U.S. ELECTION 

ASSISTANCE

COMMISSION

AGENCY FINANCIAL

REPORT

 November 15, 2021 
Election Assistance Commission

FY 2021 Agency Financial Report

ABOUT THIS REPORT

The Reports Consolidation Act of 2000 authorizes federal agencies, with the Office of 

Management and Budget’s (OMB) concurrence, to consolidate various reports to provide 

performance, financial, and related information in a more meaningful and useful format. As 

done in previous years, the EAC has chosen an alternative reporting to the consolidated 

Performance and Accountability Report. Instead, it produces an Agency Financial Report and a 

Congressional Budget Justification, under OMB Circular A-11.

This Fiscal Year (FY) 2021 Agency Financial Report describes the commission’s 

accomplishments, financial activity, and ongoing efforts to strengthen internal controls and 

financial management.

Information about EAC’s programs is available at www.EAC.gov. 
MESSAGE FROM THE CHAIRMAN

The United States Election Assistance Commission (EAC) is an independent, bipartisan agency

established by Congress in 2002, “to assist in the effective administration of Federal elections.” 

The Help America Vote Act (HAVA), which was signed into law on October 29, 2002, 

established major election reforms to the nation’s voting process. The EAC was charged with: 

the development of policies and guidelines in aiding state election agencies to meet expectations 

standardized in HAVA, the creation of the Voluntary Voting System Guidelines (VVSG), the

establishment of a national voting system certification program, the administration of HAVA 

grants, and the administration of the National Voter Registration form. The unique mission of 

the EAC makes it the nation’s only federal agency solely focused on election administration. 

The EAC presents summarized performance data in this report and will provide more detailed 

data in conjunction with the FY 2022 Congressional Budget Justification.

In FY 2021, the EAC continued to focus on its response to the unprecedented challenges of the 

COVID-19 pandemic during the primary and general election seasons. EAC related activities 

included:

a) continued oversight for $400 million in emergency funding to the states to prevent, 

prepare for, and respond to the coronavirus for the 2020 federal election cycle;

b) continued oversight for $425 million in new HAVA security grants funding to the states 

for election administration enhancements;

c) expanding the Cyber Access and Security program (CAS) team, allowing the EAC to 

improve the agency’s ability to respond to cybersecurity threats and assist the states with 

cyber resources;

d) conducting public hearings and adopting the VVSG 2.0;

e) replacing key personnel and increasing staff to enhance the EAC’s mission;

f) creating and filling several election subject matter expert (SME) positions to enhance the 

EAC’s clearinghouse function, with one of these SMEs being fully dedicated to 

accessibility issues;

g) hosting a wide range of virtual hearings, roundtable discussions, meetings of the EAC 

boards, and other events involving state and local election officials, federal partners, 

subject matter experts, and advocates;

h) creating a new discretionary federal advisory committee: The Local Leadership Council, 

which offers key input from election officials at both the state and local level;

i) responding to media inquiries regularly to dispel misinformation and serve as a trusted 

source to better educate voters;

j) implementing infrastructure security safeguards to enhance, modernize, and implement a 

cost-effective technology infrastructure and systems adhering to Federal Information 

Security Modernization Act (FISMA) and other modernization of federal government 

efforts such as Cloud First; and

k) completed relocation of EAC office space from Silver Spring to D.C.;

l) commissioned Rutgers to complete accessibility study for the 2020 elections lessons 

learned; 
m) commissioned MIT to provide a report to the EAC on lessons learned of the 2020 

election;

n) began the process to implement a pilot e-poll book program to help secure voting 

technologies that currently do not have federal standards, completed phase I of draft 

security requirements.

Below is a summary of the agency’s key activities and accomplishments during FY 2021. 

1. ADMINISTRATION AND OVERSIGHT OF HAVA GRANTS

Members of Congress provided critical financial support to the states and territories through the 

EAC under the Consolidated Appropriations Act of 2020. Election Security funds were 

authorized under Title I Section 101 of HAVA. Grants are made available to states to improve 

the administration of federal elections, including to enhance technology and make election 

security improvements. In FY 2021, the Grants Office continued providing technical assistance 

and oversight for these grants, including the CARES grants.

2. STRENGTHENING ELECTION SECURITY AND VOTER CONFIDENCE

While election security has always been a priority, the threat of foreign adversaries has resulted 

in an unprecedented commitment to improving information sharing and securing our election 

system. Alongside its federal partners, the EAC has played an integral role in preparing state 

and local election authorities for potential interference from domestic and foreign threats alike 

through election misinformation and disinformation campaigns, persistent attempts to breach 

election systems and voter registration databases, and other emerging threats.

The EAC is continually looking for additional ways to support cybersecurity efforts at the state 

and local level. As part of that effort, the EAC launched the Cyber Access and Security program 

(CAS) in FY 2020 to provide access to security training, best practices, expertise, and other 

assistance for election officials tasked with protecting critical election infrastructure. The 

program partners with public and private security experts to ensure that election officials have 

the most up-to-date and best in class information available through the EAC’s Clearinghouse.

