the question and not 

on 178.

States that completed our survey reported taking a range of actions to 

support access for voters with disabilities during the 2016 general 

election.30 These reported actions included having accessibility 

requirements, providing election worker training and voter education and 

outreach, as well as conducting oversight. These results are similar to 

what states reported in prior GAO work during the 2008 general 

election.31 Also, these reported actions included efforts to facilitate private 

and independent voting for people with disabilities. For the 39 states that 

reported requiring or allowing early in-person voting, most states reported 

taking similar actions during early in-person voting as on Election Day 

2016. Moreover, states reported that the challenges they faced to 

ensuring accessibility for Election Day were similar to the ones faced for 

early in-person voting, with a few exceptions.

 30We surveyed 50 states and the District of Columbia and received a 98 percent response 

(one state did not complete the survey). In this report, we are using the term “states” in 

reference to the states and the District of Columbia.

31Our 2016 survey allows for comparisons with past results on state accessibility 

requirements that were published in our 2009 report. See GAO-09-941. However, we 

updated and added new questions to the survey about other actions, such as conducting 

oversight, that are not comparable with our past work. For more information, see appendix 

I.

Most States Reported 

Having Accessibility 

Requirements and 

Conducting Oversight 

among Other Actions 

during the 2016 

General Election
Page 23 GAO-18-4 Voters with Disabilities

State accessibility requirements. In 2016, most states that completed 

our survey reported having accessibility requirements in place under their 

state law, regulation, executive order, or executive directive. Specifically, 

the number of states reporting requirements specifying polling place 

accessibility standards grew slightly from 43 states in 2008 to 44 states in 

2016.32 One state reported, for example, that when new polling places are 

identified, local election officials are required to file a polling place 

accessibility self-assessment, which the state reviews for approval. In 

addition, officials from 40 states reported that they required 

accommodations for wheelchairs in the voting area on Election Day, 

which increased from 38 states for the 2008 general election. In addition, 

while most states reported they had state requirements in place to help 

ensure accessibility, fewer states reported requiring polling places to be 

inspected in 2016 (26 states) than in 2008 (34 states). Similarly, fewer 

states reported requiring local jurisdictions to submit inspection reports to 

the state to help ensure accessibility of polling places for Election Day 

2016 (20 states) than in 2008 (29 in 2008).33 Figure 8 shows the number 

of states that reported having accessibility and inspection requirements in 

place for polling places for the 2000, 2008, and 2016 general elections.

 32See GAO-09-941.

33While the number of states that reported having requirements for inspections and 

reporting mechanisms decreased between 2008 and 2016, the number of states that 

reported allowing their localities to have requirements for performing inspections of and 

provide reporting on polling place accessibility increased slightly between 2008 and 2016. 

Specifically, 16 states reported in 2016 that they allowed local jurisdictions to establish 

their own requirements for reporting accessibility issues, whereas 12 states reported this 

in 2008.
Page 24 GAO-18-4 Voters with Disabilities

Figure 8: State-Reported Requirements Regarding the Accessibility of Polling Places, as of Election Days in 2000, 2008, and 

2016

Note: Data for 2016 include 49 states and the District of Columbia while data from 2000 and 2008 

includes all states and the District of Columbia; and, for the 2000, 2008, and 2016 surveys, not all 

states may have answered every survey question.

Education, outreach, and oversight. Most states reported providing 

education and training to local election officials and poll workers as well 

as conducting outreach to people with disabilities for Election Day 2016. 

For example, 43 states reported that they provided guidance to local 

election officials on voting accessibility for people with disabilities, and 

officials from 32 states reported that they provided training to local 

election officials on how to operate an electronic recording system or 

other accessible voting system. For example, one state reported that it 

produced a training video for county election officers. In addition to 

educating and training local election officials and poll workers, most 

states reported conducting outreach to people with disabilities. 

Specifically, officials from 38 states reported that they provided voter 

education to people with disabilities on voting access methods, and 

officials from 40 states reported that they provided election information at 

polling places, such as sample ballots or voter instructions. For example, 

one state reported that they contracted with a Protection and Advocacy 
Page 25 GAO-18-4 Voters with Disabilities

for Voting Access group who developed several ads that emphasized 

voter accessibility at the polls for people with disabilities.

In addition to education and outreach, 48 states reported conducting at 

least one oversight activity to ensure local compliance with state and 

federal accessibility requirements for voting on Election Day. For 

example, 39 states reported compiling and analyzing complaints of polling 

place accessibility issues occurring on Election Day; 34 states reported 

that they investigated or adjudicated local complaints on polling place 

accessibility and accommodations on Election Day; and 35 states 

reported that they evaluated and verified compliance with state 

requirements. One state, for example, reported deploying advocacy 

volunteers and volunteer attorneys to assess polling places to ensure 

compliance around the state.

Private and independent voting. In preparation for Election Day 2016, 

almost all states reported taking at least one action to facilitate private 

and independent voting for people with disabilities. Such voting methods 

are designed to provide the same level of privacy for voters with 

disabilities as offered to other voters, and enable people with disabilities 

to independently verify their vote and make any changes to their ballot 

before it is cast without assistance. Specifically, 48 states reported that 

they provided guidance on facilitating private and independent voting to 

local election officials, and 45 states reported providing training to local 

election officials and poll workers about this issue.

Early in-person voting. Thirty-nine states reported requiring or allowing 

early in-person voting, a method of voting by which a voter may complete 

a ballot in person prior to Election Day.34 Similar to their responses 

regarding Election Day voting, most states that offered early in-person 

voting also reported taking a range of actions to ensure compliance with 

accessibility requirements for people with disabilities. We found

 34For our survey purpose, we defined “early in-person voting” as voting in-person without 

providing an excuse. Our definition also included the completion of an absentee or mail 

ballot in-person at a polling place.
Page 26 GAO-18-4 Voters with Disabilities

• 35 of 39 states reported having in place state accessibility 

requirements for polling places for early in-person voting;35

• 31 of 39 states reported training election officials on voting access 

methods for people with disabilities during early in-person voting;

• 29 of 39 states reported offering voter education to people with 

disabilities on voting access methods during early in-person voting;

• 36 of 39 states reported performing at least one oversight activity to 

ensure local compliance with state and federal accessibility 

requirements for early in-person voting; and

• 36 of 39 states reported providing guidance to local election officials 

to facilitate private and independent voting for people with disabilities 

during early in-person voting.

In addition, most states reported that the challenges they face to ensure 

accessibility for voters with disabilities were similar for both early inperson voting and Election Day voting. In general, a majority of states 

reported no difference in challenges between early in-person voting or 

Election Day for these provisions and activities. For example, among the 

39 states that indicated requiring or allowing early in-person voting, 32 

states reported no difference in providing “voter information at voting 

locations,” and establishing or maintaining “state-based administrative 

complaint procedures,” whether it was during early in-person voting or for 

Election Day. For the states that reported differences in challenges 

between early in-person voting and Election Day, a majority indicated that 

there were more challenges associated with Election Day than early inperson voting. For example, 13 states reported that identifying accessible 

facilities for potential polling places was either “somewhat more 

challenging” or “more challenging” for Election Day than for early inperson voting before Election Day. Additional information is available in 

Appendix III, tables 17 and 18.

 35An additional 3 states reported that such provisions were allowed at the local level for 

early in-person voting, but were not a state-wide requirement for early in-person voting as 

they were for Election Day; 1 state reported that they did not address this provision.
Page 27 GAO-18-4 Voters with Disabilities

DOJ provides guidance related to federal accessibility requirements in the 

context of voting for people with disabilities; however, this guidance does 

not clearly specify the extent to which these requirements apply to the 

various forms of in-person voting before Election Day. For example, one 

form of in-person voting before Election Day is marking an absentee 

ballot in-person at an elections office.

HAVA and ADA contain requirements related to accessibility, including 

requirements related to the accessibility of voting systems used in federal 

elections. Specifically:

• HAVA section 301(a)(3) requires that a voting system “be accessible 

for individuals with disabilities, including nonvisual accessibility [. . .] in 

a manner that provides the same opportunity for access and 

participation (including privacy and independence) as for other 

voters.”36 This section further states that this requirement may be 

satisfied “through the use of at least one direct recording electronic 

voting system or other voting system equipped for individuals with 

disabilities at each polling place.” HAVA does not define the term 

“polling place.”

• Title II of the ADA and its implementing regulation, which prohibit 

discrimination on the basis of disability, require public entities to select 

and use facilities for its services, programs, or activities—such as 

voting—that will not exclude people with disabilities and to provide 

appropriate auxiliary aids and services where necessary to provide 

people with disabilities an equal opportunity to participate in the 

service, program, or activity.

37 According to DOJ’s guidance, The 

Americans with Disabilities Act and Other Federal Laws Protecting the 

Rights of Voters with Disabilities (Federal Voting Laws Guidance), the 

ADA’s provisions apply to all aspects of voting.38 Therefore, in 

accordance with the ADA, election officials conducting any elections, 

including federal elections, must provide an opportunity to participate 

 36See 52 U.S.C. § 21081(a)(3).

37See 42 U.S.C. § 12132; 28 C.F.R. § 35.130-35.164. 

38DOJ, Civil Rights Division, Disability Rights Section, The Americans with Disabilities Act 

and Other Federal Laws Protecting the Rights of Voters with Disabilities (Washington, 

D.C.: September 2014).

