United States Government Accountability Office

GAO Report to Congressional Committees

ELECTIONS

Action Plans Needed 

to Fully Address 

Challenges in 

Electronic Absentee 

Voting Initiatives for 

Military and Overseas 

Citizens 

June 2007 

 

GAO-07-774 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

June 2007

ELECTIONS

Action Plans Needed to Fully Address 

Challenges in Electronic Absentee Voting 

Initiatives for Military and Overseas 

Citizens 

Highlights of GAO-07-774, a report to 

congressional committees 

The Uniformed and Overseas

Citizens Absentee Voting Act 

(UOCAVA) protects the rights of 

military personnel, their 

dependents, and overseas citizens 

to vote by absentee ballot. The

Department of Defense (DOD) and

others have reported that absentee 

voting, which relies primarily on 

mail, can be slow and may, in 

certain circumstances, serve to 

disenfranchise these voters. In 

2004, Congress required DOD to

develop an Internet-based absentee

voting demonstration project and 

required the Election Assistance

Commission—which reviews 

election procedures—to develop

guidelines for DOD’s project. In

2006, Congress required DOD to

report, by May 15, 2007, on plans 

for expanding its use of electronic 

voting technologies and required

GAO to assess efforts by (1) DOD

to facilitate electronic absentee

voting and (2) the Commission to 

develop Internet voting guidelines

and DOD to develop an Internetbased demonstration project. GAO 

also assessed DOD’s efforts to

develop plans to expand its use of

electronic voting technologies. 

GAO interviewed officials and

reviewed and analyzed documents 

related to these efforts. 

What GAO Recommends

GAO made recommendations to 

DOD regarding security, guidance, 

and plans for electronic voting

initiatives and to the Commission 

on plans to develop the guidelines. 

DOD and the Commission agreed

with these recommendations. 

Since 2000, DOD has developed several initiatives to facilitate absentee 

voting by electronic means such as fax or e-mail; however, some of these 

initiatives exhibited weaknesses or had low participation rates that might 

hinder their effectiveness. For example, the 2003 Electronic Transmission 

Service’s fax to e-mail conversion feature allows UOCAVA voters who do not 

have access to a fax machine to request ballots by e-mail and then converts 

the e-mails to faxes to send to local election officials. DOD officials told us, 

however, they have not performed, among other things, certification tests 

and thus are not in compliance with information security requirements. The

2004 Interim Voting Assistance System (IVAS)—which, DOD reported, 

enabled UOCAVA voters to request and receive ballots securely—cost 

$576,000, and 17 citizens received ballots through it. The 2006 Integrated 

Voting Alternative Site (also called IVAS)—which enabled voters to request

ballots using one tool, by mail, fax, or unsecured e-mail—raised concerns, 

from Congress and others, that using unsecured e-mail could expose voters 

to identity theft if they transmit personal data. While this IVAS displayed a 

warning that voters had to read to proceed, it did not advise them to delete 

personal voting information from the computers they used. DOD spent $1.1 

million, and at least eight voted ballots were linked to this 2006 IVAS. Both 

the 2004 and 2006 IVAS were each implemented just 2 months before an 

election. DOD also has a Web site with links to guidance on electronic 

transmission options, but some of this guidance was inconsistent and could 

be misleading. DOD officials acknowledged the discrepancies and addressed 

them during GAO’s review. 

The Election Assistance Commission has not developed the Internet 

absentee voting guidelines for DOD’s use, and thus DOD has not proceeded 

with its Internet-based absentee voting demonstration project. Commission 

officials told GAO that they had not developed the guidelines because they 

had been devoting constrained resources to other priorities, including 

challenges associated with electronic voting machines. Furthermore, they

have not established—in conjunction with major stakeholders like DOD—

tasks, milestones, and time frames for completing the guidelines. The 

absence of such guidelines has hindered DOD’s development of its Internetbased demonstration project. To assist the Commission, however, DOD has 

shared information on the challenges it faced in implementing prior Internet 

projects—including security threats. 

GAO observed that DOD was developing, but had not yet completed, plans 

for expanding the future use of electronic voting technologies. Because 

electronic voting in federal elections involves numerous federal, state, and 

local-level stakeholders; emerging technology; and time to establish the 

initiatives, developing results-oriented plans that identify goals, time frames, 

and tasks—including addressing security issues—is key. Without such plans, 

DOD is not in a position to address congressional expectations to establish 

secure and private electronic and Internet-based voting initiatives. 

www.gao.gov/cgi-bin/getrpt?GAO-07-774.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Derek Stewart 

at (202) 512-5559 or stewartd@gao.gov. 
Contents 

Letter 1

Results in Brief 3 

Background 6

DOD Initiatives Assist UOCAVA Voters, but Certain Weaknesses 

May Limit Their Effectiveness 12 

Absence of Internet Absentee Voting Guidelines Has Hindered 

Development of the Mandated Internet-Based Absentee Voting

Demonstration Project 23 

DOD Was Developing Plans to Expand the Use of Electronic Voting 

Technology in the Future, but Sound Management Practices Are 

Key 28

Conclusions 30

Recommendations for DOD 31 

Recommendations for the Election Assistance Commission 32 

Agency Comments and Our Evaluation 32 

Appendix I Scope and Methodology 34 

Appendix II Examples of the Inconsistent Voting Assistance 

Guidance on DOD’s Web Site 37 

Appendix III Comments from the Department of Defense 44 

Appendix IV Comments from the Election Assistance Commission 47 

Appendix V GAO Contact and Staff Acknowledgments 49 

 

Related GAO Products 50 

Page i GAO-07-774 Elections
Tables 

Table 1: Electronic Transmission Service E-mail to Fax 

Conversions for 2004 and 2006 13 

Table 2: Comparison of Integrated Voting Alternative Site Tools 1 

and 2 for Election Year 2006 18 

Table 3: State Offices Contacted and Programs Where the States 

Were Participants 35 

Table 4: Inconsistencies Identified in Guidance on Electronic

Alternatives to Mail 37 

Figures 

Figure 1: Laws and Some DOD Programs Promoting Electronic 

Alternatives to Mail for UOCAVA Voters, 2000 through 

2007 9

Figure 2: DOD’s 2006-2007 Voting Assistance Guide 20 

Abbreviations 

DOD Department of Defense 

FVAP Federal Voting Assistance Program 

HTML Hypertext Markup Language 

IVAS Interim Voting Assistance System 

IVAS Integrated Voting Alternative Site

NDAA National Defense Authorization Act 

OMB Office of Management and Budget 

PDF Portable Document Format 

SERVE Secure Electronic Registration and Voting Experiment 

UOCAVA Uniformed and Overseas Citizens Absentee Voting Act

VAG Voting Assistance Guide

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 ii GAO-07-774 Elections
United States Government Accountability Office

Washington, DC 20548 

June 14, 2007 

The Honorable Carl Levin 

Chairman 

The Honorable John McCain 

Ranking Member 

Committee on Armed Services 

United States Senate 

The Honorable Ike Skelton 

Chairman 

The Honorable Duncan Hunter 

Ranking Member 

Committee on Armed Services 

House of Representatives 

A citizen’s right to vote is one of the hallmarks of a democratic society; yet 

exercising this right can be a challenge for millions of military personnel 

and their dependents of voting age who live away from their legal 

residences (in or outside the United States) and for overseas citizens. 

These individuals are eligible to vote by absentee ballots in federal 

elections. This eligibility is established by the Uniformed and Overseas 

Citizens Absentee Voting Act (UOCAVA),1

 which is administered by the 

Department of Defense’s (DOD) Federal Voting Assistance Program 

(FVAP). Through this program, DOD provides assistance to UOCAVA 

voters to facilitate opportunities for them to exercise their right to vote. 

The absentee voting process requires the potential voter to register to 

vote, request an absentee ballot, receive the ballot, correctly complete the 

ballot, and return it to the appropriate local election official. However, 

DOD and groups that represent voters covered under the act have 

reported that, because the multistep process of absentee voting relies 

primarily on mail, in some instances it can take so long to complete that 

these voters may, in effect, be disenfranchised. 

 1

Pub. L. No. 99-410 (1986), 42 U.S.C. §§ 1973ff et seq. 

Page 1 GAO-07-774 Elections
To address concerns about mail-based absentee voting, Congress has 

enacted several laws to promote electronic means for voters to register, 

request and receive ballots, and transmit voted ballots to local election 

officials. These laws include (1) the Help America Vote Act of 2002, which 

established the Election Assistance Commission to serve as a national 

clearinghouse for election information and to review election procedures; 

develop voluntary voting system guidelines;2

 and study, among other 

things, electronic voting—particularly Internet voting technology; 

(2) section 1604 of the National Defense Authorization Act (NDAA) for 

Fiscal Year 2002, which required DOD to carry out a secure3

 Internet-based 

electronic demonstration project4

 in the general election for federal office

in 2002 or 2004; and (3) section 567 of the Ronald W. Reagan NDAA for 

Fiscal Year 2005, which amended Congress’s mandate for DOD to develop 

a secure, Internet-based, absentee voting demonstration project—by 

requiring DOD to implement the project during the first general election 

for federal office that occurs after the Election Assistance Commission 

establishes Internet voting guidelines for the absentee voting process.5

Section 596 of the John Warner NDAA for Fiscal Year 2007 required DOD 

to submit, not later than May 15, 2007, a detailed plan to expand the use of

electronic voting technology. 

Section 596 of the John Warner NDAA for Fiscal Year 2007 also required 

GAO to review DOD’s electronic and Internet-based voting initiatives. This

report assesses (1) DOD’s efforts to facilitate registration, ballot 

 2

Voluntary voting system guidelines are to provide a set of specifications and requirements 

to be used in the certification of computer-assisted voting systems, both paper-based and 

fully electronic; states are free to adopt these guidelines in whole or in part or reject them 

entirely. 

3

In 1998, DOD had voluntarily initiated a proof of concept called “Voting Over the Internet,” 

which was a small-scale Internet-based project used in the 2000 elections. DOD’s report on 

this proof of concept acknowledged that a larger-scale pilot would result in more visibility 

and potentially attract those with malicious intent to harm the system, but suggested ways 

to mitigate such future attacks. To address these security concerns and other issues, 

Congress asked DOD, in 2002, to develop a large-scale, Internet-based demonstration 

project to ensure a methodical progression from the current mail-based process to a 

secure, easy-to-use Internet registration and voting system. 

4

One of the primary objectives of the electronic demonstration project was to assess the 

use of such technologies to improve UOCAVA participation in elections. 

5

The conference report for the bill noted that DOD’s prototype for electronic voting was 

important and should not be abandoned and encouraged the Secretary of Defense to 

provide funding to the Commission to advance electronic absentee voting by UOCAVA 

voters. H.R. Rep. No. 108-767, at 680 (2004) (Conf. Rep.). 

Page 2 GAO-07-774 Elections
transmittal, and voting by electronic means, such as e-mail and fax, for 

UOCAVA voters and (2) the Election Assistance Commission’s efforts to 

develop Internet absentee voting guidelines and DOD’s efforts to develop a 

secure, Internet-based, absentee voting demonstration project. The report

also discusses DOD’s efforts to develop plans to expand the use of 

electronic voting technology in the future. 

To address our objectives, we reviewed and analyzed laws, directives, 

reports, and plans related to DOD’s efforts to provide electronic voting 

capabilities for UOCAVA voters. We also examined the Election Assistance 

Commission’s efforts to develop Internet absentee voting guidelines. We 

reviewed and analyzed information regarding any benefits and challenges

that we, DOD, and others had identified related to DOD’s Internet-based 

electronic demonstration project and new electronic voting initiatives, 

along with the steps DOD had taken to mitigate those challenges. 

Additionally, we interviewed and obtained documentation from officials in 

several offices within DOD, the Election Assistance Commission, selected

state and local election jurisdictions, and some independent groups 

concerned with the interests of UOCAVA voters. We performed our work 

in accordance with generally accepted government auditing standards, 

from August 2006 through April 2007. Appendix I provides detailed 

information about our scope and methodology. 

Since the 2000 federal election, DOD has developed several initiatives to 

facilitate voting by electronic means such as fax or e-mail; however, some 

of these initiatives exhibited weaknesses or garnered low participation 

rates that could limit their effectiveness. DOD introduced the first of three 

initiatives, an e-mail to fax conversion enhancement to its Electronic 

Transmission Service, in 2003. This feature allows UOCAVA voters who do 

not have access to a facsimile machine to send ballot requests, via e-mail, 

to DOD’s Electronic Transmission Service, which converts e-mail 

messages to faxes and sends them to local election officials.6

 In return, 

local election officials can send ballots to the Electronic Transmission 

Service conversion feature by fax; the conversion feature then converts 

the fax to an e-mail and sends it to the voter. DOD officials told us, 

however, that this feature is not in compliance with certain DOD 

Results in Brief 

 6

The Federal Voting Assistance Program reported that some states, by law, allow voting 

materials to be sent by fax but not by e-mail. 

