Report to Congressional Requesters

United States Government Accountability Office

GAO

June 2005 ELECTIONS

Additional Data Could 

Help State and Local 

Elections Officials 

Maintain Accurate 

Voter Registration 

Lists 

GAO-05-478 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-478.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact William O. 

Jenkins, Jr., at (202) 512-8777 or 

JenkinsWO@gao.gov. 

Highlights of GAO-05-478, a report to 

congressional requesters 

June 2005

ELECTIONS

Additional Data Could Help State and 

Local Elections Officials Maintain 

Accurate Voter Registration Lists 

The methods used in seven selected states to verify voter eligibility and 

ensure accuracy of voter registration lists were varied and include relying on 

registrant self attestation, return mailings, and checking against lists of 

felony convictions or deceased individuals. Election officials from the 

selected states described some challenges that may be resolved when HAVA 

is fully implemented, such as reducing duplicates within the state. Other 

challenges—identifying duplicate registrations in other states or having 

insufficient information to match other data sources with voter registration 

lists—may continue to be issues. 

The seven states are in different phases of implementing HAVA statewide 

voter registration lists and eligibility verification requirements. Arizona 

implemented its statewide voter list by the January 1, 2004, deadline, and the 

other six states applied for a January 1, 2006, waiver. Of those six states, 

Texas, Virginia, and Wisconsin awarded contracts to develop new voter lists 

that are designed to address HAVA requirements. Michigan has had a 

statewide list since 1998, and officials believe it is near HAVA compliant. 

California election officials are still considering how to meet these HAVA 

requirements, and in New York, legislation was passed in May 2005 to create 

the state voter registration lists. 

Federal data sources have the potential to help state election officials 

identify registrants who may be convicted felons or non-citizens. While the 

potential number identified may be small, an election can be decided by a 

few votes. Regarding felons, U.S. Attorneys are required to notify state 

election officials of federal felony convictions, but the information was not 

always easy for election officials to interpret or complete. Federal jury 

services generally do not now, but might feasibly be able to notify elections 

officials when potential jurors drawn from local voter registration lists claim 

to be non-citizens. 

Federal Juror Qualification Questionnaire 

Source: U.S. District Court, Eastern District of Virginia.

Federal data sources have 

the potential to help state 

election officials ensure that 

voter lists are accurate by 

identifying registrants who 

may be non-citizens

Reports of ineligible persons 

registering to vote raised concerns 

about state processes for verifying 

voter registration lists. States base 

voter eligibility generally on the 

voter’s age, U.S. citizenship, mental 

competence, and felon status. 

Although states run elections, 

Congress has authority to affect the 

administration of elections. The 

Help America Vote Act of 2002 

(HAVA) sets a deadline for states to 

have a statewide voter registration 

list and list verification procedures. 

For this report, GAO selected seven

states (AZ, CA, MI, NY, TX, VA, and 

WI) to represent a range of 

characteristics relevant to voter 

registrations, such as whether a 

statewide voter list existed prior to 

HAVA. This report discusses how 

these states verify voter 

registration eligibility; the 

challenges they face in maintaining 

accurate voter lists; the progress 

toward implementing HAVA 

registration requirements; and 

identifies federal data sources that 

might be used to help verify voter 

registration eligibility. 

What GAO Recommends

To help assure voter lists are 

accurate, GAO recommends that 

U.S. Attorneys provide notices of 

federal felony conviction in a 

standardized format, and that the 

Administrative Office of the U.S. 

Courts study the feasibility of 

sharing certain citizenship-related 

U.S. district court juror information 

with state election officials. 

Officials at these federal agencies 

agreed with our recommendations. 
Page i GAO-05-478 Elections 

Letter 1

Results in Brief 4 

Background 6 

States Have Taken Steps to Verify Voter Registration Eligibility, but 

Methods Vary by State 13 

Election Officials Identified Challenges to Verify Voter Registration 

Eligibility 22 

The Seven States Are in Different Phases of Implementing HAVA 

Statewide Voter Registration Lists and Eligibility Verification 

Requirements 29 

Information from Federal Sources Could Assist Election Officials 

in Identifying Ineligible Felons and Non-Citizens on Voter 

Registration Lists 38 

Conclusions 49 

Recommendations for Executive Action 50 

Agency Comments and Our Evaluation 50 

Appendix I Objectives, Scope, and Methodology 52 

Appendix II Department of Homeland Security Automated 

Systems That Include Information on Non-Citizens 57 

Appendix III Voter Registration Fraud Allegations Identified at 

Selected States and at the Federal Level 59 

Appendix IV Comments from the Administrative Office of the 

United States Courts 62 

Appendix V Comments from the U.S. Department of Justice 63 

Appendix VI GAO Contact and Staff Acknowledgments 65 

Contents 
Page ii GAO-05-478 Elections 

Tables 

Table 1: Seven States’ Voter Registration Eligibility Qualifications 10 

Table 2: Selected Activities to Help Implement HAVA Voter 

Registration Requirements in Six States 30 

Table 3: State Selection Factors 53 

Figures 

Figure 1: Arizona Draft Voter Registration Application Requiring 

Proof of Citizenship 16 

Figure 2: Virginia and Wisconsin Voter Registration Attestations 

Regarding Criminal Status 19 

Figure 3: Process for Verifying Voter Registration Applicant 

Information with SSA 35 

Figure 4: Federal Jury Qualification Questionnaire Requests 

Citizenship Information 41 
Page iii GAO-05-478 Elections 

Abbreviations 

AAMVA American Association of Motor Vehicle Administrators 

AOUSC Administrative Offices of the U.S. Courts 

DHS Department of Homeland Security 

DOJ Department of Justice 

DMF Death Master File 

EAC Election Assistance Commission 

FEC Federal Election Commission 

HAVA Help America Vote Act 

HAVV Help America Vote Verification program 

INS Immigration and Naturalization Service 

MVA motor vehicle agency 

NCOA National Change of Address 

NVRA National Voter Registration Act of 1993 

OIG Office of the Inspector General 

QVF Qualified Voter File 

SAVE Systematic Alien Verification for Entitlements 

SSA Social Security Administration 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
Page 1 GAO-05-478 Elections 

June 10, 2005 

The Honorable F. James Sensenbrenner 

Chairman 

Committee on the Judiciary 

House of Representatives 

The Honorable John N. Hostettler 

Chairman 

Subcommittee on Immigration, Border 

 Security and Claims 

Committee on the Judiciary 

House of Representatives 

Reports of ineligible persons registering to vote raised concerns about 

state election administration and processes for verifying voter registration 

lists. In managing the voter registration process and maintaining voter 

registration lists, state and local election officials must balance two 

goals—(1) minimizing the burden on eligible persons of registering to vote 

and (2) ensuring that voter lists are accurate, i.e., limited to those eligible 

to vote and that eligible registered voters are not inadvertently removed 

from the voter registration lists. This report focuses on the second goal—

the efforts of state and local election officials in seven states to ensure that 

voter registration lists are accurate. 

In addition to this report, we also plan to issue reports this year on other 

specific election issues—voter access to the polls; how the nine states 

without Help America Vote Act (HAVA) waivers1

 have implemented voter 

registration requirements as of January 1, 2004; electronic voting security; 

and the Department of Defense’s implementation of the Federal Voting 

Assistance Program for Overseas Military Personnel in 2004. These reports 

respond to congressional requests made prior to the November 2004 

election. In addition, given concerns raised about the November 2004 

 1

While HAVA established a deadline of January 1, 2004, for states to have a statewide voter 

registration list and verification procedures, it also provided that states could request a 

waiver to extend the deadline to January 1, 2006. Nine states did not request a waiver, 40 

states and the District of Columbia did request and receive waivers, and 1 state (North 

Dakota) is not covered by the HAVA requirement because it does not have a voter 

registration requirement for individuals voting in federal elections. 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-478 Elections 

election process, we are undertaking a broader, more comprehensive 

study of election administration and processes related to the November 

2004 general election. This more comprehensive study will address 

activities and challenges—people, processes, and technology—associated 

with each major stage of election administration to include registration, 

absentee and early voting; Election Day preparation and activities, and 

vote counting and certification, similar to a report we issued in October 

2001.2

All states set certain eligibility requirements to register and vote. States 

establish voter eligibility requirements that generally include that the voter 

is at least 18 years of age on the day of the election, is a citizen of the 

United States, is mentally competent, and meets state requirements 

regarding felon status. Ensuring that only eligible persons are registered to 

vote is an ongoing challenge for election officials and is complicated by 

factors such as jurisdiction size, mobility of voters, and community 

diversity. In larger jurisdictions the task of identifying and removing 

registrants who have died can be substantial. For example according to 

Centers for Disease Control and Prevention records, almost 300 persons 

died in the first week of 2005 in the city of Los Angeles. Communities with 

large student or military populations must manage registrants constantly 

moving in or out of a jurisdiction, and communities with diverse 

populations must handle substantial numbers of new citizens and face 

language challenges in communicating voter registration requirements. 

After the events surrounding the November 2000 election, HAVA was 

enacted.3

 It requires states, among other things, to (a) implement an 

interactive computerized statewide voter registration list; (b) perform 

regular maintenance by comparing the voter list against state records on 

felons and deaths; (c) match applicant information on voter registration 

lists with information in state motor vehicle agency’s records; and (d) 

match voter registration applicant information on voter registration lists 

with Social Security Administration (SSA) records, as appropriate. 

This report addresses current and planned voter registration processes in 

seven selected states for verifying voter registration lists. Specifically, this 

report answers the following questions: (1) How do state election officials 

 2

GAO, Elections: Perspectives on Activities and Challenges across the Nation, GAO-02-3

(Washington, D.C.: Oct. 15, 2001). 

3

 Pub. L. No. 107-252, 116 Stat. 1666 (2002). 
Page 3 GAO-05-478 Elections 

verify voter registration eligibility and ensure voter registration lists are 

accurate? (2) What challenges do they face in maintaining accurate voter 

lists? (3) What progress have these states made toward meeting HAVA 

requirements to have voter registration verification procedures? (4) What 

federal data sources, other than those identified in HAVA, might be used to 

help verify voter registration eligibility? 

To address the first three objectives, we selected a nonprobability sample 

of seven states—Arizona, California, Michigan, New York, Texas, Virginia, 

and Wisconsin to represent a range of voter-registration factors. Our 

selection includes states in various stages of development of their 

statewide databases, variations in election administration, a range in the 

percent of the population of foreign born, and is geographically diverse. 

We also considered other characteristics that might affect the 

implementation of HAVA, such as same day registration in Wisconsin, or 

New York, with a large population who live in New York City who may not 

have driver’s licenses for verification. Our goal was not to target a 

particular state, but rather to identify a range of issues facing states in 

implementing HAVA requirements and assuring accurate voter registration 

lists. In these seven states, we interviewed state election officials and 

election officials in 14 local voting jurisdictions—two in each of these 

states. Additional information on our scope and methodology is presented 

in appendix I. 

In these seven states, we also interviewed motor vehicle agency 

(MVA)4

officials because voters can submit voter registration applications 

at MVA offices, and MVAs have a role under HAVA to assist states with 

verification of voter registration information. In addition, we reviewed 

relevant state voting laws, voter registration documents, and reports 

related to voting processes. We interviewed officials at the SSA and 

obtained documentation on how they are addressing SSA’s HAVA 

verification requirements. To identify potential federal data sources to 

verify voter registration, we gathered information from state election and 

county jury administrators, and from officials at the Department of 

Homeland Security (DHS), the Department of Justice (DOJ), the Election 

Assistance Commission (EAC), and the Administrative Offices of the U.S. 

Courts (AOUSC), and we reviewed relevant reports. We also obtained 

information on voter fraud allegations from DOJ, from U.S. Attorneys in 

 4

States may refer to their motor vehicle agencies by different names. For purposes of this 

report, we will generically refer to them as “motor vehicle agencies.” 
Page 4 GAO-05-478 Elections 

our selected states and from state and local election officials and District 

Attorneys for the local election jurisdictions we visited. See appendix I for 

additional information on our objectives, scope, and methodology. Our 

work was done between January 2004 and May 2005 in accordance with 

generally accepted government auditing standards. 

State and local election officials we interviewed in the seven states said 

they use a combination of methods and information to verify voter 

eligibility and ensure the accuracy of voter registration lists. These 

included using computer programs that only accept registrants of an 

eligible age and those who live at an address within the jurisdiction, 

confirmation mailings to registrants, and information from state vital 

statistics or court officials on persons who are deceased or have been 

convicted of a felony. 

HAVA provisions, when fully implemented, should help address some 

challenges state election officials face in obtaining timely, accurate, and 

complete information to identify ineligible voter registrants, but other 

challenges may remain. Having a statewide voter registration list and 

matching the list with state vital statistics and felon data, as required by 

HAVA provisions, could reduce the number of duplicate registrations 

within a state and provide more timely identification of ineligible 

registrants. HAVA provisions may not affect other data challenges, such as 

identifying registration duplications or deceased individuals outside the 

state, or identifying non-citizens. 

Progress to meet HAVA requirements in the seven states we visited varied. 

One state, Arizona, implemented its statewide voter list by the January 1, 

2004, deadline, and the other six states applied for and received a waiver 

to defer their implementation of these provisions until January 1, 2006. Of 

those six states, Michigan has a statewide list that has been operational 

since 1998 and state officials believe they are near compliance with HAVA 

requirements. Texas, Virginia, and Wisconsin awarded contracts to 

develop the voter lists intended to encompass HAVA requirements. 

California and New York are working toward meeting the January 2006 

deadline, but California is still evaluating its strategy for creating a 

statewide database that is HAVA compliant, and legislation approving the 

creation of New York’s state voter registration list was not passed until 

May 2005. The extent to which states verified applicant information with 

state motor vehicle agencies and compared voter lists with state records 

for deaths and felons varied in that some had agreements to verify 

information and some did not. As of March 2005, six of the states we 

Results in Brief 
Page 5 GAO-05-478 Elections 

visited still needed to sign an agreement with SSA to verify voter registrant 

information against Social Security records. The seventh state, Virginia, is 

not subject to this HAVA requirement because it is permitted to require 

voter registrants to provide their full social security number. This number 

can be used with SSA’s online verification system. 

We identified two federal data sources that have the potential to help state 

and local election officials ensure that their voter lists are accurate. The 

number of potentially ineligible voter registrants identified by these two 

federal sources may be small but could be important in determining the 

outcome of a close election. 

First, U.S. Attorneys are, by law, to send notice to state election officials 

upon conviction of felonies in federal court. State officials, in turn, are to 

forward it to local election officials in the jurisdiction where the convicted 

offender resides. The law does not establish a standardized time frame or 

format for forwarding the federal felony conviction information. Of the 19 

U.S. Attorneys’ offices covering the seven states we visited, 16 reported 

that the notices were being sent to election officials but not in a 

standardized format and 3 reported that they were implementing or 

modifying their processes to provide this information on felony 

convictions in U.S. district courts. According to state and local election 

officials with whom we spoke in the seven states, federal felony 

information was not always provided in a standard format or timely, and 

the information was sometimes difficult to interpret, such as the length of 

the sentence, or incomplete. 

Second, federal jury administrator questionnaires identify individuals who 

claim to be non-citizens when asked to serve as a juror in federal district 

court.5

 The federal district courts are not required to provide election 

officials with this information, but 1 of the 14 federal district courts we 

surveyed does so. One source that the federal district courts use to draw 

the potential jurors’ names is local voter registration lists that should only 

contain names of citizens. Federal jury administrators were mixed in their 

opinions on the feasibility of providing this information, some citing staff 

resource constraints. 