DOJ Guidance Does 

Not Clearly Specify 

the Extent to Which 

Federal Accessibility 

Requirements Apply 

to Early In-Person 

Voting
Page 28 GAO-18-4 Voters with Disabilities

in the elections process that is equal to that afforded others.39 To 

afford individuals with disabilities equal opportunity to participate in 

the election process, election officials conducting elections are 

required to furnish appropriate auxiliary aids and services. To be 

effective, “auxiliary aids and services must be provided in accessible 

formats, in a timely manner, and in such a way as to protect the 

privacy and independence of the individual with a disability.”40

However, under the ADA, officials are not required to take any action 

that they can demonstrate would result in a fundamental alteration in 

the nature of a service, program, or activity or in undue financial and 

administrative burdens.41 Nonetheless, the election officials have an 

obligation to provide, if possible, another auxiliary aid or service that 

results in effective communication. In determining the type of auxiliary 

aid or service to be provided, officials must give primary consideration 

to the request of the individual with a disability.42

DOJ is responsible for enforcing the federal voting rights and disability 

rights laws as well as providing certain guidance and technical assistance 

regarding voting accessibility. However, DOJ’s guidance does not clearly 

specify the extent to which HAVA’s accessible voting system requirement 

or the ADA’s auxiliary aids and services requirement apply to early inperson voting or other forms of in-person voting before Election Day 

versus Election Day. DOJ’s guidance is contained in (1) Federal Voting 

Laws Guidance; and (2) the ADA Checklist of Polling Place Accessibility 

(ADA Checklist), according to DOJ officials.43 In particular, the Federal 

Voting Laws Guidance discusses HAVA’s accessible voting system 

requirement, but does not clearly specify whether this requirement applies 

 39See 42 U.S.C. § 12132; 28 C.F.R. § 35.130(b). The ADA states that “no qualified 

individual with a disability shall, by reason of such disability, be excluded from participation 

in or be denied the benefits of the services, programs, or activities of a public entity, or be 

subject to discrimination by any such entity.” According to the DOJ’s Federal Voting Laws 

Guidance, the ADA’s provisions apply to all aspects of voting. 

40See 28 C.F.R. § 35.160(b).

4128 C.F.R. § 35.164.

42See 28 C.F.R. § 35.160(b)(2). 

43DOJ, Civil Rights Division, Disability Rights Section, The Americans with Disabilities Act 

and Other Federal Laws Protecting the Rights of Voters with Disabilities (Washington, 

D.C.: September 2014); and, Americans with Disabilities Act: ADA Checklist for Polling 

Places (Washington, D.C.: June 2016).
Page 29 GAO-18-4 Voters with Disabilities

to early in-person voting. Regarding the ADA, this guidance states that 

the “ADA’s provisions apply to all aspects of voting, including voter 

registration, site selection, and the casting of ballots, whether on Election 

Day or during an early voting process.”44 However, DOJ’s ADA Checklist

states that it is intended for use on Election Day.45 Further, the ADA 

Checklist does not reference HAVA’s accessible voting system 

requirement or the ADA’s requirements for providing appropriate auxiliary 

aids and services, except for noting that enough clearance must be 

provided for an individual with a disability to access and use all the voting 

equipment, including at least one accessible voting machine.

According to DOJ officials we interviewed, the department’s enforcement 

efforts under HAVA include limited assessments of a jurisdiction’s 

accessible voting systems, involving examining polling places to 

determine if an accessible voting system is available and turned on at the 

polling place and if polling place workers are trained to operate the 

machine and can demonstrate to voters how to use the machine. 

Separately, DOJ focuses its ADA enforcement efforts mainly on the 

physical accessibility of polling places, according to DOJ officials.

As previously discussed, EAC also provides advisory guidance and 

technical assistance to help improve the administration of federal 

 44In addition, DOJ’s Federal Voting Laws Guidance discusses ADA requirements, stating 

that “officials must provide appropriate auxiliary aids and services at each stage of the 

process, from registering to casting a ballot.” The guidance gives examples of appropriate 

auxiliary aids or services for people who are blind or have low vision, such as a qualified 

reader, information in large print or Braille, accessible electronic information and 

information technology; and audio recording of printed information, as well as examples of 

auxiliary aids for people who are deaf or have hearing loss. Additionally, the guidance 

discusses an example of a jurisdiction that conducts elections by paper ballot: If a blind 

voter requested an accessible ballot, a Braille ballot would not be a secret ballot because 

it would have to be counted separately, and thus the guidance states that “other aids and 

services would better afford voters who are blind the opportunity to vote privately and 

independently and to cast a secret ballot,” such as ballot overlays or templates; electronic 

information and information technology that is accessible (either independently or through 

assistive technology, such as screen readers); or, recorded text or telephone voting 

systems.

45Although the ADA Checklist states that it provides information on polling place 

accessibility on Election Day and does not state the extent to which the checklist applies 

to voting locations used during early in-person voting, DOJ officials noted that in past 

actions to enforce the ADA, the department has defined “Election” or “Election Day” to 

include both the period of in-person absentee voting and Election Day. See, e.g., 

Settlement Agreement between the U.S. and Fauquier County Regarding the Accessibility 

of Polling Places, DJ 204-79-321 (2017).
Page 30 GAO-18-4 Voters with Disabilities

elections. Within this role, EAC’s Advisory 2007-001, issued in 2007, 

states that, under HAVA, an in-person absentee voting location would be 

considered a “polling place” and therefore should be equipped with at 

least one accessible device.46 Further, the advisory states that the term 

“polling place,” as used in section 301(a)(3) of HAVA, should be 

considered any location where a voter appears in person to cast a ballot, 

including an early voting site. EAC officials confirmed to us that the 

commission’s 2007 guidance remained pertinent for the 2016 general 

election.

Against this federal policy backdrop, we found some variation in the 

extent to which accessible voting systems were made available, or were 

required by states, for early in-person voting during the 2016 general 

election, through responses to our survey of state election officials and 

our observations and measurements of polling places. In addition, during 

our follow-up interviews, some state and local election officials cited legal, 

technological, and administrative challenges to providing DREs or other 

accessible voting systems for people with disabilities during early inperson voting or other forms of in-person voting before Election Day.

Specifically, states had varying requirements with regard to accessible 

voting systems during early in-person voting, according to survey 

responses of state election officials. To examine access to polling places 

for people with disabilities, we defined early in-person voting to include 

casting a ballot in person prior to Election Day without an excuse as well 

as completing an absentee ballot or mail in ballot in person at a polling 

place or other voting location. Using this definition, almost all states that 

reported that they had early in-person voting (35 of 39) reported requiring 

or allowing DREs or other accessible voting systems. However, 4 of the 

39 states reported either prohibiting or having no explicit policy for 

providing DREs or other accessible voting systems during this period of 

voting.

In following-up on our survey, officials from these four states said that 

their states’ laws dictate the technology to be used for in-person absentee 

 46Election Assistance Commission, EAC Advisory 2007-001: Accessible Voting Systems 

For In-Person Absentee Voting (Washington, D.C.: Jan. 24, 2007).
Page 31 GAO-18-4 Voters with Disabilities

voting,47 and that in their view, the federal accessible voting system 

requirement does not apply to this form of voting required in their states.48

• According to officials from two of these four states, the states’ laws 

preclude counting or tabulating votes during the no excuse, absentee 

voting period before Election Day. As a result, according to the state 

officials, these laws exclude use of a DRE, which records a vote when 

cast by a voter.

• Officials from the other two states—which reported allowing a voter 

with a disability to complete an excused absentee ballot in-person at 

an election clerk’s office—cited similar challenges to providing DREs 

or other accessible voting systems for people with disabilities during 

in-person voting before Election Day. According to an official we 

interviewed from one of these states, the state’s long-standing law 

requires that absentee voting, which requires an excuse, be 

conducted by paper ballot. Thus, this method of voting precludes 

using accessible technology, such as DREs or ballot marking devices, 

according to one state official. However, the state allows a person 

with a disability to request and receive assistance in marking the 

individual’s ballot at a polling place, according to the state official. An 

official we interviewed from the other state said that state law does not 

define an election clerk’s office as a polling place or other voting 

location, so the federal accessible voting system requirement does 

not apply to completing an excused, absentee ballot in-person at a 

clerk’s office.

• One county in a fifth state offering early in-person voting did not have 

accessible voting systems, as previously discussed, at any of the five 

voting locations we examined during the 2016 general election. 

According to the county election officials we interviewed, the federal 

accessible voting system requirement did not apply to locations they 

used for early in-person voting. In addition, county officials said that 

they used a vote center model for early in-person voting—as opposed 

to precinct-based voting as they use on Election Day—which did not 

 47We have previously reported that, since the 1980s, ballots in the United States, to 

varying degrees, have been cast and counted using five systems: paper ballots, lever 

machines, punch cards, optical scan, and DREs. Four of these systems involve 

technology; only the paper ballot system does not. See GAO-12-69.

48Two of the four state officials we spoke to reported that their states only provide excused 

absentee voting, which requires a voter to provide an excuse such as having a disability to 

vote absentee. 
Page 32 GAO-18-4 Voters with Disabilities

permit them to use accessible voting systems. This vote center model 

instead permitted people in the county to vote outside of their 

precincts at any location available for early in-person voting. As a 

result, each early voting location needed to make available multiple 

ballots for precinct-specific candidates and initiatives (e.g., bond 

measures), as well as in different languages; their accessible voting 

systems were not designed to accommodate these needs, according 

to these officials. Officials said that they plan in the future to purchase 

accessible voting systems that will be able to accommodate this 

model of early in-person voting.49

Election officials we interviewed from two of the four states and the one 

county we discuss above also said that requiring these systems would 

affect the resources needed to facilitate in-person voting before Election 

Day as well as the election calendars. For example, an official from one 

state said that it would require more lead-time for designing and 

producing ballots, testing the voting equipment, completing paperwork 

confirming the testing, and securing the accessible voting systems during 

the period before Election Day.

During our discussions with DOJ officials, we asked them about the 

extent to which federal accessibility requirements are applicable, if at all,

to early in-person voting or in-person absentee voting. DOJ officials said 

that the department has not taken a public position on the issue of 

whether the HAVA accessible voting system requirement applies to early 

in-person voting. Further, with regard to the ADA, although DOJ’s Federal 

Voting Laws Guidance states that the ADA applies to all aspects of 

voting, to include early voting, DOJ officials said that they recognize that 

the ADA Checklist uses the term “Election Day” without further defining 

the term, and that the use of this term may be commonly understood to 

limit its application to the traditional day of the election.

