Using NCOA Files

for Verifying Voter

Registration Lists

Using NCOA Files

for Verifying Voter

Registration Lists

Author:

Charlotte G. Mullins

905 Leawood Drive #6

Frankfort, Kentucky 40601

Managed and Edited by:

William C. Kimberling

National Clearinghouse on Election Administration

Published by:

National Clearinghouse on Election Administration

Federal Election Commission

Washington, D.C. 20463

September 1992
Introduction by the

Clearinghouse

This report is another in the series on Innovations in Election Administration being published by the FEC's National Clearinghouse on

Election Administration.

The purpose of this series is to acquaint State

and local election officials with innovative election

procedures and technologies that have been

successfully implemented by their colleagues

around the country.

Our reports on these innovations do not

necessarily constitute an endorsement by

the Federal Election Commission either of

the procedures described or of the vendors

or suppliers that might be listed within the

report. Moreover, the views and opinions

expressed in these reports are those of the

author and are not necessarily shared by

the Federal Election Commission or any

division thereof.

We welcome you comments on these reports as

well as any suggestions you may have for additional topics. You may mail these to us at:

The National Clearinghouse on

Election Administration

Federal Election Commission

999 E. Street, N.W.

Washington, D.C. 20463

or else call us

toll free on 800/424-9530 or

direct on 202/219-3670.
Using NCOA Files

for Verifying Voter

Registration Lists

Executive Summary

The United States Postal Service provides,

through its National Change of Address (NCOA)

system, an automated means of verifying the

addresses of registered voters for both local jurisdictions and those States that maintain statewide registered voter files. This report addresses

the following questions regarding the NCOA program:

• The extent to which those jurisdictions that

have used the NCOA have actually benefited

from it.

• Whether or not the NCOA program is the best

method available to verify registered voter addresses.

• Whether or not this method of verifying registered voter addresses is cost effective.

The answers to each of these questions can

provide invaluable information to other State

and local election officials as they go about the

task of ensuring the accuracy and completeness

of their own voter registration records in the most

effective and efficient way possible. With this in

mind the scope of this effort was to:

• Determine which State and local government

election agencies have used the National Change

of Address System to verify the accuracy of their

voter registration lists.

• Document the procedures followed by each of

these agencies when using the National Change

of Address System.

• Evaluate the benefits of using the National

Change of Address System.

A primary focus of this research was on the

experience of the Commonwealth of Kentucky

State Board of Elections in using the United

States Postal Service National Change of Address system to verify the registered voter addresses in the central voter registration system

file of that State. The reasons for this are first, it

represents one of the major uses of the NCOA

system for registration records purposes and

second, the amount of data available and the ease

of access to this information.

Based on a survey conducted of all fifty States

plus the District of Columbia and the four Territories, the use of the NCOA system for correcting

and purging voter registration records appears

limited at this time. However, in the State and

local election jurisdictions where it has been

used, it has been generally successful, has saved

time, and has reduced costs.

Each agency that has used the NCOA system

indicated that there were some operational problems in getting the information and in matching

the records against their registration files. They

attributed these problems, however, to the newness of the process and expect future uses of the

system to function more smoothly.

Key recommendations made by the users of the

NCOA system include:

• More direct and active involvement by the

U. S. Postal Service.
• Active participation by all affected election

officials in planning and execution.

• Full written procedures and records relating

to the process.

• Clear and complete instructions to voters.

• Advance publicity regarding the process that

will be taking place.

What Is the the NCOA System?

The United States Postal Service developed

the National Change of Address System in order

to reduce the amount of undeliverable mail and

speed up the delivery of mail forwarded to new

addresses. Although the system was designed

primarily for magazines and for other such large

scale mailout operations, its applicability to updating voter registration lists is fairly obvious.

The system uses a computerized file (updated

nightly) containing some 91 million change-ofaddress records. Services are provided to users

(such as election offices) through 25 or so licensee

corporations whose pricing structures vary.

Some of the features of the system include:

• All change-of-address actions are maintained

on the computer files for three years rather than

for the eighteen months normally available from

your local postamaster's manual records.

• All addresses submitted are standardized and

zip+4 coded.

• Change-of-address information is provided

whenever a match is made between addresses

submitted and addresses maintained on the

NCOA files.

• Address lists may be submitted in virtually

any electronic medium (disk, tape, etc.) and in

virtually any format.