 5

Potential jurors for a U.S. district court are chosen by federal jury administrators in each 

of the 94 district courts from a jury pool generated by random selection of citizens’ names 

from lists of registered voters, or combined lists of voters and people with drivers’ licenses, 

in the judicial districts. The potential jurors complete questionnaires to help determine 

whether they are qualified to serve on a jury. U.S. citizenship is a qualification to be a juror. 
Page 6 GAO-05-478 Elections 

To assist state election officials in maintaining accurate voter registration 

lists, we are recommending that U.S. Attorneys provide information on 

felony convictions in U.S. district courts in a more standardized format to 

make it easier for election officials to interpret the conviction information, 

such as the length of the sentence, and help ensure that information is 

complete and timely. We also recommend that the Administrative Office of 

the U.S. Courts6

 study the feasibility of sharing certain citizenship-related 

U.S. district court juror information with state election officials. 

We provided a draft of this report to DOJ and AOUSC for review and 

comment. In their responses, officials at both DOJ and AOUSC 

acknowledged the importance of maintaining accurate voter registration 

lists, and agreed with our report recommendations. Sections of the report 

were also provided to other federal agencies and states we visited to 

confirm the accuracy of the information. Clarifications and specific 

technical comments on the draft were incorporated as appropriate into the 

final report. 

The constitutional framework for elections contemplates both state and 

federal roles. States are responsible for the administration of both their 

own elections and federal elections. States regulate various aspects of the 

elections process, including, for example, ballot access, registration 

procedures, absentee voting requirements, establishment of polling places, 

provision of election day workers, and counting and certifying the vote. 

The states in turn incur the costs associated with these activities. Although 

the states are responsible for running elections, Congress has authority to 

affect the administration of elections. Congress’ authority to regulate 

elections depends upon the type of election. With regard to federal 

elections, Congress has constitutional authority over both congressional 

and presidential elections. In addition, with respect to federal, state, and 

local elections, a number of constitutional amendments authorize 

Congress to enforce prohibitions against specific discriminatory acts. 

Congress has passed legislation regarding the administration of elections, 

both for federal elections and in certain cases at the state level. Most 

recently HAVA was enacted in 2002. HAVA established, among other 

 6

The AOUSC is the administrative arm of the federal judiciary. The agency provides service 

to the federal courts in three essential areas: administrative support, program management, 

and policy development. 

Background 
Page 7 GAO-05-478 Elections 

things: (1) a program to provide funds to states to replace punch card or 

lever voting systems used in federal elections, (2) the EAC to assist in the 

administration of federal elections and to otherwise provide assistance 

with the administration of certain federal election laws and programs, and 

(3) certain minimum election administration standards for states and units 

of local government with responsibility for the administration of federal 

elections. The act fixed enforcement authority on the Attorney General to 

bring a civil action against any state or jurisdiction as may be necessary to 

carry out the specified uniform and nondiscriminatory election technology 

and administration requirements under HAVA.7

Regarding the administration of elections, HAVA created federal 

mandates, staggered deadlines for implementing these mandates, and 

authorized about $3.86 billion over several fiscal years in election reform 

appropriations. HAVA required that states create plans detailing how they 

will meet the requirements and guidelines of the act. Among the 

requirements, section 303 mandated a computerized statewide voter 

registration list to serve as the official voter registration list for conducting 

elections for federal office in each state. States and territories were to 

implement a computerized statewide voter registration database by 

January 1, 2004. States could apply to the EAC by January 1, 2004, for a 

waiver of the effective date until January 1, 2006. Nine states and one 

territory—Alaska, Arizona, Georgia, Hawaii, Kentucky, Minnesota, South 

Carolina, South Dakota, West Virginia, and Guam—did not apply for a 

waiver. 

Section 303 also requires states to perform list maintenance on a regular 

basis by removing ineligible voters from the voter registration list. States 

are to coordinate the computerized list with state agency records on 

felony status and death. In addition, states are required to verify voter 

registration information. For federal elections, a voter registration 

application may not be processed or accepted by a state unless it contains 

the applicant’s driver’s license number, the last 4 digits of the social 

security number if there is no driver’s license number, or the state must 

create a unique identification number if the voter has neither number. 

Certain state laws allow voter registration applications to require the 

 7

These sections relate to voting system standards (section 301), provisional voting and 

voting information requirements (section 302), computerized statewide voter registration 

list requirements, and requirements for voters who register by mail (section 303). 
Page 8 GAO-05-478 Elections 

applicant to provide their full social security numbers on applications.8

Voter registration information is to be matched with motor vehicle records 

or social security records, depending on the information provided by the 

applicant. The state motor vehicle authority must enter into an agreement 

with SSA to verify the applicant information when the last 4 digits of the 

social security number are provided rather than a driver’s license or state 

identification number. SSA must develop methods to verify the accuracy 

of information provided and whether the name, date of birth, and the last 4 

digits of a social security number match SSA records, including whether 

the individual is deceased. 

HAVA is not the first federal legislation affecting the administration of 

elections. The National Voter Registration Act of 1993 (NVRA),9

 for 

example, was enacted to establish registration procedures designed to 

“increase the number of eligible citizens who register to vote in elections 

for Federal office...,” “protect the integrity of the electoral process...” and 

“ensure that accurate and current voter registration lists are maintained.” 

NVRA contains provisions regarding what information is sought on the 

voter registration application for federal elections. To enable state election 

officials to assess the eligibility of the applicant and to administer voter 

registration and other parts of the election process, the act requires that 

the voter registration application include a statement about each eligibility 

requirement to be able to vote, specifically including citizenship. It further 

requires an attestation that the applicant meets each such requirement to 

vote and requires the signature of the applicant under penalty of perjury. 

In addition, NVRA created requirements for how states maintain voter 

registration lists for federal elections. The act requires states to keep such 

voter registration lists accurate and current, such as identifying persons 

who have become ineligible due to death or change of residence to outside 

the jurisdiction. At the same time, the act requires list maintenance 

programs to incorporate specific safeguards, for example, that they be 

uniform, non-discriminatory, and in compliance with the Voting Rights 

Act. The removal of registrants for non-voting or for having moved can 

 8

Seven states—Georgia, Hawaii, Kentucky, New Mexico, South Carolina, Tennessee, and 

Virginia—require full social security numbers on applications for voter registration. HAVA 

provides that for states using full social security numbers on applications in accordance 

with section 7 of the Privacy Act of 1974, the HAVA voter registration verification 

requirements are optional. 

9

Pub. L. No. 103-31, 107 Stat. 77 (1993). 
Page 9 GAO-05-478 Elections 

only be done after meeting certain requirements provided in the act. The 

act also allows for removal of registrants from registration lists at their 

own request, when a registrant has been convicted of a disqualifying 

crime, or by reason of mental incapacity where such removals are allowed 

by state law. 

Voter registration qualifications based on age, citizenship, criminal status, 

mental competence, and residence were established in all seven states we 

reviewed, except for Michigan, which does not have a mental competency 

requirement. Table 1 summarizes the eligibility qualifications in the 

selected states. 
Page 10 GAO-05-478 Elections 

Table 1: Seven States’ Voter Registration Eligibility Qualifications 

 Age Citizenship Felon statusa

Mental 

competence 

Reside in election 

jurisdiction 

AZ At least 18 years 

old on or before 

the next general 

election 

U.S. citizen Felony conviction will generally 

prohibit a person from being eligible 

to register or trigger the cancellation 

of the felon’s pre-existing registration. 

1st time felons otherwise eligible may 

reregister when discharged, or 

probation is complete. With more than 

1 felony conviction after an absolute 

discharge, a felon must have a judge 

reinstate voting rights. 

Not be currently declared an 

incapacitated person by a 

court of law 

State resident in county 

at least 29 days before 

election 

CA At least 18 years 

of age at the time 

of the next 

election 

U.S. citizen A person in prison or on parole for the 

conviction of a felony is not entitled to 

register and cancellation of the felon’s 

pre-existing registration will be 

triggered. Once the sentence is 

complete, including parole, a felon 

who is otherwise eligible may 

reregister. Voting rights may also be 

restored by the governor. 

Not currently judged 

mentally incompetent by a 

court of law 

California resident and 

registered at least 15 

days prior to an election 

MI At least 18 years 

old by the next 

election 

U.S. citizen Persons confined in jail after 

conviction and sentencing are not 

eligible to register or vote. Prior to trial 

or conviction and sentence, persons 

confined in jail may register at their 

prior address. Upon release, person 

who is otherwise eligible may register 

or reregister.b

Not a state eligibility 

disqualification 

Michigan resident and at 

least a 30-day resident 

of the city or township, 

by election day 

NY At least 18 years 

old by the date of 

the election 

U.S. citizen Felony conviction will generally 

prohibit a person from being eligible 

to register or trigger the cancellation 

of a pre-existing registration. Felons 

who are otherwise eligible may 

register or reregister after a pardon or 

restoration of rights by the governor 

of the state where such conviction 

took place (or the President for 

federal felony conviction), completing 

the maximum sentence of 

imprisonment, or when they are 

discharged from parole. 

Not currently judged 

incompetent by order of a 

court of competent judicial 

authority 

A resident of the state 

and of the county, city, 

or village for at least 30 

days before an election 
Page 11 GAO-05-478 Elections 

 Age Citizenship Felon statusa

Mental 

competence 

Reside in election 

jurisdiction 

TX At least 17 years 

and 10 months 

old to register and 

must be 18 to 

vote 

U.S. citizen Felony conviction will generally 

prohibit a person from being eligible 

to register or trigger the cancellation 

of a pre-existing registration. Felons 

who are otherwise eligible may 

reregister when their sentence has 

been fully discharged or have been 

pardoned or otherwise released from 

the resulting disability to vote. 

Have not been declared 

incompetent by final 

judgment of a court of law 

Be a resident of the 

county in which the 

application for 

registration is made 

VA At least 18 years 

old by the next 

general election 

U.S. citizen Felony conviction will generally 

prohibit a person from being eligible 

to register or trigger the cancellation 

of a pre-existing registration. Felons 

who are otherwise eligible may qualify 

to register or reregister if their civil 

rights have been restored by the 

governor or other appropriate 

authority. 

Not currently declared 

mentally incompetent by a 

court of law 

A resident of VA and of 

the precinct in which 

he/she wants to vote 

and registered no later 

than 29 days before the 

general election 

WI At least 18 years 

old 

U.S. citizen Persons convicted of a felony are 

disqualified from voting. Voting rights 

are restored upon completion of the 

term of imprisonment, probation, or 

parole, or through a pardon. 

Not have been found by a 

court to be incapable of 

understanding the objective 

of the electoral process 

A resident in an election 

district or ward of the 

state for at least 10 days 

before an election 

Source: GAO summary of information verified by states. 

a

This table may not reflect the full range of possible measures available under state law. Other 

measures, such as reversals, set-asides, or pardons may be available under specific state laws to 

restore civil rights for convicted felons. In addition, this table does not reflect other non-felony 

convictions, such as bribery, that may serve to disenfranchise an individual under state laws. 

b This provision of Michigan law applies not just to convicted felons who are confined in a jail but to all 

persons who are confined in a jail as a result of non-felony offenses for which they have been 

convicted and sentenced. 

Registering more than once is explicitly addressed in some state laws. For 

example, under Virginia law, the intentional registration to vote at more 

than one residence address at the same time, whether such registrations 

are within Virginia or in Virginia and any other state or U.S. territory, is 

prohibited.10 In New York, it is illegal to register or attempt to register as 

an elector in more than one election district for the same election, or more 

than once in the same election district.11 While federal law does not 

explicitly prohibit being registered to vote more than once, such as in 

more than one state, various federal laws could apply to certain types of 

 10Va. Code Ann. § 24.2-1004. 

11NY CLS Elec. § 17-104. 
Page 12 GAO-05-478 Elections 

wrongful activities that might result in such multiple registrations related 

to a federal election. For example, knowingly or willfully providing false 

information (e.g., name, address, or period of residence) to establish 

eligibility to register to vote with respect to a federal election is 

prohibited.12

Voters are not now required to register in all jurisdictions in Wisconsin. 

Currently, only municipalities with a population of 5,000 or more are 

required to register voters.13 About 75 percent of the voting age population 

lives in the municipalities that have some form of voter registration. Voters 

may also register in Wisconsin on Election Day at the polling place. Under 

“same-day registration” potential voters are required to complete a 

registration form that includes a certification as to their eligibility14, and 

present an acceptable proof of residency. The municipal clerk for a 

jurisdiction is responsible for verifying that each person allowed to vote 

was properly registered, and sends a postcard confirming registration to 

the person, or a 1st class letter if the registration cannot be confirmed. If 

the letter is undelivered or an improper address was provided, municipal 

clerks are to notify the district attorney.15 In jurisdictions without 

registration, the voting officials enter the full name and address of voters 

on a poll list in the order they voted. 

 1242 U.S.C. § 1973i(c). 

13Changes made in 2003 to Wisconsin’s election laws will require voter registration in every 

municipality, regardless of size. This registration requirement first applies to the 2006 

spring primary election. 

14Wisconsin has voters self-certify as follows: “I (name) hereby certify that to the best of my 

knowledge, I am a qualified elector, having resided at (address) for at least 10 days 

immediately preceding this election, and that I am not disqualified on any grounds from 

voting, and I have not voted, at this election.” In addition to Wisconsin, Idaho, Maine, 

Minnesota, New Hampshire, and Wyoming allow same day registration. 

15The Wisconsin Joint Legislative Audit Committee has an ongoing audit of voter address 

verifications based on allegations of inappropriate election procedures in Milwaukee to 

verify same day voter registration eligibility in the November 2004 election. According to 

Joint Legislative Audit Committee official, the report is due for completion by the fall of 

2005. 
Page 13 GAO-05-478 Elections 

State and local election officials in the seven states we reviewed reported 

that specific steps are taken to verify eligibility when an applicant applies 

to register and that voter registration lists are also reviewed periodically to 

identify registrants who may no longer be eligible, such as those who have 

moved, have been convicted of a felony, or are deceased. Officials in the 

seven states use a combination of methods, including computer 

programming, return mailings, and information from state vital statistics to 

identify registrants who should be removed from voter rolls. 

Self-attestation is included in every voter registration application in the 

seven states we visited but varies by the terms used and format of the 

attestation. All voter registration application forms in the seven states we 

visited asked applicants to certify with their signature that the information 

provided is correct and true. The forms ask the applicant to attest to their 

age, citizenship, and residency. The format asking for additional 

information varied in the seven states. 

To determine eligibility based on age, all states we reviewed, except 

Texas, required applicants to declare, swear, affirm, or attest on the voter 

registration application that they meet state age requirements. In addition, 

officials in Arizona, Texas, Virginia, and New York City said that their 

voter registration computer system is programmed to calculate the age of 

the applicant, based on the date of birth the registrant provides, and reject 

applications of individuals who will be younger than 18 years of age on the 

day of the next election. Michigan’s computer system accepts registrations 

from voters who are at least 17-1⁄2 years of age; however, the names will 

not appear on a precinct list until the voter has reached the age of 18. In 

addition, Arizona and Michigan election officials match their voter 

registration applications against the state motor vehicle agency’s records 

to verify the information. 