DOJ officials also stated that the department has not received any voter 

complaints about the lack of an accessible voting system during in-person 

voting before Election Day. They stated that DOJ provides state and local 

jurisdictions flexibility in applying HAVA provisions given the considerable 

variation in how election jurisdictions arrange polling places, buy and 

maintain voting equipment, conduct elections, and count votes. DOJ 

 49An election official from another state we interviewed cited a similar issue, stating that 

the greater numbers of people voting before Election Day had outpaced purchasing 

decisions for voting equipment.
Page 33 GAO-18-4 Voters with Disabilities

officials also noted that there are various possible implications to the 

department taking a more specific position on guidance related to early 

in-person voting. For example, these officials told us that changes in their 

guidance could result in states or local jurisdictions expending additional 

resources to procure certain types of voting systems or could affect state 

and local jurisdictions’ decisions on offering early in-person voting.

Given that these various factors could affect implementation of federal 

accessibility requirements in the context of early in-person voting, 

studying this issue and considering changes to existing guidance, as 

appropriate, would help DOJ to determine the extent to which any 

changes to its guidance are necessary. Federal internal control standards

and Office of Management and Budget (OMB) guidance call for agencies 

to review policies for continued relevance and effectiveness in achieving 

their objectives and, in turn, to communicate changes in policy to external 

stakeholders when significant changes in conditions occur.50 DOJ helps 

enforce state and local compliance with federal laws and regulations 

designed to provide voters with disabilities access to both the locations 

used as polling places and the voting systems, which provide the means 

to cast the ballot. As previously discussed, more states and voters today 

are voting in-person before Election Day than when HAVA was enacted in 

2002.51 Within this context, studying the implementation of federal 

accessibility requirements in relation to early in-person voting could help 

DOJ take account of conditions that have changed in recent years, such 

as the increases in early in-person voting, and position the department to 

 50GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: Sept. 10, 2014). Office of Management and Budget (OMB), Final 

Bulletin for Agency Good Guidance Practices (January 2007). According to OMB’s 

guidance, agencies may provide helpful guidance to interpret existing law through an 

interpretive rule or to clarify how they tentatively will treat or enforce a governing legal 

norm through a policy statement. Guidance documents, used properly, can channel the 

discretion of agency employees, increase efficiency, and enhance fairness by providing 

the public clear notice of the line between permissible and impermissible conduct while 

ensuring equal treatment of similarly situated parties. Moreover, guidance should aim to 

communicate effectively to the public about the legal effect of the guidance and the 

consequences for the public of adopting an alternative approach.

51National Conference of State Legislatures, Election Administration website, accessed 

July 6, 2017, http://ncsl.org/research/elections-and-campaigns/absentee-and-earlyvoting.aspx; and, Michael P. McDonald, 2016 November Election Early Voting, United 

States Election Project (July 13, 2017), http://www.electproject.org/early_2016. 
Page 34 GAO-18-4 Voters with Disabilities

determine the extent to which any changes to guidance might be 

warranted or appropriate.

Our work examining the accessibility of polling places for voters with 

disabilities during the 2000, 2008, and 2016 general elections points to 

the need for additional progress to help voters with disabilities enter and 

move through polling places, access voting systems, and cast a private 

and independent vote.

The ADA and HAVA help provide a framework for ensuring access to 

polling places and voting methods, thereby helping ensure equal 

opportunity for voters with disabilities to participate in America’s 

democracy. Since the enactment of HAVA in 2002, changes have 

occurred in how local and state election jurisdictions implement key 

election activities, such as early in-person voting. Notably, the number of 

states offering and voters nationwide using early in-person voting 

methods during the 2016 general election has increased relative to 

previous federal elections, as previously discussed, and may continue to 

grow in the future. As voting practices evolve, the need for federal and 

state agencies to review and update existing policies and guidance on 

voting accessibility is an important step in providing greater clarity about 

how they will treat or enforce legal requirements. With a perspective 

towards future elections, DOJ studying the implementation of the legal 

requirements for accessible voting systems in the context of early inperson voting and making changes to guidance, as appropriate, could 

help provide additional information to federal, state, and local entities on 

these requirements, which could in turn help inform future decision 

making about how to interpret and address the requirements.

The Attorney General should study the implementation of federal 

accessibility requirements in the context of early in-person voting and 

make any changes to existing guidance that are determined to be 

necessary as a result of the study. (Recommendation 1)

We provided a draft of this report to the Department of Justice (DOJ) and 

the Election Assistance Commission (EAC) for review and comment. See 

Appendix IV for DOJ’s written comments and Appendix V for EAC’s 

comments. In its written comments, DOJ generally agreed with our 

recommendation to study the implementation of federal accessibility 

requirements in the context of early in-person voting and to make any 

Conclusions

Recommendation for 

Executive Action

Agency Comments
Page 35 GAO-18-4 Voters with Disabilities

changes to existing guidance that DOJ determines to be necessary as a 

result of the study. DOJ also outlined its efforts to enforce the protections 

for voters with disabilities found in federal law. In addition, DOJ provided 

technical comments, which we incorporated as appropriate.

The EAC agreed with the information in our report and provided no 

technical comments.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the appropriate 

congressional committees, the Attorney General, the EAC’s Executive 

Director, and other interested parties. In addition, the report is available at 

no charge on GAO’s website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

Barbara Bovbjerg at (202) 512-7215 or BovbjergB@gao.gov; or, Rebecca 

Gambler at (202) 512-8777 or GamblerR@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made major contributions to 

this report are listed in appendix VI.

Barbara D. Bovbjerg

Managing Director

Education, Workforce, and Income Security

Rebecca Gambler

Director, Homeland Security and Justice
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-18-4 Voters with Disabilities

Our objectives were to (1) examine the extent to which polling places in 

selected locations used during the 2016 election had features that might 

impede access for voters with disabilities, (2) describe the actions states 

took to facilitate voting access for people with disabilities in the 2016 

general election, and (3) examine guidance the Department of Justice 

(DOJ) has provided on the extent to which federal accessibility 

requirements apply, if at all, to early in-person voting.

To determine the number of selected polling places with features that 

might impede access for people with disabilities, we examined a 

nongeneralizable sample of 178 polling places during either early inperson voting or on Election Day (November 8, 2016) to make 

observations, take measurements, and conduct interviews with chief 

polling place officials. To determine what actions states took to facilitate 

voting for people with disabilities, we administered a web-based survey to 

state election officials in all 50 states and the District of Columbia. For all 

three objectives, we reviewed relevant federal laws, regulations, federal 

guidance, and other relevant documentation. In addition, we interviewed 

officials at DOJ, Election Assistance Commission (EAC), and selected 

national election organizations, along with selected national disability 

advocates, and election administration experts.

We conducted this performance audit from May 2016 to October 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

To examine selected polling places for features that might impede access 

for people with disabilities, we examined a nongeneralizable sample of 

178 polling places during either early in-person voting or on Election Day 

(November 8, 2016). Our sample included:

• 45 early in-person voting polling places in 11 counties in 6 states and 

the District of Columbia; and

Appendix I: Objectives, Scope, and 

Methodology

Early In-Person Voting and 

Election Day Polling 

Places

Selection of Polling Places
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-18-4 Voters with Disabilities

• 133 Election Day polling places in 21 counties in 12 states and the 

District of Columbia.

The counties we examined during early in-person voting were a subset of 

the counties visited on Election Day. However, in all local election 

jurisdictions, we did not examine the same polling places on Election Day 

that we examined during early in-person voting.

To identify polling places to examine, we first selected 21 counties from 

among the 84 randomly selected counties that were part of our study on 

the accessibility of polling places for voters with disabilities during the 

2008 general election.1 We selected these 21 counties based on: (1) 

variation in county population size, with most counties being larger in 

population size; (2) variation in type of election administration (that is, we 

selected some counties in which the county administers elections, and we 

selected other counties in which elections are administered by other 

government entities, such as cities, townships, or other local government 

entities); and (3) variation in geographic location. For the selected 

counties in which elections were administered by cities, townships, or 

villages—generally known as minor civil divisions (MCD)—we chose up to 

six MCDs based on their population and on their proximity to each other.

We selected polling places within each county on a nonprobability basis. 

To do this, we searched the internet in September and early October 

2016 to determine whether each county or MCD posted a listing of its 

polling places. If the information was posted, we downloaded the list. If 

not, we contacted county or MCD officials to obtain a list of the 

jurisdiction’s polling places. We selected up to seven polling places in 

each county based on the relative proximity of polling places to each 

other and variation in the types of facilities used as polling places (such 

as schools, houses of worship, fire stations, or city halls).2 We identified 

up to three polling places in each MCD. In advance, we contacted 

election officials in each of the selected states, counties, and MCDs to 

request permission to visit polling places, and were granted permission to 

visit any available polling places, including the 178 selected polling 

places.

 1

GAO, Voters with Disabilities: Additional Monitoring of Polling Places Could Further 

Improve Accessibility, GAO-09-941 (Washington, D.C.: Sept. 30, 2009).

2

A few jurisdictions used a small number of polling places during early in-person voting, 

which limited our ability to select various types of facilities in these locations.
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-18-4 Voters with Disabilities

Because we selected a nongeneralizable sample of polling places for the 

2016 general election, the results cannot be used to make generalizations 

about polling places nationwide used during the 2016 general election or 

to make comparisons with the results from our polling place accessibility 

assessments for the 2000 and 2008 general elections. However, our 

examination of the selected 178 polling places provided important 

information about voter accessibility in a range of polling places in various 

types of local election jurisdictions across the country during the 2016 

general election.

We sent teams of two GAO analysts to each county in our 

nongeneralizable sample during early in-person voting from October 26, 

2016, through November 6, 2016, and separately on Election Day, 

November 8, 2016. In counties selected for both early in-person voting 

and Election Day voting, the same team generally was used. Each team 

was equipped with a tape measure and a digital level,3 as well as a 

structured data collection instrument with which to document their 

observations and measurements.

The teams used a data collection instrument similar to the one we used to 

document observations and measurements of features at polling places in 

the 2008 general election, as well as to document the responses of chief 

polling place officials to our interview questions. However, we revised the 

2008 data collection instrument to reflect changes made in the Americans 

with Disabilities Act: ADA Checklist for Polling Places 2016—issued by 

DOJ—and in the 2010 ADA Standards for Accessible Design.