Page 3 GAO-07-774 Elections
information security requirements,7

 which include performing and 

documenting risk assessments and security certification testing. Without 

such compliance, DOD cannot certify that it has employed the basic 

practices necessary to apply security measures. DOD officials said that 

they plan to award a contract to meet the requirements. Also, DOD 

voluntarily launched a second initiative—the Interim Voting Assistance 

System (IVAS)—in September 2004, to enable, as DOD reported, absentee 

voters to request and receive state or territory ballots securely for use in 

the November 2004 election. DOD spent $576,000 on this project, but only 

17 citizens received ballots through this system—in part, because it was 

implemented just 2 months before the election. Further, in September 

2006, DOD developed, in response to a legislative mandate,8

 a third 

initiative—the Integrated Voting Alternative Site (also called IVAS). This 

site included (1) a ballot request only tool—called Tool 1—that enabled 

voters to request their state or territory ballots from election officials by 

fax, regular mail, or unsecured e-mail and (2) a ballot request and receipt

tool—called Tool 2—that enabled voters to request and receive their state 

or territory ballots through a secured server. Officials within Congress, 

and others, expressed concerns that using the Tool 1 with unsecured 

e-mail could expose voters to the risk of identity theft. DOD displayed a 

warning on the site—which voters had to read to continue processing their 

request—that explained the risks associated with e-mailing ballot requests. 

While the warning addressed the risks of transmitting personal 

identification information by e-mail, it did not inform voters of the risks 

involved in leaving such personal information on the computers they 

used—especially public computers or those shared by others. DOD 

officials said they would incorporate lessons learned, such as adding a 

cautionary statement to future systems to warn UOCAVA voters to remove 

personal information from the computers they use. DOD spent about 

$1.1 million on the 2006 IVAS, but local election officials could link only 

eight ballots to IVAS Tool 2.9

 In addition to these initiatives, DOD has 

established a Web site with links to guidance that provides UOCAVA 

 7

DOD, Interim Department of Defense (DOD) Certification and Accreditation (C&A) 

Process Guidance, July 6, 2006. 

8

Emergency Supplemental Appropriations Act for Defense, the Global War on Terror, and 

Hurricane Recovery, 2006. Pub. L. No. 109-234 (2006). 

9

FVAP reported that, since ballot requests could be printed and returned through the mail 

or by fax instead of the secured server, an accurate reporting could not be obtained

through Tool 2. FVAP also reported that ballot requests submitted using Tool 1 could not 

be tracked and reported because voters sent the requests directly to local election officials 

using their personal e-mail accounts, mail, or fax. 

Page 4 GAO-07-774 Elections
voters with, among other things, information on electronic alternatives to 

mail for each of the 55 states and territories. These links lead to DOD’s 

2006 IVAS, the Voting Assistance Guide, news releases, and guidance 

updates. Our analysis of information on DOD’s Web site, however, showed 

that for 14 of the 55 states and territories, some of the information about 

the alternatives was inconsistent and could be misleading. For example, 

for one state, information on three links correctly stated that only overseas 

military and overseas civilian voters were eligible to receive or return a 

ballot by fax; however, a fourth link did not include this restriction. As a 

result, military personnel stationed in the United States, but away from 

their state of residence, may have incorrectly concluded that they were 

eligible to vote by fax. While these inconsistencies were not widespread, 

their mere existence could lead UOCAVA voters to rely on incorrect 

information and therefore adversely affect the citizens’ ability to vote. 

Agency officials acknowledged these discrepancies and addressed them 

during the course of our review. We are recommending that DOD improve 

the security and accuracy of its systems by (1) complying with information 

security requirements, (2) incorporating lessons learned, such as adding a 

cautionary statement to future systems to warn UOCAVA voters to remove 

personal information from the computers they use, and (3) 

institutionalizing a review process for its online guidance to ensure that 

information for absentee voters is accurate and consistent. DOD 

concurred with these recommendations. 

The Election Assistance Commission has not yet developed guidelines for 

Internet absentee voting for DOD’s use, and, thus, DOD has not proceeded 

with developing its secure, Internet-based, absentee voting demonstration 

project. Specifically, Commission officials stated that they had not yet 

developed the guidelines because they had been devoting constrained 

resources to meeting the challenges associated with current electronic

voting machines. Furthermore, the Commission has not yet established—

in conjunction with major stakeholders, like DOD—tasks, including 

addressing security and privacy risks; time frames; or milestones for 

completing the guidelines. Similarly, DOD has not developed the secure, 

Internet-based, absentee voting demonstration project because, DOD 

officials said, by law, the Commission must develop Internet absentee 

voting guidelines for DOD to follow before it can proceed. To support the 

Commission in developing these guidelines, DOD officials said they gave 

the Commission a report and an internal DOD document that provides the 

framework for a system, along with challenges DOD found in its earlier 

Internet voting projects. These challenges included security threats such 

as computer viruses, malicious insider attacks, and inadvertent errors that 

could disrupt system performance. DOD officials stated that, even if the 

Page 5 GAO-07-774 Elections
Internet absentee voting guidelines had been available at the time of our 

review, the time remaining before the 2008 federal election would be 

inadequate for developing the secure, Internet-based, demonstration 

project. We are recommending that the Election Assistance Commission, 

in conjunction with major stakeholders such as DOD, create an action 

plan with tasks including actions to address the security and privacy risks 

associated with Internet voting processes and time frames for developing

the Internet absentee voting guidelines. The Election Assistance 

Commission concurred with our recommendation. 

We observed that DOD was developing, but had not yet completed, plans 

for expanding the use of electronic voting technology for military 

personnel and overseas citizens, as required by the John Warner NDAA for 

Fiscal Year 2007. The act requires DOD to submit these plans to Congress, 

not later than May 15, 2007. Our analysis of existing DOD and Commission

documents and our interviews with agency officials show that DOD has 

not sufficiently involved stakeholders in recent electronic voting efforts—

such as its 2006 IVAS. In addition, it has not established interim tasks that 

address issues such as security and privacy, milestones, time frames, or 

contingency plans, following the sound management practices used by 

leading organizations. Implementation of new electronic voting initiatives

requires careful planning, particularly in light of the large number of 

stakeholders, the application of new technology, the remote location of 

troops, and the lead time required for implementation. Without an 

integrated, results-oriented plan that involves all stakeholders and 

identifies, among other things, goals, tasks, time frames, and contingency

plans, DOD is not in a position to address congressional expectations to 

establish secure and private electronic and Internet-based voting 

initiatives. We are recommending that DOD, in conjunction with major 

stakeholders such as the Election Assistance Commission and local 

election officials, develop a comprehensive, results-oriented plan for 

future efforts that specifies, among other things, tasks including 

identifying safeguards for security and privacy of all DOD’s voting 

systems—both electronic and Internet-based. DOD concurred with this 

recommendation. 

DOD’s and the Commission’s written comments are contained in 

appendixes III and IV, respectively. DOD also provided technical 

comments, which we incorporated in the final report, as appropriate. 

The U.S. election system is highly decentralized and relies on a complex

interaction of people, processes, and technology. Voters, local election Background 

Page 6 GAO-07-774 Elections
jurisdictions (which number over 10,000), states and territories, and the 

federal government all play important roles in the election process. The 

process, however, is primarily the responsibility of the individual states 

and territories and their election jurisdictions. As we reported in our 2006 

testimony,10 states and territories have considerable discretion in how they 

organize the elections process; this is reflected in the diversity of 

procedures and deadlines that states and jurisdictions establish for voter 

registration and absentee voting. Furthermore, these states and 

jurisdictions use a variety of voting techniques, from paper ballots to faxes 

and e-mails. We also reported that the voter is ultimately responsible for 

being aware of and understanding the absentee voting process and taking 

the actions necessary to participate in it. 

The UOCAVA established that members of the military and their 

dependents of voting age living away from their legal residences (in or 

outside the United States) and American citizens who no longer maintain a 

permanent residence in the United States are eligible to participate by 

absentee ballot in all federal elections. According to DOD, the act covers 

more than 6 million people. Executive Order and DOD guidance related to 

the act include the following: 

• Executive Order 12642, dated June 8, 1988, made the Secretary of Defense,

or his designee, responsible for carrying out the federal functions under 

UOCAVA, including (1) compiling and distributing information on state 

absentee voting procedures, (2) designing absentee registration and voting

materials, (3) working with state and local election officials, and 

(4) reporting to Congress and the President after each presidential 

election on the effectiveness of the program’s activities (including a 

statistical analysis of UOCAVA voters’ participation). 

• DOD Directive 1000.4, updated April 14, 2004, assigned the Office of the 

Under Secretary of Defense for Personnel and Readiness responsibility for 

administering and overseeing the program, and it established the FVAP to 

manage the program. In 2006, FVAP officials told us that they were 

authorized a full-time staff of 13 and had a fiscal year budget of 

approximately $3.8 million. 

FVAP facilitates the absentee voting process for UOCAVA voters; its 

mission is to (1) inform and educate U.S. citizens worldwide about their 

 10GAO, Elections: DOD Expands Voting Assistance to Military Absentee Voters, but

Challenges Remain, GAO-06-1134T (Washington, D.C.: Sept. 28, 2006).

Page 7 GAO-07-774 Elections
right to vote, (2) foster voter participation, and (3) enhance and protect 

the integrity of the electoral process at the federal, state, and local levels. 

FVAP also, among other things, provides training opportunities for Voting 

Assistance Officers (service, State Department, and overseas citizen 

organization officials who carry out the implementation of their respective 

voting assistance programs); prescribes, coordinates, and distributes 

voting materials, such as the Federal Post Card Application (the 

registration and absentee ballot request form for UOCAVA voters); and 

provides for alternatives to regular mail, including Express Mail and the 

use of electronic solutions. 

The Election Assistance Commission, which was established by the Help

America Vote Act of 2002, also contributes to the absentee voting process. 

The act specifically established the Commission as a national 

clearinghouse for election information and procedures and assigned it 

responsibility for developing voting system guidelines for the entire 

election process. The act also specifies that the development of voluntary 

voting system guidelines should be informed by research and development 

in remote access voting, including voting through the Internet, and the 

security of computers, networks and data storage. In 2005, the 

Commission issued guidelines that, among other things, addressed gaps in

the security measures of prior standards. However, these guidelines do not 

comprehensively address telecommunications and networking services or

their related security weaknesses, such as those related to the Internet. 

The act also amended UOCAVA to require states to report to the 

Commission, after each regularly scheduled general election for federal 

office, on the aggregate number of (1) absentee ballots transmitted to 

absentee uniformed services voters and overseas voters for the election 

and (2) ballots returned by those voters and cast in the election. The 

Commission collects this information through its biennial state surveys of 

election data. 

DOD, the Commission, and organizations representing UOCAVA voters 

have noted that these voters may effectively become disenfranchised 

because the multistep process for voting by absentee ballot—which relies 

primarily on mail—can take too long, especially for mobile 

servicemembers and overseas citizens or those deployed to or living in 

remote areas. Congress and DOD have taken action to facilitate the use of

alternatives to mail, including electronic means such as fax, e-mail, and the

Internet. Figure 1 shows (1) the laws designed to facilitate the use of 

electronic capabilities for UOCAVA voters and (2) some of DOD’s efforts,

either voluntary or in response to a statute, to provide electronic 

capabilities to these voters during fiscal years 2000 through 2007. 

Page 8 GAO-07-774 Elections
Figure 1: Laws and Some DOD Programs Promoting Electronic Alternatives to Mail for UOCAVA Voters, 2000 through 2007 

2000 2002 2004 2005 2006 2007

Voting Over the 

Internet. DOD 

designed Voting 

Over the Internet as

a small-scale project 

to assess the 

feasibility of using 

the Internet as an 

alternative to the 

by-mail process for 

absentee UOCAVA 

registration and 

voting. This project 

was used in the 

2000 elections.

Secure Electronic 

Registration and 

Voting Experiment.

DOD created the 

Secure Electronic 

Registration and 

Voting Experiment 

to address the 2002 

NDAA; it was

terminated in early 

2004. 

Interim Voting

Assistance System 

(IVAS). In 

September 2004, 

DOD voluntarily 

created IVAS, which 

was concluded after 

the November 2004 

election.

Integrated Voting

Alternative Site 

(IVAS). DOD 

implemented IVAS

in September 2006, 

which contained 

two tools. Congress, 

in the John Warner 

National Defense 

Authorization Act 

for Fiscal Year 2007, 

directed DOD to 

continue IVAS for 

the general election 

and all elections

through December 

31, 2006, and DOD 

removed the tools

from its Web site in 

January 2007.

John Warner 

National Defense 

Authorization Act 

for Fiscal Year 

2007. Congress

mandated DOD 

to report detailed 

plans by May 15, 

2007, for expanding 

the use of electronic 

voting for elections

through November 

30, 2010. 

Emergency 

Supplemental 

Appropriations Act 

for Defense, the 

Global War on 

Terror, and 

Hurricane 

Recovery, 2006. 

Congress directed 

DOD, in June 2006, 

to re-establish the 

2004 IVAS program.

Ronald W. Reagan 

National Defense 

Authorization Act 

for Fiscal Year 

2005. Congress

amended the 

requirement for 

DOD to create an 

electronic 

demonstration 

project, by allowing 

DOD to do so after 

the Election 

Assistance 

Commission 

develops voting 

guidelines for the 

project.