Key program initiatives included the following:

a) An important part of this program has been the addition of staff who have a range of 

experience in the cybersecurity and elections fields.

b) Continuing throughout FY 2021, the EAC offered online cybersecurity training at no 

cost and developed specifically for election officials. The online training consists of both 

video and written materials separated into three modules. It provides foundational 

knowledge on cybersecurity terminology, best practices in election offices, practical 

application, and communication.

c) Throughout FY 2021, the EAC continued hosting a joint CISA-EAC online risk 

management tool on its website allowing election officials at the local level to easily 

measure and mitigate risks to their specific environments.

d) CAS continues to update materials currently posted to the EAC website and works to 

develop new material related to vulnerability disclosure programs, social engineering 

mitigation, and case studies.
3. VOTING SYSTEM TESTING AND CERTIFICATION

As states seek to invest in the purchase of new voting equipment, election leaders are continuing 

to turn to the EAC’s Testing and Certification Program as a key resource in ensuring the 

nation’s voting systems are tested to confirm the secure and accurate tabulation of ballots. This 

includes seeking information about how best to develop Requests for Proposals, information on 

the systems currently certified, and implementation of the next iteration of the Voluntary Voting 

System Guidelines, known as VVSG 2.0.

The VVSG consists of guidelines and requirements against which voting systems are tested to 

determine if the systems meet required standards. The EAC’s goal is to bring technological 

gains in security and other factors to the voters. Some additional factors examined under these 

tests include functionality, accessibility, accuracy, and auditability. HAVA mandates that the 

EAC develop and maintain these requirements, as well as test and certify voting systems. These 

guidelines are voluntary, and states may decide to adopt them entirely or in part.

In February the EAC Commissioners unanimously approved the VVSG 2.0 documents 

including the Principles and Guidelines, the Testing and Certification Program Manual, the 

Voting System Test Laboratory Manual, and the VVSG 2.0 Test Assertions. The VVSG 2.0 

represents a significant advancement in defining standards that will serve as the cornerstone of 

the next generation of voting systems. It contains much needed improvements in cybersecurity, 

accessibility, and usability requirements. The VVSG 2.0 also supports various audit methods 

supporting software independence to confirm the accuracy of the vote and increase voter 

confidence. With its adoption, manufacturers are empowered to begin designing and building 

voting machines according to these new guidelines.

Since adoption of the VVSG 2.0, the EAC has worked to implement the new standard by 

working with NIST’s NVLAP to prepare for accreditation of the voting system test laboratories 

(VSTLs), drafting a VVSG Lifecycle Policy, and working with NIST on establishing an end-toend cryptographic protocol evaluation plan.

One growing area of voting technology that is not subject to federal standards is electronic 

pollbooks, also known as e-poll books. The EAC unanimously supports the development of 

federal standards to better secure voting technology in order to secure voting systems nationally. 

The EAC has begun the process to implement a pilot e-poll book program and has completed 

phase I of draft security requirements. The agency is meeting with manufacturers, testing labs, 

and election officials to build a robust, cost saving, and security enhancing e-poll book program 

moving forward. 

4. ELECTION ADMINISTRATION RESEARCH & BEST PRACTICES

a) Election Administration and Voting Survey (EAVS)

In 2021, EAC collected data related to the administration of elections from 56 U.S. States and

Territories. Using the EAVS and Policy Survey, this data collection informs on the impact

of election day operations, NVRA and UOCAVA. The EAVS is comprised of more than 400

variables and reaches approximately 6,500 respondents. The Policy Survey accompanies the

EAVS and provides a contextual understanding of state laws, policies and procedures

governing federal elections. In August 2021, the EAC has published its comprehensive report 
on the 2020 election.

In anticipation of compiling information from the 2022 election and publishing the EAC’s 

Election Administration and Voting Survey (EAVS) comprehensive report in 2023, the EAC 

initiated a needs assessment review in FY 2021 by interviewing 27 states about their 

experiences completing the 2020 EAVS and also gathered input from participants about the 

2022 EAVS. 

Based on the increased use of absentee and mail ballots by voters during the pandemic, the 

Policy Survey was revised and expanded with new questions on electronic ballot transmission, 

mail balloting deadlines, postmark requirements, and election certification dates. For the second 

time since publishing the survey, the EAC initiated usability testing of the survey, and 

conducted outreach calls with nine states to improve the agency’s technical assistance for 

completing the survey. A second round of user testing for the 2022 survey instruments is 

planned for late 2021.

b) Original Research Studies

As a resource for best practices the EAC commissioned two original research studies. Lesson 

Learned from the 2020 Election is a report that provides an account of how the American 

system of election administration responded to the significant barriers erected by the pandemic 

challenges. Disability and Voting Accessibility in the 2020 Elections: Final Report on Survey 

Results is a study that examines progress in voting accessibility since 2012.

c) Voter Registration and Accessibility for Voters with Disabilities

The EAC updated the National Mail Voter Registration form instructions and accompanying 

language translations in response to requests from nine different states. EAC is currently in the 

process of renewing OMB approval and accepting the first round of public comments on the 

form until November 12, 2021. The EAC offers a Braille translation of the form’s content 

alongside 15 other language translations.