4

Additionally, officials at DOJ, EAC, and disability advocates reviewed a 

draft version of our data collection instrument, and we incorporated their 

comments where appropriate. Finally, to examine the ease of use, clarity, 

and time required to complete the data collection instrument, we 

pretested the data collection instrument at polling places during one 

state’s congressional primary in September 2016.

 3

The digital levels were used to measure potential structural impediments in buildings and 

on walkways. We tested the reliability of the digital levels based on the consistency of 

readings from all digital levels, by reviewing the manufacturer’s specifications, and talking 

with a representative of the manufacturer. We determined that the levels were sufficiently 

reliable for our purposes.

4

In particular, the data collection instrument was updated to include the cross-slope 

measurement of ramps or curb cuts. 

Polling Place Examinations 

and the Data Collection 

Instrument
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-18-4 Voters with Disabilities

To ensure uniformity of data collection, we trained all teams on how to (1) 

complete the data collection instrument; (2) use the measurement tools; 

and (3) interview the chief election official in each polling place about the 

location’s accessible voting systems as well as its accommodations for 

voters with disabilities. See figure 9 for examples of measurements and 

items for observation that were used to train GAO teams. We also 

instructed teams to not approach voters or interfere with the voting 

process.

Figure 9: Examples of Items for Observation and Measurements from Our Data Collection Instrument That Were Used to Train 

GAO Teams for Polling Place Examinations

Each GAO team received a list of up to seven polling places to examine 

in each county for early in-person voting or on Election Day. Teams were 

expected to complete at least four examinations of polling places from the 

lists where possible. For ease of travel, we allowed GAO teams to 

examine polling places in the order that was most convenient. We 

instructed GAO teams not to disclose to anyone outside of GAO the 

selected polling places to maintain the integrity of data collection. As a 

result of time constraints, traffic patterns, and/or geography, some teams 

were not able to complete examinations of their assigned polling places 

while other teams were able to examine up to seven polling places.
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-18-4 Voters with Disabilities

We examined features both outside and inside polling places that might 

pose a potential impediment during early in-person voting and Election 

Day voting.5 Data were first collected in four zones outside of the polling 

place voting area and were next collected inside the voting area.

• Outside the voting area. We examined features in four different 

zones outside of the voting area: (1) parking, (2) the path from parking 

to the building entrance, (3) the building entrance, and (4) the path 

from the entrance to the voting area. We examined several features 

within these zones, such as the slopes of sidewalks, ramps or curb 

cuts, paved surfaces, and door openings.6 Consequently, the number 

and percentage of polling places cited as having one or more potential 

impediments outside the voting area is derived from an observation 

that at least one feature located in these zones might impede access 

to voting.

• Inside the voting area. We assessed whether (1) an accessible 

voting system was provided and (2) whether aspects of the voting 

station could enable the casting of a private and independent vote by 

a person with a disability. To assess whether an accessible voting 

system could impede private and independent voting, we examined 

the following four aspects: (1) whether the system was turned on, (2) 

whether it was equipped with special features such as ear phones, (3) 

whether it was set up to accommodate voters using wheelchairs, and 

(4) whether it was positioned in such a way as to provide the same 

level of privacy as afforded to other voters. As a part of this 

assessment, we identified the types of voting methods available to all 

voters and took measurements of voting station(s) or table(s) used by 

people with disabilities to determine if wheelchairs could fit inside the 

station or underneath the table (see fig. 10 for the measurements we 

 5

Our use of the term potential impediments is broader in this report than it was in our 2008 

general election report. In our 2008 election report, we used “potential impediments” in 

reference only to features outside the voting area. In this report, the term refers to features 

either outside or inside the voting area.

6

We used DOJ’s 2010 ADA Standards for Accessible Design criteria to determine if these

features could potentially impede access (for example, if the slopes of sidewalks, ramps or 

curb cuts had a running slope steeper than 8.3 percent or a cross slope steeper than 2.1 

percent; paved surfaces had abrupt changes of over 1⁄2 inch; or door openings were less 

than 32 inches wide).The digital level—which we used to measure the slopes of ramps or 

curb cuts—measured to the tenth decimal place while the ADA criterion for the running 

slope is 8.3333 percent and the criterion for the cross slope is 2.0833 percent. Thus, we 

rounded the criteria to 8.3 percent and 2.1 percent, respectively.

Collection of Data
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-18-4 Voters with Disabilities

took).7 We also interviewed chief poll workers about the availability of 

curbside voting and accommodations available to people with 

disabilities. 

Figure 10: Measurements Used to Determine If a Voting Station Was Set Up to 

Accommodate People Using Wheelchairs Based on Criteria in the Americans with 

Disabilities Act

For our measurements in both areas, we did not differentiate the severity 

of potential impediments because disabilities and access are dependent 

on numerous factors, including the nature of an individual’s disability. In 

addition, we did not assess polling places for legal compliance with the 

Help America Vote Act of 2002 (HAVA) accessible voting system 

requirements or other federal or state laws, but we examined features 

that might impede access to voting for people with disabilities.

 7

We took multiple measurements of voting station(s) or table(s) used by people with 

disabilities, such as the height, width, and depth based on the criteria we used. If at least 

one of these measurements did not conform with the criteria, we identified the polling 

place as having one or more potential impediments inside the voting area.
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-18-4 Voters with Disabilities

In general, the denominator for our calculations is the 178 polling places 

we examined in which we were able to take measurements and make 

observations. However, the number of measurements and observations 

we completed at polling places varied. In some instances our examiners 

were not able to complete all measurements inside the voting area 

because of voting area restrictions.

• Of the 178 polling places, we examined features outside of the voting 

area at all 178.

• Of the 178 polling places, we observed whether or not the polling 

place had an accessible voting system at 167 polling places, although 

we were not able to observe every measurable aspect of the voting 

station.8 At the remaining 11 polling places, we were unable to 

observe if an accessible system was available. Further, for these 

polling places, we were able to determine potential impediments both 

outside and inside the voting area. 

• Of the 178 polling places, we were able to determine whether or not 

the polling place had a voting station inside the voting area that could 

facilitate or impede the casting of a private and independent vote at 

137 polling places. At the remaining 41 polling places we were not 

able to observe if voting stations with accessible voting systems could 

impede private and independent voting.

We assessed the accuracy of information collected through our data 

collection instrument by reviewing responses to identify obvious errors or 

inconsistencies; conducting follow-up to clarify responses when needed; 

and, checking responses from the paper-based data collection instrument 

that were entered manually into an electronic format.

To characterize the number of selected polling places with potential 

impediments throughout this report, we defined modifiers (e.g., “most”) to 

quantify this information as follows:

• “almost all” represents 90 percent or more of selected polling places,

• “most” represents 60 percent or more of selected polling places,

 8

We define “voting station” as the location within a polling place where voters may record 

their votes, including the area around and the actual voting booth or enclosure where 

voting takes place as well as the voting system. “Voting system” refers to the voting 

equipment that was used to cast a ballot, such as a DRE, a ballot-marking device, or 

another type of machine or technology. 
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-18-4 Voters with Disabilities

• “the majority” represents 51 percent or more of selected polling 

places,

• “many” represents 40 percent or more of selected polling places,

• a “minority” represents 20 or fewer of selected polling places.

To identify the actions states took to facilitate voting for people with 

disabilities during the 2016 general election, we administered a webbased survey to state election officials in all 50 states and the District of 

Columbia.9 Survey topics included: (1) state actions to accommodate 

people with disabilities; (2) state implementation of the Help America Vote 

Act of 2002 (HAVA) voting access requirements and other 

accommodations for people with disabilities; and (3) state requirements, 

policies, and methods for voting before Election Day, particularly early inperson voting and other convenience voting methods like absentee 

voting.

The 2016 survey was based on the survey used in our 2008 work. 

However, we updated several of the questions and added new questions 

to examine early in-person voting and application of HAVA requirements 

in more depth. We also added questions to examine actions states took 

to facilitate private and independent voting for people with disabilities. 

These revisions were informed by discussions with election administration 

experts and election officials. Several experts and election administrators 

reviewed our draft survey, and we incorporated their comments as 

appropriate. We conducted the survey using a self-administered 

electronic questionnaire administered via the internet. We collected the 

survey data from January 31, 2017, to May 5, 2017. We received surveys 

from 49 states and the District of Columbia, for a 98 percent response 

rate.10 As a result, the survey will allow for comparison with past results 

that were published in our 2009 report.11

 9

In this report, we are using the term “states” in reference to the states and the District of 

Columbia.

10Not all respondents answered every survey question. In addition, the wording of the 

2016 survey question stem changed slightly from our 2000 and 2008 surveys, but the 

wording for the questions about specific provisions and accommodations are consistent 

with our previous surveys.

11GAO-09-941.

Survey of States and the 

District of Columbia
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-18-4 Voters with Disabilities

This survey was not a sample survey, so there are no sampling errors. 

However, the practical difficulties of conducting any survey may introduce 

nonsampling errors, such as variations in how respondents interpret 

questions and their willingness to offer accurate responses. To minimize 

nonsampling errors, we pretested the draft survey instrument in five 

states to ascertain the following: (1) clarity and unbiasedness of survey 

questions; (2) precision of terminology; and (3) ability of respondents to 

provide the information sought. We made changes to the content and 

format of the questionnaire on the basis of pretest results.

Almost all respondents entered their web-based questionnaire responses 

directly into our survey database, thereby greatly reducing the possibility 

of data entry errors. However, because of a technical difficulty, two states 

had to provide their responses directly to a GAO analyst, who then 

entered the responses directly into the database. To minimize data entry 

errors for these two surveys, a second analyst separately reviewed the 

entered responses for accuracy. We also identified any inconsistencies in 

responses and other indications of error. In addition, a second analyst 

verified that the computer programs used to analyze the data were written 

correctly.

Our verification of survey results did not include contacting all state or 

local election officials to verify survey responses or other information 

provided by state officials. In general, we also did not analyze states’ laws 

to determine their voting access requirements, but instead relied on the 

states’ responses to our survey. However, in several cases, we 

conducted a limited review of states’ laws or other related information 

(such as type of early in-person voting provided) to understand the 

context of a state’s response.