National Defense 

Authorization Act 

for Fiscal Year 

2002. After Voting 

Over the Internet, 

Congress required 

DOD to conduct 

an electronic 

demonstration 

project for the 2002 

or 2004 federal 

elections.

Help America Vote 

Act of 2002. The act 

established the 

Election Assistance 

Commission and 

required the 

Commission to 

conduct studies on 

electronic voting, 

including an Internet 

voting study that was

due no later than 

June 29, 2004.

Laws

DOD programs

Source: GAO analysis of Laws and DOD information. 

FVAP stated that it implemented the Voting Over the Internet project in 

2000 as a small-scale pilot project to provide military personnel and their 

dependents and overseas citizens covered under UOCAVA the ability to

securely register to vote, request and receive ballots from local election 

officials, and vote via the Internet. DOD voluntarily developed the project

as a small-scale proof-of-concept Internet voting project. This project 

enabled 84 voters to vote over the Internet—the first time that binding 

votes were cast in this manner.11 While the project demonstrated that it 

 11UOCAVA voters in Florida, South Carolina, Texas, and Utah, who were away from their

legal residences, cast a total of 84 votes from their homes, workplaces, or duty stations on 

personal computers.

Page 9 GAO-07-774 Elections
was possible for a limited number of voters to cast ballots online, DOD’s 

report concluded that security concerns needed to be addressed before it 

could expand remote (i.e., Internet) voting to a larger population. 

In 2001, Congress noted that the Voting Over the Internet project had 

demonstrated that the Internet could be used to enhance absentee voting.

12

To continue the examination of a secure, easy-to-use Internet voting 

system as an alternative to the regular mail process, Congress mandated, 

in the NDAA for Fiscal Year 2002, that DOD conduct a large-scale Internetbased absentee voting demonstration project to be used for the 2002 or 

2004 federal election. DOD responded to this mandate by creating the 

Secure Electronic Registration and Voting Experiment (SERVE) for 

Internet-based absentee registration and voting; SERVE used a system 

architecture similar to the one used for the Voting Over the Internet 

project. However, as we previously reported,13 a minority report published 

by four members of the Security Peer Review Group—a group of 10 

computer election security experts that FVAP assembled to evaluate

SERVE—publicly raised concerns about the security of the system 

because of its use of the Internet.14 The four members suggested that 

SERVE be terminated because potential security problems left the 

information in the system vulnerable to cyber attacks that could disclose 

votes or personal voter information. Furthermore, they cautioned against 

the development of future electronic voting systems until the security of 

both the Internet and the world’s home computer infrastructure had been 

improved. Because DOD did not want to call into question the integrity of 

votes that would have been cast via SERVE, the Deputy Secretary of 

Defense terminated the project in early 2004, and DOD did not use it in the 

November 2004 election.

 12The U.S. Senate Committee on Armed Services report on Senate bill 1416 regarding the 

NDAA for Fiscal Year 2002 noted that the Voting Over the Internet project was an 

important first step in assessing how to use the Internet to enhance absentee voting; 

reducing traditional barriers to participation in elections by absentee voters; and providing

insight into issues that must be considered for broader use of remote registration and 

voting through the Internet. (S. Rep. No. 107-62, at 307 [2001]). 

13GAO, Elections: Absentee Voting Assistance to Military and Overseas Citizens 

Increased for the 2004 General Election, but Challenges Remain, GAO-06-521 

(Washington, D.C.: Apr. 7, 2006). 

14Security Peer Review Group, A Security Analysis of the Secure Electronic Registration 

and Voting Experiment (SERVE), January 21, 2004. The Security Peer Review Group 

consisted of 10 experts on computer security and voting systems drawn from academia and 

the private sector. As stated above, the report was written by 4 of the 10 experts. 

Page 10 GAO-07-774 Elections
The points raised in these security reviews are consistent with concerns 

we raised in our 2001 reports.15 We found that broad application of Internet

voting presented formidable social and technological challenges. In 

particular, we noted that challenges to remote Internet voting16 involve 

securing voter identification information and ensuring that voters secure 

the computer on which they vote. We also reported that because voting 

requires more stringent controls than other electronic transactions, such 

as online banking, Internet voting systems face greater security challenges

than other Internet systems. Furthermore, we found that remote Internet 

voting was recognized as the least protective of ballot secrecy17 and voter 

privacy18 and was most at risk from denial of service and malicious 

software, such as computer viruses. While opinions of groups considering 

the pros and cons of Internet voting were not unanimous, we found that 

they agreed in principle on major issues, including considering security to

be the primary technical challenge for Internet voting.19 Because of serious 

concerns about protecting the security and privacy of the voted ballot, we

concluded that Internet-based registration and voting would not likely be

implemented on a large scale in the near future.

In the Ronald W. Reagan NDAA for Fiscal Year 2005, Congress amended 

the requirement for the Internet-based absentee voting demonstration 

project by permitting DOD to delay its implementation until the first 

federal election after the Election Assistance Commission developed 

guidelines for the project. The conference report for the act20 stated that, 

 15GAO, Elections: Voting Assistance to Military and Overseas Citizens Should be 

Improved, GAO-01-1026 (Washington, D.C.: Sept. 28, 2001) and Elections: Perspectives on

Activities and Challenges Across the Nation, GAO-02-3 (Washington, D.C.: Oct. 15, 2001). 

16Various approaches to Internet voting are possible, ranging from the use of Internet

connections at traditional polling stations to the ability to remotely vote from anywhere

(remote Internet voting). An intermediate step along this range is an option referred to as

“kiosk voting,” which uses conveniently located voting terminals provided and controlled 

by election officials. 

17Ballot secrecy refers to protecting the content of the vote. 

18Voter privacy refers to protecting the voters’ ability to cast votes without being observed. 

In poll-site voting, voter privacy is generally ensured by election officials and observers. 

However, we reported that remote Internet voting would not protect voters’ physical 

privacy, leaving them open to the risk that they might be coerced (through threats, bribery, 

or other forms of pressure). 

19Other challenges that affect implementation of Internet voting include the costs of the

voting method versus its benefits and the availability of Internet technology to voters. 

20H.R. Rep No. 108-767, at 680 (2004) (Conf. Rep.). 

Page 11 GAO-07-774 Elections
although Congress recognized the technical challenges of Internet voting, 

SERVE was an important prototype that should not be abandoned. 

Since the 2000 federal election, DOD has established several initiatives as 

alternatives to the by-mail process to facilitate voter registration and ballot 

request, receipt of a ballot, and submission of a voted ballot by electronic 

means—such as fax and e-mail—for UOCAVA voters. These include the

Electronic Transmission Service’s fax to e-mail and e-mail to fax 

conversion enhancement (hereafter referred to as the e-mail to fax 

conversion feature); the 2004 Interim Voting Assistance System (IVAS); the 

2006 Integrated Voting Alternative Site (also called IVAS); DOD’s online 

voting assistance guidance; and online forms to register, request, receive,

or submit ballots. While these efforts provide valuable guidance, services, 

and information to UOCAVA voters, some of them had limited 

participation rates or exhibited weaknesses in security, consistency, and 

accuracy that might hinder their use and effectiveness. DOD officials have 

acknowledged these weaknesses and they began taking action to address 

them during the course of our review. 

The electronic transmission service is a fax forwarding system, established

by FVAP in 1990, that allows UOCAVA voters and state and local election 

officials, where permitted by law, to fax election materials to each other. 

These voters and election officials can use this service and do not have to 

pay long distance fees for faxing out of state, because DOD provides the 

service through a toll-free line. In 2003, after discussions with Mississippi 

state officials and a Mississippi National Guard unit, FVAP added the 

e-mail to fax conversion capability to its electronic transmission service. 

These officials asked FVAP for help in transmitting voting materials 

because, by state law, Mississippi allowed only faxing as an electronic 

means of transmission—a capability that the Guard unit would not have 

while it was deployed to Iraq.21 The e-mail to fax conversion feature allows 

UOCAVA voters who do not have access to a facsimile machine to send 

ballot requests, via e-mail, to DOD’s Electronic Transmission Service, 

which converts e-mail attachments to faxes and sends them to local 

election officials. In return, local election officials can send ballots to the 

Electronic Transmission Service conversion feature by fax; the conversion 

DOD Initiatives Assist 

UOCAVA Voters, but 

Certain Weaknesses 

May Limit Their 

Effectiveness 

Electronic Transmission 

Service’s E-mail to Fax 

Conversion Capability 

Facilitates Transmission of 

Voting Materials but Does 

Not Fully Comply with 

Information Security 

Requirements 

 21The FVAP reported that some states, by law, allow voting materials to be sent by fax but

not by e-mail. 

Page 12 GAO-07-774 Elections
feature then converts the fax to an e-mail attachment and sends it to the 

voter. 

FVAP stated that it notifies states and territories whenever it converts an 

e-mail containing voting materials to a fax, or vice versa, so that the state

or territory can decide whether or not to accept it. Table 1 shows 

Electronic Transmission Service activity for the conversion feature for 

2004 and 2006. 

Table 1: Electronic Transmission Service E-mail to Fax Conversions for 2004 and

2006 

Years 

2004 2006

E-mails converted to fax—sent from citizens to local election officials 

Voted ballots 67 53

Federal post card applications and remaining ballot materials 389 190

Subtotal 456 243

E-mails converted to fax—sent from local election officials to citizensa

Federal post card applications and remaining ballot materials 153b182

Subtotal 153b182

Total 609 425

Source: DOD. 

a

FVAP officials stated that the local election officials who send e-mails to the Electronic Transmission 

Service conversion feature use it to store ballots that will be sent to UOCAVA voters, through DOD, at

some future date.

b

FVAP noted that for the 2004 elections the Electronic Transmission Service conversion feature 

received 61 e-mails from local election officials which they converted to 153 faxes to citizens covered 

under UOCAVA. FVAP explained that this allowed one local election official to send one e-mail with a

PDF attachment to the Electronic Transmission Service, which would then get converted to a fax and 

sent to multiple UOCAVA voters per the local election official’s instructions. PDF means Portable 

Document Format; it is a file format that is used to view electronic copies of paper documents, which

allows an exact copy of the paper document. 

Although FVAP has made progress in assisting servicemembers to 

transmit voting materials with the e-mail to fax conversion enhancement,

FVAP officials told us they have not fully complied with certain 

information security requirements in the Interim DOD Information 

Assurance Certification and Accreditation Process.22 This guidance 

 22DOD, Interim Department of Defense (DOD) Certification and Accreditation (C&A) 

Process Guidance, July 6, 2006. 

Page 13 GAO-07-774 Elections
requires DOD components, among other things, to implement controls and 

to certify and accredit such e-mail systems. 

FVAP officials initially stated that the information security guidance did 

not apply to the conversion feature; they saw it as an enhancement to the 

original Electronic Transmission Service’s fax system. During the course 

of our review, however, FVAP officials said they consulted with officials 

responsible for DOD’s information assurance certification and 

accreditation and concluded that the requirements did, in fact, apply.

These officials stated that, by the end of fiscal year 2007, they plan to 

award a contract to obtain services to meet the information security 

requirements. The FVAP officials further stated that, while they do not 

have the required documentation—such as risk assessments or 

certification tests and accreditations—they have taken some measures to 

ensure security. We note that the statement of work for FVAP’s April 29, 

2005, contract for the Electronic Transmission Service recognizes the 

sensitivity of the data associated with election materials and includes 

provisions for certain security functions, such as ensuring that adequate 

steps are taken to prevent unauthorized access or manipulation of the 

data. Until FVAP performs and documents the security assessments and 

certifications, however, it has not taken all the necessary measures to 

secure its system and comply with DOD’s information security

requirements. 

Federal law includes a number of separate statutes that provide privacy 

protections for certain information. The major requirements for the 

protection of personal privacy by federal agencies come from two laws: 

the Privacy Act of 197423 and the privacy provisions of the E-Government 

Act of 2002. Section 208 of the E-Government Act of 200224 requires 

agencies, among other things, to conduct privacy impact assessments 

before developing, upgrading, or procuring information technology that

collects, maintains, or disseminates personally identifiable information. 

DOD developed departmentwide guidance—the DOD Privacy Impact 

Assessment Guidance—for implementing the privacy impact assessment 

requirements mandated in the E-Government Act of 2002. In this guidance, 

DOD directs the components to adhere to the requirements prescribed by 

the Office of Management and Budget (OMB)—Guidance for 

 235 U.S.C. § 552a. 

24Pub. L. No. 107-347 (2002). 

Page 14 GAO-07-774 Elections
Implementing the Privacy Provisions of the E-Government Act of 2002.25

FVAP officials stated that they had not conducted a privacy impact 

assessment for the Electronic Transmission Service’s e-mail to fax 

conversion enhancement, but they told us that a privacy impact 

assessment will be done as part of the previously mentioned contract to 

meet information security requirements. A privacy impact assessment 

would identify specific privacy risks to help determine what controls are 

needed to mitigate those risks associated with the Electronic 

Transmission Service. Furthermore, building in controls to mitigate risks 

could ensure that personal information that is transmitted is only used for 

a specified purpose. FVAP noted that when information is sent by e-mail,

the conversion feature retains the following information: full name, fax 

number, city, state, zip code, and e-mail addresses. FVAP’s Electronic 

Transmission Service retains this personally identifiable information both 

to provide transmission verification or confirmation to users and to 

comply with election document retention requirements under the Civil 

Rights Act of 1960.