California’s MVA procedure manual instructs clerks to “flag” voter 

registration applications for election officials if they have concerns about 

a voter registration applicant’s age. According to the MVA manual, if the 

birth date on the voter registration form does not agree with the birth date 

on documentation, clerks are to note “BD” on the voter registration form 

so election officials will know to verify the birth date. However, neither of 

the local election officials we spoke with in this state recalled having an 

application flagged by the MVA for closer review of an applicant’s age. 

None of the officials in other states (excluding Wisconsin, which is not 

currently subject to the NVRA requirement to register voters at motor 

vehicle agencies because of certain NVRA exemption provisions for states 

States Have Taken 

Steps to Verify Voter 

Registration 

Eligibility, but 

Methods Vary by State 

Verification of age 
Page 14 GAO-05-478 Elections 

allowing voters to register on Election Day) reported having a policy for 

motor vehicle agency clerks to share eligibility concerns. 

All election officials we spoke with told us that non-citizens are not 

permitted to vote in elections, including non-federal elections.16

Citizenship eligibility was based on applicant self-attestation in all seven 

states, with application blocks that must be checked by the applicant 

specifically affirming U.S. citizenship. Five of the states require applicants 

to swear, affirm, or attest that they are U.S. citizens in addition to checking 

the block. In Texas applicants affirmed that they understood giving false 

information is perjury and a crime under state and federal law. In 

Wisconsin, applicants are to certify that they meet all the voter registration 

requirements, and, according to Wisconsin state law, the municipal clerk 

or board of election commissioners may require naturalized applicants to 

show their naturalization certificates. New York State election officials 

said that their state law entitles any voter to challenge a person’s right to 

vote if they think that voter is not a citizen. 

As with age, California’s MVA procedure manual instructs clerks to “flag” 

voter registration applications if citizenship status is in question by writing 

“US” on the corner of the form. According to the manual, when 

immigration documents provided to a MVA staff do not confirm 

citizenship, the staff is to remind the customer of the voter registration 

eligibility requirements. If the customer still desires to submit a voter 

registration application, the staff places the notation on the form. No other 

state that we visited has this provision. Many of the motor vehicle officials 

we spoke with stated a view that it was up to state election officials to 

determine a registrant’s eligibility to vote, not the motor vehicle agency, 

and that all applications are forwarded to election officials. 

In Arizona, a ballot initiative passed in November 2004 that will require 

proof of citizenship to register to vote (and identification upon voting). 

The registration requirement does not apply to those who are currently 

registered, or when a registrant changes their registration address within a 

single county. Arizona’s Secretary of State, as of March 4, 2005, was 

determining which forms of identification will be acceptable as proof. 

 16New York state election officials said that until 2003, when the administration of school 

elections was transferred to the New York City Department of Education, non-citizens with 

a student in a New York City school were allowed to vote in school board elections. 

Verification of citizenship 
Page 15 GAO-05-478 Elections 

According to Arizona draft procedures released for public comment, 

acceptable identification included 

• a copy of a birth certificate that verifies citizenship, 

• a copy of pertinent passport pages of a U.S. passport, 

• a copy of naturalization documents, 

• selected Bureau of Indian affairs documents, and 

• Arizona driver’s license or non operating license issued after October 1, 

1996, or the equivalent government document from another state if the 

agency indicates on the applicant’s driver license or nonoperating 

license that the person has provided satisfactory proof of U.S. 

citizenship. 

Figure 1 shows sections of the draft proposed application requiring 

citizenship information that was made available for public comment. 

According to local election officials in one Arizona jurisdiction, mail 

applications will not be processed without citizenship documentation. The 

applicants will be sent a letter asking for documentation, and the letter 

will include a list of documents that are acceptable as proof of citizenship. 
Page 16 GAO-05-478 Elections 

Figure 1: Arizona Draft Voter Registration Application Requiring Proof of Citizenship 

Some local election jurisdictions receive information from county jury 

administrators to help identify potential non-citizens on voter registration 

lists. County jury pools are drawn from a variety of sources, which may 

include voter registration lists. In five of the states we visited, county jury 

administrators use voter registration lists, and potential jurors are asked to 

indicate citizenship status on jury service screening questionnaires. In 4 of 

the 10 local jurisdictions in those five states, election officials said they 

receive notification from county jury administrators when a potential juror 

claimed to be a non-citizen as a justification for being excused from jury 

Source: Arizona Secretary of State website (www.azsos.gov) for public comment.
Page 17 GAO-05-478 Elections 

duty. None of the local election officials said that they receive notifications 

from federal jury administrators. 

In addition to the state or local election jurisdiction efforts to help ensure 

registrants are eligible based on citizenship, Federal Election Commission 

(FEC)17 officials noted that some federal measures have been adopted to 

discourage non-citizens from registering to vote. Measures include: 

• possible deportation, under immigration laws, for knowingly making a 

false statement about citizenship status to register; 

• the NVRA requirement that applications list eligibility requirements 

(including citizenship); 

• the prohibition in federal law on governmental use of a voter 

registration card for a federal election as proof of U.S. citizenship; and 

• the HAVA requirement that a statement identifying eligibility 

requirements, including citizenship, be included on voter registration 

applications. 

Nevertheless, the FEC officials noted that non-citizens may be encouraged 

to register to vote because the I-9 form used to provide proof of 

employment eligibility and its implementing regulations18 includes, among 

other documents, the voter registration card as an acceptable document 

for employment identity purposes. 

In six of the seven states we visited, the eligibility of applicants, in terms of 

criminal status, was based on the self-certification signed by registration 

applicants. In Arizona, Texas, and Virginia, the application includes 

language specifically certifying eligibility based on criminal status. In New 

York and Wisconsin, applicants certify to a general statement that they 

meet all the requirements to register for their state, which includes a 

restriction based on criminal status. California uses both specific and 

general attestations. Michigan applicants do not attest to their criminal 

status, but voting is prohibited only for those serving time in prison or jail. 

 17Prior to HAVA, the FEC’s Office of Election Administration was the federal focal point for 

election administration issues. This office was transferred to the EAC as part of HAVA. 

188 C.F.R. § 274a.2–Verification of Employment Eligibility. 

Verification of criminal 

status 
Page 18 GAO-05-478 Elections 

According to election officials, they do not accept voter registrations or 

absentee ballots from prison addresses. Examples of the at testation 

language used on voter registration applications are presented in figure 2. 
Page 19 GAO-05-478 Elections 

Figure 2: Virginia and Wisconsin Voter Registration Attestations Regarding Criminal Status 

Officials in Arizona, California, New York, Texas, and Virginia said they 

receive state court information on felony convictions to remove voter 

registrants no longer eligible to vote based on a criminal conviction. Court 

information on felons in these states was provided to election officials in 

different formats and at different intervals. The data came in either paper 

or electronic format depending on the location. State election officials in 

two states said that the format varied by county within their states. 

Election officials in the five states reported receiving information at 

different intervals, such as weekly, monthly, intermittently, or biannually. 

State election officials in six of the seven states and 9 of the 14 local 

election officials said that they received information on federal felony 

Source: Voter registration forms provided by Virginia and Wisconsin election officials.

Virginia

Wisconsin

An example of an application requesting certification to a specific statement on criminal status.

An example of an application requesting certification to a general statement on criminal status.
Page 20 GAO-05-478 Elections 

convictions. Most election officials said the information was received on a 

sporadic or intermittent basis, in a paper format. 

Michigan election officials do not receive information from state courts on 

felony convictions. Officials there told us that state felony conviction 

information was not needed because they only restrict the right to vote 

while the person is incarcerated. Local election officials in Wisconsin said 

they do not receive state felony conviction information. The Wisconsin 

state election official said that felon records are diffused and difficult to 

compare with voter lists. Wisconsin plans to create a statewide database 

that will consolidate criminal records from 17 different correctional 

databases, the state election official said. However, the system will not be 

available by the January 1, 2006, HAVA deadline, according to the state 

election official. 

The laws in five of the states we visited (California, New York, Texas, 

Wisconsin, and Arizona), for first-time felony convictions, allow felons to 

gain eligibility to vote when a felony sentence is completed—which can 

include time on probation, parole, payment of fines, or supervision related 

to the conviction. States do not require proof that the non-incarcerated 

segments of a sentence be completed, according to all of the officials we 

spoke with and state regulations we reviewed in those states. 

Six of the seven states we visited have a state law that disqualifies persons 

legally declared to be mentally incompetent or incapacitated from 

registering to vote and cancels the voter’s registration upon such 

adjudication. Michigan’s constitution has provided that the legislature 

may, by law, exclude persons from voting because of mental 

incompetence, but no such law has been enacted. Wisconsin limits 

disqualifications based on mental incompetence to those where a court 

specifically determines that the registrant is incapable of understanding 

the objective of the electoral process. State and local election officials in 

Arizona, California, New York, Texas, and Virginia reported that courts 

notify registrars periodically when adjudications on mental incompetence 

are made. Two rural jurisdictions reported that family members or 

caretakers sometimes notify the registrar of mental competency 

adjudications. In one Texas jurisdiction, the election official said that the 

court sends a notice to the county elections office, which in turn sends a 

letter to the voter confirming the voter’s removal from the registration list. 

Verification of mental 

competence 
Page 21 GAO-05-478 Elections 

Officials we spoke with in the seven states said that in addition to initially 

checking that an applicant resides in the jurisdiction (either by using an 

automated address file or manually checking), they also use a variety of 

sources to periodically verify their voter lists for registrants who may have 

moved. The National Change of Address (NCOA) list19 is used by Virginia 

state officials on a yearly basis and used in at least one of the local 

election jurisdictions we visited in Arizona, California, New York, and 

Virginia. How often the national list was checked varied, but of the eight 

jurisdictions using this source, five said they checked on an annual basis. 

Twice a year, New York county election officials send their voter lists to 

state officials for comparison with the NCOA list, according to a state 

election official. Election officials in every state said returned mail was 

used, either at the state or local election level—some on a daily basis, 

others intermittently, annually, or before a major election. Ensuring that 

registrants live in an election jurisdiction is generally a task for local 

election officials but can be part of a statewide system, as in Michigan, 

where the voter registration system electronically assigns the voter’s 

jurisdiction based on the address provided by the registrant. Residency is 

further verified by the mailing of a non-forwardable voter identification 

card to each new registrant in Michigan.20

For duplicate registrations, election officials said that existing voter lists 

are checked by election officials before adding a new registrant or are 

checked periodically. In the case of Arizona, Michigan, and Virginia, the 

statewide voter registration system enables jurisdictions to identify 

duplicates statewide. California and Texas state election officials said they 

compare local jurisdiction records and will notify local officials of 

potential duplicates. New York and Wisconsin primarily check for 

duplicates within the election jurisdiction. Some officials also reported 

periodically checking against other data sources, noted below. Officials 

reported using varying combinations of name, address, and other 

identifying information collected on the application to identify existing 

registrations, such as social security number in Virginia. In Michigan, 

 19The U.S. Post Office National Change of Address list is compiled from change of address 

forms filed by individuals who have moved and want their mail forwarded to their new 

address. 

20In Michigan, the address for a state identification card or license and voter registration 

must be the same. These files are linked to automatically update each file of the addresses 

changes. 

Verification of residency 

Identification of duplicate 

registrations 
Page 22 GAO-05-478 Elections 

election officials demonstrated how the states voter registration file has 

computer software with a search capability to identify similar names as 

potential duplicates. These similar names are researched manually to 

determine whether they are actually duplicates. 

The data sources state and local election officials reported checking to 

identify duplications and ensure that registrants reside in the election 

district varied in terms of what information was used, and the frequency of 

use. Sources included 

• National Change of Address List, 

• return mailings of non-deliverable mail, 

• individuals reporting an address change, 

• notice from other election jurisdictions or state election officials of a 

change, and 

• a check against state MVA records. 

State vital statistics offices in six of the seven states reported that they 

provide data periodically—from weekly to quarterly—to election officials 

to identify registrants who have died. In addition to state vital statistics, 

state and local officials said they use various sources of data to identify 

deceased voter registrants on their registration lists. Data sources included 

• county Vital Statistics Office records, 

• newspaper obituaries, and 

• miscellaneous sources, such as family members, city vital statistics 

offices, funeral homes, the U. S. Postal Service, probate courts, and 

MVAs. 

Wisconsin local and state election officials said that state vital statistics 

are not currently used to identify deceased registrants. Local election 

officials said they review obituaries to identify deceased persons. 

Ensuring that voter lists are accurate is a task that has challenged election 

officials across the country for some time and was also a concern of 

election officials in the seven states we visited. Officials in one jurisdiction 

characterized voter registration lists as dynamic and constantly changing. 

In larger jurisdictions the task of identifying and removing registrants who 

died can be substantial; for example, according to Center for Disease 

Controls and Prevention records, almost 300 persons died in the first week 

of 2005 in the city of Los Angeles. If verification information is available to 

Identification of deceased 

registrants 

Election Officials 

Identified Challenges 

to Verify Voter 

Registration Eligibility 
Page 23 GAO-05-478 Elections 

officials at all, then quality considerations become a factor, such as the 

timeliness, accuracy, and completeness of the data. Some challenges faced 

by election officials, particularly identifying duplicates in other 

jurisdictions within the state, may be reduced with the implementation of 

the HAVA-required statewide, computerized voter registration lists; but the 

data availability and quality considerations may continue to be issues. 

FEC reports have documented problems in maintaining accurate voter 

registration lists. The reports are mandated by Congress to document the 

impact of NVRA provisions, including provisions to ensure that voter lists 

are accurate by removing those who are no longer eligible.21 The number 

of states identifying problems has diminished since the NVRA was first 

implemented. The FEC reported in 1998 that officials in 26 states reported 

problems including duplicate registrations, inaccurate information for 

matching, and the difficulty of removing names without confirmation.22

The number of states identifying voter list maintenance challenges to FEC 

dropped from 26 in 1998 to 6 states in the 2001-2002 report, with the most 

commonly reported change being that states implemented or enhanced 

their computerized voter registration lists. 

Some of the concerns highlighted below remain problems for election 

officials and may not be addressed by a statewide voter list. Based on a 

national survey of local election officials, we reported in 200123 on the 

challenge of continually updating and deleting information from voter 

registration lists, and the concerns of election officials in obtaining 

accurate and timely information to keep voter lists accurate. 

Voter registration list maintenance challenges that were identified by 

officials in the seven states we visited, and in the prior reports are 

described below. 

 21Section 9 of the NVRA requires the FEC to report to Congress by June 30 of each oddnumbered year. A Report to the 108th Congress: The Impact of the National Voter 

Registration Act of 1993 on the Administration of Elections for Federal Office, 2001-2002, 

is the most recent report. HAVA transferred responsibility for the report to the EAC. 

22NVRA covers 44 states and the District of Columbia, according to DOJ. In the 1998 FEC 

survey, 43 of the 45 responded. The report was silent regarding whether similar issues 

existed beyond the 26 states’ reporting problems. 

23GAO, Elections: Perspectives on Activities and Challenges across the Nation, GAO-02-3

(Washington, D.C.: Oct. 15, 2001). 
Page 24 GAO-05-478 Elections 

• Deceased Persons: The timeliness of death data was a concern 

identified by state level election officials in all but Wisconsin and 

Arizona and by local election officials in three of the jurisdictions we 

visited.24 Concerns echoed many of the same issues raised in earlier 

reports. For example, Texas officials said that the health data they 

receive identifying deaths is about 3 to 4 months old, resulting in some 

deceased voters remaining on the voter registration list possibly 

through an election period. Another concern raised by a local Michigan 

official was the lack of birth dates on some state death records, 

resulting in difficulty identifying which voter of several with the same 

name actually passed away. Identifying deaths occurring outside of the 

state was a problem raised by election officials at the state and local 

levels in New York, and by local officials in one Arizona jurisdiction. 