For all three objectives, we reviewed relevant federal laws, regulations, 

guidance, and other documentation as well as interviewed officials at the 

DOJ and EAC. Specifically, we reviewed the Americans with Disabilities 

Act: ADA Checklist for Polling Places 2016 and additional guidance, such 

as the 2007 advisory issued by the EAC regarding the HAVA accessible 

voting system requirement and DOJ’s 2014 guidance on ADA and HAVA 

implementation, the Americans with Disabilities Act and Other Federal 

Laws Protecting the Rights of Voters with Disabilities. We assessed 

DOJ’s guidance in the context of federal standards for internal control for 

identifying, analyzing, and responding to change as well as 

Review of Federal Laws, 

Documentation, and 

Interviews with Federal 

Officials and Experts
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-18-4 Voters with Disabilities

communicating with external parties.12 Relevant documents were 

obtained and reviewed for selected states.

To learn more about the extent to which the accessible voting system 

requirements apply to voting locations used for early in-person voting, we 

spoke with officials from the EAC as well as officials in both the Voting 

and Disability Rights Sections of DOJ’s Civil Rights Division.13 These 

interviews were used to document DOJ’s internal processes for handling 

enforcement actions, to clarify our understanding of the language in 

official documents, and to review DOJ’s actions to monitor and enforce 

voting accessibility requirements. Further, we interviewed selected local 

and state election officials from the counties we selected and states we 

surveyed. In addition, we interviewed officials from the National Disability

Rights Network, officials from the National Association of Secretaries of 

State, and officials from the National Association of State Election 

Directors, as well as other election and disability area experts. We 

selected experts based on their experience working with state and local 

election officials and their expertise with accessibility issues concerning 

voting for people with disabilities during federal elections, among other 

factors. The perspectives we obtained from our interviews with 

association and election officials and disability experts provided insights 

regarding officials’ views on the accessible voting system requirements. 

These perspectives cannot be generalized to other associations or 

officials.

 12GAO-14-704G. 

13The Voting Section, within Justice’s Civil Rights Division, is responsible for enforcement 

of civil provisions of federal voting laws, such as HAVA. The Disability Rights Section, also 

within the Civil Rights Division, is primarily responsible for protecting the rights of persons 

with disabilities under the ADA, which includes ensuring that people with disabilities have 

access to basic services, such as voting.
Appendix II: List of Potential Features Outside 

of the Voting Area That Might Impede Access 

to Voting

Page 46 GAO-18-4 Voters with Disabilities

Table 4: Selected Features Outside the Voting Area That Might Impede Access to Voting: Selected Early In-Person Voting 

Polling Places

Potential impediment

Number of polling places 

with potential impediment

Number of

polling places 

Parking

Poor parking surface 0 45

One or more unramped or uncut curbs 0 45

One or more ramped or cut curbs less than 36 inches wide 0 45

One or more ramps or cut curbs with running slope steeper than 8.3% 3 45

One or more ramps or cut curbs with cross slope steeper than 2.1%a 2 45

Other potential impediments in parking lot 3 45

Path from parking to building entrance

No sign clearly indicating path designated for people with disabilities 5 45

Overly narrow sidewalk/pathway 0 45

No sidewalk/pathway from parking area to building entrance 0 45

Sidewalk/pathway running slope is steeper than 8.3% 5 45

Sidewalk/pathway cross slope is steeper than 2.1% 4 45

Unpaved or poor surface in parking lot or route to building entrance 2 45

Leaves, snow, litter in path from parking area to building entrance 0 45

Objects (e.g., signs) protrude into pathway where object not touching the 

ground without safety cones 0 45

Steps required in path from parking area to building entrance 0 45

Poor ramp surfaces (e.g., unpaved, abrupt surface changes, etc.) 0 45

Presence of leaves, snow, litter on the ramp from parking area to building 

entrance 0 45

Suspended objects (e.g., signs, decorative objects) protrude into ramp more 

than 4 inches where the object is not touching the ground and is at least 27 

inches through 80 inches off the ground, without safety cones to identify them 0 45

Ramps along pathway had a running slope steeper than 8.3% 4 45

Ramps along pathway had a cross slope steeper than 2.1% 2 45

Lack handrails on ramp 3 45

Improper handrails on ramp 0 45

Ramps in path from parking area to building entrance is < 36 inches wide or 

can go down to 32 inches wide for 2 feet 0 45

Ramps in path from parking area to building entrance do not have a level 

landing at the top and bottom of each section that is at least 60 inches long 0 45

Other potential impediments in the path from parking area to building entrance 2 45

Appendix II: List of Potential Features 

Outside of the Voting Area That Might 

Impede Access to Voting
Appendix II: List of Potential Features Outside 

of the Voting Area That Might Impede Access 

to Voting

Page 47 GAO-18-4 Voters with Disabilities

Potential impediment

Number of polling places 

with potential impediment

Number of

polling places 

Building entrance

Doorway threshold exceeds 1⁄2 inch in height 4 45

Single building entrance doorway opening is < 32 inches wide 3 45

Double building entrance door opening is <32 inches wide, including situations 

in which one of the doors cannot be opened 0 45

Door hardware requires more than one hand to open 1 45

Revolving door is the only door provided 0 45

Automatic door opener for people with disabilities does not work 5 45

Doorbell does not function 2 45

Other potential impediments at the building entrance 0 45

Path from building entrance to voting area

No sign clearly indicating route to the voting area designated for people with 

disabilities 4 45

Doorway threshold exceeds 1⁄2 inch in height 0 45

Single doorway opening is <32 inches wide 3 45

Double door opening is <32 inches wide, including situations in which one of 

the doors cannot be opened 0 45

Doors that would be difficult for a person using a wheelchair to open 1 45

Revolving door is the only door provided 0 45

Automatic door opener does not work 1 45

Steps are required to gain access to voting area 0 45

Ramp’s running slope is steeper than 8.3% 0 45

Ramp’s cross slope is steeper than 2.1% 0 45

No handrails on ramp inside the building 0 45

Improper handrails on ramps inside the building 0 45

One or more ramps that are < 36 inches wide or can go down to 32 inches 

wide for 2 feet 0 45

Elevator is not operational or is not properly equipped for people with 

disabilities

Elevator is not operational 0 45

The center of the top outside call button in the hall is higher than 48 

inches from the ground or floor 0 45

The panel surrounding the elevator car buttons lacks raised lettering or 

Braille 2 45

Outside or inside elevator buttons require a human touch to operate 0 45

The center of the top floor button(s) in the elevator car is higher than 48 

inches from the floor of the elevator 2 45

The elevator is not equipped with audible tones or bells or verbal 

annunciators that signal each floor as it passes 3 45
Appendix II: List of Potential Features Outside 

of the Voting Area That Might Impede Access 

to Voting

Page 48 GAO-18-4 Voters with Disabilities

Potential impediment

Number of polling places 

with potential impediment

Number of

polling places 

Other potential elevator impediments 0 45

Wheelchair lift or buttons are not operational or not proper dimensions 0 45

The lift is not operational or the lift requires a key which is not visibly 

present 0 45

The outside call button in the hall is higher than 48 inches from the ground 

or floor 0 45

The width of the opening to enter the lift is less than 32 inches wide 0 45

There is less than a 30-inch by 48 unobstructed floor space on the lift 0 45

The controls inside the lift are higher than 48 inches from the floor of the 

lift 0 45

Outside or inside lift buttons require a human touch to operate 0 45

The lift requires assistance to operate 0 45

Other potential lift impediments 0 45

Corridors that do not provide an unimpeded width of at least 36 inches can go 

down to 32 inches for 2 feet, or objects protrude into the corridor where object 

not touching the ground without safety cones 3 45

Objects (e.g., signs, decorative objects hanging overhead, exposed 

undersides of stairs) protruding more than 4 inches into the pathway where the 

object is not touching the ground and is at least 27 inches through 80 inches 

off the ground, without safety cones to identify them. 3 45

Other potential impediments at doorways and entrances 0 45

Other potential impediments with ramps 0 45

Other potential impediments with corridors 1 45

Source: GAO analysis of selected polling place data collected on Oct. 26, 2016 through Nov. 6, 2016. Criteria to determine if features might impose impediments to access are based on the Department of 

Justice’s 2010 ADA Standards for Accessible Design. | GAO-18-4

a

The 2016 data collection instrument was updated to include the measurement of the cross slope for 

ramps, sidewalks, and curb-cuts on the basis of the Department of Justice’s ADA Checklist for Polling 

Places 2016.

Table 5: Selected Features Outside the Voting Area That Might Impede Access to Voting: Selected Polling Places on Election 

Day

Potential impediment

Number of polling places 

with potential impediment

Number of

polling places 

Parking

Poor parking surface 5 133

One or more unramped or uncut curbs 1 133

One or more ramped or cut curbs less than 36 inches wide 0 133

One or more ramps or cut curbs with running slope steeper than 8.3% 11 133

One or more ramps or cut curbs with cross slope steeper than 2.1%a 4 133

Other potential impediments in parking lot 3 133
Appendix II: List of Potential Features Outside 

of the Voting Area That Might Impede Access 

to Voting

Page 49 GAO-18-4 Voters with Disabilities

Potential impediment

Number of polling places 

with potential impediment

Number of

polling places 

Path from parking to building entrance

No sign clearly indicating path designated for people with disabilities 5 133

Overly narrow sidewalk/pathway 1 133

No sidewalk/pathway from parking area to building entrance 3 133

Sidewalk/pathway running slope is steeper than 8.3% 13 133

Sidewalk/pathway cross slope is steeper than 2.1% 9 133

Unpaved or poor surface in parking lot or route to building entrance 8 133

Leaves, snow, litter in path from parking area to building entrance 1 133

Objects (e.g., signs) protrude into pathway where object not touching the 

ground without safety cones 0 133

Steps required in path from parking area to building entrance 1 133

Poor ramp surfaces (e.g., unpaved, abrupt surface changes, etc.) 4 133

Presence of leaves, snow, litter on the ramp from parking area to building 

entrance 1 133

Suspended objects (e.g., signs, decorative objects) protrude into ramp more 

than 4 inches where the object is not touching the ground and is at least 27 

inches through 80 inches off the ground, without safety cones to identify them 0 133