26

DOD’s Electronic Ballot 

Request and Receipt 

Initiatives Had Limitations 

in Participation and 

Security 

In September 2004, just 2 months prior to the election, DOD voluntarily 

implemented what it reported as a secure electronic system for voters to 

request and receive ballots—the Interim Voting Assistance System 

(IVAS)—as an alternative to the traditional mail process. IVAS was open to 

active duty servicemembers, their voting age dependents, and DOD 

overseas personnel who were registered in a state or territory participating 

in the project27 and enrolled in the Defense Enrollment Eligibility 

Reporting System—a DOD-managed database that includes over 23 million 

records pertaining to active duty and reserve military and their family 

members, retired military, DOD civil service personnel, and DOD 

contractors. DOD had limited IVAS participation to UOCAVA voters who 

were affiliated with DOD because their identities could be verified in the 

Defense Enrollment Eligibility Reporting System. Voters obtained their 

state or territory ballots through IVAS by logging on to a special Web site 

 25OMB, Guidance for Implementing the Privacy Provisions of the E-Government Act of 

2002, September 26, 2003. (M-03-22). 

26Every officer of election must retain and preserve all election records and papers for 

certain federal elections for a period of 22 months from the date of the election. Civil 

Rights Act of 1960, § 301, 42 U.S.C. § 1974. 

27States and territories participating in the 2004 IVAS included Kansas, Kentucky, Maryland, 

Mississippi, Montana, New Mexico, South Carolina, the Virgin Islands, and Wisconsin. 

Page 15 GAO-07-774 Elections
and then requesting ballots from their participating local election 

jurisdictions. After the local election officials approved the requests and 

the ballots were finalized, IVAS notified voters via e-mail that the ballots 

were available to download and print. DOD reported that 108 counties in 

eight states and one territory agreed to participate in this 2004 IVAS; 

however, only 17 citizens downloaded their ballots from the site during the 

2004 election. FVAP officials noted that participation was low, in part 

because this IVAS was implemented just 2 months before the election. 

FVAP further reported that many states did not participate—for a variety 

of reasons, including state legislative restrictions, workload surrounding 

regular election responsibilities, and lack of Internet access. FVAP 

officials noted that this system, which was maintained through the 

conclusion of the election, cost $576,000. 

In September 2006—again, just 2 months before the next general 

election—FVAP launched a follow-on Integrated Voting Alternative Site, 

also called IVAS, in response to a June 2006 legislative mandate to 

reestablish the 2004 IVAS. This 2006 IVAS expanded on the 2004 effort, by

providing information on electronic ballot request and receipt options for 

all UOCAVA citizens in all 55 states and territories. It also provided two 

tools that registered voters could access through the FVAP Web site, using 

DOD or military identification, to request or receive ballots from local 

election officials. As with the 2004 IVAS, local election officials used 

information in these tools to verify the identity of UOCAVA voters who 

used them.28 The first tool—called Tool 1—contained a ballot request form 

only, accessed through DOD’s Web site, which voters could fill out and 

download to their computers. Voters could then send the downloaded 

form to the local election officials either by regular mail, fax, or unsecured 

e-mail, per state or territory requirements. FVAP officials reported to 

Congress that no information on the number of users was available on the 

use of Tool 1 because the department was no longer involved in the 

process once the voter downloaded the ballot request and they, 

essentially, had no visibility into what transpired directly between the 

voter and the election officials. 

 28Verification was made by the use of WebGuard, which determines the status of an 

individual enrolled in the Defense Manpower Data Center’s Defense Enrollment Eligibility

Reporting System database using that individual’s name, Social Security number, and date

of birth. Ballot requests saved and downloaded to the voter’s computer for voters who used

Tool 1 and those requests sent to the election officials using Tool 2 both include text

indicating the forms were generated via IVAS. 

Page 16 GAO-07-774 Elections
The second tool—called Tool 2—provided a ballot request and receipt

capability for voters, similar to the 2004 IVAS, which also allowed voters to 

fill out ballot request forms online, send them to local election officials 

through a secure line, and receive their state or territory ballots from the 

local election officials through a secured server. Again, no voted ballots 

were transmitted through this IVAS system given that it was not designed 

for that purpose. Absentee voters, instead, would return voted ballots, 

outside of IVAS, in accordance with state law. Tool 2 had a tracking 

feature which showed that 63 voters had requested ballots through the 

system. Of these, local election officials approved and made their state or

territory ballots available to 35 UOCAVA voters. However, of the 35 sent

out, local election officials reported that only 8 voted ballots29 were traced 

back to the IVAS Tool 2, in part because this IVAS was implemented just 

2 months before the election. DOD reported that the total cost for the 2006 

IVAS was about $1.1 million, and given that the tools were used only to 

request or receive ballots for the November 2006 elections,30 DOD removed 

the tools from FVAP’s Web site in January 2007. Table 2 compares and 

provides additional details on the two tools. 

 29FVAP reported that, since ballot requests could be printed and returned through the mail 

or by fax instead of the secured server, an accurate reporting could not be obtained

through Tool 2. FVAP also reported that ballot requests submitted using Tool 1 could not 

be tracked and reported because voters sent the requests directly to local election officials 

using their personal e-mail accounts, mail, or fax. 

30Congress directed DOD, in June 2006, to reestablish the 2004 IVAS program. Congress

also directed, in October 2006, that DOD continue IVAS for the general election and all 

elections through December 31, 2006. 

Page 17 GAO-07-774 Elections
Table 2: Comparison of Integrated Voting Alternative Site Tools 1 and 2 for Election Year 2006 

Tool 1 Tool 2

Developer/ 

contractor 

Defense Manpower Data Center Merlin International, Incorporated’s PostX 

User(s) • Uniformed servicemembers 

• Servicemembers’ dependents

• Overseas DOD employees and contractors 

• Uniformed servicemembers 

• Servicemembers’ dependents

• Overseas DOD employees and contractors 

• Local election officials 

Tracking • System is not able to track ballot request 

forms sent to local election officials because

users submitted their Federal Post Card 

Applications directly to local election officials 

using their personal e-mail accounts. 

• System can provide only how many times it 

was accessed. 

• System is able to track ballot request forms sent to 

local election officials; local election officials reported 

that they received 8 voted ballots.a

• PostX reported 63 ballot requests were submitted to 

the system; 35 were approved—29 out of 35 blank 

ballots were viewed by voters on the system. 

Step-by-step 

process 

• Registered voters use a unique DOD 

identifier or credential to log in to the IVAS 

tool. 

• Voters complete the automated Federal Post 

Card Applications, without their signature, to 

request a ballot. 

• Voters save the Federal Post Card 

Applications to their computers as PDF files. 

• Voters e-mail the Federal Post Card 

Applications over an unsecured Internet line 

to local election officials; voters may also fax

or mail the Federal Post Card Applications to 

local election officials—depending on state or

territory procedures. 

• Registered voters use unique DOD identifier or 

credential to log in to the IVAS tool. 

• Voters complete the automated Federal Post Card 

Applications, without their signature, to request a ballot.

• Voters save the Federal Post Card Applications to the 

secure server and the system sends a notification to 

the local election officials of completed ballot requests. 

• Local election officials receive automated e-mails with 

notification of new ballot requests and log onto the 

secure server to access the Federal Post Card 

Applications. 

• Local election officials approve applications and upload 

blank ballots onto the secure server. 

• Voters log onto the secure server and fill out ballots. 

• Voters print completed ballots.

• Voters submit voted ballot directly to local election 

officials, in accordance with state law. 

• Local election officials confirm voted ballot receipts. 

• Voters log on to check confirmation of voted ballot 

receipts. 

Source: DOD information. 

a

FVAP reported that, since ballot requests could be printed and returned through the mail or by fax 

instead of the secured server, an accurate reporting could not be obtained through Tool 2. FVAP also

reported that ballot requests submitted using Tool 1 could not be tracked and reported because voters 

sent the requests directly to local election officials using their personal e-mail accounts, mail, or fax. 

Officials within Congress, and others, have expressed concerns that voters 

could be exposed to a heightened risk of identity theft if they used Tool 1 

to send voting materials that contain personally identifiable information 

(including Social Security number, date of birth, and address), by 

unsecured e-mail. FVAP officials acknowledged in their December 2006 

Page 18 GAO-07-774 Elections
report to Congress31 that Tool 1 was less secure, but said (1) DOD was 

providing access to a capability that states already provide,32 (2) most 

states and territories only required the last four digits of the Social 

Security number on the ballot requests,33 and (3) Tool 1 displayed a 

cautionary statement that voters had to read to go on with the request 

process; this cautionary statement explained the risk associated with 

e-mailing ballot requests and that the government assumed no liability if 

voters did so. While we confirmed a cautionary statement related to the

transmission of personal data did exist for Tool 1, it did not advise voters, 

after submitting their ballot request, to remove voting materials that they 

have stored on their computers. For example, voters using Internet cafes 

overseas could have been subject to identity theft if they did not delete

their personal information from the computer and a subsequent user 

gained access to the stored file. FVAP officials acknowledged that users 

were not advised of the risks of storing personal voting information on 

their computers, and these officials stated that they will incorporate 

lessons learned, such as adding a cautionary statement in any future ballot 

request system. 

Online Voting Guidance Is 

Useful but Some 

Inconsistencies Exist in 

the Links 

In addition to these initiatives, DOD also has established the FVAP Web 

site,34 which contains information on FVAP programs and links to assist 

UOCAVA voters in the voting process. Specifically, these links access 

FVAP’s online guidance, including several versions of FVAP’s biennial 

Voting Assistance Guide, shown in figure 2. 

 31DOD, Report on IVAS 2006, As Required by Section 596 of the National Defense

Authorization Act for Fiscal Year 2007, December 2006. 

32FVAP reported that states and territories allowing e-mail of the ballot request include 

Alaska, Colorado, Illinois, Indiana, Iowa (2006 only), Minnesota, Mississippi, Montana,

North Carolina, North Dakota, Oregon, Puerto Rico, South Dakota, Virginia, Washington,

and Wisconsin.

33As reported by FVAP, 7 states require the full Social Security number, 41 require the last 4 

digits or driver’s license, and 7 do not require the Social Security number. 

34DOD established this Web site in 1995. 

Page 19 GAO-07-774 Elections
Figure 2: DOD’s 2006-2007 Voting Assistance Guide

Source: DOD. 

This guide tells the UOCAVA voter how to register, request a ballot, 

receive a ballot, and vote the ballot electronically—including by e-mail or 

fax—where state or territory law allows this. One link on FVAP’s Web site 

had a full-text version of the guide, so that a Voting Action Officer35 or 

other user could download and print the entire guide and use it to provide 

assistance to absentee voters from various states and jurisdictions. 

Another link goes to a Web page containing “State-by-State Instructions,” 

where two additional links—one a PDF guide, the other an HTML 

version36—are provided for each state or territory. This allows voters to 

read or print off only their own state’s or territory’s instructions and to 

 35Service Voting Action Officers, for example, are responsible for voting assistance 

operations within their service. 

36PDF means Portable Document Format; it is a file that is used to view electronic copies of

paper documents, which allow an exact copy of the paper document. HTML means

Hypertext Markup Language and is used to structure and format documents to be displayed 

on the World Wide Web. 

Page 20 GAO-07-774 Elections
have a choice of formats.37 Another link goes to the Integrated Voting 

Alternative Site—this site provides information for the 55 states and 

territories regarding the electronic ballot request and receipt options 

available to UOCAVA voters. FVAP’s Web site also has another link to 

News Releases, which contains updates on changes to the guidance, 

including changes to state laws that affect UOCAVA voters. Finally, a link 

goes to FVAP’s Voting Assistance Guide Errata Sheets—this contains 

changes that have been made to the archived Voting Assistance Guide 

since its last printing. 

Our review of the FVAP Web site, however, revealed inconsistencies in 

some of the information about electronic transmission options that the 

voters could access through different links on the site. Our analysis 

specifically showed that, while not widespread, for 14 of the 55 states or 

territories, some of the guidance regarding requirements for electronic 

transmission was inconsistent and could be misleading, as the following 

examples illustrate: 

• For the state of California, we found that three of the FVAP links correctly 

stated that only overseas military and overseas civilian voters were eligible

to receive or return a ballot by fax; a fourth link, however, did not include 

this restriction. As a result, military personnel stationed in the United 

States, but away from their state of residence, might conclude—

incorrectly—that they were eligible to vote by fax. FVAP officials 

acknowledged this discrepancy and updated the information reached from

the fourth link on January 25, 2007, to reflect the fact that uniformed 

servicemembers must be residing or deployed overseas to be able to 

receive and send ballots by fax. 