d) Employee Engagement Committee

In 2021, the EAC revitalized its Employee Engagement Program by establishing a committee of 

employees that works towards fostering stronger employee connections to their organization, 

job, and coworkers. EAC is committed to building a more engaged workforce to positively 

drive productivity, service quality, and organizational performance. Throughout the year, the 

Employee Engagement Committee worked on several initiatives with these commitments in 

mind. The committee gathered feedback from employees through a general satisfaction survey 

to create an employee feedback loop that leadership can use to adjust the organization, explore 

what was needed to increase employee job satisfaction; and increase employee buy-in and input 

into agency objectives and procedures. The Awards for Years of Service is an opportunity for 

the agency to recognize employees that have dedicated 5, 10 and 20 years of service to the 

agency. EAC also deployed an Institutional Knowledge survey, which was an opportunity for 

staff to inform leadership of their specialized skills. With such a diverse staff comprised of 

many talents and skillsets, the purpose of this survey was to identify and get a better 

understanding of staff specializations that will enable the EAC to optimize its workforce. As a 

product of this committee, EAC intends to improve productivity, performance, customer 
satisfaction and morale.

e) Clearinghouse Awards

In February, the EAC announced the winners of the 2020 Clearinghouse Awards for Best 

Practices in Election Administration. The awards, also known as the Clearies, provide election 

offices across America an opportunity to share their innovative efforts and election 

administration successes. The Clearies further the EAC’s responsibilities under HAVA to serve 

as a clearinghouse for election administration information. The EAC received a record 137 

submissions for the awards, tripling the number from 2019. 

Now in its fifth year, the award categories celebrate innovation in election administration, 

improving voting accessibility for voters with disabilities, best practices in recruiting, training 

and retaining election workers, and creative and original “I Voted” sticker design. New for the 

2020 Clearies was the category for innovation in election cybersecurity and technology. 

5. AGENCY CYBERSECURITY AND TECHNOLOGY 

The EAC continued to implement its multiyear technology upgrade plan to secure and 

modernize its information technology systems in FY 2021. The EAC implemented numerous 

real-time threat protection tools with enhanced traffic visibility (hardware and software) to 

mitigate risk to the EAC network. In accordance with EO 14028, Improving the Nation’s 

Cybersecurity, the EAC has developed a plan to migrate to a zero-trust architecture and 

performed the first steps in completing this plan. Also, in accordance with EO 14028, the EAC 

entered into a memorandum of understanding with CISA to participate in their continuous 

diagnostics and mitigation (CDM) program. Finally, the agency began the roll out of updated 

end-user laptops agency wide during FY 2021. These efforts have resulted in a more scalable, 

cost effective, robust, secure, and efficient network for the agency.

6. CLEARINGHOUSE SUPPORT TO ELECTION OFFICIALS

The EAC is required by HAVA to establish best practices for election administration. While all 

divisions of the EAC work to fulfill the agency’s mission, additional funding in FY 2021 

allowed the EAC to create a dedicated Clearinghouse Division in furtherance of the 

clearinghouse mandate of HAVA.

To further improve how the agency fulfills the clearinghouse mandate, a new division was 

formed in 2021 to build on subject matter expertise for the development of best practices and 

guidance to EAC stakeholders including election officials at the state and local levels. 

Consisting of 6 former election officials and experts on election law, accessibility, and design, 

the Clearinghouse Division has led the creation of additional timely guidance documents to 

address pressing issues in election administration. The team published the following 

documents: Best Practices: FAQs, EAC's Testing and Certification Program, Local Election 

Officials' Guide to Redistricting, Chain of Custody Best Practices, and Best Practices: 

Accessible Voter Registration. 

7. AGENCY RELOCATION

The EAC was funded by Congress in FY 2020 to relocate. The agency finalized the move the 

week of November 2020 and since then, construction has progressed throughout FY 2021. The 
EAC’s previous space was inadequate for the growing number of staff, which forced the agency 

to assume unnecessary costs to host hearings and other events. The agency relocation will 

better position it to interact with stakeholders and other federal partners in the space.

Donald Palmer

U.S. Election Assistance Commission Chairman
TABLE OF CONTENTS

 Page

SECTION I - Management Discussion and Analysis....................................................1

I.A. Background, Vision, Mission and Organizational Structure .....................................1

 Funding ......................................................................................................................4 

 Organization by Program ...........................................................................................5

 Organization Chart .....................................................................................................8

I.B. Performance Goals, Objectives, and Results..............................................................9

How EAC Assesses Performance ...............................................................................9

Accomplishments by Goal..........................................................................................9

FY 2021 Performance Summary ..............................................................................23

Portfolio Analysis.....................................................................................................25

I.C. Financial Results ......................................................................................................26

Budgetary Resources................................................................................................26

Financial Position.....................................................................................................26

 Results of Operations ...............................................................................................27

 Limitations of the Financial Statements...................................................................27

I.D. Analysis of Controls, Management Systems, and Legal Compliance .....................28

 Internal Control Environment ..................................................................................28

 Federal Manager’s Financial Integrity Act ..............................................................28

 Entity-Wide Security Program.................................................................................28

 Federal Information Security Management Act.......................................................29

 Audit Follow-Up ......................................................................................................29

 Federal Financial Management Improvement Act...................................................29