Ramps along pathway had a running slope steeper than 8.3% 13 133

Ramps along pathway had a cross slope steeper than 2.1% 6 133

Lack handrails on ramp 1 133

Improper handrails on ramp 3 133

Ramps in path from parking area to building entrance is < 36 inches wide or 

can go down to 32 inches wide for 2 feet 0 133

Ramps in path from parking area to building entrance do not have a level 

landing at the top and bottom of each section that is at least 60 inches long 4 133

Other potential impediments in the path from parking area to building entrance 4 133

Other potential impediments on a ramp to the actual building entrance 0 133

Building entrance

Doorway threshold exceeds 1⁄2 inch in height 9 133

Single building entrance doorway opening is < 32 inches wide 5 133

Double building entrance door opening is <32 inches wide, including situations 

in which one of the doors cannot be opened 3 133

Door hardware requires more than one hand to open 4 133

Revolving door is the only door provided 0 133

Automatic door opener for people with disabilities does not work 5 133

Doorbell does not function 2 133

Other potential impediments at the building entrance 2 133
Appendix II: List of Potential Features Outside 

of the Voting Area That Might Impede Access 

to Voting

Page 50 GAO-18-4 Voters with Disabilities

Potential impediment

Number of polling places 

with potential impediment

Number of

polling places 

Path from building entrance to voting area

No sign clearly indicating route to the voting area designated for people with 

disabilities 5 133

Doorway threshold exceeds 1⁄2 inch in height 0 133

Single doorway opening is <32 inches wide 3 133

Double door opening is <32 inches wide, including situations in which one of 

the doors cannot be opened 0 133

Doors that would be difficult for a person in a wheelchair to open 1 133

Revolving door is the only door provided 0 133

Automatic door opener does not work 1 133

Steps are required to gain access to voting area 0 133

Ramp’s running slope is steeper than 8.3% 4 133

Ramp’s cross slope is steeper than 2.1% 0 133

Improper handrails on ramps inside the building 0 133

One or no handrails on ramps inside the building 2 133

One or more ramps that are < 36 inches wide or can go down to 32 inches 

wide for 2 feet 1 133

Elevator is not operational or is not properly equipped for people with 

disabilities

Elevator is not operational 0 133

The center of the top outside call button in the hall is higher than 48 

inches from the ground or floor 0 133

The panel surrounding the elevator car buttons lacks raised lettering or 

Braille 2 133

Outside or inside elevator buttons require a human touch to operate 0 133

The center of the top floor button(s) in the elevator car is higher than 48 

inches from the floor of the elevator 0 133

The elevator is not equipped with audible tones or bells or verbal 

annunciators that signal each floor as it passes 2 133

Other potential elevator impediments 1 133

Wheelchair lift or buttons are not operational or not proper dimensions

The lift is not operational or the lift requires a key which is not visibly 

present 1 133

The outside call button in the hall is higher than 48 inches from the ground 

or floor 0 133

The width of the opening to enter the lift is less than 32 inches wide 1 133

There is less than a 30-inch by 48 unobstructed floor space on the lift 0 133

The controls inside the lift are higher than 48 inches from the floor of the 

lift 0 133

Outside or inside lift buttons require a human touch to operate 0 133
Appendix II: List of Potential Features Outside 

of the Voting Area That Might Impede Access 

to Voting

Page 51 GAO-18-4 Voters with Disabilities

Potential impediment

Number of polling places 

with potential impediment

Number of

polling places 

The lift requires assistance to operate 0 133

Other potential lift impediments 0 133

Corridors that do not provide an unimpeded width of at least 36 inches can go 

down to 32 inches for 2 feet, or objects protrude into the corridor where object 

not touching the ground without safety cones 2 133

Objects (e.g., signs, decorative objects hanging overhead, exposed 

undersides of stairs) protruding more than 4 inches into the pathway where the 

object is not touching the ground and is at least 27 inches through 80 inches 

off the ground, without safety cones to identify them. 2 133

Other potential impediments at doorways and entrances 3 133

Other potential impediments with ramps 0 133

Other potential impediments with corridors 2 133

Source: GAO analysis of selected polling place data collected on Nov. 8, 2016. Criteria to determine if features might pose impediments to access are based on the Department of Justice’s 2010 ADA 

Standards for Accessible Design. | GAO-18-4

a

The 2016 data collection instrument was updated to include the measurement of the cross slope for 

ramps, sidewalks, and curb-cuts on the basis of the Department of Justice’s ADA Checklist for Polling 

Places 2016.
Appendix III: Survey of States Actions to 

Facilitate Voting Access for People with 

Disabilities

Page 52 GAO-18-4 Voters with Disabilities

To identify the actions states took to facilitate voting for people with 

disabilities during the 2016 general election, we administered a webbased survey to state election officials in all 50 states and the District of 

Columbia. We received surveys from 49 states and the District of 

Columbia, for a 98 percent response rate. The tables provided below 

represent the frequencies of state responses to the questions listed in the 

title. In addition, we provide comparative information below that was 

reported in our 2009 report, updated with corresponding responses from 

our 2016 survey results.1 We did not verify survey responses or other 

information provided by state officials, and some states did not respond to 

all survey questions.

Table 6: States’ Responses to GAO 2016 Survey Question: “To the best of your knowledge, did your state office take any of 

the following actions to facilitate private and independent voting for people with disabilities in preparation for Election Day, 

November 8, 2016?”

Yes No Don’t know

Conducted demonstrations of voting equipment to people with disabilities 27 20 3

Provided election information on accessible voting procedures in advance to people with 

disabilities

40 7 2

Provided guidance to local election officials on facilitating voting for people with 

disabilities 

48 2 0

Provided training to local election officials on assisting voters with disabilities 45 5 0

Provided specific guidance on positioning voting stations at voting locations to prevent 

other voters from seeing how voters using the accessible machines were marking their 

ballots

40 7 3

Coordinated with disability council, Protection Advocate Voting agency (PAVA) or other 

advocacy groups

41 6 3

Other 8 6 15

Source: GAO survey of state election officials. | GAO-18-4

Note: Respondents were asked to select one answer per row. Some states did not respond to all 

survey questions.

 1

GAO-09-941.

Appendix III: Survey of States Actions to 

Facilitate Voting Access for People with 

Disabilities
Appendix III: Survey of States Actions to 

Facilitate Voting Access for People with 

Disabilities

Page 53 GAO-18-4 Voters with Disabilities

Table 7: States’ Responses to GAO 2016 Survey Question: “For Election Day, November 8, 2016, did your state obligate or 

spend any Help America Vote Act (HAVA), state, and/or local funds for any of the following activities to help facilitate voting 

access for people with disabilities?”

Yes, we

obligated

or spent

HAVA funds

Yes, we

obligated

or spent

state funds

Localities

obligated

or spent

No

funds were

obligated

or spent

Don’t

know

State has

not taken

this action

Provide voter education to people with

disabilities on voting access methods 16 16 14 6 3 2

Providing voting information at polling 

places, such as sample ballots or voter 

instructions 10 19 22 6 2 1

Identify accessible facilities for potential 

voting locations 4 4 26 8 4 5

Train election officials on voting access 

methods for people with disabilities 18 18 20 4 0 2

Improve, acquire, lease, modify, or 

replace voting systems and technology 18 13 19 6 1 5

Improve the accessibility of polling 

places, such as improving physical 

access for people with disabilities and 

providing non-visual access for people 

with visual impairments 17 2 20 7 3 5

Establish or maintain state-based 

administrative complaint procedures 7 20 1 20 2 2

Establish or maintain a toll-free 

telephone hotline that voters may use to 

file accessibility complaints or to obtain 

voter-related information including voter 

accessibility issues 6 26 4 12 1 6

Conduct pre-election reviews of voting 

locations for accessibility or 

accommodations 6 7 22 4 5 9

Conduct audits of voting locations’

accessibility or accommodations 8 7 15 7 5 12

Monitor local governments’ efforts to 

address the state’s audit findings and 

implementing corrective actions 6 8 5 10 6 18

Other 1 1 1 4 4 13

Source: GAO survey of state election officials. | GAO-18-4

Note: Respondents were asked to select ALL answers that applied within each row. Some states did 

not respond to all survey questions.
Appendix III: Survey of States Actions to 

Facilitate Voting Access for People with 

Disabilities

Page 54 GAO-18-4 Voters with Disabilities

Table 8: States’ Responses to GAO 2016 Survey Question: “In your opinion, for the 2016 general election, how challenging, if 

at all, has it been for your state to ensure voting access for people with disabilities in the following ways?”

Very

challenging

Moderately

challenging

Slightly

challenging

Not

challenging

No

opinion

State

has not

taken

this

action

Provide voter education to people with 

disabilities on voting access methods 1 3 25 17 2 1

Provide voting information at voting 

locations, such as sample ballots or 

voter instructions 0 1 9 34 2 3

Identify accessible facilities for 

potential voting locations 3 10 15 7 3 11

Train election officials on voting

access methods for people with 

disabilities 1 5 17 19 3 3

Improve, acquire, lease, modify, or 

replace voting systems and 

technology 7 6 11 8 2 14

Improve the accessibility of voting 

locations, such as improving physical 

access for people with disabilities and 

providing non-visual access for people 

with visual impairments 2 15 11 9 4 8

Establish or maintain a state-based 

administrative complaint procedures 0 0 4 41 2 2

Establish or maintain a toll-free 

telephone hotline that voters may use 

to file accessibility complaints or to 

obtain voter-related information 

including voter accessibility issues 0 1 2 36 1 9

Conduct pre-election reviews of voting 

locations for accessibility or 

accommodations 2 5 14 10 3 15

Conduct audits of voting locations’

accessibility or accommodations 2 7 9 10 4 16

Monitor local governments’ efforts to 

address the state’s audit findings and 

implementing corrective actions 2 4 11 5 6 19

Other activities your state used to help 

facilitate voting access for people with 

disabilities 0 1 8 11 10 11

Source: GAO survey of state election officials. | GAO-18-4

Note: Respondents were asked to select one answer per row. Some states did not respond to all 

survey questions.
Appendix III: Survey of States Actions to 

Facilitate Voting Access for People with 

Disabilities

Page 55 GAO-18-4 Voters with Disabilities

Table 9: States’ Responses to GAO 2016 Survey Question: “For the 2016 general election, did your state office perform any of 

the following oversight activities to ensure local compliance with state and federal requirements for voting accessibility and 

accommodations?”