Local New York officials said that when residents spend part of the 

year in other parts of the country and pass away there, they may not 

get a record of death in a timely manner. The 1998 FEC report 

highlighted this as an issue, noting the problem of identifying residents 

who die outside of the state or local jurisdiction because they may not 

be identified in vital statistics reports they receive.25

• Citizenship: The concern for election officials we spoke with regarding 

a registrant’s eligibility based on citizenship was the reliance on selfattestation. As stated by the FEC, the challenge for states is to develop 

procedures that maintain the integrity of the election process without 

penalizing the majority of applicants, who are law abiding citizens.26

Two types of standard sources of identification, such as a driver’s 

license, state identification or social security numbers are not useful 

because neither are evidence of citizenship. Other sources, such as a 

passport or birth certificate more clearly indicate citizenship. However, 

these sources may not be available, or conveniently at hand for all who 

would like to register to vote, according to a review by election 

officials in Philadelphia.27

 24Officials were asked in general terms about data considerations. We did not determine if 

the same issues existed in other jurisdictions if it was not mentioned. 

25Implementing the NVRA: A Report to State and Local Election Officials on Problems 

and Solutions Discovered 1995-1996., Federal Election Commission, March 1998, pp.5 -19. 

26Federal Election Commission March 1998, pp 5 - 25. 

27Administration of Voter Registration, Qualification of Applicants and Registrants 

Verification of Citizenship, March 2001, City Commissioner’s Office, Philadelphia County. 
Page 25 GAO-05-478 Elections 

• Criminal Information: Criminal information is often incomplete, not 

timely, or difficult to decipher. One state official and six local election 

officials we visited stated concerns about the timeliness or accuracy of 

the criminal information they receive for removing ineligible persons 

from the voter registration list. For example, New York officials said 

that the birth date on conviction notifications was sometimes not 

included, which meant there could be multiple matches on the same 

name. Wisconsin officials do not receive data from state courts on 

felony convictions, the state and local officials in one jurisdiction said. 

Lack of complete information is a concern that has been raised in 

jurisdictions outside the ones we visited. For example, a recent audit of 

the voter list in the City of St. Louis reported identifying over 900 

possible voting felons on the City’s voters list that were not identified 

by city election officials, primarily because the information they had to 

identify the felons was incomplete.28Auditors reported that a primary 

reason so many were not removed was that election officials only 

received conviction reports from the local court and not from other 

sources, such as the state or county. Other officials we interviewed 

stated that the information they did receive on felony convictions, 

particularly from federal sources, was not useful because it was old, 

had limited matching criteria, or was in different formats and hard to 

decipher. 

In addition to a need for more complete or useful information on 

convictions, it may be difficult for election officials to determine when 

a convicted felon is eligible to reregister. In five of the seven states we 

visited, and many others around the country, 29 felons may reregister 

after serving their sentence, which could include parole or probation if 

applicable under that state’s law. Arizona (for one felony conviction), 

California, New York, Texas, and Wisconsin officials cancel a voter’s 

registration based on court notification of a felony conviction, but 

officials noted that they relied on an applicant’s attestation of eligibility 

to reregister because no verification is required to document the 

 28Board of Election Commissioners, City of St. Louis., Office of the State Auditor of 

Missouri, May 26, 2004. Potential felons on the City of St. Louis voter list were identified by 

matching the voter list with convictions outside the City, based on matches of name, date 

of birth, and full or partial SSN where available. Auditors noted that each instance had to 

be investigated thoroughly before taking legal action or removing registrants from the voter 

list. 

29Felony Disenfranchisement Laws in the United States. The Sentencing Project, April 

2005, identifies 35 states where felons may reregister after the completion of their 

sentence. 
Page 26 GAO-05-478 Elections 

completion of a felon’s sentence. Arizona (for persons convicted of two 

or more felonies) and Virginia require that felons have their rights 

restored before they can register to vote—by a judge in Arizona after 

more than one felony conviction and by the Governor in Virginia. 

Arizona does not require proof of restoration. Virginia’s application 

asks specifically if voting rights have been restored and the date when 

they were restored. Arizona officials said they looked into the 

feasibility of the court system notifying the Secretary of State when 

someone was released from prison, completed probation, and paid any 

fine or restitution. However, all three events are not clearly defined 

according to these Arizona officials, and no workable solution was 

found. Michigan restores voting rights upon release from incarceration. 

• Duplicate Registrant: Officials in 7 of the 21 state and local election 

jurisdictions we spoke with had some concern with the timeliness or 

accuracy of the data they receive to identify duplicate registrants or 

verify registrants reside within the jurisdiction. The matching and 

validation of names are complex and made more so when considering 

aliases and name changes, as are matches such as “Margie L. Smith” 

with “Margaret Smith” according to a Wisconsin study.30 The study 

estimated that even a 1 percent error rate on a match validating names, 

driver license numbers, etc., could generate tens of thousands of bad 

matches. Officials from several states that do not have a statewide 

database noted that there was no way to identify duplicates outside 

their jurisdiction. New York state election officials said there is 

currently no way to systematically clear duplicates in the state. 

Officials rely on voters to identify if they have registered elsewhere. 

This problem was documented in the review of the City of St. Louis 

voter registration list, where auditors reported identifying about 13,600 

potential duplicates on voter lists in other election jurisdictions in 

Missouri.31 Followup would be needed to determine which registrations 

were actual duplicates. 

None of the officials we spoke with reported that they check for voter 

registration duplication in other states. Texas state election officials 

said they only received information from other states when the other 

state’s application asks where the person was previously registered, the 

 30Project Charter: Statewide Voter Registration System prepared for the Wisconsin State 

Election Board, May 15, 2003, by Virchow Krause and Company. 

31Office of the State Auditor of Missouri, May 26, 2004. 
Page 27 GAO-05-478 Elections 

person completes that portion of the form, and the information is 

forwarded to Texas. Texas does not forward information on new 

applicants from other states because the Texas application only asks 

for prior city and county in Texas. Local election officials in Arizona, 

Michigan, and Texas said they sometimes get reports of registrants 

relocating from other states. According to an EAC Commissioner in 

April 2005 (also the Chair for the EAC) making statewide voter 

registration systems compatible would be extremely costly, and HAVA 

does not address interactivity among states.32

• Residency of Registrants: Election officials we contacted identified a 

number of challenges to ensuring voter registrants reside within an 

election jurisdiction, including matching problems based on missing 

information or variation in how an address is listed, no street numbers 

in rural areas, new streets, redistricting, or untimely forwarding of new 

addresses. Officials in one local Arizona jurisdiction said residency 

issues are complex because not all the properties in the county have 

addresses. In one Wisconsin jurisdiction, election officials said they 

may not get notice for 4 or 5 months that a registrant within their 

jurisdiction has moved to another jurisdiction and, therefore, no longer 

meets the residency requirement (during this time the voter could also 

be registered twice). Michigan officials are considering using a 

Geographic Information System to improve their ability to identify and 

map eligible addresses for specific jurisdictions. Election officials 

reported to the FEC in 1998 and 2002 that the process required for 

removing registrants who have moved from the jurisdiction was a 

problem, for example, citing the cost of confirmation mailings and 

people not providing forwarding addresses.33 Furthermore, some state 

officials surveyed for our 2001 report stated that matches with the 

Postal Service’s NCOA or information from state motor vehicle 

agencies had potential drawbacks, such as the verification costs or 

incomplete information. For example, the NCOA files may not identify 

registrants who have moved if the voter did not submit a change of 

address form. In addition, according to some of these state officials, the 

names of ineligible registrants remained on the list because officials 

could not obtain verification required to remove them. 

 32EAC Commissioner and Chair Gracia Hillman, speaking at the Commission on Federal 

Election Reform hearing held on April 18, 2005, at American University, Washington, D.C. 

33Federal Election Commission, March 1998, pp.5 - 43; Federal Election Commission, 2001-

2002, pp.19 - 20. 
Page 28 GAO-05-478 Elections 

Four local election officials believed that self-certification is sufficient 

because of the penalties for falsely registering, or did not believe that 

ineligible voters were of concern. State and local election officials who 

we interviewed said that they have had few voter registration fraud34

allegations pertaining to eligibility requirements. Many of the 

jurisdictions we visited said that they have reported instances of voter 

registration fraud allegations to appropriate agencies for investigation. 

We contacted District Attorneys covering election jurisdictions in the 

seven states, and they reported that they prosecuted some cases 

related to ineligible registrants or voter fraud. For example, in 

California, a state with an investigative unit dedicated to voter fraud 

issues, 15 cases of the 108 allegations for fraudulent voter registration 

opened from January 2001 to May 2004 were sent to the District 

Attorney for prosecution. Of the 15 cases, the outcome had been 

determined in 11 cases (6 cases declined for prosecution, 5 were 

prosecuted and the individuals were convicted). In four cases, the 

outcome is yet to be determined. See appendix III for additional 

information on allegations of voter registration fraud. 

HAVA requirements for having a statewide voter registration list and 

matching with other state databases are expected to improve the 

accuracy of voter lists, particularly for identifying duplicates in other 

jurisdictions within the state. Election officials we spoke with for our 

2001 report and those we spoke with recently for this report stated that 

statewide voter lists helped in solving some accuracy problems. 

Michigan officials stated that when its statewide database was first 

created in 1998, over 600,000 duplicate voter registration records were 

eliminated. Arizona local officials said that their concerns about the 

timeliness and accuracy were less, now that state election officials 

managed the process through the statewide voter list. For example, 

state Vital Statistics data are received more frequently so that 

registrants who have died can be more quickly removed. For some 

jurisdictions, such as those in Wisconsin that do not receive death or 

felony information, the HAVA requirements to match the statewide 

voter list with state records on felons and death are to provide 

information not now available for removing ineligible registrants. 

 34Election fraud is conduct that corrupts the electoral processes for (1) registering voters; 

(2) obtaining, marking, or tabulating ballots; or (3) canvassing and certifying election 

results. Types of fraudulent conduct include, among others, voting by ineligibles, voting 

more than once, voter impersonation, intentional disruption of polling process either 

physically or by corrupting tabulating software, or destroying ballots or voter registrations. 
Page 29 GAO-05-478 Elections 

Some concerns, such as timeliness, accuracy, and completeness of the 

data used to match against voter lists, may continue to be issues, even 

after the HAVA requirements are fully implemented. For example, the 

1998 FEC report noted that states making good faith attempts to 

remove from the registry the names of persons no longer eligible to 

vote (e.g., deceased persons, ineligible felons, and those who have 

moved) are stymied when they receive inaccurate, incomplete, or outof-date information. These concerns might continue with the voter 

registration lists as, for example, Virginia officials stated that there is a 

3-month delay in receiving vital statistics data on deceased persons 

because that is how long it takes for processing. Virginia officials also 

identified a need for state standards for the exchange of information 

from state to state regarding voters who move from one state to 

another. 

Even in states with a statewide system for comparison, duplicate 

registrations can be added. As one local Michigan election official 

stated, if the system does not recognize that the registrant is already on 

the registration list, a new voter record is created. For example, Micky 

Jones and J. William Jones, Jr., might not be recognized as the same 

individual. A 2003 audit by the Michigan Office of the Auditor General 

identified approximately 24,000 potential duplicates in the state voter 

registration list, and about 10,000 registered voters with inaccurate 

birth dates. State agency officials attributed the duplicates as 

registrations that remain to be verified as the result of inaccurate or 

incomplete data received during the conversion of records to the state 

voter list in 1998, and the federal and state requirements that must be 

followed before records can be removed. Further, officials noted that 

tens of thousands of duplicates from voters moving within Michigan 

have been prevented by the voter registration system. 

In the seven states we visited, progress varied in carrying out HAVA 

requirements to (1) implement a computerized statewide voter registration 

list; (2) verify voter application information with state MVA or SSA records 

and (3) match the voter list with state records on deaths and felony 

convictions. Six of the seven states (except Arizona) applied for a waiver 

of these requirements until January 1, 2006. The six states that applied for 

a waiver said they plan to meet the 2006 requirements deadline; however, 

their progress varies. 

The Seven States Are 

in Different Phases of 

Implementing HAVA 

Statewide Voter 

Registration Lists and 

Eligibility Verification 

Requirements 
Page 30 GAO-05-478 Elections 

Arizona, which did not request a waiver, implemented a statewide voter 

list which became operational in December 2003, prior to the HAVA 

January 1, 2004, deadline. Of the six states visited that requested a waiver 

until 2006, Michigan had a statewide voter registration database, called the 

Qualified Voter File (QVF) that has been operational since 1998. According 

to a state election official, Michigan has about 90 percent of the changes in 

place to meet HAVA requirements. Still remaining is a change to match 

QVF data to SSA data. Contracts have been awarded for development of 

statewide computerized voter registration lists in Texas, Virginia, and 

Wisconsin, with completion by the January 1, 2006, deadline as part of the 

contracts. Virginia currently has a statewide database but is replacing it to 

be fully compliant with all state and federal laws governing voter 

registration and elections, according to the request for proposals for the 

new system. States are eligible to receive federal payments to meet HAVA 

requirements (which may be used to develop or modify a statewide voter 

registration list) after complying with certain requirements, such as filing a 

state plan and appropriating funds to match up to 5 percent of the federal 

funding the state would receive. Table 2 details selected activities that the 

six states are to implement related to the statewide voter registration list. 

Table 2: Selected Activities to Help Implement HAVA Voter Registration Requirements in Six States 

States we reviewed 

that requested waiver 

from HAVA 2004 

database deadline 

EAC approved HAVA 

state plan in fiscal 

year 2004 

State authorized 

“matching” funds to 

receive HAVA funding 

State issued request for 

proposal to develop 

computerized list 

State awarded contract 

(date of contract) 

CA Yes Yes To be determined To be determined 

MI Yes Yes Not applicable (there will be 

no request for proposal) 

Not applicable 

NY Yes Yes No No 

TX Yes Yes Yes Yes (Oct. 2004) 

VA Yes Yes Yes Yes (Mar. 2004) 

WI Yes Yes Yes Yes (Nov. 2004) 

Source: GAO analysis. 

The contracts in Texas, Virginia, and Wisconsin have been designed to 

help the states implement functions specified under HAVA for creating a 

unified statewide voter list, as well as other functions. For example, 

Virginia’s contract for a new system supports the conduct of elections as 

well as voter registration functions. Texas’ voter registration database is to 

include additional capabilities that can create jury summons, jury lists, and 

track jurors and jury payments. Wisconsin’s contract includes poll worker 

Computerized Voter 

Registration List 

Completion Closer in 

Some States Than Others 
Page 31 GAO-05-478 Elections 

management requirements, including for example, poll worker training 

information, certification level, and attendance. 

California may not meet the HAVA voter registration list deadline, 

according to the California State Auditor. A December 2004 state audit 

concluded that California is at risk of failing to meet certain HAVA 

requirements, for example, to provide a fully functioning statewide voter 

registration database by the HAVA deadline, and questioned the use of 

some HAVA funds.35 Based on the state report, the EAC initiated a special 

audit in January 2005 to investigate potential misuse of HAVA funds in 

California. 