 Accountability of Tax Dollars Act of 2002..............................................................29

 Inspector General Act Amendments of 1988 ...........................................................29

Fraud Reduction Report ...........................................................................................29

GONE Act ................................................................................................................34

 Annual Assurance Statement on Internal Control....................................................35

 

SECTION II – Financial Section ..................................................................................36

II.A. Inspector General’s Assessment ..............................................................................37

II.B. Independent Auditor’s Report..................................................................................39

SECTION III - Other Accompanying Information ....................................................63

III.A. Major Management and Performance Challenges Facing the EAC.......................64

III.B. Improper Payments.................................................................................................72

III.C. Summary of Financial Statement Audit and Management Assurances..................72
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SECTION I 

Management Discussion and Analysis

The Management Discussion and Analysis (MD&A) is presented per the Statement of Federal

Financial Accounting Standards (SFFAS) 15. The MD&A intends to provide a clear and concise 

description of the agency’s mission and organizational structure; high-level discussion of key 

performance goals, results, and measures; analysis of financial statements, systems, controls, and 

legal compliance; and actions taken or planned to address issues. It provides a balanced analytical 

assessment, with both positive and negative information, of key program, and financial 

performance. The MD&A is a vehicle for communicating insights about the agency, its operations, 

programs, successes, challenges, and future outlook. Contents of this report and the MD&A are in 

conformance with the Office of Management and Budget (OMB) Circular A-136, Financial 

Reporting Requirements. 

I.A. BACKGROUND, VISION, MISSION AND ORGANIZATIONAL STRUCTURE

In October 2002, Congress passed the Help America Vote Act (HAVA) of 2002. The law 

recognized the need for states to invest in their election infrastructure. The Act set out 

comprehensive programs of funding, voluntary guidance, and research. HAVA established the 

Election Assistance Commission (EAC) to foster those programs and promote and enhance voting 

for United States citizens. In passing the EAC’s 2018-2022 Strategic Plan, the EAC framed the 

mission and vision of the agency set out in its chartering legislation with the following:

EAC Mission Statement:

The U.S. Election Assistance Commission helps election officials improve the administration of 

elections and helps Americans participate in the voting process. 

EAC Vision Statement:

A trusted, proactive, and responsive federal agency that helps election officials administer and 

voters participate in elections.

The EAC is an independent, bipartisan agency. By statute, four full-time Commissioners, 

appointed by the President and confirmed by the U.S. Senate, and three federal advisory 

committees: the Standards Board, Board of Advisors, and Technical Guidelines Development 

Committee guide the EAC. Currently, there are four Commissioners. The EAC’s statutory mission 

consists of:

a) adopting voluntary voting system guidelines available for use by the states;

b) accrediting voting system testing laboratories and certifying voting systems;

c) developing guidance for state and local election officials to meet HAVA requirements;

d) serving as a national clearinghouse of information on election administration, including 

tools and best practices;

e) maintaining the National Mail Voter Registration Form, developed per the National Voter 

Registration Act (NVRA) of 1993;

f) promoting accessibility for voters with disabilities;

g) providing grantees with technical assistance on use of payments and grant funds, and 
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h) auditing the use of HAVA funds.

The Standards Board and the Board of Advisors provide advice and guidance to the EAC on the 

Voluntary Voting System Guidelines (VVSG) and other election administration issues. HAVA 

established the Technical Guidelines Development Committee (TGDC) to help the EAC prepare 

the VVSG and voting systems test against the established VVSG standards.

The Director of the National Institute of Standards and Technology (NIST) of the U.S. Department 

of Commerce serves as the Chair of the TGDC and provides technical support to the Committee. 

Additionally, HAVA specifies that NIST provides recommendations to the EAC regarding voting 

system test laboratories. Since Fiscal Year (FY) 2004, the EAC’s annual appropriations have 

included a total to date of $40.9 million for NIST support. 

In FY 2003 and FY 2004, Congress appropriated nearly $3 billion in federal financial assistance 

for payments to states under Titles I and II of HAVA. States received the funds to upgrade their 

voting systems, establish statewide voter registration databases, train election officials, and educate 

voters. In FY 2003, the General Services Administration (GSA) distributed $649.5 million in 

HAVA funds to the fifty states, Guam, Puerto Rico, the U.S. Virgin Islands, American Samoa, and 

the District of Columbia on the EAC’s behalf. The funds were distributed for activities to improve 

the administration of elections (HAVA Section 101) and replace punch cards and lever voting 

machines (Section 102). 

The Senate confirmed four Commissioners in December 2003, and the EAC began operations in 

January 2004. The agency’s FY 2004 operating budget was $1.7 million. At the close of the fiscal 

year, the EAC had a staff of 18. The EAC’s focus in 2004 was to assemble a team, obtain office 

space, arrange for administrative support from the GSA, establish a website, start election 

administration clearinghouse operations, and distribute federal financial assistance to the states.

In FY 2004, EAC also appointed a statutorily required General Counsel. During FY 2005, EAC

appointed its other statutorily required positions: the Executive Director, and an interim Inspector 

General. The EAC had several focus areas in subsequent years. 