• A uniform method for delivering address lists

is provided.

Election officials seeking more information on

the National Change of Address files may want to

contact:

The National Address Information Center

6060 Primacy Parkway, Suite 101

Memphis, Tennessee 38188-0001

Tele: 800/238-3150.

The Center can provide informational brochures

as well as an updated listing of licensees.

Jurisdictions Using the

NCOA System

In order to determine the extent to which the

National Change of Address system has been

used for verifying voter registration lists (and the

success of this use), all 50 States plus the District

of Columbia and the 4 Territories were surveyed.

Following is a summary of the 36 responses

received.

State/Locality

Alabama

Alaska

Arizona

California

Delaware

Wash. DC

Florida

Georgia

Use NCOA

No

No

No

Yes

No

No

No

No

Remarks

Used by some of the larger counties on an individual basis.

These include:Sacramento, San Diego and Santa Clara
State/Locality

Hawaii

Idaho

Illinois

Indiana

Kentucky

Louisiana

Use NCOA

No

No

No

No

Yes

Yes

Remarks

Maryland No

Massachusetts

Michigan

Minnesota

Missouri

Montana

Nebraska

New Hampshire

Nevada

New Jersey

New Mexico

North Carolina

North Dakota

Ohio

Oklahoma

Rhode Island

South Carolina

South Dakota

Tennessee

Texas

Utah

No

No

No

No

No

No

No

No

No

No

No

No

No

No

No

No

No

No

No

No

Used in conjunction with centralized statewide voter

registration system.

Used in conjunction with centralized statewide voter

registration system

State surveyed localities and got 11 responses. None use

NCOA.

State is designing a system that will provide the ability

to use NCOA with statewide voter registration system.

State surveyed localities and got eight responses. Six do

not use NCOA, two get copies of change of address cards

directly from local post office.

Those States and localities identified as having

used the NCOA system were contacted directly to

obtain full information regarding the extent of

their use of the system, their success in using the

system, and how the process was operationally

carried out.

Program Descriptions

Of the States and localities identified as having

used the NCOA system, two States and two

localities were selected to provide detailed information about how their systems operate and how
they employed the NCOA files. These are discussed below.

Commonwealth of Kentucky

Prior to 1972 the registration of voters and the

maintenance of current and accurate voter registration records was carried out exclusively as a

local function of the individual elected County

Clerks in the 120 counties of Kentucky. County

Clerks were not notified when a registrant moved

to and registered in another Kentucky County.

Often they did not know when a voter was deceased or declared ineligible to vote for some

other reason. And as a result, there were many

voters on the rolls who were not in fact eligible to

be on those rolls. In fact, in numerous cases

voters were shown as active registrants in more

than one county.

In 1972 the Kentucky General Assembly completely changed the election statutes and created

a State Board of Elections. It also passed legislation calling for the establishment of a statewide

computerized voter registration system. In accordance with this new legislation, each voter

was required to re-register in their county of

residence. A short period of time was provided for

all persons to re-register and those who did not do

so were removed from the rolls of qualified voters.

The law included a provision that voters who did

not vote at least once in a four-year period would

be removed from the rolls and be notified of this

fact.

As a part of the registration process, a statewide uniform voter registration card was established. Once' completed by the voter, this card

was sent to the office of the State Board of Elections located in the State Capitol. There the

information on the card for that voter was entered into a central computer file maintained by

the Board of Elections staff. The card was then

returned to the appropriate County Clerk's office

where it was permanently retained and used as

the basis for registration record up-dates and

changes.

When changes were made to registration

records, the appropriate local County Clerk's

office completed a standardized change form and

submitted it to the State Board of Elections.

There the appropriate change was made to the

record for that registrant. At the end of each

month a report was prepared and sent to each

County showing all transactions processed for

the month — including those registrants who had

moved and transferred their registration to another county within the State and should thus be

removed from the manual files of their previous

county.

This original statewide voter registration system was successful and played an important role

in improving the ability of the individual counties

to maintain accurate files of registered voters.

Further improvements were made in 1986 with

a conversion to an on-line computer system that

enabled local County Clerks' offices to instantly

add registered voters, change registration records,

and remove voters from the active rolls. This new

system increased the efficiency of each local office

and enhanced the ability to maintain active

records of registered voters.