California’s Final HAVA Plan36 identified a need to modify the existing 

statewide database or establish a new database to be in compliance with 

HAVA. The state issued a request for information in July 2004 to gather 

information on alternatives to replace the current statewide list “Calvoter” 

with a system that meets HAVA requirements. In late April 2005, the plan 

was to modify the Calvoter system rather than replace it. However, 

according to the state’s new HAVA Coordinator, as of May 11, 2005, the 

new Secretary of State is revisiting the earlier HAVA plans and evaluating 

the approach they will take in meeting HAVA compliance. The 

administrator said they realize there is a January 1, 2006, deadline, and the 

statewide database is a priority. 

In New York, legislation directing the creation of a statewide voter list was 

signed May 3, 2005. The next step, according to a state election office 

official, is to obtain consultant services to develop a request for proposal 

for a contractor to create the statewide voter list. The state board of 

elections is to establish rules and regulations needed for compliance by 

July 1, 2005. While state officials will give their best effort to meeting the 

January 1, 2006, deadline, it will be difficult, the official said. According to 

the legislation, New York’s voter list will be created by combining the 

existing voter lists maintained by each local board of election into a single 

integrated list, and the state will update it regularly. 

 35Office of the Secretary of State: Clear and Appropriate Direction Is Lacking in Its 

Implementation of the Federal Help America Vote Act, California State Auditor, December 

2004, report number 2004-139. 

36My Vote Counts, California’s Plan for Voting in the 21st Century,. Secretary of State, 

September 2003. 
Page 32 GAO-05-478 Elections 

HAVA requires that voter registration applicants for federal elections 

provide an identification number that can be matched with other records 

for verification.37 Applicants are to be asked for their state driver’s license 

or state identification number obtained through state MVAs, or (if an 

applicant does not provide either state number) the last 4 digits of their 

social security number for this purpose. An eligible applicant who does 

not have a state driver’s license, state identification card, or a social 

security card can still register to vote. In those cases, election officials are 

required to assign the registrant a unique identification number. Of the six 

states we reviewed that requested waivers, several have moved forward in 

arranging for verification of voter registration applicants with state MVA 

records. Election and MVA officials in Arizona, Michigan, and New York 

have agreements for voter registration applications to be verified with 

motor vehicle agency records. In Michigan, because both functions are 

under the Secretary of State, the agreement is between units within the 

Secretary of State’s office and has been in place since 1997. Arizona 

election officials and the state MVA agreed in June 2002 to verify 

information from voter registration applicants. Depending on how the 

Arizona county decides to proceed, the entire voter list or just information 

on new applicants is to be sent to the Secretary of State and matched with 

MVA records on a daily basis. The match is sent back to each county to 

resolve any discrepancies. Each record is to be given a code indicating the 

type of follow-up needed, if any, for that voter registrant. 

In fall 2004, election officials said that New York began matching voter 

registration applications under an interim process where counties send the 

information for verification to the MVA. According to these officials, when 

the statewide list is in operation the matching will be done by state 

officials, but the results will be sent to local election officials for resolving 

any discrepancies, as is the case now under the interim process. 

California’s HAVA Administrator said the connectivity of the statewide 

database with other state agency records was part of the strategy being 

considered by the Secretary of State. 

Texas, Virginia, and Wisconsin included matching with motor vehicle 

agency records as part of their database development contracts. Texas 

defines the validation of voter driver’s license numbers by the MVA as a 

 37HAVA section 303 (a)(5)(A). Section 303 (a)(5)(B) requires state election officials to 

verify the accuracy of the voter registration application information by matching it with the 

state motor vehicle agency database records. 

Progress to Verify Voter 

Applications with MVA Has 

Been Made in Most of the 

Seven States We Visited, 

but Verification Has Not 

yet Taken Place with SSA 
Page 33 GAO-05-478 Elections 

key feature of their new system. Virginia’s contract requires matching 

voter applicant information with the MVA records on a real-time basis. The 

MVA is 1 of 10 agencies that the Virginia system is to interface with. 

Wisconsin’s voter registration system contract requires the contractor to 

prepare a document describing the interface strategy for matching the 

voter registration list with other state agencies’ data. 

HAVA requires that MVAs enter into an agreement with SSA to match 

selected voter registrant information with SSA records when a voter 

registration applicant provides their 4-digit social security number for 

verification purposes. Of the seven states we reviewed, Virginia is not 

subject to this HAVA requirement because of a HAVA exemption for 

certain states such as Virginia that require applicants to provide their full 

social security number on their voter registration application, and the state 

can decide to use SSA’s online verification system.38 None of the remaining 

six states have signed agreements with the SSA to verify voter applicant 

information. An Arizona motor vehicle agency official said that they 

expect the agreement with SSA will be signed in June 2005,39 and the 

remaining five states requested a waiver from this requirement until 

January 2006. A Social Security administrator reported that, as of February 

2005, only Iowa and Idaho had signed agreements. 

To implement the HAVA verification requirement, SSA developed a new 

program using only 4 digits. This program—called the Help America Vote 

Verification program (HAVV)—receives voter registration “transactions” 

through an arrangement with the American Association of Motor Vehicle 

Administrators (AAMVA). All requests from states for voter registration 

verification are electronically sent to AAMVA, which then sends them to 

SSA.40 For each transaction, SSA compares a voter registration applicant’s 

name, date of birth, and last 4-digit social security number against SSA 

records. SSA records have a “death indicator” if SSA has been notified that 

 38Georgia, Hawaii, Kentucky, New Mexico, South Carolina, Tennessee, and Virginia require 

full social security numbers on voter registration applications and the state MVAs have 

existing agreements with SSA for verifying against SSA records using the complete number. 

The agreements would need to be modified to reflect use for voter registration verification 

purposes. 

39An Arizona Department of Transportation official said the agency computer programmers 

needed to implement the Memorandum of Understanding and are working on other 

projects that they expect will be available in June 2005. 

40With the exception of the covered U.S. territories, such as Guam and Puerto Rico, that do 

not have connections with AAMVA. 
Page 34 GAO-05-478 Elections 

the person with that social security number is deceased. Based on the 

match, a result code is assigned for the transaction, and the result is 

returned to AAMVA, which forwards results to state motor vehicle 

agencies who, in turn, provide the results to election officials. Only one of 

the codes indicates a one-to-one match between the voter registrant 

information and SSA records. However, six other codes may be generated 

for the registrant indicating some combination of multiple matches with 

the registrant or that the matching records indicate at least one of the 

matches is deceased. Figure 3 graphically describes the HAVV process. 
Page 35 GAO-05-478 Elections 

Figure 3: Process for Verifying Voter Registration Applicant Information with SSA 

SSA stated that there were too many variables to predict the number of 

SSA verifications that might be processed, but based on the numbers in 

Iowa, the only state to use HAVV as of February 2005, about 1 percent of 

applicants provided the 4-digit number. The HAVV verification service is 

for new voter registration applicants, not for voters already on state voter 

registration rolls. Of the 7,231 voter registration transactions sent to SSA 

by Iowa in 2004 for verification, 4,631 (64 percent) were returned as “one 

unique match-no death indicator present,” and another 14 transactions 

were “one unique match—death indicator.” No unique match was found 

for the remaining 2,586 transactions, according to SSA records. According 

Source: GAO analysis of SSA data.

Input

Code Code

Result

Social Security Administration

Records

Response 

1

Response 

2

Response 

3

Response 

4

Response 

5

Response 

6

Response 

7

Single match

Single match

deceased

Multiple matches

(some alive/

some deceased)

Multiple matches

(all deceased)

Multiple matches

(all alive)

No match

Did not process

State election 

office State motor 

vehicle agency

Voter 

registration 

application

American 

Association of 

Motor Vehicles

Administrators

CODECode

Registrant is 

either added to 

the voter list or 

more information 

is needed

Code generated

based on 

response 

(AAMVA) Code

Input

Vot

Applicant

er

Information

Input
Page 36 GAO-05-478 Elections 

to SSA, agency records and verification procedures are normally based on 

using the full 9-digit social security number. When that number is paired 

with specific individual information, the result is a unique match. With 

only the last 4 digits of the social security number, the match results may 

not be unique. Iowa officials said that the biggest problem they are facing 

is that SSA is not specifying what voter information was not matching, 

(i.e., was the mismatch in name, date of birth, or 4-digit social security 

number). Without this information they are not able to efficiently resolve 

the non-matching problems. An SSA official said that the HAVV system is 

not able to provide this detail. 

Most state election officials we spoke with were still determining the 

process they would follow when a voter registration sent to SSA (or to 

their MVA) for verification was returned with something other than one 

live match (e.g., several live matches or a death indicator for the match). 

In Iowa, the only state to have used the SSA verification system as of 

February 2005, officials said they first tried reentering the data with 

variations of the name and date of birth (i.e., Bill for William) and ensuring 

numbers that can be mistaken are correct. Iowa officials said that they 

send a letter to registrants asking them to clarify or come in and reregister. 

Arizona and Wisconsin said that a matching protocol still needed to be 

worked out, but any inconsistent or questionable matches would be 

resolved by local election officials. AAMVA officials and some of its 

members identified the variation in names as a factor in finding no match 

with SSA records. For example, the Virginia MVA representative said that 

when the MVA matched its entire driver’s license database with SSA using 

the full social security number, most of the 3 percent of mismatches were 

women who had registered using their married name but had not changed 

their name with the SSA. 

SSA is to be reimbursed by the states and territories required to verify 

voter applicants with SSA for certain HAVV costs, which could include, for 

example development, start-up, and maintenance, as well as for voter 

registration applicant verifications.41 HAVV development and start-up costs 

estimated by SSA are approximately $1.3 million, and yearly maintenance 

is estimated to be about $200,000. Development and ongoing costs are 

divided among the entities based on the proportionate share of national 

HAVA funds received by the state or territory. For verification, SSA’s 

current fee is $0.0062 per record. In addition, a fee for AAMVA services is 

 41 42 U.S.C. § 405(r). 
Page 37 GAO-05-478 Elections 

to be added by AAMVA. SSA estimated HAVV development reimbursement 

costs for Arizona, California, Michigan, New York, and Wisconsin to be 

approximately $25,000, $163,000, $49,000, $95,000, and $27,000, 

respectively. (States that collect full social security number for voter 

registration, including Virginia, are exempt from HAVV costs because they 

may take advantage of existing verification programs.) 

Election officials in four of the states we visited—Arizona, Michigan, New 

York, and Texas—foresaw no need to change their processes to meet 

HAVA requirements regarding identifying registrants who are deceased.42

State officials in all of these states but Wisconsin reported receiving State 

Vital Statistics information on deceased individuals for matching against 

voter lists. Arizona reported that the State Department of Health Services 

provides monthly death data via computer-to-computer match of records 

to the statewide voter database. Arizona, California, Michigan, New York, 

and Texas state officials said the vital statistics information is forwarded 

to each jurisdiction for verification. Virginia officials said that, once the 

new database is in place, there will be an automated interface with state 

vital statistics and with the SSA Death Master File (DMF). Jurisdictions in 

Michigan receive information on deceased individuals from the county and 

state vital statistics offices. 

In California and Wisconsin, officials reported that the match of state 

death records with the state voter registration list would be addressed 

when their statewide database was complete. California is still 

determining its strategy for database matching, according to a state 

official. Wisconsin’s request for proposal states that information from the 

state vital statistics office will be integrated using a system the state 

recently implemented for integrating state databases, but the details are to 

be defined with input from the vendor selected to develop the voter 

registration database. 

To identify ineligible registrants based on felon status, New York and 

Texas election officials said they already compare voter registration 

records and state information on felons. Michigan election officials said 

that they are in compliance because voting is restricted only for those who 

are incarcerated. Arizona election officials said they receive some felony 

 42HAVA requires the state to coordinate the computerized list with state agency records on 

felony status and death. 

Some States Already Meet 

HAVA Requirement to 

Match Registration List 

with State Records on 

Deceased Persons and 

Felons 
Page 38 GAO-05-478 Elections 

information in a paper format now and are working with the Arizona State 

Supreme Court to obtain information on felonies electronically on a 

weekly basis. Similarly, Virginia has an electronic matching component in 

its statewide voter registration database contract. Wisconsin officials told 

us that records of felony convictions are diffused among 17 different 

correctional databases with some in paper form. A state official said that 

the state has plans to create a single state prison database that would be 

matched against the state voter registration list, but the database might not 

be complete by January 1, 2006. An election official in California said that 

the connectivity of state databases with a state voter list is part of what is 

currently being considered in planning for the state list. 

Some federal data sources may help election officials identify ineligible 

registrants. Although the number of ineligible registrants may be small, 

identifying these ineligible voters may be important when an election is 

close. To assist in identifying ineligible felons, federal law requires U.S. 

Attorneys to notify state election officials of felony convictions in district 

courts. In the district courts serving the seven states we visited, 16 U.S. 

Attorney offices report sending notices to election officials and 3 offices 

reported that they were implementing or modifying their processes to 

provide this information on felony convictions in U.S. district courts. 

According to state and local election officials with whom we spoke in the 

seven states, federal felony information was not always provided in a 

standard format and the information was sometimes difficult to interpret, 

untimely, or incomplete. A second source to identify ineligible voter 

registrants could be the federal jury administrators. Although not required 

to share information with election officials, the jury administrators could 

help identify potential voter registrants who are non-citizens on the basis 

of information potential jurors provide when identifying themselves as 

non-citizens on their jury service questionnaire. Other federal data 

sources—DHS databases and SSA’s Death Master File—might identify 

additional ineligible voter registrants; however, the potential is limited 

because of difficulties such as matching information from these sources 

with voter registrant information. 

Information from 

Federal Sources 

Could Assist Election 

Officials in Identifying 

Ineligible Felons and 

Non-Citizens on Voter 

Registration Lists 
Page 39 GAO-05-478 Elections 

Under federal law,43 U.S. Attorneys are required to give written notice of 

felony convictions in federal district courts to the chief state election 

official of the offender’s state of residence upon conviction of the 

offender. The law also requires the state election officials to notify the 

election officials of the local jurisdiction in which an offender resides of 

federal felony convictions. In the year ending March 31, 2004, 74,642 

criminal defendants were convicted and sentenced in U.S. district courts. 

According to the U.S. Sentencing Commission, of the 69,023 federal 

offenders for whom sentencing data were available, 59,554 were sentenced 

to prison in fiscal year 2003. 

The U.S. Attorney notification to state officials is required to include 

• the name of the offender, 

• the offender’s age and residence address, 

• the date of entry of the judgment, 

• a description of the offenses of which the offender was convicted, and 

• the sentence imposed by the court. 

EOUSA provided us information on how 19 U.S. Attorneys’ offices in the 

seven states we visited were implementing the law, which became 

effective in 1993. Sixteen of the offices reported that they were sending 

notices of certain felony convictions in U.S. district courts to state election 

officials. Officials in three U.S. Attorneys’ offices reported that they were 

implementing or modifying their processes to provide this information on 

felony convictions in U.S. district courts. According to an EOUSA official, 

one U.S. Attorneys’ office expects to have a fully functioning notification 

system in place in the future but no specific time frame was provided. A 

second U.S. Attorneys’ office is instituting a policy to consistently provide 

conviction data, according to EOUSA. In the third U.S. Attorneys’ office, 

EOUSA said the support staff person assigned to each felony case will email required information to the state election official. This U.S. Attorneys’ 

office reported to EOUSA that it has modified the criminal case intake 

form to include the defendant’s state of residence to help ensure that the 

information is available upon conviction. The same office also reported 

that it is now working on new quality control procedures for case 

management data. When completed, a list of felons is to be created and 

 43 42 U.S.C. § 1973gg-6(g). This provision was enacted into law in 1993 in section 8 of the 

National Voter Registration Act. 