• Upgrading the VVSG; 

• Performing research to promote effective federal elections; 

• Presenting vital data on election best practices; 

• Instituting a testing and certification program; 

• Auditing state HAVA funds; and 

• Disseminating information on improving elections to its stakeholders.

In FY 2007, Congress recognized the expanding agency responsibilities and lifted the full-time 

equivalent (FTE) staffing ceiling of 24. As of the end of FY 2021, the EAC had 46 FTE. Since its 

inception, the EAC has received $2,606,150,000 in requirements payments; and $25,550,000

in discretionary grant funds for poll workers, mock elections, election data collection, voting 

technology improvement research and equipment, pre-election logic and accuracy testing, and postelection verification. The EAC also tracks and provides technical assistance on the Section 101 funds 

to improve the administration of federal election, which is reported by the states. The period for using 

the Section 102 punch card/lever replacement funds expired, and the EAC collected all unused funds 
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by the end of FY 2018. In FY 2018 and FY 2020, Congress appropriated $380 million and $425 

million in formula grants to improve federal elections. In FY 2020, Congress appropriated an 

additional $400 million in grant funds to the EAC through the Coronavirus Aid, Relief, and Economic 

Security (CARES) Act to help states prevent, prepare for, and respond to the coronavirus for the 2020 

federal election cycle.

In FY 2015, the Senate confirmed three Commissioners appointed by the President. In FY 2018, 

there were two Commissioner vacancies.

In FY 2019, the Senate confirmed two Commissioners appointed by the President. The EAC 

currently has a full quorum of Commissioners. 

COVID-19 Activity

The EAC did not receive supplemental funding for internal operations. On March 12, 2020, the 

EAC expeditiously moved to conduct all operations and activities remotely in response to the 

pandemic. While EAC already had a functioning telework system, the shift of daily operations to 

full remote work led to increased provisions in IT equipment, telecommunication equipment, and 

software, such as Zoom, to assist a constant level of productivity and activity. Virtual operations 

continued throughout FY 2021.

In the latter half of FY 2020 and throughout FY 2021, the EAC adapted how it served election 

stakeholders and provided resources throughout the pandemic. All divisions worked closely with 

the Finance Division to coordinate budget and resource adjustments. In adherence to COVID-19 

restrictions, the EAC adjusted activities and programs. The agency added resources and events to 

help support election administration during the pandemic. The EAC Commissioners limited 

activity to mission-critical travel and instead conducted a series of virtual interviews and 

roundtables with stakeholders. Also, the EAC hosted virtual annual board meetings. Additionally, 

the agency oversees the return of the unused CARES grants from states that are sent to Treasury.
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FUNDING

EAC Appropriation History Fiscal Years 2003 – 2021

Fiscal Year 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 Total

Section 101 and 102 649,500 649,500

Administrative 

Expenses 500 500

Subtotal 101, 102 650,000 650,000

Election Reform Program Grants

Requirement 

Payments 830,0001 1,491,150 115,000 100,000 70,000 2,606,150

Poll Worker Grants 1,500 1,500

Foundation 1,500 1,500

Voting Technology 

Research 5,000 3,000 8,000

Testing & 

Verification 1,000 2,000 3,000

Election Security 

Grants 380,000 425,000 805,000

Subtotal, Election 

Reform 833,000 1,491,150 115,000 106,000 75,000 380,000 425,000 3,425,150

Election Data Collection Grants

Subtotal, Data 

Collection 10,000 10,000

COVID-19 Response (CARES) Grants

Subtotal, 

COVID-19 

Response 

(CARES) 400,000 400,000

EAC Salaries & Expenses (S&E)

Operations 2,000 1,6742 11,110 10,986 11,313 12,330 12,909 13,409 13,024 8,750 8,292 8,100 8,100 8,100 8,200 8,600 7,950 11,271 15,500 181,618

Mock Election 

Grants 200 300 300 800

Poll Worker Grants 750 750 750 2,250

Transfer to NIST 2,778 2,772 4,950 3,250 4,000 3,500 3,243 2,750 2,745 1,900 1,900 1,500 1,400 1,500 1,250 1,500 1,500 42,438

Relocation 2,400 2,400

Subtotal, S&E 2,000 1,674 13,888 13,758 16,263 16,530 17,959 17,959 16,267 11,500 11,037 10,000 10,000 9,600 9,600 10,100 9,200 15,171 17,000 229.506

TOTAL 1,485,000 1,492,824 13,888 13,758 16,263 141,530 123,959 92,959 16,267 11,500 11,037 10,000 10,000 9,600 9,600 390,100 9,200 840,171 17,000 4,714,656
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Organization by Program

The EAC has organized its offices around the mandates of HAVA. Below are brief explanations of 

the divisions responsible for implementing the Strategic Plan programmatic goals. Following the 

descriptions is EAC’s organization chart.

Communications

The Communications Division:

• is responsible for external communications and the tools and platforms used to provide 

information to election officials and the general public;

• maintains the EAC website;

• collects, develops, and publishes resources (Clearinghouse function);

• operates agency social media;

• responds to and manages media inquiries;

• plans and executes agency events in coordination with agency leadership and state and 

local election officials; 

• manages external communications;

• responds to Congressional inquiries; and

• provides editorial support, including press releases, speeches, and Congressional testimony.