Yes No Don’t know

Evaluated and verified compliance with state requirements 34 15 0

Inspected Election Day voting location accessibility 18 30 1

Evaluated and verified that localities provide voter education/outreach for people with 

disabilities 21 26 2

Required certification from county or local election officials that training on voting location 

accessibility and accommodations was performed 15 33 1

Provided training to county or local election officials to operate a direct recording electronic 

devices (DRE) or other accessible voting machine 32 17 0

Compiled and analyzed complaints of voting location accessibility issues occurring on 

Election Day 39 7 3

Investigated or adjudicated local complaints on voting location accessibility and 

accommodations on Election Day 34 8 7

Other state oversight actions to ensure local compliance with state and federal requirements 11 12 18

Source: GAO survey of state election officials. | GAO-18-4

Note: Respondents were asked to select one answer per row. Some states did not respond to all 

survey questions.

Table 10: States’ Responses to GAO 2016 Survey Question: “For the 2016 general 

election, did your state allow for or require jurisdictions to provide early in-person 

voting?”

Number

Yes, the state required jurisdictions to provide early in-person voting 36

Yes, the state allowed jurisdictions to provide early in-person voting 3

No 11

Don’t know 0

Source: GAO survey of state election officials. | GAO-18-4

Note: Respondents were asked to select one answer. Some states did not respond to all survey 

questions.
Appendix III: Survey of States Actions to 

Facilitate Voting Access for People with 

Disabilities

Page 56 GAO-18-4 Voters with Disabilities

Table 11: States’ Responses to GAO 2016 Survey Question: “For early in-person voting, did your state require, allow, prohibit, 

or not address each of the following accessibility provisions and at voting locations for people with disabilities?”

State

requirement

State allowed

but not a

requirement

State

prohibited

Not

applicable

State did

not address

Provision of ballot or methods of voting in 

Braille 6 8 1 2 21

Provision of ballots with larger type 12 11 0 1 15

Provision of magnifying instruments 11 21 0 0 7

Curbside voting available during early inperson voting period 16 9 9 1 3

Voting location accessibility standards 35 3 0 0 1

Inspection of polling place accessibility 18 9 0 1 11

Reporting by local jurisdictions to the state on 

voting location accessibility 13 11 0 2 13

Accommodation of wheelchairs in voting areas 32 4 0 0 3

Notification to voters of any inaccessible voting 

locations 13 4 0 4 18

Other accessibility provisions or 

accommodations 5 2 0 13 12

Source: GAO survey of state election officials. | GAO-18-4

Note: Respondents were asked to select one answer per row. Some states did not respond to all 

survey questions.

Table 12: States’ Responses to GAO 2016 Survey Question: “For early in-person 

voting for the 2016 general election, which of the following statements best 

describes your state’s policy for providing a direct recording electronic (DRE) 

system or other accessible machine at voting locations used by jurisdictions?”

Number

State required a direct recording electronic system or other accessible 

machine at voting locations used by jurisdictions 30

State allowed a direct recording electronic system or other accessible 

machine at voting locations used by jurisdictions 5

State had no explicit policy for a direct recording electronic system or 

other accessible machine at voting locations used by jurisdictions 3

State prohibited direct recording electronic systems or other accessible 

machines at voting locations used by jurisdictions 1

Don’t know 0

Source: GAO survey of state election officials. | GAO-18-4

Note: Respondents were asked to select one answer. Some states did not respond to all survey 

questions. For the purpose of this question, we did not consider the accessibility of the voting booth 

or voting station as part of an “other accessible machine.” Only states that allowed or required 

jurisdictions to provide early in-person voting responded to this question.
Appendix III: Survey of States Actions to 

Facilitate Voting Access for People with 

Disabilities

Page 57 GAO-18-4 Voters with Disabilities

Table 13: States’ Responses to GAO 2016 Survey Question: “To the best of your knowledge, did your state office take any of 

the following actions to facilitate private and independent voting for people with disabilities during early in-person voting for 

the 2016 general election?”

Yes No

Don’t

know

Conducted demonstrations of voting equipment to people with disabilities 20 17 2

Provided election information on accessible voting procedures in advance to people with 

disabilities 34 4 1

Provided guidance to local election officials on facilitating voting for people with disabilities 36 2 1

Provided training to local election officials on assisting voters with disabilities 35 3 3

Provided specific guidance on positioning voting stations at voting locations to prevent other 

voters from seeing how voters using the accessible machines were marking their ballots 30 6 3

Coordinated with disability council, Protection Advocate Voting agency (PAVA) or other 

advocacy groups 30 5 4

Other 2 8 12

Source: GAO survey of state election officials. | GAO-18-4

Note: Respondents were asked to select one answer per row. Some states did not respond to all 

survey questions. Only states that allowed or required jurisdictions to provide early in-person voting 

responded to this question.

Table 14: States’ Responses to GAO 2016 Survey Question: “For early in-person voting for the 2016 general election, did your 

state obligate or spend any Help America Vote Act (HAVA), state, and/or local funds for any of the following activities to help 

facilitate voting access for people with disabilities?”

Yes, we

obligated

or spent

HAVA funds

Yes, we

obligated

or spent

state funds

Localities

obligated

or spent

No

funds were

obligated

or spent Don’t know

State as not

taken this

action

Provide voter education to people with

disabilities on voting access methods 11 15 15 5 1 3

Provide voter education to people with

disabilities on voting access methods 8 15 19 5 2 1

Identify accessible facilities for potential 

voting locations 3 4 20 5 6 4

Train election officials on voting access 

methods for people with disabilities 13 14 14 5 1 1

Improve, acquire, lease, modify, or 

replace voting systems and technology 12 6 15 4 1 8

Improve the accessibility of polling places, 

such as improving physical access for 

people with disabilities and providing nonvisual access for people with visual 

impairments 13 4 16 5 4 3

Establish or maintain state-based 

administrative complaint procedures 6 15 1 13 2 3
Appendix III: Survey of States Actions to 

Facilitate Voting Access for People with 

Disabilities

Page 58 GAO-18-4 Voters with Disabilities

Yes, we

obligated

or spent

HAVA funds

Yes, we

obligated

or spent

state funds

Localities

obligated

or spent

No

funds were

obligated

or spent Don’t know

State as not

taken this

action

Establish or maintain a toll-free telephone 

hotline that voters may use to file 

accessibility complaints or to obtain voterrelated information including voter 

accessibility issues 5 15 4 9 1 7

Conduct pre-election reviews of voting 

locations for accessibility or 

accommodations 5 3 19 4 2 9

Conduct audits of voting locations’

accessibility or accommodations 4 7 10 6 2 11

Monitor local governments’ efforts to 

address the state’s audit findings and 

implementing corrective actions 3 6 4 6 4 17

Other 2 1 0 2 3 14

Source: GAO survey of state election officials. | GAO-18-4

Note: Respondents were asked to select ALL answers that applied within each row. Some states did 

not respond to all survey questions.

Table 15: States’ Responses to GAO 2016 Survey Question: “In your opinion, how challenging, if at all, has it been to 

implement the following aspects of Help America Vote Act (HAVA) during early in-person voting in your state for the 2016 

general election?”

Very

challenging

Moderately

challenging

Slightly

challenging

Not

challenging No opinion

State has

not taken

this action

Interpreting HAVA

accessibility requirements 1 1 6 25 5 1

Obtaining federal guidance regarding 

HAVA accessibility requirements, if 

needed 0 1 7 15 8 7

Source: GAO survey of state election officials. | GAO-18-4

Note: Respondents were asked to select one answer per row. Some states did not respond to all 

survey questions.
Appendix III: Survey of States Actions to 

Facilitate Voting Access for People with 

Disabilities

Page 59 GAO-18-4 Voters with Disabilities

Table 16: States’ Responses to GAO 2016 Survey Question: “For early in-person voting for the 2016 general election, did your 

state office perform any of the following oversight activities to ensure local compliance with state and federal requirements

for voting accessibility and accommodations?”

Yes No Don’t know

Evaluated and verified localities’ compliance with state requirements 16 21 1

Inspected early in-person voting location accessibility 12 26 0

Evaluated and verified that localities provide voter education/outreach for people with 

disabilities 10 27 1

Required certification from county or local election officials that training on voting location 

accessibility and accommodations was performed 11 27 0

Provided training to county or local election officials to operate a direct recording electronic 

devices (DRE) or other accessible voting machine 26 11 1

Compiled and analyzed complaints of voting location accessibility issues occurring during 

early in-person voting 23 12 3

Investigated or adjudicated local complaints on voting location accessibility and 

accommodations during early in-person voting 24 11 3

Other state oversight actions to ensure local compliance with state and federal 

requirements 10 9 10

Source: GAO survey of state election officials. | GAO-18-4

Note: Respondents were asked to select one answer per row. Some states did not respond to all 

survey questions. Only states that allowed or required jurisdictions to provide early in-person voting 

responded to this question.

Table 17: States’ Responses to GAO 2016 Survey Question: “In your opinion, for the 2016 general election, has it been more 

challenging to ensure accessibility for early in-person voting than for Election Day, more challenging to ensure accessibility 

on Election Day than for early in-person voting, or has there been no difference between early in-person voting and Election 

Day?”