U.S. Attorneys Are 

Required to Provide 

Information on Felons 

Convicted in Federal Court 

to Election Officials but 

Have Not Done So 

Consistently 
Page 40 GAO-05-478 Elections 

felony conviction notices are to be sent to state election officials. In all of 

the above cases no timeframe for implementation was provided. 

The law does not require standardized formats or time frames for 

reporting the federal felony conviction data. In the 16 U.S. Attorneys’ 

offices that reported sending notices to state election officials, when the 

information was sent varied, for example monthly, bi-weekly (when there 

are a significant number of convictions to report), bi-monthly, quarterly, 

several times a year, upon receipt of the judgment and commitment order, 

and 6 months from the date of sentencing or later if the case is on appeal, 

according to these U.S. Attorney’s office officials. What information was 

sent to election officials also varied (the judgment and commitment order 

or the judgment and commitment order with a notification letter) as did 

the process. For example: 

• The designated paralegal prepares a monthly printout of the required 

information, which is forwarded to the responsible assistant U.S. 

Attorney to produce and send the information to the appropriate state 

officials. 

• The supervisory legal assistant collects judgment and commitment 

orders and mails them to the appropriate state agency. 

• The judgment and commitment order is copied and then routed to the 

first assistant U.S. Attorney, who reviews the order and then sends it to 

the secretary to the U.S. Attorney. The secretary forwards the judgment 

and commitment order directly to the election board of the secretary of 

state. 

• The judgment and commitment orders are collated by month of 

imposition, sorted for approximately 6 months, and then compared to 

the appellate docket to determine whether a defendant has appealed. If 

the defendant has appealed, the judgment and commitment order is 

retained and periodically checked to determine the outcome of the 

appeal. If there is no appeal or when the appellate process is 

completed, the judgment and commitment order is sent to the state 

election authority for the state the defendant claims as his or her last 

residence. 

State and local election officials in 7 of the 14 jurisdictions we visited told 

us that they had concerns about the timeliness or accuracy of the federal 

felony conviction notices they received. Election officials told us that 

notices are not easy for them to use, such as determining the length of 
Page 41 GAO-05-478 Elections 

sentence. They also said birth dates on records were sometimes missing, 

which can lead to multiple matches on the same name. 

Jurors must be U.S. citizens to serve on a jury in U.S. district court. The 

federal jury administrators we surveyed by phone in all 14 U.S. court 

districts that cover the local election jurisdictions we visited asked about 

citizenship status on questionnaires sent to prospective jurors.44 Figure 4 

provides an example of a juror qualification questionnaire from the 

Eastern District of Virginia. 

Figure 4: Federal Jury Qualification Questionnaire Requests Citizenship 

Information 

All of the jury administrators45 for the U.S. district courts told us they use 

voter registration lists to draw names for the jury pool. Ten of the 14 

 44County courts commonly used the term jury services to describe the officials responsible 

for jury selection, whereas U.S. district courts generally used the term jury administrators 

to describe the officials responsible for the juries, according to AOUSC officials. For the 

purposes of the report, we will use the term county jury administrators for county 

jurisdictions and federal jury administrators for the federal court system. 

45Potential jurors for a U.S. district court are chosen by jury administrators in each of the 

94 district courts from a jury pool generated by random selection of citizens’ names from 

lists of registered voters, or combined lists of voters and people with drivers’ licenses, in 

the judicial districts. The potential jurors complete questionnaires to help determine 

whether they are qualified to serve on a jury. U.S. citizenship is a qualification to be a juror. 

Federal Jury 

Administrators in the U.S. 

District Courts Have 

Information about NonCitizens Taken from Voter 

Registration Lists That 

Could Be Shared with 

Election Officials 

Source: U.S. District Court, Eastern District of Virginia.

Federal data sources have 

the potential to help state 

election officials ensure that 

voter lists are accurate by 

identifying registrants who 

may be non-citizens
Page 42 GAO-05-478 Elections 

district court administrators said they use only voter registration lists, 

while the other 4 use voter lists in conjunction with other sources.46

According to officials of the AOUSC, it would be under penalty of perjury 

to deliberately make false statements about citizenship on the 

questionnaire, although the extent to which the matter is pursued is up to 

each U.S. district court. Generally, districts we surveyed did not verify 

claims of non-citizenship; however, two districts verified prospective juror 

claims of non-citizenship. The Eastern District of Virginia called 

prospective jurors to gather verbal confirmation of citizenship status and 

the Eastern District of Michigan requires that immigration documentation 

be provided to verify non-citizen status. 

AOUSC officials and federal jury administrators we spoke with generally 

did not have exact data on the number of people called for jury service 

that responded that they were non-citizens. Consequently, no information 

was available from federal jury administrators in six U.S. district courts, 

but federal jury administrators in eight U.S. district courts provided either 

exact numbers or estimates. Of the eight district courts, four federal jury 

administrators said no one had been disqualified from jury service because 

they were not U.S. citizens. In the other four district courts: 

• a federal jury administrator in one U.S. district court estimated that 1 to 

3 percent of the people out of a jury pool of 30,000 over 2 years (about 

300 to 900 people) said they were not U.S. citizens; 

• a federal jury administrator in a second U.S. district court estimated 

that less than 1 percent of the people out of a jury pool of 35,000 names 

each month (less than 350 people) said they were not U.S. citizens; 

• a federal jury administrator in a third U.S. district court estimated that 

about 150 people out of a jury pool of 95,000 names over 2 years said 

they were not U.S. citizens; and 

 46Of the remaining courts, three use both voter registration lists and MVA records. One uses 

voter registration, MVA, and state identification records. Officials in each of the four 

federal district courts that use more than one source for selecting jurors stated that they 

can identify from which source(s) a name is drawn. As currently configured, the jury pool 

lists do not specify sources, therefore, to determine whether a name was taken from a 

particular source, such as the voter registration list, would require manually comparing the 

jury pool list to each source. 
Page 43 GAO-05-478 Elections 

• a federal jury administrator in a fourth U.S. district court estimated that 

annually about 5 people typically claimed non-citizenship in a jury pool 

of about 50,000 individuals. 

Of the 14 U.S. district courts contacted, only the jury administrator for the 

Eastern District of Virginia provided feedback to voter registration 

authorities if a prospective juror claimed not to be a U.S. citizen. Of the 13 

U.S. district courts that do not currently provide feedback, none planned 

to do so in the future. However, the federal jury administrators’ opinions 

on the feasibility of providing this form of feedback were mixed. For 

example, 7 of the 11 district officials who commented on feasibility 

indicated that providing feedback to election officials regarding noncitizens is currently possible while 4 other federal jury administrators 

claimed the responsibility would be difficult due to staffing resource 

constraints. According to an AOUSC official, there is no Judicial 

Conference47 policy that instructs the courts to notify election officials 

when it is determined that a potential juror is not a U.S. citizen. 

At the county level, some county jury administrators share information 

with election officials about people who ask to be excused from jury 

service because they are not U.S. citizens. Jurors for county courts are 

also drawn from a variety of sources, sometimes including voter 

registration lists. Other sources county officials cited for their jury pools 

included state drivers’ licenses, state identification cards, social services 

department information, employment department information, and state 

tax rolls. Similar to federal district courts, county jury administrators 

determine if a person qualifies for jury service based on citizenship by 

specifically asking on a form if the person is a citizen. Jury officials in 

three county court jurisdictions in New York and Texas require people 

who claim non-citizenship to furnish proof in the form of immigration 

documents. One of those jurisdictions will allow a notarized statement in 

lieu of immigration papers, and another jurisdiction would accept a letter 

from an immigration attorney. 

 47The fundamental purpose of the Judicial Conference is to make policy with regard to the 

administration of the U.S. courts. The Director of AOUSC implements the policies of the 

Judicial Conference as part of the performance of his duties as the administrative officer of 

the courts of the United States. 
Page 44 GAO-05-478 Elections 

Of the 10 locations we visited where county jury administrators48 draw the 

names of potential jurors from a pool that includes names taken from 

voter registration lists, five county jury administrators said they provided 

feedback to election officials when a potential juror claimed not to be a 

citizen as a reason to be excused from jury duty. With respect to county 

jury administrators who use more than one source for their jury pool, one 

county jury administrator said that she could not determine if the potential 

juror was drawn from the voter registration list or the other sources used 

for selection, and therefore could not provide feedback. However, a 

county jury administrator for another county court in the same state that 

also used multiple sources for the jury pool said they provide feedback to 

election officials on all people who claim non-citizenship as a reason to be 

excused from jury duty. 

In one local election jurisdiction that receives feedback from county jury 

administrators, election officials estimated that they have removed about 

500 people who were self-identified as non-citizens during jury selection 

from the voter registration lists since 2000. This jurisdiction had 889,000 

registrants in 2004. For example, during 2003, the county jury 

administrator for this jurisdiction had 1,693 people ask to be excused from 

jury duty because they were not citizens. Of those, election officials sent 

letters requesting documentation of citizenship to 413 people. As a result 

of the process, they removed 83 people who were identified as noncitizens from the voter registration lists. Other examples include: 

• A county jury administrator for one county court estimated they 

annually refer to election officials about 2,000 names of jurors who 

identified themselves as non-citizens to be excused from jury duty. The 

election officials in this jurisdiction said that they remove about 400 to 

500 names a year from the voter registration list because the registrants 

are not citizens (out of between 3 and 4 million registrants). 

• In another county court, a county jury administrator estimated that, 

annually, about 5 people at most who were drawn from the voter 

registration lists (which includes about 130,000 registrants in 

November 2004) claim non-citizenship as a reason to be excused from 

jury duty. 

 48Jury services officials in the other four court jurisdictions in two states—Michigan and 

Wisconsin—said that the jury pool is drawn only from their state’s department of motor 

vehicles driver’s licenses and state identification cards, and they do not use voter 

registration lists. 
Page 45 GAO-05-478 Elections 

In one jurisdiction, election officials receiving jury service information 

commented that they must follow up on each referral, and sometimes 

people may have wrongly claimed non-citizenship in order to be excused 

from jury duty. Election officials will generally mail a notification to the 

registrant asking them to verify the information to remain on the voter 

registration list. Those who do not reply are removed. Non-response on 

the part of a registrant does not necessarily mean that they are not 

citizens. 

Federal law provides a statutory framework that requires non-citizens 

entering or residing in the United States to provide certain identification 

information. This information was historically provided to the Immigration 

and Naturalization Service (INS), which when abolished, had its functions 

transferred to various components within DHS on March 1, 2003. DHS 

maintains multiple databases containing information on non-citizens 

within its component agencies: the U.S. Citizenship and Immigration 

Service, the U.S. Immigration and Customs Enforcement, and the U.S. 

Customs and Border Protection. Appendix II shows examples of the 

databases identified by DHS officials. 

DHS officials said that the usefulness of their information to identify noncitizens on voter registration lists may be limited because of system 

constraints for commonly used data matching identifiers (such as name, 

birth date, address, social security number, and alien number) that are 

needed for a match and the need for law enforcement to verify the 

information. For example, the matching of databases may not always be 

reliable because matching on names alone may produce multiple matches 

on the same name, depending on whether there is middle initial, middle 

name, or simply the same common name. As an example of restrictions on 

usage for data matching identifiers, DHS officials said that address 

information on non-citizens in some DHS databases, which these officials 

believe is important for voter registration, was not always reliable in the 

databases because it was self-reported information and would require 

verification. We recently reported on the limited usefulness of selfreported address information by non-citizens in some DHS databases.49 We 

reported that 16 of 17 Immigration and Customs Enforcement agents 

interviewed did not use the change of address data in one of the DHS 

 49GAO, Alien Registration: Usefulness of a Nonimmigrant Alien Annual Address 

Reporting Requirement Is Questionable, GAO-05-204 (Washington, D.C.: January 2005). 

DHS Databases Contain 

Selected Information on 

Non-Citizens, but the 

Usefulness May Be Limited 
Page 46 GAO-05-478 Elections 

databases to help locate the non-citizens as part of their investigations 

because the agents said that the change of address information, which is 

self-reported data, is often unreliable. 

We identified two instances where DHS databases were used to help 

identify non-citizens for voter eligibility purposes. In the first instance, in 

the late 1990s, DHS officials noted that a match was performed between 

information on non-citizens in then INS files and voter registration records 

at the request of a House Committee that oversaw the results of a 

California congressional election being contested. The data-matching 

effort sometimes produced multiple name matches in INS databases for a 

single name from the voter registration list. For example, in 

documentation of the California matching effort, 1 name from the voter 

registration list matched with 44 names in the INS databases. According to 

DHS officials, the effort to investigate those matches was extremely labor 

intensive and required immigration officials to manually pull non-citizen 

records from around the world to determine the identity of the individual 

from the match. DHS officials said the initial matching of the database was 

unreliable because of the lack of common data identifiers, usually only 

name and date of birth, and the accuracy of those identifiers. Common 

names were especially problematic in producing multiple matches on the 

same name. Address information, which DHS officials believe is important 

for voter registration, was not always reliable in the databases on noncitizens, as mentioned previously. 

In the second instance, California state election officials said that they 

tried a database-sharing pilot program with INS in the mid-1990s to 

investigate allegations of ineligible voters. At the time, the state election 

officials said that INS officials advised them that their data might not be 

reliable for their purposes. In a letter to the House Chairman regarding the 

matching of voter registration information and INS data, the INS 

Commissioner wrote that the data sharing was by names and date of birth, 

and there would be no match if the person’s name on the state voter 

registration rolls is different that what it is in the INS system. In addition, 

the INS Commissioner wrote that a match does not necessarily mean the 

person is not eligible to vote. According to California state election 

officials, their experience confirmed that indeed the reliability of the data 

was poor for their purposes and that they could not use them. 

While matching of voter registration lists with DHS databases could be 

problematic, the California Secretary of State’s office has been exploring 

the possibility of using the DHS Systematic Alien Verification for 

Entitlements (SAVE) program to pursue specific allegations of voter 
Page 47 GAO-05-478 Elections 

ineligibility. The SAVE Program was developed to allow federal, state, and 

local government agencies to obtain information they need on immigration 

status in order to determine an applicant’s or recipient’s eligibility for 

many public benefits. The SAVE Program also administers an employment 

verification pilot program, in cooperation with SSA, to help employers 

verify the work authorization of their newly hired employees. As proposed 

by the California Secretary of State, the use of SAVE would involve 

querying individual voter names on the basis of specific allegations or 

challenges that a registered voter was a non-citizen. This proposal does 

not involve matching entire voter registration lists with DHS databases. 

SAVE is more inclusive than other databases (containing over 60 million 

alien records) and could provide election officials the means to identify 

some non-citizens; however, according to DHS officials, it has limitations. 

For example, DHS officials said that the SAVE Program is set up to query 

information based on the number on the alien’s Arrival and Departure 

Record form (I-94) or an alien’s DHS assigned “A” number. It is a webbased system, and records are normally queried one at a time, although 

processing multiple records using the SAVE program is possible. Because 

voter registration is limited to U.S. citizens, voter registration records 

would not contain alien or form I-94 numbers. The SAVE Program can be 

queried by a social security number, name, and date of birth if the alien’s 

“A” number or I-94 number are unknown. However, DHS officials 

emphasized that the system is alien-number-driven. Also, DHS officials 

opined that using the SAVE Program would require additional verification 

of the person’s identity, either automated or manual, as a precautionary 

measure before removing a person from a voter registration list based on a 

match. 