EAC.gov is the agency’s primary communications tool and contains thousands of documents and 

information about voting systems and election administration, informational videos, research, data, 

and program-related content. It also features on-demand webcasts and related information from 

public meetings, hearings, summits, and roundtables. 

Finance

The Finance Division:

• is responsible for all areas of budget formulation, execution and funds administration;

• is responsible for coordinating with Treasury and OMB on all financial matters as 

necessary;

• processes and disburses payments to the states and executes all essential grants 

management responsibilities; and

• is responsible for oversight of funds and coordinating with the IG and Treasury on all 

required annual audits.

Grants

The Grants Division:

• provides technical assistance to the states on administering federal funds;

• tracks the submission and reviews the content of financial and performance reports 

submitted by states;

• analyzes grant audit reports and works with fund recipients on recommendations to resolve 

audit findings applicable to EAC’s programs;
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• reviews amended State Plan submissions on the use of Requirements Payments funds so 

states can comply with HAVA Title III, Uniform and Nondiscriminatory Election 

Technology and Administration Requirements; and

• drafts advisory opinions for commission approval and issuance.

Research

The Research Division: 

• administers the biennial Election Administration and Voting Survey (EAVS) to 50 states, 

the District of Columbia, American Samoa, Guam, Puerto Rico, the Northern Mariana 

Islands and the Virgin Islands. The survey produces data and reports mandated by HAVA. 

Topics include the impact of the National Voter Registration Act of 1993 and the impact of 

the Uniformed and Overseas Citizens Absentee Voting Act (UOCAVA) on military and 

overseas voters’ participation in federal elections. EAVS is the only comprehensive 

collection and report of data on elections in the United States;

• research election administration topics as mandated by Congress and at the discretion of 

the EAC. Research has included voter accessibility, administering elections in urban and 

rural areas; the feasibility and advisability of establishing free absentee ballot return 

postage; the feasibility of alternative voting methods; and the voting experiences of firsttime voters who register to vote by mail;

• manages the National Mail Voter Registration Form as prescribed by the National Voter 

Registration Act of 1993 (NVRA), also known as “Motor Voter;”

• manages the translation of the National Mail Voter Registration Form into languages other 

than English; and

• conducts complex analyses of election administration data in order to ensure factual, 

evidence-based information is available to voters, election officials and the general public. 

Voting System Testing and Certification

Under the Help America Vote Act, the EAC is responsible for assisting states with improvements 

to voting systems through the distribution of federal funds. The EAC accredits voting system test 

laboratories and certifies voting equipment. Participation by states in the certification program is 

voluntary. Throughout the certification process, the EAC provides election officials with test 

plans, test reports, and reports on voting system anomalies in the field. Staff members work with 

the National Institute of Standards and Technology (NIST) to evaluate and accredit voting system 

test laboratories, and the criteria regarding the voting system certification process’s life cycle.

The Testing and Certification (T&C) Division:

• assists states with voluntary certification of voting systems;

• supports local elections officials in the areas of engineering change order updates, 

acceptance testing, and pre-election system verification for EAC-certified systems, 

issuance of Requests for Proposal, and information on how to maintain aging voting 

technology;
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• promotes quality control in test laboratories and voting system manufacturing through the 

EAC Quality Monitoring Program, including periodic lab and manufacturing facility 

audits of EAC-registered entities; 

• provides procedures to voting system manufacturers for the testing and certification of 

voting systems to specified federal standards consistent with the requirements of HAVA 

Section 231(a)(1);

• upon invitation or with permission from election officials, conducts reviews of systems in 

use in the field; and

• along with its advisory boards, EAC and NIST work together to update and implement 

voluntary testing guidelines for voting systems. 
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Organizational Chart
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I.B. PERFORMANCE GOALS, OBJECTIVES, AND RESULTS

The EAC formalized its planning, reporting, and execution activities with its first five-year 

Strategic Plan 2009-2014. The Office of Management and Budget reviews the plan, and EAC 

presents it to its Board of Advisors and Standards Board for comment, as required by HAVA. EAC 

adopted the Plan in March 2009. Per OMB A-11, the EAC adopted a new strategic plan in 2018. 

The new Strategic Plan covers 2018-2022. Following OMB-136, the performance goals and results 

align with the Statement of Net Cost.

How EAC Assesses Performance

The sections below describe the role that the programs play in helping the commission meet its 

congressional mandates and the results needed to accomplish its goals. The EAC’s 2018-2022 

Strategic Plan extensively lists the strategy for collectively driving its programs to achieve the 

agency’s mission. Outcomes measure the effect program outputs have on their stakeholders. 

Outputs are quantifiable targets that directly measure the results of a program. A program may 

have multiple outputs, but each output is associated with one program. Performance measures are 

quantifiable and documentable representations of a capacity, process, or outcome that is relevant 

to the assessment of performance.

Program Area: Clearinghouse 

The Clearinghouse Division was formed in FY 2021 to provide subject matter expertise to support 

the agency’s mission of providing best practices and guidance to EAC stakeholders including 

election officials at the state and local levels. Consisting of former election officials and experts on

election law, accessibility, and design, the Clearinghouse Division has led on the creation of timely 

guidance documents to address pressing issues in election administration including chain of 

custody, redistricting, and a universal election terminology glossary.