In 1988, the Kentucky legislature again

changed the statute so that persons who did not

vote in a four-year period were no longer automatically removed as a registrant. Under this

new law, the State Board of Elections was required to conduct a purge of ineligible and deceased voters each two years. The State Board of

Elections was to mail to each registered voter, by

first class mail, a notice of voter registration. The

notice was to be non-forwardable and to be returned to the State Board of Elections if undeliverable. If the notice was returned as undeliverable, the State Board of Elections was to immediately mail each of these voters, by forwardable

mail, a notice of intent to remove the voter from

the list of active registrants within 30 days.

The notice of intent to remove a registrant was

to contain a change of address form addressed to

the County Clerk for the county in which the
records showed the voter resided. With this form,

the voter could request that his voter registration

be transferred to his new address so he could be

placed in the proper voting precinct. As an

alternative, the voter could request a hearing

before the County Board of Elections protesting

removal and asking that he continue to be shown

as a properly registered voter in that county.

At the time these notices were mailed to the

individual voters, a list containing the names of

individuals in each county sent purgation notices

was also to be prepared and sent to the appropriate county. If the voter failed to respond to the

notice within the given time, the county was to

remove that person from the rolls. If a change of

address was received, then the county was to

change the address and precinct as appropriate.

If the voter filed a protest against removal, the

County Board of Elections was to hear their

protest at the next regular monthly meeting following the 30 day expiration period. At that

meeting the Board was to determine if the voter

remained eligible to vote in their precinct and

county of registration. If they were determined to

be ineligible to vote the name was to be removed

from the central registration system files.

The estimated cost of this procedure, as established by the Kentucky Legislature, was about

one million dollars. It would have been necessary

for the State Board of Elections to hire additional

staff and rent additional facilities to house and

process the quantity of cards expected to be returned by the Postal Service. Modifications would

had to have been made to the computer system,

and an extensive amount of additional computer

time would have been required.

Funding was not provided by the 1988 Kentucky General Assembly, and, as a result, action

on these legislated changes was deferred until

1990. In that year, the General Assembly appropriated $300,000 for the 1990-1992 fiscal year to

carry out the process.

The Federal Election Commission's National

Clearinghouse on Election Administration had

become aware of the new Kentucky legislative

requirements and of the financial limitations

imposed by the General Assembly. They recommended that the State Board of Elections use the

National Change of Address system as a cost

effective and efficient means of meeting the requirements imposed by the legislation.

After meeting with the appropriate representatives of the U.S. Posatl Service, the State Board

of Elections met with the Kentucky Elections and

Constitutional Amendments Committee to explain the recommended approach and how it

would enable the Board of Elections to carry out

the task within the $300,000 limit. Based on this

recommendation, the 1990 General Assembly

amended the statutes so that the State Board of

Elections could adopt regulations that would enable use of the NCOA system. The regulations

were adopted, the procedures were put in place,

and the process was initiated using the National

Change of Address system in May 1991.

All change-of-address data received by the

Postal Service is transmitted electronically to

their National Address Information Center in

Memphis Tennessee daily. There the information is consolidated and placed on computer tapes.

Address information changes and corrections are

standardized against a Zip+4 database. This

standardized address information is then transmitted to the private companies operating under

a licensing agreement with the Postal Service.

The first step taken by the Kentucky State

Board of Elections was to select a Postal Service

NCOA licensee. Using this vendor, the Board of

Elections then:

• Provided them with a tape containing the

voter registration records for a selected sample of

counties and had them run these records against

the NCOA files.

• Reviewed the results of this test run to determine that the system would in fact provide the

information needed and improve the ability to

carry out the function required.
Once the suitability of the approach and vendor services were verified, the State Board of

Elections provided the vendor with magnetic tapes

containing all 1,850,000 registered voters in the

central registration system computer files. The

first step the vendor took was to standardize the

tape data and add the Zip+4 numbers to each

record. Next the registration records were compared with those in the NCOA system files. When

this was done the following was found:

• 131,522 individuals were found to have moved

with forwarding addresses.

• 1,177 individuals were found to have moved

and left no forwarding address.

• 131 were found to now have foreign addresses.

All of the identified changes were then put on

a computer tape by the vendor and returned to

the State Board of Elections.