More

challenging

for early inperson voting

than on

Election Day

Somewhat

more

challenging

for Early inperson voting

than on

Election Day

No

difference

between

early inperson

voting and

Election Day

Somewhat

more

challenging on 

Election Day

than for earl

in-person

voting

More

challenging on

Election Day

than for early

in-person 

voting

No

opinion

State has 

not taken 

this action

Provide voter education 

to people with

disabilities on voting 

access methods 1 3 29 1 0 2 2

Provide voting

information at voting 

locations, such as 

sample ballots or voter 

instructions 0 2 32 1 1 2 0

Identify accessible

facilities for potential 

voting locations 2 1 16 5 8 2 3
Appendix III: Survey of States Actions to 

Facilitate Voting Access for People with 

Disabilities

Page 60 GAO-18-4 Voters with Disabilities

More

challenging

for early inperson voting

than on

Election Day

Somewhat

more

challenging

for Early inperson voting

than on

Election Day

No

difference

between

early inperson

voting and

Election Day

Somewhat

more

challenging on 

Election Day

than for earl

in-person

voting

More

challenging on

Election Day

than for early

in-person 

voting

No

opinion

State has 

not taken 

this action

Train election officials 1 1 28 2 3 2 1

Improve, acquire, lease, 

modify, or replace 

voting systems and 

technology 1 0 26 0 0 2 9

Improve the 

accessibility of voting 

locations, such as 

improving physical 

access for people with 

disabilities and 

providing non-visual 

access for people with 

visual impairments 0 2 22 4 5 2 3

Establish or maintain a 

state-based 

administrative complaint 

procedures process 0 0 32 0 0 3 3

Establish or maintain a 

toll-free telephone 

hotline that voters may 

use to file accessibility 

complaints or to obtain 

voter-related

information, including 

voter accessibility 

issues 0 0 30 0 0 2 6

Conduct pre-election 

reviews of voting 

locations for 

accessibility or

accommodations 1 0 18 3 3 4 9

Conduct audits of voting 

locations’ accessibility 

or accommodations 1 2 17 1 2 4 9

Monitor local

governments’ efforts to 

address the state’s audit

findings and 

implementing corrective 

actions 1 2 18 1 2 4 10

Source: GAO survey of state election officials. | GAO-18-4
Appendix III: Survey of States Actions to 

Facilitate Voting Access for People with 

Disabilities

Page 61 GAO-18-4 Voters with Disabilities

Note: Respondents were asked to select one answer per row. Some states did not respond to all 

survey questions. Only states that allowed or required jurisdictions to provide early in-person voting 

responded to this question.

Table 18: States’ Responses to GAO 2016 Survey Question: “In your opinion, have the following aspects of the Help America 

Vote Act (HAVA) been more challenging to implement for early in-person voting than for Election Day, more challenging to 

implement on Election Day than for early in-person voting, or has there been no difference between early in-person voting 

and Election Day?”

More

challenging

for early inperson voting

than on 

Election Day

Somewhat

more

challenging for

early in-person

voting than on

Election Day

No

difference

between

early inperson

voting and

Election Day

Somewhat

more

challenging on

Election Day

than for early

in-person

voting

More

challenging on

Election Day

than for early

in-person

voting

No

opinion

State has

not taken

this

action

Interpreting HAVA

accessibility 

requirements 0 1 33 0 0 3 1

Obtaining federal

guidance regarding 

HAVA accessibility 

requirements, if needed 0 0 28 1 0 6 3

Source: GAO survey of state election officials. | GAO-18-4

Note: Respondents were asked to select one answer per row. Some states did not respond to all 

survey questions.

Table 19: State-Reported Requirements Concerning the Accessibility of Polling Places: Election Days 2000, 2008 and 2016

State-Reported Requirement 2000 2008 2016

Voting location accessibility standards 23 43 44

Accommodation of wheelchairs in voting areas 17 38 40

Inspection of voting location accessibility 15 34 26

Reporting by local jurisdictions to the state on voting location accessibility 10 29 20

Sources: GAO-09-941 and GAO analysis of data from its 2016 survey of state election officials. | GAO-18-4

Note: Some states did not respond to all survey questions.
Appendix III: Survey of States Actions to 

Facilitate Voting Access for People with 

Disabilities

Page 62 GAO-18-4 Voters with Disabilities

Table 20: States’ Reported Challenges in Implementing Various Aspects of the Help America Vote Act (HAVA), 2008 and 2016

Very or 

moderately 

challenging

Slightly 

challenging Not challenging

State has not taken

this action

2008 2016 2008 2016 2008 2016 2008 2016

Ensuring voting location accessibility 31 16 16 13 3 9 1 6

Purchasing direct recording electronic 

devices (DRE) or other accessible voting 

systems 24 11 8 5 15 7 4 20

Providing guidance to counties, cities, or 

local entities for HAVA-required voting 

access activities for people with disabilities 20 5 18 13 12 25 1 3

Securing HAVA funding for your state 19 9 13 4 17 16 0 11

Disseminating HAVA funding to counties, 

cities, or local entities 16 4 12 10 11 17 10 13

Sources: GAO-09-941 and GAO analysis of data from its 2016 survey of state election officials. | GAO-18-4

Note: Some states did not respond to all survey questions.

Table 21: Accommodations That States Reported Requiring Local Jurisdictions to Offer to Voters with Disabilities, as of 

Election Days 2000 2008 and 2016

Reported Required Accommodations 2000 2008 2016

Curbside voting available on Election Day 28 23 21

Provision of magnifying instruments 7 12 14

Provision of ballots with larger type 2 11 13

Ballot taken to voter’s residence on or before Election Day 21 9 27

Provision of ballot or methods of voting in Braille 3 6 9

Sources: GAO-09-941 and GAO analysis of data from its 2016 survey of state election officials. | GAO-18-4

Note: Some states did not respond to all survey questions.
Appendix III: Survey of States Actions to 

Facilitate Voting Access for People with 

Disabilities

Page 63 GAO-18-4 Voters with Disabilities

Table 22: State-Reported Provisions Concerning Accessibility of Polling Places and Accommodations for Individuals with 

Disabilities, 2008 and 2016

Required Allowed Not Allowed Not 

Addressed

Not 

Applicablea Required or allowed

2008 2016 2008 2016 2008 2016 2008 2016 2008 2016 2008 2016

Voting location accessibility 

standards 43 44 6 4 0 0 0 2 0 n/a 49 48

Inspection of voting location 

accessibility 34 26 11 13 0 1 4 10 1 n/a 45 39

Reporting by local jurisdictions 

to the state on voting location 

accessibility 29 20 12 16 0 0 8 13 0 n/a 41 36

Accommodation of wheelchairs 

in voting areas 38 40 9 6 0 0 3 4 0 n/a 47 46

Curbside voting available on 

Election Day 23 21 6 7 12 13 8 9 8 n/a 29 28

Notification to voters of any

inaccessible voting locations 16 21 12 5 1 2 20 22 1 n/a 28 26

Provision of ballot or methods of 

voting in Braille 6 9 14 9 0 1 30 31 30 n/a 20 18

Provision of ballots with larger 

type 11 13 13 15 0 0 26 22 0 n/a 24 28

Provision of magnifying 

instruments 12 14 29 25 0 0 9 11 0 n/a 41 39

Sources: GAO-09-941 and GAO analysis of data from its 2016 survey of state election officials. | GAO-18-4 

Note: Some states did not respond to all survey questions

a

”Not Applicable” was not a response option for this question for the 2016 survey

Table 23: Reported Changes in State Requirements Concerning Alternative Voting Methods from the 2000, 2008 and 2016

Methods and accommodations 2000 2008 2016

Absentee/mail voting 51 51 49

Curbside voting available on Election Day 28 29 28

Ballot taken to voter’s residence on or before Election Day 21 24 27

Early In-Person votinga 39 23 39

Sources: GAO-09-941 and GAO analysis of data from its 2016 survey of state election officials | GAO-18-4 

a

In our report on the 2000 general election (GAO-02-107), we did not identify states that offered early 

voting as part of our analyses, as we defined it in later reports (2004 general election: see 

GAO-06-450). Rather we reported on the absentee and early voting together. For our 2016 report, we 

define early in-person voting as a method of voting by which any voter may cast a ballot in person 

prior to Election Day without providing an excuse. For the purposes of this questionnaire, early inperson voting includes completing an absentee or mail ballot in-person at a voting location (as 

defined in this questionnaire), which is also known as “in-person absentee” voting in some states. 

Some states did not respond to all survey questions.
Appendix IV: Comments from the Department 

of Justice 

Page 64 GAO-18-4 Voters with Disabilities 

Appendix IV: Comments from the 

Department of Justice 
Appendix IV: Comments from the Department 

of Justice

Page 65 GAO-18-4 Voters with Disabilities
Appendix V: Comments from the Election 

Assistance Commission

Page 66 GAO-18-4 Voters with Disabilities

Appendix V: Comments from the Election 

Assistance Commission
Appendix V: Comments from the Election 

Assistance Commission

Page 67 GAO-18-4 Voters with Disabilities
Appendix V: Comments from the Election 

Assistance Commission

Page 68 GAO-18-4 Voters with Disabilities
Appendix VI: GAO Contacts and Staff 

Acknowledgments

Page 69 GAO-18-4 Voters with Disabilities

Barbara D. Bovbjerg, (202) 512-7215 or BovbjergB@gao.gov

Rebecca Gambler, (202) 512-8777 or GamblerR@gao.gov

In addition to the contacts above, the following staff members made 

significant contributions to this report: Brett Fallavollita (Assistant 

Director), James Whitcomb (Analyst in Charge), Daniel Bertoni, Anna 

Duncan, Rebecca Kuhlmann Taylor, Shelia Thorpe, and John Vocino.

In addition, key support was provided by David Alexander, Carl Barden, 

David Barish, James Bennett, Carolyn Blocker, Jennifer Cook, Jessica 

Du, Justin Dunleavy, Alexander Galuten, Tom Jessor, Jill Lacey, Serena 

Lo, Sheila McCoy, Margo Mitchell, Jan Montgomery, Heidi Nielson, 

Jessica Orr, James Perez, Minette Richardson, Almeta Spencer, Jeff 

Tessin, Walter Vance, and Michelle Wilson.

Appendix VI: GAO Contacts and Staff 

Acknowledgments

GAO Contacts 

Staff 

Acknowledgments

(100921)
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