Current Strategic Plan (2018-2022) Goals:

• Build: Proactively and responsively create products that help election officials improve the 

administration of elections and help voters more easily participate in elections.

• Distribute: Help election officials improve the administration of American elections

 through the distribution of EAC assistance and products.

FY 2021 Accomplishments

The EAC is required by HAVA to establish best practices for election administration. While all 

divisions of the EAC work to fulfill the agency’s mission, additional funding in FY 2021 allowed

the EAC to create a dedicated Clearinghouse Division in furtherance of the clearinghouse mandate 

of HAVA. Additional FTEs for this division included a Senior Program Advisor and six Subject 

Matter Experts (SMEs). This division brings to the agency former election officials and experts on 

election law, accessibility, and design with over 40 years of election experience to assist in 

creating and distributing EAC assistance and products to improve the administration of American 

elections. 
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The Clearinghouse Division has led on the production, updates, and distribution of several timely 

and informative products for election officials. The 1,300-term election terminology glossary was 

updated to provide a uniform vocabulary for election terms and is currently being translated into 

multiple languages to assist election officials in creating documents for language minority 

populations. Chain of Custody Best Practices were released to assist election officials in 

developing or revising chain of custody procedures for physical election materials, voting systems, 

and the use of third-party auditors for conducting audits and electronic discovery. A Best Practices 

Toolkit for Voter FAQs was developed to guide election officials in expanding their websites, 

helping to drive traffic to trusted and accurate information. Every ten years, election officials 

across the country are faced with the redistricting of precincts and district boundaries. To assist

election officials in navigating their tasks following the 2020 Census, the EAC released the Local 

Election Officials’ Guide to Redistricting to provide general guidance to assist election officials 

when making technical changes to precinct and district information. Additionally, the EAC 

released a Testing and Certification 101 resource to demystify the process of testing and certifying 

election equipment. The document describes the procedures of testing and certifying systems and

provides a glossary of terminology. 

Through the addition of an accessibility expert, the agency is working to ensure that all EAC best 

practices and resources address the unique challenges of voters with disabilities. In correlation 

with National Disability Voter Registration Week, the EAC released Best Practices: Accessible 

Voter Registration. This resource for election officials addressed the unique hurdles that voters 

with disabilities often face during the first step of the voting process and highlighted actionable 

steps that officials can take to remove these barriers. With the hire of a graphics specialist, the 

agency has made concerted efforts to solidify the branding of EAC materials following the release 

of a new agency logo in FY 2020. These efforts will help ensure all documents display consistent 

EAC branding to easily identify official agency releases. With mis- and disinformation posing 

consistent threats to the elections process, consistent and identifiable EAC branding flags each of 

our products as being from a trusted source of information and models best practices for election 

officials.

Program Area: Communications

The Communications Division supports the mission of the agency by providing state and local 

election officials, voters, Congress, other federal agencies, and the public with reliable, accurate, 

and nonpartisan information about the administration of federal elections.

Current Strategic Plan (2018-2022) Goals:

• Build: Proactively and responsively create products that help election officials improve the

administration of elections and help voters more easily participate in elections.

• Distribute: Help election officials improve the administration of American elections

 through the distribution of EAC assistance and products.

FY 2021 Accomplishments 

Throughout 2021, the EAC explored what lessons could be learned from the 2020 election year.

The communications team worked to promote EAC research products such as the 2020 EAVS 
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report and “Disability and Voting Accessibility in the 2020 Elections” study, interviews with 

election officials, and other EAC meetings. This section primarily addresses the distribution of 

materials and information. Goal 3 describes the development of original research, promotion of

election security and accessibility resources, and the creation of other best practices resources.

Communications, Events, and Outreach 

Elections at the state and local level, and some federal races were held in 2021. Even though there 

was less attention on elections this year compared to 2020, the EAC recognizes the ongoing need 

to provide resources and updated information for election officials and voters. EAC continued to 

update and improve its website with voting information and additional resources resulting in 3.4

million users on the website, with over 5.1 million page views. The EAC grew its social media 

community resulting in over 12,000 Twitter followers, 4,792 Facebook likes, 290 Facebook posts, 

833 Instagram followers, and 1,260 LinkedIn follows.

As the COVID-19 pandemic impacted the country, EAC hearings, Board meetings, and forums 

moved to a virtual format. The EAC’s YouTube page also hosts resources for election officials on 

grants and EAVS. This year the EAC posted 61 videos and virtual events resulting in almost 

6,500 views on the EAC’s YouTube channel alone. The following provides additional detail about 

some of these efforts. 

On February 10, the EAC Commissioners unanimously approved VVSG 2.0 Requirements and 

Principles and Guidelines. This meeting was live-streamed and was a major step toward 

improving the manufacturing and testing of voting machines. As part of the continuing work to 

implement these standards, the EAC held a virtual event on September 8 to discuss important next 

steps and considerations with voting system manufacturers, voting system test laboratories, and 

representatives from the election administration community.