• For the state of Colorado, we identified a news release that was issued on 

October 18, 2006, announcing a new initiative to allow uniformed 

servicemembers deployed outside the United States to request, receive, 

and return absentee ballots via e-mail. One other FVAP link reflected this 

change; however, four other links did not capture this change. FVAP 

officials acknowledged this discrepancy, updated two of the links, and 

 37The Executive Branch’s “Access Board,” which consists of cabinet-level officials from 

twelve federal agencies, among others, developed standards to implement section 508 of 

the Rehabilitation Act, which required federal agencies to have electronic information that 

is accessible to people with disabilities on government Web sites. FVAP stated that they 

provide access to an HTML version of their Voting Assistance Guide on their Web site to

comply with this act. They also provide a PDF format of the Voting Assistance Guide for 

UOCAVA voters. 

Page 21 GAO-07-774 Elections
issued an errata sheet on January 22, 2007. FVAP officials did not update 

the third link—the 2006-2007 Voting Assistance Guide accessed through 

the publications link on their Web site—stating that it was considered an 

archive document and was not intended for update. However, DOD did not 

clearly identify this link as an archived document; as a result, this link 

could mislead voters who relied on it. FVAP officials later acknowledged 

that the archived version of the 2006-2007 Voting Assistance Guide could 

have been labeled better, and eventually deleted this version from their 

Web site. 

Appendix II provides details on the inconsistencies we found on FVAP’s 

Web sites for 14 states and identifies the links, along with DOD’s 

responses regarding each. Under internal control guidance, organizations 

are to apply policies and procedures consistently.38 As noted previously, 

while the inconsistencies were not widespread, the fact that 

inconsistencies exist at all could lead UOCAVA voters— especially busy

voters residing or deployed in remote locations—to rely on incorrect 

information and therefore adversely affect their ability to vote. Agency 

officials acknowledged these discrepancies and addressed them during the 

course of our review. 

In addition, FVAP administers two online forms, (1) the Federal Post Card 

Application, which allows absentee voters to register to vote or request 

ballots; and (2) the Federal Write-in Absentee Ballot, which allows 

absentee voters to vote even if they have not yet received the absentee 

ballot they requested from their state or territory. The Federal Post Card 

Application has been online since 1999, in PDF format, and is postage-free

within the U.S. mail system when appropriate markings, provided on 

FVAP’s web site, are used. The online Federal Post Card Application 

allows voters to download a PDF version to their computers to complete,

e-mail, print, sign, and send to their local election official via mail. Some 

state and local election officials we spoke with indicated that the online 

version of the Federal Post Card Application has many benefits because it

is easy to fill out and read, and it provides sufficient space for the voter to

write in. 

Online Voting Forms 

 38GAO, Assessing Internal Controls in Performance Audits, GAO/OP-4.1.4 (Washington,

D.C.: September 1990) and Standards for Internal Control in the Federal Government 

(Exposure Draft), GAO/AIMD-98-21.3.1 (Washington, D.C.: December 1997). 

Page 22 GAO-07-774 Elections
A UOCAVA voter can also use the Federal Write-in Absentee Ballot as a 

backup ballot when the state or territory has not sent a regular absentee 

ballot in time for the voter to participate in the election. On October 21, 

2004, just a few weeks before the national election, FVAP issued a news 

release announcing the electronic version of the ballot as an emergency 

ballot. The Ronald W. Reagan NDAA for Fiscal Year 2005 amended the 

eligibility criteria in UOCAVA39 to allow states and territories to accept the

Federal Write-in Absentee Ballot under a broader range of circumstances. 

Prior to the change, a UOCAVA citizen had to be outside of the United 

States, have applied for a regular absentee ballot early enough to meet 

state election deadlines, and not have received it from the state. Under the 

new criteria, the Federal Write-in Absentee Ballot can be used by military 

servicemembers and their dependents stationed in the United States, as 

well as by military personnel, their dependents, and citizens living 

overseas. 

The Election Assistance Commission has not yet developed the Internet 

absentee voting guidelines, and because it is required by law to develop

them for DOD’s use in the secure, Internet-based, absentee voting 

demonstration project, DOD has not moved ahead with the project. 

Commission officials told us that they have not yet developed the required 

Internet absentee voting guidelines because the Commission has been 

working on other priorities—including standards for electronic voting 

machines, challenges associated with these electronic voting machines, 

and a process for certification and accreditation—and it lacks the 

resources to work on the Internet absentee voting guidelines or the 

mandated study of the issues and challenges for Internet technology at the 

same time. Although the Internet voting study is now underway, the 

Commission has said that it will not be completed until September 2007 

and thus does not have the results it needs to establish time frames or a 

plan for developing the guidelines. Regarding the demonstration project, 

DOD officials stated that they had not taken action to develop this project 

because the Ronald W. Reagan NDAA for Fiscal Year 2005 requires the 

Commission to develop the guidelines first. DOD officials stated that, in an

effort to assist the Commission in developing the Internet absentee voting

guidelines, they have provided information on prior Internet voting efforts, 

along with challenges associated with these Internet voting efforts and 

views on how to mitigate those challenges. 

Absence of Internet 

Absentee Voting 

Guidelines Has

Hindered 

Development of the 

Mandated InternetBased Absentee 

Voting Demonstration 

Project 

 39Pub. L. No. 108-375 § 566(c) (2004). 

Page 23 GAO-07-774 Elections
Commission officials stated that they have not developed Internet 

absentee voting guidelines because the Commission and the organizations

that would normally provide assistance to it are directing their constrained 

resources to other priorities. This includes addressing challenges 

associated with electronic voting machines and establishing a process for 

certification and accreditation. Additionally, the Help America Vote Act of

2002 requires the Commission’s Technical Guidelines Development 

Committee to assist the Executive Director of the Commission in 

developing voluntary voting system guidelines.40 The act also requires the 

Director of the National Institute of Standards and Technology to provide 

the Development Committee with technical support in developing those 

guidelines, including research and development related to computer and 

network security, voter privacy, remote access voting (including voting

through the Internet), and voting fraud. 

Commission officials told us, however, that the Development Committee 

has not been able to work on Internet absentee voting guidelines for 

UOCAVA voters because it had other priorities and constraints on its 

resources.41 In light of the Development Committee’s low priority for 

working on the Internet absentee voting guidelines, officials from the 

Commission asked officials from the National Institute of Standards and 

Technology to assist with developing the guidelines. However, officials 

from the National Institute of Standards and Technology said that they 

could not provide support because they also lacked sufficient resources at 

the time. Commission officials told us that, at the time of our review, the 

National Institute of Standards and Technology was also using its 

resources to work with the Development Committee on the current 

voluntary voting guidelines and would not have sufficient resources to 

work on Internet absentee voting guidelines until after July 2007. 

Additionally, Commission officials stated that they were waiting for DOD 

to provide information that describes the type of system around which the 

The Commission Has Not 

Developed Internet 

Absentee Voting 

Guidelines because of 

Other Priorities, 

Constraints on Resources, 

and Lack of DOD 

Information 

 40These guidelines provide a set of specifications and requirements to be used in the 

certification of computer-assisted voting systems, both paper-based and fully electronic, 

and are voluntary—that is, states are free to adopt them in whole or in part or to reject

them entirely. 

41For example, Commission officials told us that the Development Committee is working

on updates to the Voluntary Voting System Guidelines that were established in 2005. These 

guidelines will become effective December 2007. The guidelines focus primarily on 

electronic voting machines and ballot counters, but not on Internet voting systems for 

UOCAVA voters. 

Page 24 GAO-07-774 Elections
guidelines should be developed. DOD officials, however, stated that they 

gave the Commission reports that provided the framework for the 

Internet-based absentee voting system they envisioned. Specifically, these

DOD officials told us that they provided the Commission, in 2004, with a 

report on their 2000 proof of concept for Internet-based voting called 

“Voting Over the Internet,”42 and in March 2006, they provided the 

Commission with an internal DOD document assessing the terminated 

SERVE project. DOD and Commission officials told us that they had not 

communicated in depth on the guidelines and the DOD system before our 

review. 

To gain a better understanding of the Internet voting environment, in 

September 2006, the Commission started an Internet voting study as a 

precursor to developing the Internet absentee voting guidelines. The Help

America Vote Act of 2002 required the Commission to conduct this study 

to determine the issues and challenges presented by incorporating 

communications and Internet technology into elections, including the 

potential for election fraud, and to issue a report no later than June 29, 

2004. However, the Commission did not meet this reporting date. 

Commission officials told us that they were unable to complete the study 

sooner—or even begin it—because of the resource constraints they have 

worked under since the Commission’s inception, and because they were 

working on other priorities. They noted, for example, that under the act,

the Commission was to be established by February 26, 2003, but the 

Commissioners were not appointed until almost a year later, in December, 

2003. They also told us that, although 23 employees were allocated to the 

Commission, they had to build up staff gradually, starting in January 2004,

by hiring two employees each month. Accordingly, Commission officials 

testified in June 200443 that, as a result of these constraints, the 

Commission was able to meet only some of its mandates, such as 

developing the 2005 Voluntary Voting System Guidelines. As a result, the 

Commission was not able to conduct the Internet voting study in a timely 

manner. 

The Election Assistance 

Commission Has Started a 

Study as a Precursor to the 

Internet Absentee Voting 

Guidelines 

 42Department of Defense, Federal Voting Assistance Program: Voting Over the Internet, 

June 2001. 

43Statement of U.S. Election Assistance Commission before the U.S. House Of 

Representatives, Committee on House Administration, dated June 17, 2004. 

Page 25 GAO-07-774 Elections
Commission officials stated that the Internet voting study, which was 

underway during the course of our review, includes several case studies to 

monitor current Internet voting usage and electronic transmission of 

ballots. The four states participating in this part of the study are Florida, 

Montana, South Carolina, and Illinois. The study also includes (1) a survey 

of UOCAVA voters to collect information on their level of interest in 

electronic voting and (2) a conference to gather states’ experiences on 

topics such as Internet voting, electronic transmission of ballots, security 

risks for voting systems, and verification of voters’ identities. Commission

officials told us that they plan to issue a final report on the Internet voting 

study in September 2007. 

The Ronald W. Reagan NDAA for Fiscal Year 2005 did not establish a 

deadline by which the Commission was to complete the Internet absentee

voting guidelines, and the Commission has not set time frames for itself, 

primarily because it has been working on guidelines for current voting

systems. Additionally, as stated previously, the Commission has not 

completed the precursor Internet voting study to identify critical issues 

and challenges such as those related to security and privacy. Also, it has 

not established a plan, in conjunction with major stakeholders like DOD, 

to develop appropriate guidelines for Internet voting with specific tasks 

that would address security risks such as those identified in its study and 

other security evaluations and reports, as well as time frames and 

milestones. 

In previous reports, we have noted that leading organizations develop 

long-term results-oriented plans that involve all stakeholders and identify

specific tasks, milestones, time frames, and contingency plans;44 this 

practice is also embodied in the underlying principles of the Government 

Performance and Results Act of 1993.45 Similarly, without a plan for the 

UOCAVA Internet absentee voting guidelines—including specific tasks, 

time frames, milestones, necessary resources, and alternatives—the 

Commission cannot inform Congress, FVAP, and local election officials 

when it will meet the mandate to develop the required guidelines. As we 

The Commission Does Not 

Have a Plan for Assessing 

Security Issues and 

Developing Internet 

Absentee Voting 

Guidelines 

 44GAO, Executive Guide: Effectively Implementing the Government Performance and

Results Act, GAO-GGD-96-118 (Washington, D.C.: June 1996) and Military Readiness: 

Navy’s Fleet Response Plan Would Benefit from a Comprehensive Management Approach

and Rigorous Testing, GAO-06-84 (Washington, D.C.: Nov. 22, 2005). 

45Pub. L. No. 103-62 (1993). 

Page 26 GAO-07-774 Elections
previously noted, some technologies may not yet be mature enough to 

support Internet voting. Therefore, the plan for developing Internet 

absentee voting guidelines may require an incremental approach that 

reflects emerging solutions to security and privacy challenges, as well as 

changing views on acceptable levels of risk and cost. 

Similarly, DOD has not developed a secure, Internet-based absentee voting

demonstration project, as Congress mandated in the Ronald W. Reagan 

NDAA for Fiscal Year 2005. DOD reported that the principal objective of 

the Internet-based electronic demonstration project was to assess the use 

of such technologies to improve UOCAVA participation in elections. The 

department planned to conduct the project during the first general 

election for federal office after the Commission has established Internet

voting guidelines for the project. However, DOD has not moved forward 

with the electronic demonstration project because, by law, the 

Commission must first develop the Internet absentee voting guidelines. 

DOD officials stated, as mentioned previously, that they provided 

information to assist the Commission in developing the guidelines, and 

Commission officials acknowledged that DOD had provided them with a 

report on “Voting Over the Internet,” DOD’s assessment of its November 

2000 Internet-based voting project, in 2004—the first year of the 

Commission’s operation. DOD also provided the Commission with an 

internal document that contained information on its SERVE project. 

However, Commission officials told us that they did not receive the 

SERVE document until June 2006. This document discussed challenges 

DOD identified with Internet voting, which included security threats such 

as computer viruses, malicious insider attacks, and inadvertent errors that 

could disrupt system performance. 