To facilitate investigations of alleged non-citizens having registered to 

vote, the California Secretary of State’s Office has proposed accessing the 

SAVE Program. An official in the State’s Election Fraud Investigation Unit 

saw this as a time- and effort-saving tool. Rather than contacting a DHS 

agent to obtain information and waiting for a response that, according to 

this official, sometimes could be months in coming, the unit could make 

direct queries through the SAVE Program. DHS has provided the California 

Secretary of State with a memorandum of understanding to allow this 

process to proceed, but as of February 2005, California officials said that 

the Secretary of State had not signed the memorandum. 
Page 48 GAO-05-478 Elections 

The DMF consolidates death records across the country and potentially 

could be used by election officials to identify voters on their registration 

lists that died in another state.50 While about 2.7 million people die in the 

United States each year and about 2 million are SSA beneficiaries, 

matching difficulties and the timeliness and completeness of the data may 

lessen DMF’s usefulness to election officials. 

Matching voter registration records with DMF records requires that the 

sets of records contain at least some of the same identifiers for an 

individual. The social security number is the primary way to identify a 

unique individual in SSA’s databases, but only seven states allow the full 

social security number to be collected for voter registration purposes. One 

of the states we visited (Virginia) collects the 9-digit social security 

number as part of the voter registration application, and election officials 

there said that they plan to use the DMF for verification when the 

statewide, computerized voter registration list has been developed. Even 

without the full social security number, matching can still be done with 

other identifiers in the DMF, such as name, date of birth, or address, but 

problems, such as people using different names for voter registration than 

on social security records, currency of addresses, and the number of 

people on a national basis with similar names, may make matching 

difficult. One study51 of the DMF suggested that without a correct social 

security number, researchers would need to consult other sources of 

mortality information. 

Timeliness and completeness may also lessen the usefulness of the DMF 

for identifying deceased voter registrants. According to a 2001 SSA Office 

of the Inspector General (OIG) report, some states had been taking over 

200 days to report.52 SSA officials told us that the information is untimely 

for a number of reasons, such as manual recordkeeping or outdated 

computer systems at the state level. Under SSA’s ongoing Electronic Death 

Registration initiative, SSA plans to receive death reports within 5 days of 

 50The DMF contains over 76 million records of deceased individuals enrolled in the U.S. 

Social Security program. For an individual, the DMF record can contain the person’s social 

security number, name, date of birth, date of death, state or county and zip code of last 

payment residence, and zip code for the lump sum payment, if the information is available. 

51Use of the Social Security Administration Death Master File for Ascertainment of 

Mortality Status Population Health Metrics: 2004; 2:2,. March 5, 2004. 

52Effectiveness of the Social Security Administration’s Death Termination Process (A-09-02-

22023), September 2001. State and federal sources supply some death information to SSA, 

but most deaths are reported to SSA by friends, relatives, and funeral homes. 

Use of SSA Database to 

Identify Deceased 

Registrants Has Matching 

and Timeliness Limitations 
Page 49 GAO-05-478 Elections 

death. SSA estimates the initiative will be complete in 2012, but recent 

federal legislation may provide grants for computerizing state records that 

could affect SSA’s ability to meet the completion date sooner. In addition 

to timeliness considerations, a 2003 OIG report stated that the 

completeness of the DMF is not consistent, citing research indicating 

younger deceased persons were less likely to be included.53 The OIG report 

further stated that the DMF does not contain every decease social security 

number holder and also includes individuals who are not actually 

deceased. 

State and local election officials face many challenges in maintaining 

accurate voter registration records. Because voter registration lists are 

dynamic and constantly changing, officials turn to a variety of sources to 

identify registrants who may be ineligible to vote. HAVA included 

provisions directed at maintaining accurate voter registration lists that 

included, among other things, requirements for states to develop a 

computerized, interactive statewide voter registration list and to match 

that list against other state databases and records. However, after 

provisions are implemented, states will continue to face challenges to 

maintain accurate voter registration lists and verifying voter eligibility, 

particularly identifying out-of-state registration duplicates and deceased 

registrants. Thus, the effect of HAVA’s voter registration reform initiatives 

is yet to be determined. 

Election officials we contacted in seven selected states noted that they 

experienced specific problems verifying voter registration application 

information related to felony convictions and citizenship status. We found 

two federal information sources that could provide election officials 

information on federal felony convictions or citizenship status 

requirements. The number of potentially ineligible voter registrants 

identified by these two federal sources may be small but could be 

important in determining the outcome of a close election. One, the U.S. 

Attorneys, is already required to provide state election officials with 

information about felony convictions, but the information could be 

provided in a more standardized format to ensure that the information is 

easier for election officials to interpret and more complete and timely. 

 53The Social Security Administration’s Efforts to Process Death Reports and Improve its 

Death Master File, January 2003, Office of the Inspector General, Social Security 

Administration. 

Conclusions 
Page 50 GAO-05-478 Elections 

The second information source that could help identify potential ineligible 

voters is federal jury administrators. Although not required to share 

information with election officials, the jury administrators could help 

identify potential voter registrants who are non-citizens on the basis of 

information potential jurors provide when identifying themselves as noncitizens on their jury service questionnaire. 

To assist state election officials in identifying individuals on voter 

registration lists who may be ineligible to vote because of their felon or 

non-citizen status, we are recommending the following two actions: 

We recommend that the Attorney General direct the U.S. Attorneys to 

provide information on felony convictions in U.S. district courts in a more 

standardized format to make it easier for election officials to interpret the 

conviction information, such as the length of the sentence, and to help 

ensure information on felons is complete and timely. 

We recommend that the Administrative Office of the U.S. Courts 

determine the feasibility and steps necessary to implement a requirement 

that U.S. district court jury administrators provide notice to state election 

officials of potential jurors who identify themselves as non-citizens on 

their jury qualification questionnaire. 

We provided a draft of this report to DOJ and AOUSC for review and 

comment. The Director of EOUSA in her comments agreed with our 

recommendation. She acknowledged that maintaining accurate voter lists 

is an important goal and that an EOUSA working group has been tasked to 

develop a standardized process for the 94 U.S. Attorneys’ Offices to send 

felony conviction information in the best format for use by state election 

officials. AOUSC’s Director agreed with our recommendation and stated 

that this matter would be brought to the attention of district courts. 

Despite resource shortages in the federal courts and the fact that most 

juror are screened by local and state courts, the AOUSC Director 

acknowledged the public interest in ensuring that non-citizens are not 

afforded the privilege of voting. Written comments from AOUSC and DOJ 

are included in appendices IV and V. Sections of the report were also 

provided to SSA, DHS, and states we visited to confirm the accuracy of the 

information. Technical comments from the federal agencies and states 

that we reviewed were incorporated, as appropriate, in the report. 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 
Page 51 GAO-05-478 Elections 

As we agreed with your office, unless you publicly announce the contents 

of this report earlier, we plan no further distribution of it until 30 days 

from the date of this letter. We then plan to provide copies of this report to 

the Attorney General, Department of Justice; Director, Administrative 

Office of U.S. Courts; Ranking Minority Members, House Committee on 

the Judiciary and Subcommittee on Immigration, Border Security and 

Claims; Chairman and Ranking Minority Member, Senate Committee 

Homeland Security and Governmental Affairs; Chairman and Ranking 

Minority Member, House Committee on Government Reform; Chairman 

and Ranking Minority Member, Senate Committee on Rules and 

Administration; and Chairman and Ranking Minority Member, House 

Committee on House Administration. Copies of this report will also be 

made available to others upon request. In addition, this report will be 

available at no charge on GAO’s Web site at http://www.gao.gov. 

If you or your staffs have any questions about this report, please contact 

me on (202) 512-8777 or at jenkinswo@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 contributing to this report are listed in 

appendix VI. 

William O. Jenkins, Jr. 

Director, Homeland Security and Justice Issues 
Appendix I: Objectives, Scope, and 

Methodology 

Page 52 GAO-05-478 Elections 

Our objectives were to describe: (1) the processes in selected states to 

verify that voter registration applicants met state eligibility criteria and to 

help ensure that voter registration lists are accurate; (2) the challenges 

officials face in maintaining voter lists; (3) the implementation status of 

the Help America Vote Act of 2002 (HAVA) voter registration verification 

procedures in selected states; and (4) potential data sources for verifying 

voter registration eligibility. 

We selected the following states using a non-probability sample: Arizona, 

California, Michigan, New York, Texas, Virginia, and Wisconsin. Our 

selection of states took into consideration several voter registrationrelated factors. We sought to select states that represented differences in 

terms of the stage of development of their statewide databases and had 

unique characteristics that might affect the implementation of HAVA. For 

example, Wisconsin has same day registration; Arizona has on-line voter 

registration; Michigan has a reputation as a model for registration 

practices; and New York State may have to rely on social security number 

verification procedures more than other states because it has a large 

population who live in New York City and may not have driver’s licenses 

for verification. We also selected states to provide geographic diversity 

and variation in election administration—some administer elections at the 

county level and others at lower levels such as city or townships. States 

also varied in the size of the immigrant populations, of interest because of 

the citizenship requirement for voter registration. Our goal was not to 

target a particular state, but rather to identify a range of issues facing 

states in implementing HAVA requirements and assuring accurate voter 

registration lists. Information from these seven states is not generalizable 

to all states. Table 3 describes characteristics in each state. 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology 

Page 53 GAO-05-478 Elections 

Table 3: State Selection Factors 

State Voter registration-related characteristics 

Arizona • No statewide database prior to HAVA. 

• Did not request a waiver from HAVA database and verification requirements deadline of January 1, 2004. 

• Census 2000 percent of population foreign born: 12.8. 

• Voter registration administered at county level. 

• Has implemented an on-line voter registration process. 

California • Statewide database prior to HAVA that is compiled from local election lists. Local jurisdictions can access entire 

list. 

• Requested a waiver from HAVA database and verification requirements deadline of January 1, 2004. 

• Census 2000 percent of population foreign born: 26.2. 

• Voter registration administered at county level. 

Michigan • Unified statewide database. 

• Requested a waiver from HAVA database and verification requirements deadline of January 1, 2004. 

• Census 2000 percent of population foreign born: 5.3. 

• Voter registration administered at township, city, and village level. 

• Secretary of State responsible for election and motor vehicle licensing functions. 

New York • No statewide database prior to HAVA. 

• Requested a waiver from HAVA database and verification requirements deadline of January 1, 2004. 

• Census 2000 percent of population foreign born: 20.4. 

• Voter registration administered at county level. 

• Expected higher use of social security records for registrant verification due to fewer drivers in New York City. 

Texas • Statewide database prior to HAVA that is compiled from local election lists. Local jurisdictions do not have access 

to entire list. 

• Requested a waiver from HAVA database and verification requirements deadline of January 1, 2004. 

• Census 2000 percent of population foreign born: 13.9. 

• Voter registration administered at county level. 

Virginia • Unified statewide database. 

• Requested a waiver from HAVA database and verification requirements deadline of January 1, 2004. 

• Census 2000 percent of population foreign born: 8.1. 

• Voter registration administered at county level. 

• May use 9-digit social security number for voter registration verification (rather than 4 digits outlined by HAVA). 

Wisconsin • No statewide database prior to HAVA. Some jurisdictions currently do not maintain voter registration rolls. 

• Requested a waiver from HAVA database and verification requirements deadline of January 1, 2004. 

• Census 2000 percent of population foreign born: 3.6. 

• Voter registration administered at municipal level. 

• Allows Election Day voter registration. 

Source: GAO. 
Appendix I: Objectives, Scope, and 

Methodology 

Page 54 GAO-05-478 Elections 

Within each state, we selected two local jurisdictions using a 

nonprobability sample. Our selection criteria included population size, the 

proximity of the locations to our site visits with state election officials, 

suggestions by state election officials, and proximity to a motor vehicle 

office. Local jurisdictions included 

• Mariposa County, Arizona; 

• Gila County, Arizona; 

• Los Angeles County, California; 

• Yolo County, California; 

• Detroit, Michigan; 

• Delta Township, Michigan; 

• New York City, New York; 

• Rensselaer County, New York; 

• Bexar County, Texas; 

• Webb County, Texas; 

• Arlington County, Virginia; 

• Albemarle County, Virginia; 

• Madison, Wisconsin; and 

• Franklin City, Wisconsin. 

To describe state voter registration processes and challenges (objectives 1 

and 2), we conducted semi-structured on-site interviews with state and 

local election officials, and supplemented the interviews with phone and 

email updates. We are relying on testimonial evidence because most states 

(all but Arizona in our sample) obtained an extension for implementing 

HAVA and, therefore, data were not available to assess the status of 

implementation. Our interviews included questions on registration 

processes, any voter registration fraud allegations, and discussion of 

challenges identified by officials in maintaining voter roll accuracy. 

Because so many voter registrations originate with applications from 

motor vehicle agencies, interviews were conducted with motor vehicle 

agency officials in the same jurisdictions regarding their voter registration 

procedures. In Michigan, where we spoke only with Secretary of State 

officials, the Secretary of State’s office is responsible for elections and 

driver’s licenses. We also reviewed current HAVA plans, relevant reports, 

and documents related to the voter registration process in seven states. 

State level election officials were provided an opportunity to verify the 

accuracy of information regarding their particular state. All but one state 

responded. 
Appendix I: Objectives, Scope, and 

Methodology 

Page 55 GAO-05-478 Elections 

In addition to asking state election officials about allegations of voter 

registration fraud, we interviewed Department of Justice (DOJ) Criminal 

Division officials, and obtained a list of election fraud active matters from 

2002-2004, filed by U.S. Attorneys and Public Integrity section attorneys 

(the section that handles election issues within DOJ). We also contacted 

U.S. Attorneys responsible for the states we reviewed for any additional 

cases handled locally by those offices. We contacted District Attorneys in 

the counties for the local election districts we visited and asked for 

information regarding actions related to ineligible voter registration. We 

also asked state and local election officials if they had referred any 

reported incidents of voter registration fraud or irregularities to county, 

state, or federal officials since January 2003. District attorney and state 

and local election official reports of fraud related to voter registration 

were based on the recall of the officials, except in California, where the 

state fraud unit routinely catalogs allegations and their disposition. 

To describe the HAVA implementation status in the seven states 

(objective 3), we reviewed HAVA plans to develop a statewide voter 

registration database and to verify voter registration lists against motor 

vehicle agency and Social Security Administration records. We also 

included questions on the status of the database and verification 

procedures in the semi-structured interviews with state and local election, 

and state motor vehicle officials. We interviewed and obtained documents 

from the Social Security Administration on how that agency was 

addressing HAVA verification requirements. 

To identify potential data sources for verifying voter registration eligibility 

(objective 4), we reviewed and summarized sources currently used for 

verification in the selected states and localities, and discussed potential 

verification sources with state and local election officials. 