The State Board designed a post card to be used

for notifying each person that had an address

change of their need to inform their County Clerk

of that change. The Board then contracted with

a Kentucky printing and mailing company to

process the computer tape and to carry out the

mailing. This organization was provided a list of

all County clerks and the Zip codes that were

within their counties.

The first task of the printing and mailing

company was to code each record contained on the

tape with the correct County Clerk code. This

information was then used to sort the records by

county and to count the total number of records

for each county. Following this, a label was

printed for each registrant on the tape and affixed

to the two part post card. Then a peel-off label

was printed showing the proper County Clerk's

return address for each post card. These were

affixed to the postcards being mailed. The post

cards were then mailed to the affected voters.

When these voters received the post cards,

they could use the peel-off labels to mail the

completed cards to the County Clerk. The voter

also had the option, however, of going personally

to the County Clerk's office in order to make the

necessary change. Those registrants who failed

to make the address change or who were found to

be ineligible were removed from the voter registry. They had then to re-register in order to be

eligible to vote.

Other Jurisdictions

In Louisiana, the State was required, in 1990,

to determine the continued eligibility of each

registered voter annually. In order to accomplish

this feat, the Commissioner of Elections sent a

tape of registered voters to an NCOA licensee

which identified those registrants who had

changed addresses and provided this information

to the State. This information, coupled with the

names of registrants who have not voted within

five years, was provided in list form to the individual parish voter registrars with a request that

the local registrar attempt to obtain a current

address for each registrant.

In January of 1991, a listing of the names and

addresses of individuals whose records had not

been corrected and updated was published in

each local newspaper. Each individual on the

list was asked to contact the local registrar and

provide their current address so they could be

placed in the proper precinct.

In April, registrants who had not supplied

their address change were sent a card advising

them that if no change was made within 21 days

their name would be removed from the registered

voter rolls. If no response to that notice was

received, then the name was removed and placed

on the inactive list. The individual then had to

request reinstatement in order to be eligible to

vote.

Sacramento and San Diego Counties in California have used the National Change of Address

system at least three times to identify registered

voters who have moved. There the registration

lists are compared to the NCOA database, and

those who have moved are selected. In each case,
either their new address is obtained or else it is

determined that there is no forwarding address.

The counties then proceed to process each case

according to California law.

The Effectiveness of

Using the NCOA System

Each of the State and local jurisdictions that

have used the National Change of Address system

have benefited from it both operationally and

financially.

In the Commonwealth of Kentucky, the estimated cost of verifying 1,850,000 registrants was

$50,000. This included:

• the contract award to the NCOA vendor,

• the printing of cards and labels, and

• the postage and mailing of notifications to

voters.

This does not, however, include the cost of inhouse staff and computer time at the State Board

of Elections or at the local County Clerks' offices.

These are considered to be the normal costs of

registration file maintenance and, thus, not additional costs related specifically to using NCOA.

In Sacramento County, California, the previous

cost to mail notifications to 495,587 non-voters

had been $65,000. Using the NCOA system the

cost to process 562,664 voter records was reduced

to a vendor processing fee of $2,272.

In San Diego County, California, the temporary

staff required to conduct a purge was reduced

from 18 to 3. Postage costs were reduced 88%.

Actual costs savings were 20%, but if the costs

were compared to a full purge, the savings would

be approximately 63%. There was no negative

publicity and the staff found the NCOA system to

be extremely helpful in carrying out their responsibilities.

Kentucky made an effort to determine the

degree of local satisfaction with using the NCOA

system. They contacted 78 of the 120 County

Clerks several were personally visited. Of the

clerks surveyed, 24% rated the method as good,

26% rated it as fair and 35% rated it as poor. The

remaining 15% had not yet used the information

supplied to complete the process due to massive

address changes being made in the counties

In Sacramento County, the benefits of NCOA

were found to far outweigh any drawbacks.

Benefits cited by the county include:

• Changes and corrections are made to the entire voter file and not just non-voters.

• Certain administrative costs such as printing,

sample ballot mailings, and ballots ordered are

reduced because the voter file is more accurate

and current.

• The labor time required to process changes

and cancellations was reduced from 1,920 hours

to 200 hours because a large portion of this

function was done automatically.

There were, however, some drawbacks expressed by the county. These include:

• If there is an error in the NCOA file, it may stay

there for three years. As a result, it may recur

each time there is a purge.