In 2001, we also identified several challenges to Internet voting, such as 

privacy and security.46 As previously mentioned, we reported that broad 

application of Internet voting faced formidable challenges, including the

difficulty of providing adequate voter privacy—that is, protecting the 

voter’s ability to cast a ballot without being observed. We further reported 

that, although not unanimous on all issues, groups considering the pros 

and cons of Internet voting were in consensus in identifying security as the 

primary technical challenge for Internet voting. We also reported that, 

DOD Has Not Developed a 

Secure, Internet-based, 

Absentee Voting 

Demonstration Project 

 46GAO-01-1026; GAO-02-3. 

Page 27 GAO-07-774 Elections
because of the security risks involved, Internet voting would not likely be

implemented on a large scale in the near future. Moreover, DOD officials 

told us that even if the Commission had developed Internet voting 

guidelines at the time of our review, DOD would not have been able to 

develop a secure, Internet-based, electronic demonstration project in time 

for the 2008 presidential election. DOD officials said that—depending on 

the Internet voting guidelines provided by the Commission—the final 

system design, full development, testing and deployment phases would 

take an estimated 24 to 60 months. Furthermore, deployment of any 

system requires participation of the military services, which have many 

additional, competing priorities that may cause delays in deployment. 

Given that less than 17 months remain before the November 2008 election,

FVAP officials said there is insufficient time to advertise and launch the 

Internet-based electronic demonstration project.

We observed that DOD was developing, but had not yet completed, plans 

to expand the use of electronic voting technology for UOCAVA voters use 

in federal elections through November 2010, as required by the John 

Warner NDAA for Fiscal Year 2007. DOD officials told us that they 

anticipated providing the plans to Congress, in accordance with the act, by 

May 15, 2007. Because electronic voting initiatives for the absentee voting

process (fax, e-mail, and Internet) involve numerous stakeholders at the 

federal level—including DOD and the Commission—as well as the various 

state and local levels, developing a plan is key. Implementation of new 

electronic voting initiatives requires careful planning, particularly in light 

of the remote location of troops, the application of new technology, and 

the lead time required for implementation. As DOD develops these plans, 

employing a comprehensive strategic approach that incorporates sound 

management principles could provide a framework for DOD’s plans. Our 

analyses of DOD and Commission documents and our interviews—

including those with officials from these agencies, organizations 

representing UOCAVA voters, and state and local election officials—show 

that DOD did not obtain sufficient stakeholder involvement in planning its 

recent electronic voting initiatives—the 2004 and 2006 IVAS initiatives. In 

fact, Commission officials mentioned that DOD’s recent initiatives took a 

“top down” approach and did not seek input from the Commission or from 

local jurisdictions during the planning stage. DOD officials noted that both 

the 2004 and 2006 IVAS initiatives were planned, designed, advertised, and 

implemented just months before those two elections. In the case of the 

2006 IVAS, however, the department reported that it developed the system 

within 79 days of passage of the mandate—June 2006—and noted that it 

was in fact responsive to that mandate. The Commission and state and 

DOD Was Developing 

Plans to Expand the 

Use of Electronic 

Voting Technology in 

the Future, but Sound 

Management 

Practices Are Key 

Page 28 GAO-07-774 Elections
local election officials noted that the aggressive schedules for these latest 

electronic initiatives did not allow sufficient time to enable full

participation, training, and dissemination of information on the efforts. 

Additionally, at the time of our review, DOD officials said they had not yet 

established interim tasks that address issues such as security and privacy,

milestones, time frames, and contingency plans. 

The principles of sound management used by leading organizations and 

embodied in the Government Performance and Results Act of 199347

provide a methodology to establish a results-oriented framework for DOD 

to develop its detailed plans. Such a framework would provide a firm 

foundation for DOD’s long-term plan for electronic voting initiatives. Some 

of the key management principles include (1) involving stakeholders when 

defining the mission and outcomes, (2) identifying specific actions and 

tasks, such as monitoring and assessing security of the initiatives, 

(3) developing schedules and time frames for tasks, and (4) evaluating the 

overall effort, with specific processes to allow for adjustments and 

changes. Furthermore, as we reported in one of our executive guides, 

leading organizations plan for a continuous cycle of risk management. This

includes determining needs, assessing security risks, implementing 

policies and controls, promoting awareness, and monitoring and 

evaluating controls.48 Combined with effective leadership, these principles 

provide decision makers with a framework to guide program efforts and 

the means to determine if these efforts are achieving the desired results. 

In its December 2006 report to Congress on IVAS,49 DOD stated the 

following: 

• Development of a long-term strategic plan was necessary to ensure that all 

related initiatives were effectively integrated, but this was dependent on 

having sufficient time to assess, improve, and evaluate new or evolving 

electronic alternatives. 

• Major recommendations for its future electronic voting projects would 

include, for example, 

• recognizing the variation in state and local laws, procedures, and 

systems; 

 47Pub. L. No. 103-62 (1993). GAO/GGD-96-118. 

48GAO, Executive Guide: Information Security Management, Learning From Leading 

Organizations, GAO/AIMD-98-68 (Washington, D.C.: May 1998). 

49DOD, Report on IVAS 2006. 

Page 29 GAO-07-774 Elections
• identifying and mitigating actual and perceived risks, by educating 

people about risk management practices; and 

• building consensus among key stakeholders. 

As stated previously, Commission officials told us that, for recent 

initiatives, DOD did not seek input from the Commission or local 

jurisdictions during the planning stage of these efforts. Without a 

proactive, integrated, long-term, results-oriented plan that involves all 

major stakeholders; includes goals, interim tasks—such as identifying 

security risks and addressing privacy concerns—milestones, time frames, 

and contingency plans; and follows the sound management practices used 

by leading organizations, DOD is not in a position to address congressional 

expectations to establish secure and private electronic and Internet-based

voting initiatives. 

It is imperative that the 6 million Americans who are covered under the 

Uniformed and Overseas Citizens Absentee Voting Act have the 

opportunity to exercise their right to vote—one of the hallmarks of a 

democratic society. The fact that time is an issue with absentee voting by 

regular mail has led many to look toward electronic and Internet voting, 

which represent the next generation of voting technology, as alternatives.

While these alternatives may expedite the absentee voting process, they 

are more vulnerable to privacy and security compromises than the 

conventional methods now in use. Electronic and Internet voting require 

safeguards to limit such vulnerabilities and prevent compromises to votes 

from intentional actions or inadvertent errors. However, available 

safeguards may not adequately reduce the risks of compromise. To date,

the Election Assistance Commission has not assessed the risks or possible 

safeguards for Internet voting, nor has it developed corresponding 

guidelines that define minimum Internet voting capabilities and safeguards 

to be considered by the election community. Furthermore, electronic and 

Internet-based absentee voting can be challenging for UOCAVA voters, 

who reside at multiple locations across the globe. These voters are also 

registered to vote in thousands of local jurisdictions across 55 states and 

territories that employ varying levels of technology—from paper ballots to 

faxes and e-mail. DOD faces significant challenges in leveraging electronic 

and Internet technology to facilitate this complex, global absentee voting 

process. Delays in developing guidelines and a demonstration project have 

resulted in two presidential elections passing without significant progress

in moving toward expanded use of electronic and Internet absentee voting. 

DOD officials told us it is now too late in the cycle to implement 

significant changes before the 2008 election. The challenges of

Conclusions 

Page 30 GAO-07-774 Elections
coordinating among numerous stakeholders—including DOD, the 

Commission, and state and local election officials, as well as organizations 

representing UOCAVA voters—are substantial, and, to date, efforts to 

involve stakeholders in the planning stage of DOD’s recent initiatives have 

fallen short. This delay has left an expectation gap between what Congress 

required and what has been accomplished so far. Several steps would have 

to be taken to overcome these challenges, including better coordination 

between the Commission and DOD regarding their complementary roles in

developing Internet voting guidelines and the mandated demonstration 

project. Unless the Commission and DOD move in a timely manner to 

assess the technology risks, develop guidelines that address the risks, 

coordinate among election stakeholders, and establish and execute 

prudent plans, they are unlikely to meet the expectations of Congress and 

military and overseas voters to establish a secure and private electronic 

and Internet-based UOCAVA voting environment. 

To improve the security and accuracy of DOD’s electronic and Internet 

initiatives, we recommend that the Secretary of Defense direct the Under 

Secretary of Defense for Personnel and Readiness to take the following 

four actions:

Recommendations for 

DOD 

• Comply with the information security requirements in the DOD 

Certification and Accreditation Process guidance.

• Incorporate lessons learned into plans for future systems such as those we 

identified, including adding cautionary statements to future ballot request 

and receipt systems to warn UOCAVA voters to remove personal data 

from their computers. 

• Institutionalize a process to review online UOCAVA guidance to ensure

that DOD provides accurate and consistent information to UOCAVA 

voters. 

• Create an integrated, comprehensive, long-term, results-oriented plan for 

future electronic voting programs that specifies, among other things, the 

goals to be achieved along with tasks including identifying safeguards for 

the security and privacy of all DOD’s voting systems—both electronic and 

Internet. The plan should also specify milestones, time frames, and 

contingencies; synchronize them with planned development of the 

Commission’s guidelines for Internet voting; and be developed in 

conjunction with major stakeholders—including state and local election 

officials, the Election Assistance Commission, overseas voting groups, and 

each of the armed services. The plan should also include initiatives that 

will be done well in advance of federal elections, to allow adequate time 

Page 31 GAO-07-774 Elections
for training and dissemination of information on the options available to 

UOCAVA voters. 

To improve the Election Assistance Commission’s efforts to comply with 

the direction from Congress to develop the Internet absentee voting 

guidelines, we recommend that the Commission take the following two 

actions: 

• Determine, in conjunction with major stakeholders like DOD, whether the 

Commission’s 2007 Internet voting study and any other Commission 

efforts related to Internet or electronic voting are applicable to DOD’s 

plans for Internet-based voting, and incorporate them where appropriate.

• Develop and execute, in conjunction with major stakeholders—including 

state and local election officials and DOD—a results-oriented action plan 

that specifies, among other things, goals, tasks, milestones, time frames, 

and contingencies that appropriately address the risks found in the 

UOCAVA voting environment—especially risks related to security and 

privacy. 

In written comments on a draft of this report, DOD concurred with our 

recommendations to (1) comply with the information security

requirements, (2) incorporate lessons learned into plans for future 

systems—to include adding cautionary statements to warn UOCAVA 

voters to remove personal data from their computers, (3) institutionalize a 

process to review online UOCAVA guidance, and (4) create a 

comprehensive, results-oriented, long-term plan for future electronic 

voting initiatives. The department said that it will contract for services to 

comply with the information security requirements and will incorporate 

identified lessons learned into future registration, ballot request, and ballot 

receipt systems. The department said that it has already streamlined its 

online guidance by, among other things, eliminating the archived 

“Publications” version of the Voting Assistance Guide entirely; it will also

establish a revised review process for online information. DOD noted that 

these changes will reduce the possibility of human error and simplify the 

review and verification process of online information. Finally, DOD stated 

that it was in full support of a long-term, comprehensive plan for future 

electronic voting projects that would allow for sufficient time to involve 

the major stakeholders, train, and disseminate information and ultimately 

serve UOCAVA voters. The department said it looked forward to working 

on this multiyear project plan in cooperation with the Election Assistance 

Commission, the National Institute of Standards and Technology, and 

Recommendations for 

the Election 

Assistance 

Commission 

Agency Comments 

and Our Evaluation 

Page 32 GAO-07-774 Elections
other major stakeholders. It further stated that FVAP, the Commission, 

and the National Institute of Standards and Technology are scheduling a 

meeting to lay the groundwork for the plan. DOD’s comments are 

reprinted in appendix III. DOD also provided technical comments, which 

we incorporated in the final report, as appropriate. 

In its written comments, the Election Assistance Commission concurred 

with our recommendations to (1) determine the applicability of the 

Commission’s 2007 Internet voting study and other Commission studies to 

DOD’s plans for Internet-based voting, and (2) develop and execute a 

results-oriented action plan to provide guidelines that appropriately 

address the risks found in the UOCAVA voting environment. The 

Commission stated that it has already met with FVAP and the National 

Institute of Standards and Technology and agreed to develop a time line 

for creating the UOCAVA guidelines. The Commission’s comments are 

reprinted in appendix IV.

We are sending copies of this report to the Secretary of Defense and the 

Under Secretary of Defense (Personnel and Readiness) and the 

Commissioners of the Election Assistance Commission. We will also make 

copies available to others upon request. In addition, the report will be 

available at no charge on the GAO Web site at http://www.gao.gov. 

Should you or your staff have any questions about this report, please 

contact me at (202) 512-5559. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. Key contributors to this report are listed in appendix V. 