We then gathered additional information on the forwarding of federal 

felony convictions to state election officials from the Executive Office for 

U.S. Attorneys. We requested information from the 19 U.S. Attorney 

Offices corresponding to the seven selected states—Arizona, California, 

Michigan, New York, Texas, Virginia, and Wisconsin—we visited. The 19 

U.S. Attorneys’ Offices were the District of Arizona, the Central District of 

California, the Eastern District of California, the Northern District of 

California, the Southern District of California, the Eastern District of 

Michigan, the Western District of Michigan, the Eastern District of New 

York, the Northern District of New York, the Southern District of New 

York, the Western District of New York, the Eastern District of Texas, the 

Northern District of Texas, the Southern District of Texas, the Western 
Appendix I: Objectives, Scope, and 

Methodology 

Page 56 GAO-05-478 Elections 

District of Texas, the Eastern District of Virginia, the Western District of 

Virginia, the Eastern District of Wisconsin, and the Western District of 

Wisconsin. 

We contacted federal jury administrators by phone in the 14 U.S. court 

districts that covered those same local election jurisdictions and requested 

information on reporting between federal jury administrators and election 

officials. The 14 district courts were: District of Arizona, Central District of 

California, Eastern District of California, Eastern District of Michigan, 

Western District of Michigan, Eastern District of New York, Southern 

District of New York, Northern District of New York, Southern District of 

Texas, Western District of Texas, Eastern District of Virginia, Western 

District of Virginia, Eastern District of Wisconsin, and Western District of 

Wisconsin. 

We also contacted 14 county court jurisdictions by phone that covered the 

same election jurisdictions and requested information on reporting 

between county jury administrators and election officials. The 14 local 

courts were: Superior Court of Arizona, Maricopa County; Gila County 

Superior Court; Superior Court of California, Los Angeles County; 

Superior Court of California, Yolo County; Third Judicial Circuit Court of 

Michigan; Eaton County Courts; New York County Courts; Rensselaer 

County Courts; Texas Office of Court Administration, Bexar County; 

Texas Office of Court Administration, Webb County; 17th Judicial District 

of Virginia; 16th Judicial Circuit of Virginia; Dane County Courts; and 

Milwaukee County Courthouse. 

We requested information on data regarding citizenship from officials in 

the Department of Homeland Security’s Customs and Border Protection, 

Immigration and Customs Enforcement, and U.S. Citizenship and 

Immigration Services. We also reviewed selected federal and local agency 

reports with relevant information. 

Our work was performed between January 2004 and May 2005 in 

accordance with generally accepted government auditing standards. 
Appendix II: Department of Homeland 

Security Automated Systems That Include 

Information on Non-Citizens 

Page 57 GAO-05-478 Elections 

Name Description 

Asylum Pre-screening System The Asylum Pre-screening System provides case tracking for asylum pre-screening 

credible fear claims that are presented during the expedited removal process. 

Computer-Linked Application Management 

Information System, 

Version 3 

The Computer-Linked Application Management Information System, 

Version 3, is a high-speed transaction processing system with client server 

and mainframe components. It is designed to support the processing (receipt, 

adjudication, and notification) pertaining to all U.S. Citizenship and 

Immigration Service benefits applications and petitions, except naturalization 

(see Computer Linked Application Information System, Version 4 ). Pertinent 

information is uploaded to the Central Index System. 

Computer Linked Application Information 

System, Version 4 

The Computer Linked Application Information System, Version 4, is a nationallydeployed Client-Server, workflow-driven case management system that supports the 

processing of naturalization applications. Pertinent information is uploaded to the 

Central Index System. 

Central Index System The Central Index System provides automated information on individuals of interest 

and identifies the location of an alien's hardcopy A-file. It also provides information for 

federal and state entitlement programs and is a single centralized source of data for 

many mission functions. Data is routinely captured in the Central Index System via 

daily data uploads from the Computer-Linked Application Management Information 

System, Versions 3 and 4. 

Employment Authorization Document System The Employment Authorization Document System is an antiquated stand-alone 

personal computer system used to capture data at U.S. Citizenship and Immigration 

Service field offices. In combination with Polaroid camera pictures, it generates a 

standardized identification document issued to aliens who are authorized to be 

temporarily employed in the U.S. Data is electronically consolidated from the standalone devices throughout each workweek and uploaded to the Computer-Linked 

Application Management Information System, Version 3, and subsequently to the 

Central Index System (see above) for nationwide terminal inquiry access. 

Marriage Fraud Amendment Act System A centralized, mainframe case tracking system that supports the adjudication of 

petitions covered by the Immigration Marriage Fraud Amendment Act of 1986. 

Refugee, Asylum & Parole System A centralized mainframe system that provides full case tracking and management 

capability for asylum casework. 

Reengineered Naturalization Application 

Casework System 

A centralized, mainframe system reengineered from the Naturalization Application 

Case-processing System. It no longer takes new naturalization applications (see 

Computer Linked Application Information System, Version 4), but continues to process 

applications for citizenship (N600), and applications for duplicate certificates (N565). 

Deportable Alien Control System One nationwide database of deportation and detention information that operates on 

computer hardware owned by the federal government and is accessible through the 

network of user terminal across the country. It automates many of the clerical docket 

control functions associated with the arrest, detention, and deportation of illegal aliens. 

The Juvenile Alien Management System This database tracked juvenile aliens in the removal process. This system is no 

longer used and supported. Juvenile case tracked in the Juvenile Alien Management 

System had been recorded in DACS. 

Student and Exchange Visitor Information 

System 

An internet-based system that provides tracking and monitoring functionality, with 

access to accurate and current information on nonimmigrant students and exchange 

visitors and their dependents and the approved schools and designated programs 

sponsor in the United States that host these individuals. 

Appendix II: Department of Homeland 

Security Automated Systems That Include 

Information on Non-Citizens 
Appendix II: Department of Homeland 

Security Automated Systems That Include 

Information on Non-Citizens 

Page 58 GAO-05-478 Elections 

Name Description 

The Student and School System With the implementation of the Student and Exchange Visitor Information System , this 

database previously utilized by legacy Immigration and Naturalization Service fell into 

disuse. The data in this system has not been updated since the Student and 

Exchange Visitor Information System came online. The Student and School System 

was official retired on September 30, 2004, and is no longer available. 

Arrival and Departure Information System The Arrival and Departure Information System provides a Department of Homeland 

Security intranet accessible web-based browser application that correlates information 

from multiple sources to show the person’s travel history, current immigration status, 

and overstay information. The Arrival and Departure Information System currently 

receives, filters, processes, matches and stores biographic and biometric border 

crossing information for all non-citizens, air and sea travelers entering and departing 

the United States and status update information for aliens within the United States. 

Non-Immigrant Information System An online, automated central repository of information designed to track and maintain 

the status of all foreign visitors and immigrants. This system provides information on 

arrivals and departures, to support the controlled admission of non-immigrants to the 

United States through ports of entry and to track non-immigrant departures for 

identifying information. 

Enforcement Case Tracking System An automated system that supports the Border and Transportation Security in the 

accomplishment of its law enforcement mission. The Enforcement Case Tracking 

System comprises numerous modules for specific processing needs—needs such as 

identifying, apprehending, detaining, and removing aliens illegally in the United States, 

filing administrative and criminal charges against aliens who commit illegal acts; and 

seizing contraband associated with illegal alien activity. 

United States Visitor and Immigrant Status 

Indicator Technologya

An automated system that collects, maintains, and shares information, including 

biometric identifiers, on selected foreign nationals who travel to the United States.a

Among other things, the program is designed to identify foreign nationals who (1) have 

overstayed or violated the terms of their visit; (2) can receive, extend, or adjust their 

immigration status; or (3) should be apprehended or detained by law enforcement 

officials. On January 5, 2004, Department of Homeland Security began operating the 

first stage of its planned United States Visitor and Immigrant Status Indicator 

Technology at 115 air and 14 sea ports of entry.

Systematic Alien Verification for Entitlements 

(SAVE) 

An automated system responsible for administering programs involving customer 

access to information contained in the Department of Homeland Security’s Verification 

Information System database. The Verification Information System database is a 

nationally accessible database of selected immigration status information on over 60 

million records. The SAVE Program enables federal, state, and local government 

agencies to obtain immigration status they need in order to determine an applicant’s or 

recipient’s eligibility for many public benefits. The SAVE Program also administers, in 

cooperation with SSA, employment verification pilot programs that enable employers 

to quickly and easily verify the work authorization of their newly hired employees. 

Source: GAO summary of Department of Homeland Security information provided by United States Citizenship and Immigration 

Service, Immigrations and Customs Enforcement, and Customs and Border Protection officials. 

a For more information on this program, see GAO, Homeland Security: First Phase of Visitor and 

Immigration Status Program Operating, but Improvements Needed, GAO-04-586 (Washington, D.C.: 

May 11, 2004). 
Appendix III: Voter Registration Fraud 

Allegations Identified at Selected States and 

at the Federal Level 

Page 59 GAO-05-478 Elections 

In California, the only state with an investigative unit dedicated to voter 

fraud issues, 15 cases of the 108 allegations for fraudulent voter 

registration opened from January 2001 to May 2004 were sent to the 

District Attorney for prosecution. Of the 15 cases, the outcome had been 

determined in 11 cases (6 cases declined for prosecution; 5 were 

prosecuted and the individuals were convicted). In four cases, the 

outcome is yet to be determined. Similarly, the California investigative unit 

opened for investigation 29 allegations of non-citizens either registering or 

voting, 1 case of a non-citizen voting was sent to a District Attorney for 

prosecution, but the District Attorney declined it. At the federal level, DOJ 

attorneys initiated at least 61 election fraud investigations or matters (an 

alleged possible criminal occurrence that still has to be investigated) from 

2000 to 2003. Of those cases, 15 involved voter registration or ineligible 

voters 

Election officials in seven of the locations we visited reported that they 

have referred reported instances of voter registration fraud allegations to 

appropriate agencies, such as the District Attorney and the U.S. Attorney 

for investigation. Election officials referred allegations of voter 

registration fraud such as the following to the appropriate agencies for 

investigation: 

• A Texas local jurisdiction referred to the State Board of Elections an 

allegation that state officials investigated where 27 people were 

registered at one address. The investigation revealed that the location 

was an orphanage, and the registrants were resident workers. 

• Texas local jurisdictions reported referring to their local District 

Attorney instances of (1) an individual trying to register using the 

names of 42 deceased individuals, (2) the receipt of many voter 

registration applications from the same address, and (3) a non-citizen 

who incorrectly believed she could vote in a school board election if 

she was a property owner. 

• One Arizona local jurisdiction reported that between 1997 and 2003, 23 

cases had been prosecuted by local District Attorneys or the U.S. 

Attorney for election-related violations and petition forgeries. Eleven of 

the 23 cases were for petition forgery. 

• Local jurisdictions in California and Michigan each reported instances 

of voter registration drive irregularities such as altering or falsifying 

registration forms. Election officials in California referred the matter to 

Appendix III: Voter Registration Fraud 

Allegations Identified at Selected States and 

at the Federal Level 
Appendix III: Voter Registration Fraud 

Allegations Identified at Selected States and 

at the Federal Level 

Page 60 GAO-05-478 Elections 

the Secretary of State’s office for investigation and Michigan officials 

referred the matter to the local county prosecutor. 

• One New York jurisdiction reported referring an allegation made by an 

ex-spouse to the U.S. Attorney that the former spouse was not a citizen. 

• One Arizona local jurisdiction official referred to the District Attorney 

an instance of a person trying to vote before being officially sworn in as 

a U.S. citizen. 

In deciding to investigate allegations of voter registration fraud given the 

competing demands for investigative and prosecutorial resources, local 

and federal prosecutors reported they take various factors into 

consideration. District Attorneys in jurisdictions we visited gave various 

reasons for not pursuing allegations. One District Attorney reported that 

they were unable to investigate the allegations of voter registration fraud 

because they could not compel a person to provide proof of citizenship 

based only on an allegation. A District Attorney in another jurisdiction 

reported that registration allegations are not pursued because they are 

victimless and non-violent crimes. Another District Attorney said that 

registration issues are not one of the county’s priorities. 

District Attorneys in the local jurisdictions we visited reported initiating 

matters or cases since January 1, 2004, pertaining to ineligible persons 

registering to vote. Three jurisdictions reported prosecuting one case 

each, two reported having matters still under investigation, and two 

reported that they did not prosecute the matter. 

Within the Department of Justice, the U.S. Attorneys and the Public 

Integrity Section (PIN) are responsible for enforcing federal criminal laws 

applicable to federal election fraud offenses, among other things. PIN is 

also responsible for overseeing the U.S. Attorneys’ investigations and 

prosecution of federal election fraud. A senior PIN official said the 

decision to pursue an allegation depends on a number of factors. When an 

allegation is received, it is evaluated in terms of factors such as quality of 

the witnesses, quality of evidence, historical problems in the area, 

resources, coordinating with state Attorney General’s office priorities, and 

the priority of election crimes within the responsibilities of the 

Department of Justice. U.S. Attorneys and PIN attorneys initiated at least 

61 election fraud matters, or investigations, related to election years 2000 

through 2003. Most of the 61 matters related to elections held in 2002. 

(Matters were initiated in 28 states and 1 U.S. territory and ranged from 1 

to 7 matters per state/territory over the 4-year period.) Of these election 

fraud matters, 15 related to voter registration or ineligible voters. 
Appendix III: Voter Registration Fraud 

Allegations Identified at Selected States and 

at the Federal Level 

Page 61 GAO-05-478 Elections 

According to PIN, many of the 61 matters resulted in indictments and 

subsequent convictions. A PIN official told us that 43 voter registration 

matters are currently under investigation and another 7 have been closed 

related to the November 2004 federal election. According to the Criminal 

Division, the information provided by PIN does not include all election 

fraud investigations that the U.S. Attorneys have initiated because (1) U.S. 

Attorneys are not required to consult with PIN for preliminary 

investigations as opposed to grand jury investigations, which require 

consultations; (2) PIN did not track election fraud investigations prior to 

October 2002; and (3) election fraud investigations are sometimes initiated 

under non-election statutes. 

In addition to the PIN election fraud matters, we asked the 19 U.S. 

Attorney Offices that cover the seven states we visited the number of fraud 

matters or investigations they had in 2003 and 2004 relating to ineligible 

voter registration. Five offices reported investigating allegations. Three 

offices reported that among them there were four ongoing investigations. 

One office reported that they investigated a matter, but no prosecution 

arose from the investigation. Another office reported that they declined to 

prosecute a number of investigations (number not tracked) that involved 

aliens who registered to vote. Rather than prosecute, they allowed 

administrative procedures regarding deportation to occur. 
Appendix IV: Comments from the 

Administrative Office of the United States 

Courts 

Page 62 GAO-05-478 Elections 

Appendix IV: Comments from the 

Administrative Office of the United States 

Courts 
Appendix V: Comments from the U.S. 

Department of Justice 

Page 63 GAO-05-478 Elections 

Appendix V: Comments from the U.S. 

Department of Justice 
Appendix V: Comments from the U.S. 

Department of Justice 

Page 64 GAO-05-478 Elections 
Appendix VI: GAO Contact and Staff 

Acknowledgments 

Page 65 GAO-05-478 Elections 

William O. Jenkins, Jr., (202) 512- 8777 

In addition to the contact mentioned above, Orin B. Atwater, Carla Brown, 

Grace Coleman, Michele Fejfar, Daniel Garcia, Richard Griswold, Geoffrey 

Hamilton, Monica Kelly, Jean McSween, Jean Orland, Emmy Rhine, Sandra 

Sokol, and Linda Watson contributed to this report. 

Appendix VI: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments 

(440262) 
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