• Since the NCOA system is not specifically

designed for tracking voters, it does not keep

track of voters who move without filling out a

change of address card.

Nevertheless, based on the experience with it

to date, the NCOA system has provided positive

results to the users. The extent to which the

system has been of value is, in large measure,

dependent on how well the total process is planned

and organized before it is initiated. It is also

important that the process be well documented so

that all steps can be easily followed by all persons

involved.

Recommendations

There were a number of recommendations made

by the individuals interviewed regarding their
use of the NCOA system. There are also several

recommendations that have evolved from reviewing the procedures followed by each of the electoral

organizations reviewed. These recommendations

are as follows:

• The U.S. Postal Service should make an effort

to impress upon local postmasters the importance of maintaining the NCOA files and, hence,

the importance of ensuring that patrons complete

change-of-address forms accurately and completely. This is especially true with regard to

"individual" versus "all residents" changes of

address as well as "temporary" versus "permanent" changes of address.

• Each election office using the NCOA system

should include representatives from the Postal

Service offices in their district in their planning

process. The post offices that will be required to

participate in the mailing can provide much better support if they can also plan for the process. It

is particularly helpful for them if they can participate in the timing of the mailings.

• If the program is being conducted on a statewide basis, it is important that the local election

officials be included in the planning process and

be informed of the procedures and schedule to be

followed. This can often be accomplished by

working through the leadership of the local

election officials' association. When such an organization exists, their meetings can be used as a

vehicle to explain any mandated requirements

and to provide written procedures that are to be

followed. Ideally, the local election officials should

participate in the development of the procedures.

• Proper and complete written records should be

maintained for each purge and kept on file with

the chief election official in charge of the purge

process. One of the difficulties in evaluating the

value of the NCOA system was the absence of

complete information about how it worked. In

some cases it was very difficult to obtain this

information because only minimal records were

kept. Full and complete records are important in

monitoring the process, in assessing its value,

and in planning future uses of the NCOA system.

• Whenever possible, use the NCOA system in a

non-election year rather than a year in which

major elections are conducted. This process can,

depending on the law, be a complex one. When

carried out on a statewide basis, it requires a

great deal of coordination in order to function

smoothly. This can best be accomplished when

there is no pressure to carry out a major election.

• Provide advance publicity about the procedures that will be taking place. One of the most

important tasks is making the public aware of the

process and what will be expected from them.

Voters should be advised of the importance of

responding to the notices they receive in order to

remain actively registered. This can be accomplished through public service announcements

on radio, television, and in the local newspapers.

• The wording of notification cards and other

mailed materials should be carefully reviewed to

ensure they are easily and fully understandable

by the registrant. Poor wording of these materials can create a great deal of confusion for the

voter. This in turn can make the entire process

more difficult, time consuming, and costly for the

election officials.
Appendix 1

Contacts

9
At the U.S. Postal Service:

The National Address Information Center

6060 Primacy Parkway, Suite 101

Memphis, Tennessee 38188-0001

Tele: 800/238-3150

In Kentucky:

George Russell

Executive Director

State Board of Elections

State Capitol rm 71

Frankfort, Kentucky 40601-3493

Tele: 502/564-7100

In Louisiana:

Alan Elkins

First Assistant

Office of the Commissioner of Elections

4888 Constitution AvenueP.O. Box 14179

Baton Rouge, Louisiana 70898-4179

Tele: 504/925-1841

In California:

Ernie Hawkins

Registrar of Voters

3700 Branch Center Road

Sacramento, California 95827

Tele: 916/366-2658

Caesar Bolchini

Election Processing Supervisor

Office of the Registrar of Voters

P.O. Box 85093

5201 Ruffin Rd. Ste I

San Diego, California 92186-5093

Tele: 619/694-3409

10
Appendix 2

NCOA Vendors

11
12
Appendix 3

Kentucky Voter

Registration Application

13
J018!88B/JBJJ6|B9J JO
Appendix 4

Kentucky Voter Registration

Change Form

15
Registration Record Change
Appendix 5

Kentucky Purgation Notice

17
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For information about other

Innovations in Election Administration

contact

National Clearinghouse on Election Administration

Federal Election Commission

999 E. Street, N.W.

Washington, D.C. 20463

Toll Free 800/424-9530

Direct 202/219-3670

FAX 202/219-3880

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