Derek Stewart 

Director, Defense Capabilities and Management 

Page 33 GAO-07-774 Elections
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To assess DOD’s electronic initiatives, we reviewed and analyzed relevant 

laws, directives, and guidance. These included DOD Directive 1000.4, 

Federal Voting Assistance Program (FVAP), updated April 14, 2004; and 

DOD’s Interim Department of Defense (DOD) Certification and 

Accreditation (C&A) Process Guidance, dated July 6, 2006. We also 

reviewed applicable requirements documents for DOD’s electronic efforts, 

as well as relevant reports by GAO, DOD, FVAP, the DOD Inspector 

General, and others, including A Security Analysis of the Secure 

Electronic Registration and Voting Experiment (SERVE), dated January 

21, 2004. In addition, we reviewed FVAP’s 2006-2007 Voting Assistance 

Guide and its Web site to ascertain what type of information on electronic 

voting alternatives is provided to UOCAVA citizens.

We interviewed key program officials at the Office of the Under Secretary 

of Defense for Personnel and Readiness’s Federal Voting Assistance 

Program (FVAP), the Business Transformation Agency, the Defense 

Manpower Data Center, and Voting Action Officers from several service 

headquarters. We also contacted officials from (1) election organizations, 

including the National Association of Secretaries of State and Joint 

Election Officials Liaison Committee and (2) organizations representing

UOCAVA voters, including those from the National Defense Committee 

and the Overseas Vote Foundation. We made contact with officials from 

14 of the 16 state and local election offices we called to obtain their 

perspectives on DOD’s initiatives. Specifically, we included all 11 states 

that had participated in DOD’s 2006 Integrated Voting Alternative Site—

some of which participated in SERVE and other DOD programs and 

initiatives. We also included three other states that had 10 or more military 

bases and had participated in SERVE though not in IVAS. Table 3 lists the 

states we contacted and the programs in which these states participated.

Page 34 GAO-07-774 Elections
Appendix I: Scope and Methodology 

Table 3: State Offices Contacted and Programs Where the States Were Participants

States contacted SERVE participantsaIVAS Tool 1 participantsaIVAS Tool 2 participantsa

1 Arkansas Yes Yes No

2 Florida Yes No No

3 Hawaii Yes No No

4 Illinois No Yes No

5 Indiana No No Yes

6 Kentucky No No Yes

7 Mississippi No Yes No

8 Montana No No Yes

9 North Carolina Yes Yes No

10 Puerto Rico No Yes No

11 South Carolina Yes No No

12 Vermont No Yes No

13 Virgin Islands No Yes No

14 Washington Yes Yes No

Totals 14 states contacted 6 SERVE states contacted 8 IVAS Tool 1 states contacted 3 IVAS Tool 2 states 

contacted

Source: GAO analysis of DOD data. 

a

While a number of jurisdictions were included under each of the DOD programs listed, we spoke to 

at least one election official from each state. 

To determine the Commission’s efforts to develop Internet voting 

guidelines and DOD’s efforts to develop the secure, Internet-based, 

absentee voting demonstration project, we reviewed and analyzed relevant 

laws, Commission reports, and to the extent they existed, the 

Commission’s strategic plan and other documents to ascertain its plans 

and efforts to develop Internet voting guidelines for UOCAVA voters. We

also reviewed and analyzed various DOD requirements documents, GAO 

reports, internal DOD reports, and other reports related to DOD’s prior 

Internet-based absentee voting initiatives—Voting Over the Internet and 

SERVE—to ascertain, among other things, challenges and benefits 

associated with Internet voting efforts. Additionally, we interviewed key 

program officials within FVAP, including the Director and Deputy Director 

of FVAP and the Project Manager for SERVE, who is currently retired, 

along with officials on DOD’s private sector Security Peer Review Group. 

We also spoke with officials on the Commission’s Technical Guidelines 

Page 35 GAO-07-774 Elections
Appendix I: Scope and Methodology 

Development Committee and with the National Institute of Standards and 

Technology.

To ascertain DOD’s efforts to develop plans to expand the use of 

electronic voting technologies in the future, we reviewed and analyzed 

laws, guidance, and reports to determine DOD’s current and future plans 

for the Internet-based absentee voting demonstration project. Additionally, 

we examined, to the extent they existed, DOD’s strategic plan and other 

documentation to determine its current and future plans for the Internetbased absentee voting demonstration project. We also interviewed 

responsible officials within DOD about these plans—including the 

Principal Deputy Under Secretary of Defense for Personnel and Readiness 

and the Director and Deputy Director of FVAP. 

We conducted our work from August 2006 through April 2007 in 

accordance with generally accepted government auditing standards. 

Page 36 GAO-07-774 Elections
Appendix II: Examples of the Inconsistent

Voting Assistance Guidance on DOD’s Web Appendix II: Examples of the Inconsistent Site 

Voting Assistance Guidance on DOD’s Web 

Site 

During the course of our review, we compared and analyzed the voting

assistance guidance provided on DOD’s Federal Voting Assistance 

Program (FVAP) Web site that covered electronic alternatives to mail. The 

online links we reviewed included FVAP’s: (1) 2006-2007 Voting Assistance 

Guide (VAG)—a PDF version;1

 (2) 2006-2007 VAG—an HTML version; 2 

(3) the archived 2006-2007 VAG—a PDF version dated October 25, 2005;3

(4) changes to the archived 2006-2007 VAG—called Errata Sheets; 

(5) News Releases; and (6) the 2006 Integrated Voting Alternative Site

(IVAS). While not widespread, for 14 of the 55 states and territories, we 

found differences in some of the guidance provided on these links.4

 Table 

4 shows the differences we identified. 

Table 4: Inconsistencies Identified in Guidance on Electronic Alternatives to Mail 

State Differences identified Questions FVAP response GAO observation 

1 California Both PDF versions and the 

HTML Voting Assistance 

Guides state that only 

overseas military and overseas

citizens may receive and send

the ballot by fax. 

IVAS instruction does not 

restrict who can receive or 

send the ballot by fax. 

Could an absentee 

ballot sent by fax by 

military personnel within 

the United States be 

rejected if a voter 

covered under the 

Uniformed and

Overseas Citizens 

Absentee Voting Act 

relied solely on IVAS for 

voting guidance? 

IVAS page was incorrect 

and was updated 

on1/25/07. The instruction 

should have specified that 

Uniformed 

Servicemembers must be 

overseas to receive and 

send the ballot by fax. By 

law, an absentee ballot 

faxed from within the 

United States should be 

rejected. 

Correction to IVAS has 

been verified. 

 1

PDF means Portable Document Format; it is a file format that is used to view electronic 

copies of paper documents, which allows an exact copy of the paper document. 

2

HTML means Hypertext Markup Language and is used to structure and format documents

to be displayed on the World Wide Web. 

3

This 2006-2007 VAG was accessed at http://www.fvap.gov/pubs/vag/pdfvag/2006-07vag.pdf; 

but DOD deleted this link in February 2007. 

4

We found 16 instances in total. Two of the states had two separate discrepancies

identified. 

Page 37 GAO-07-774 Elections
Appendix II: Examples of the Inconsistent

Voting Assistance Guidance on DOD’s Web 

Site 

State Differences identified Questions FVAP response GAO observation 

2 Colorado The News Release for 

Colorado on October 18, 2006, 

and IVAS “allow Uniformed 

Servicemembers deployed 

outside the U.S. to request, 

receive, and return absentee 

ballots via e-mail.” 

This is not reflected in the two 

PDF versions or HTML Voting

Assistance Guides, nor was an

errata sheet created. 

Would overseas

uniformed voters know 

of the e-mail options if 

they relied on the Voting

Assistance Guide for 

voting guidance? 

The Voting Assistance 

Guide, PDF, HTML, and 

errata sheet have been 

updated to reflect the 

change. Web site 

changes to the Voting 

Assistance Guide were

made January 22, 2007. 

Corrections to PDF, 

HTML, and errata sheet 

have been verified. 

FVAP stated that the 

“Publications” version of 

the Voting Assistance 

Guide in PDF format 

was the original book 

version of the Guide in

electronic form. Since it 

was considered an 

archived document, 

FVAP officials stated 

that it was not intended 

for update; but, 

acknowledged that this 

version could have 

been marked better as 

an archived document. 

These officials have 

since deleted this 

version of the Guide 

from their Web site. 

3 Illinois FVAP issued an errata sheet 

for Illinois on September 29, 

2006, and all changes except 

one are reflected in the HTML

and PDF “Publications” 

versions of the Voting 

Assistance Guide and IVAS did 

not mention the change. 

Specifically, the change that is

not captured is in Item IIE 

(Uniformed Services): 

“The Publications” PDF and 

HTML Voting Assistance 

Guides say Illinois does not 

allow receipt of blank ballots by 

fax or e-mail and IVAS does 

not address this issue. 

Would uniformed voters 

be aware of the fax and 

e-mail provisions if they 

relied on IVAS, HTML 

Voting Assistance 

Guide, or “publications” 

PDF version? 

The fax and e-mail 

provisions on the errata 

sheet and the Voting 

Assistance Guide PDF

are correct as accepted

by the State of Illinois. 

The IVAS page and the 

Voting Assistance Guide 

HTML were missing the 

information about the City 

of Chicago and Suburban 

Cook County allowing 

receipt of the blank ballot 

by fax or e-mail. The 

information was added on 

both the IVAS and the 

HTML on January 26, 

2007. 

See note below on 

“Publications” version of 

the Voting Assistance 

Guide.a

 

Corrections to IVAS and 

HTML have been 

verified. 

FVAP officials 

acknowledged that the 

“Publications” version of 

the Voting Assistance 

Guide could have been 

marked better as an 

archived document, and 

have since deleted this 

version of the Guide 

from their Web site. 

Page 38 GAO-07-774 Elections
Appendix II: Examples of the Inconsistent

Voting Assistance Guidance on DOD’s Web 

Site 

State Differences identified Questions FVAP response GAO observation 

4 North Carolina FVAP issued a News Release

and updated IVAS on October

20, 2006, stating that North 

Carolina now allows all citizens

covered under the Uniformed 

and Overseas Citizens 

Absentee Voting Act to, among 

other things, receive blank 

absentee ballots and return 

voted ballots by fax. It also 

stated that the Federal Post 

Card Application could be 

faxed or e-mailed. 

This information was not 

reflected in the FVAP PDFs or

HTML versions of the Voting 

Assistance Guide, nor was an

errata sheet created. 

Would voters covered 

under the Uniformed 

and Overseas Citizens 

Absentee Voting Act 

know of the fax or e-mail 

options if they relied on 

the Voting Assistance 

Guide publications? 

Voting Assistance Guide 

pages updated to reflect 

information contained in 

News Release on January 

29, 2007. 

See note below on 

“Publications” version of 

the Voting Assistance 

Guide.a

Corrections to PDF and 

HTML Voting 

Assistance Guide and 

errata sheet have been 

verified. 

FVAP officials 

acknowledged that 

“Publications” version of 

the Voting Assistance 

Guide could have been 

marked better as an 

archived document, and 

have since deleted this 

version of the Guide 

from their Web site. 

5 Rhode Island Rhode Island’s Overseas 

Civilians instructions for 

FVAP’s PDFs and HTML 

Voting Assistance Guide 

include language in Section 

IIIB stating that ballots “may be 

requested by using the Federal 

Post Card Application, letter, 

telephone, fax, or e-mail.” 

This language contradicts 

guidance in Section IIIE of the 

HTML and PDF Voting 

Assistance Guides which only

mentions fax transmissions. 

Furthermore, the IVAS Web 

site says no e-mail is 

permitted. 

Would overseas

civilians know of the 

option to request the

blank ballot by e-mail if 

they relied on Section 

IIIE of the Voting 

Assistance Guide or 

IVAS? 

The language in question 

does not refer to the 

ability of the voter to 

request an absentee 

ballot via e-mail, but to 

request that a copy of a 

state form (now 

discarded) be sent to 

them, which could be

requested by using a 

Federal Post Card 

Application, via fax, email, phone, etc. Given 

that the state form has 

been discarded, the 

Voting Assistance Guide 

has been updated to 

reflect the change. Web 

site changes to the Voting 

Assistance Guide were

made January 29, 2007. 

Corrections to the PDF,

HTML, IVAS, and errata 

sheet have been 

verified. 

Page 39 GAO-07-774 Elections
Appendix II: Examples of the Inconsistent

Voting Assistance Guidance on DOD’s Web 

Site 

State Differences identified Questions FVAP response GAO observation 

6 South Dakota South Dakota’s errata sheet 

from June 19, 2006 and the 

PDF Voting Assistance Guide

require the Federal Post Card

Application be notarized for 

stateside military voters. 

This is not mentioned as a 

requirement in IVAS, or the 

HTML or “Publications” Voting

Assistance Guide. 

(Specifically, these say that “no 

registration or voting materials 

are notarized or witnessed.”) 

Would stateside military 

voters know that they 

are required to have the 

Federal Post Card 

Application notarized if 

they rely on IVAS, 

HTML or “Publications” 

Voting Assistance 

Guides instead of the 

errata sheet? 

The change was made by 

South Dakota and 

approval signed. The PDF

and errata sheet were 

changed, the HTML was 

overlooked, and 

correction was made 

January 26, 2007. The 

IVAS page did not contain 

full instructions but 

referred the reader to the 

Voting Assistance Guide 

instructions. 

See note below on 

“Publications” version of 

the Voting Assistance 

Guide.a

 

Correction to the HTML 

has been verified. 

IVAS referred the voter 

to the Voting Assistance 

Guide instructions. 

FVAP officials 

acknowledged that 

“Publications” version of 

the Voting Assistance 

Guide could have been 

marked better as an 

archived document, and 

have since deleted this 

version of the Guide 

from their Web site. 

7 South Dakota South Dakota’s errata sheet 

from October 4, 2006, and 

HTML and PDF Voting 

Assistance Guides allow voters

covered under the Uniformed 

and Overseas Citizens 

Absentee Voting Act to send 

the Federal Post Card 

Application by fax and allow a 

voter to submit a scanned 

application as an e-mail

attachment. 

This is not reflected in the 

“Publications” Voting 

Assistance Guide. 

Would voters covered 

under the Uniformed 

and Overseas Citizens 

Absentee Voting Act 

know of the option to 

send the Federal Post 

Card Application by fax 

or via e-mail attachment 

if they relied on the 

“Publications” Voting 

Assistance Guide? 

See note below on 

“Publications” version of 

the Voting Assistance 

Guide.a

FVAP officials 

acknowledged that 

“Publications” version of 

the Voting Assistance 

Guide could have been 

marked better as an 

archived document, and 

have since deleted this 

version of the Guide 

from their Web site. 

8 Utah Utah’s errata sheet from May 

11, 2006, and PDF Voting 

Assistance Guide (uniformed 

services) states that 

registration and voting 

materials are not notarized or 

witnessed. 

This is not reflected in the 

HTML or PDF “Publications” 

version of the Voting 

Assistance Guide. 

For example, the HTML Voting

Assistance Guide says that no

notary or witness is required, 

but mentions certification. 

Would uniformed voters 

know that they were not 

required to have their 

voting materials 

notarized if they relied 

on the HTML or

“Publications” Voting 

Assistance Guide? 

Change was made to 

reflect Utah’s election law 

and approval signed. The 

PDF and errata sheet 

were corrected, however, 

the HTML was 

overlooked. Correction 

was made January 26, 

2007. See note below on 

“Publications” version of 

the Voting Assistance 

Guide.a

Correction to the HTML 

has been verified. 

FVAP officials 

acknowledged that 

“Publications” version of 

the Voting Assistance 

Guide could have been 

marked better as an 

archived document, and 

have since deleted this 

version of the Guide 

from their Web site. 

Page 40 GAO-07-774 Elections
Appendix II: Examples of the Inconsistent

Voting Assistance Guidance on DOD’s Web 

Site 

State Differences identified Questions FVAP response GAO observation 

9 Vermont While the notary section of 

Civilian Outside U.S. in the 

PDF Voting Assistance Guide

has the statement about 

witness requirements for the 

return ballot, it does not have 

the statement: “However, your

signature must be on the inside

envelope certificate.” 

This line is reflected in the 

HTML Voting Assistance Guide

and in all notary sections of the 

Uniformed Services Voting

Assistance Guides. 

Would overseas

civilians know that their 

signature is required on 

the inside envelope 

certificate if they relied 

on the PDF Voting 

Assistance Guide? 

The PDF Voting 

Assistance Guide had the 

signed approval of 

Vermont. The missing line 

was simply overlooked by 

the state and FVAP and 

was updated on January 

25, 2007. 

Correction to the PDF

has been verified. 

10 Alaska The HTML, “State-by-State” 

PDF Voting Assistance Guide,

and IVAS instruction allow emailing of the blank ballot and 

voted ballot. 

This is not reflected in the 

“Publications” version of the 

PDF Voting Assistance Guide

for Alaska. 

Would voters covered 

under the Uniformed 

and Overseas Citizens 

Absentee Voting Act 

know of the option to email the blank and voted 

ballot if they relied on

the “Publications” Voting 

Assistance Guide? 

See note below on 

“Publications” version of 

the Voting Assistance 

Guide.a

FVAP officials 

acknowledged that 

“Publications” version of 

the Voting Assistance 

Guide could have been 

marked better as an 

archived document, and 

have since deleted this 

version of the Guide 

from their Web site. 

11 Oregon An errata sheet on August 22,

2006 for Oregon and the HTML

and PDF Voting Assistance 

Guides added, in addition to 

faxing, the words “or e-mail” to

the electronic transmission 

sections in the Voting 

Assistance Guide. 

This information is not reflected 

in the “Publications” version of

the Voting Assistance Guide. 

Would voters covered 

under the Uniformed 

and Overseas Citizens 

Absentee Voting Act 

know of the option to 

use e-mail for their 

voting materials if they 

relied on the 

“Publications” Voting 

Assistance Guide? 

See note below on 

“Publications” version of 

the Voting Assistance 

Guide.a

FVAP officials 

acknowledged that 

“Publications” version of 

the Voting Assistance 

Guide could have been 

marked better as an 

archived document, and 

have since deleted this 

version of the Guide 

from their Web site. 

12 South Carolina An errata sheet and a news 

release on May 5, 2006 and 

the HTML and PDF Voting 

Assistance Guides announced

that voters are allowed to 

receive and return the ballot by

fax or e-mail under any 

conditions or circumstances. 

This information is not reflected 

in the “Publications” version of

the Voting Assistance Guide, 

which only allows fax and email for emergencies. 

Would voters covered 

under the Uniformed 

and Overseas Citizens 

Absentee Voting Act 

know of the fax and email options if they 

relied on the 

“Publications” Voting 

Assistance Guide? 

See note below on 

“Publications” version of 

the Voting Assistance 

Guide.a

FVAP officials 

acknowledged that 

“Publications” version of 

the Voting Assistance 

Guide could have been 

marked better as an 

archived document, and 

have since deleted this 

version of the Guide 

from their Web site. 

Page 41 GAO-07-774 Elections
Appendix II: Examples of the Inconsistent

Voting Assistance Guidance on DOD’s Web 

Site 

State Differences identified Questions FVAP response GAO observation 

13 Texas FVAP issued an errata sheet 

for Texas on July 24, 2006, 

that changed the first bullet in

both electronic transmission

sections, which says Texas 

allows voters to send the 

Federal Post Card Application

by fax; but adds “to request an

absentee ballot and for 

temporary registration only.” 

This information was in the 

HTML and PDF Voting 

Assistance Guides but is not 

reflected in the “Publications” 

version of the Voting 

Assistance Guide. 

Would voters covered 

under the Uniformed 

and Overseas Citizens 

Absentee Voting Act 

know the fax option was 

for only to request the 

ballot and temporary 

registration, if they relied 

on the “Publications” 

Voting Assistance 

Guide? 

See note below on 

“Publications” version of 

the Voting Assistance 

Guide.a

 

The state of Texas only 

allows faxing to be used

to request a ballot and for 

temporary registration. It 

is not allowed for the use 

of permanent registration. 

The impact on voters may 

be negligible as these 

voters still receive ballots 

for two successive 

election cycles.

FVAP officials 

acknowledged that 

“Publications” version of 

the Voting Assistance 

Guide could have been 

marked better as an 

archived document, and 

have since deleted this 

version of the Guide 

from their Web site. 

14 Virginia An errata sheet for Virginia on

July 20, 2006, and the HTML 

and PDF Voting Assistance 

Guides allow only overseas 

military members to receive the 

blank ballot by e-mail or fax 

upon request. 

This information is not reflected 

in the “Publications” version of

the Voting Assistance Guide. 

Would stateside military 

members know of the 

stipulation that only 

overseas military 

members may receive 

the blank ballot by email or fax if they relied 

on the “Publications” 

Voting Assistance 

Guide? 

See note below on 

“Publications” version of 

the Voting Assistance 

Guide.a

 

FVAP officials 

acknowledged that 

“Publications” version of 

the Voting Assistance 

Guide could have been 

marked better as an 

archived document, and 

have since deleted this 

version of the Guide 

from their Web site. 

15 Virginia An errata sheet for Virginia on

July 20, 2006, and the HTML 

and PDF Voting Assistance 

Guides changed the Civilian

language to “Some Virginia 

counties and cities allow you to

receive the blank ballot by email or fax upon request.” 

This limiting information “some” 

is not reflected in the 

“Publications” version of the 

Voting Assistance Guide. It 

simply says that Virginia 

“allows you to receive the 

blank ballot you e-mail or fax 

upon request.” 

Would overseas

civilians know of the 

stipulation that only 

some Virginia counties 

and cities allow receipt 

of the blank ballot by fax 

or e-mail if they relied 

on the “Publications” 

Voting Assistance 

Guide? 

See note below on 

“Publications” version of 

the Voting Assistance 

Guide.a

FVAP officials 

acknowledged that 

“Publications” version of 

the Voting Assistance 

Guide could have been 

marked better as an 

archived document, and 

have since deleted this 

version of the Guide 

from their Web site. 

Page 42 GAO-07-774 Elections
Appendix II: Examples of the Inconsistent

Voting Assistance Guidance on DOD’s Web 

Site 

State Differences identified Questions FVAP response GAO observation 

16 Wisconsin FVAP issued an errata sheet 

on July 24, 2006 for Wisconsin

allowing voters to send the 

Federal Post Card Application

for absentee ballot request by

fax or e-mail. 

This information is not reflected 

in the “Publications” Voting 

Assistance Guide. 

Would voters covered 

under the Uniformed 

and Overseas Citizens 

Absentee Voting Act 

know of the option to 

send the Federal Post 

Card Application by fax 

or e-mail if they relied 

on the “Publications” 

Voting Assistance Guide 

instead of the errata 

sheet? 

See note below on 

“Publications” version of 

the Voting Assistance 

Guide.a

FVAP officials 

acknowledged that 

“Publications” version of 

the Voting Assistance 

Guide could have been 

marked better as an 

archived document, and 

have since deleted this 

version of the Guide 

from their Web site. 

Source: GAO analysis of DOD information. 

a

FVAP stated that the “Publications” version of the Voting Assistance Guide in PDF format 

(http://www.fvap.gov/pubs/vag/pdfvag/2006-07vag.pdf) created on October 25, 2005, was the original 

book version of the Voting Assistance Guide in electronic format. Since it was considered an archived 

document it was not intended for update. 

Page 43 GAO-07-774 Elections
Appendix III: Comments from the Department Appendix III: Comments from the of Defense 

Department of Defense 

Page 44 GAO-07-774 Elections
Appendix III: Comments from the Department 

of Defense 

Page 45 GAO-07-774 Elections
Appendix III: Comments from the Department 

of Defense 

Page 46 GAO-07-774 Elections
Appendix IV: Comments from the Election

Appendix IV Assistance Commission : Comments from the Election 

Assistance Commission 

Page 47 GAO-07-774 Elections
Appendix IV: Comments from the Election

Assistance Commission 

Page 48 GAO-07-774 Elections
Appendix V: 

A

GAO Contact and Staff 

cknowledgments 

Page 49 GAO-07-774

Appendix V: GAO Contact and Staff 

Acknowledgments 

Derek B. Stewart, (202) 512- 5559 or stewartd@gao.gov 

In addition to the individual named above, David E. Moser, Assistant 

Director; Marion A. Gatling; Pawnee A. Davis; Amber M. Lopez; Joanne 

Landesman; Paula A. Moore; John K. Needham, John J. Smale; and Julia C.

Matta made key contributions to this report. 

GAO Contact 

Acknowledgments 

Elections
Related GAO Products Related GAO Products 

Elections: All Levels of Government Are Needed to Address Electronic 

Voting System Challenges. GAO-07-576T. Washington, D.C.: March 7, 2007. 

Elections: DOD Expands Voting Assistance to Military Absentee Voters, 

but Challenges Remain. GAO-06-1134T. Washington, D.C.: September 28, 

2006. 

Elections: The Nation’s Evolving Election System as Reflected in the 

November 2004 General Election. GAO-06-450. Washington, D.C.: June 6, 

2006. 

Election Reform: Nine States’ Experiences Implementing Federal 

Requirements for Computerized Statewide Voter Registration Lists. 

GAO-06-247. Washington, D.C.: February 7, 2006. 

Elections: Views of Selected Local Election Officials on Managing Voter 

Registration and Ensuring Eligible Citizens Can Vote. GAO-05-997. 

Washington, D.C.: September 27, 2005. 

Elections: Federal Efforts to Improve Security and Reliability of 

Electronic Voting Systems Are Under W ay, but Key Activities Need to Be 

Completed. GAO-05-956. Washington, D.C.: September 21, 2005. 

Elections: Additional Data Could Help State and Local Elections 

Officials Maintain Accurate Voter Registration Lists. GAO-05-478. 

Washington, D.C.: June 10, 2005. 

Department of Justice’s Activities to Address Past Election-Related 

Voting Irregularities. GAO-04-1041R. Washington, D.C.: September 14, 

2004. 

Elections: Electronic Voting Offers Opportunities and Presents 

Challenges. GAO-04-975T. Washington, D.C.: July 20, 2004. 

Elections: Voting Assistance to Military and Overseas Citizens Should 

Be Improved. GAO-01-1026. Washington, D.C.: September 28, 2001. 

Elections: The Scope of Congressional Authority in Election 

Administration. GAO-01-470. Washington, D.C.: March 13, 2001. 

(350900) Page 50 GAO-07-774 Elections
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