Typically held in person in the spring, the EAC’s annual Standards Board and meetings, as

mandated by HAVA, include election officials and other election stakeholders from around the 

country. As the EAC did in 2020, these meetings were held virtually in the summer. VVSG 2.0 

continued to be a focus. In September, the Technical Guidelines Development Committee also 

held its annual meeting. These meetings were live-streamed.

The EAC held several events exploring new research the agency commissioned. Public events 

including virtual hearings and roundtable discussions featured state and local election officials, 

federal partners, researchers, and subject matter experts. The EAC hosted a combination of five 

virtual hearings and roundtable discussions:

• Election Night Reporting Roundtable

• Accessibility Lessons Learned During the 2020 Elections

• EAC Roundtable: Voter Turnout and Trends for People with Disabilities During the 2020 

Election

• 2020 EAVS and 2020 Elections Lessons Learned Roundtable
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The EAC Commissioners also recorded multiple series of interviews with election officials, 

partners, and subject matter experts. Many of these discussions focused on lessons learned from 

the 2020 elections and tapped into the expertise and insights of election officials across the 

country. The result is an extensive library of 41 videos on best practices and lessons learned for 

election administration. The video series include:

• 2021 Black History Month

• Women in Elections

• Clearinghouse Awards “Clearies” Best Practices

• Military Appreciation Month

• AAPI Heritage Month

• Election Technology Features

• 2020 Election Lessons Learned

• Serving Voters With Disabilities

Other videos recognized the 26th Amendment, shared ideas on how election offices can participate 

in civic holidays like National Voter Registration Day and Vote Early Day, and how election 

officials can utilize one of the EAC’s new resources, an FAQ toolkit. 

Media Coverage & Engagement 

The EAC worked to be proactive with press outreach as 

well as responding to requests and making sure reporters 

have timely and accurate information about U.S. 

election administration. The EAC’s staff and leadership 

regularly provide expertise on a broad range of topics 

and often highlight the Election Administration and 

Voting Survey data and other EAC research. In FY 21, 

the communications team distributed 25 press releases 

and generated over 15,400 press mentions in print and 

broadcast. 

Outreach to Election Officials

In September 2020, the EAC started a quarterly 

newsletter for state and local election officials. Since 

then, the communications team has worked to improve 

usability, content, and access for officials so they can be 

informed on events, new resources, and other EAC 

updates. The newsletter is sent to a list of 4,500 election 

officials across the country. In late FY 2021, the newsletter transitions from quarterly to monthly 

to ensure timely updates were being provided to election officials. This newsletter is a valuable 

communications tool and supplements the EAC’s work with our FACA boards, Commissioner 

participation in events such as state local election official association events, and other direct 

outreach to these stakeholders.
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Clearinghouse Awards

In February, the EAC announced the winners of the 2020 Clearinghouse Awards for Best Practices 

in Election Administration. The awards, also known as the Clearies, provide election offices across 

America an opportunity to share their innovative efforts and election administration successes. The 

Clearies further the EAC’s responsibilities under HAVA to serve as a clearinghouse for election 

administration information. The EAC received a record 137 submissions for the awards, tripling 

the number from 2019. 

In its fifth year, the award categories recognize innovation in election administration, improving 

voting accessibility for voters with disabilities, best practices in recruiting, training and retaining 

election workers, and creative and original “I Voted” sticker design. New for the 2020 Clearies

was the category for innovation in election cybersecurity and technology. 

Federal Advisory Committee Act (FACA) Activities

The EAC established a new FACA board on June 8, 2021, entitled the Local Leadership Council.

The new FACA board will be made up of 100 local election officials who are current or former 

officers in each state’s local election official association. The Local Leadership Council will 

provide a relevant and comprehensive source of expert, unbiased analysis and recommendations to 

the EAC on local election administration topics to include but not limited to voter registration and 

voter list maintenance, voting system user practices, ballot administration (programming, printing, 

and logistics), processing, accounting, canvassing, auditing and testing of ballots, and certification 

of results. The inaugural meeting of the new FACA board will occur in FY 2022.

The EAC’s three statutory FACA boards held a collective total of three meetings, including 

electing board officers and passing resolutions. The EAC also timely published Sunshine Act 

Notices in the Federal Register for the Federal Advisory Committee Meetings (the boards). The 

EAC Office of General Counsel coordinates EAC engagement with the EAC FACA boards with 

programmatic and technical assistance in hosting meetings provided by the Communications and 

IT departments. The charters for the three statutory FACA board were renewed on April 13, 2021.

Freedom of Information Act (FOIA) Activity

The Office of General Counsel completed 44 FOIA requests during FY 2021. It also maintained its 

online FOIA reading room to ensure frequently requested documents and information is easily 

available to the public.

Program Area: Finance 

The EAC Finance Division is responsible for all matters related to agency budget formulation, 

execution, and oversight. The Finance Division coordinates with all necessary partners including 

the US Department of Treasury and Office of Management and Budget (OMB).
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Current Strategic Plan (2018-2022) Goals:

• Operate: Ensure continued effective operation of the EAC in order to achieve its goals 

while acting as good stewards of public funds.

FY 2021 Accomplishments

In FY 2021, the EAC Finance Division successfully executed its highest operating budget since 

2010, leaving less than one-half percent unobligated by year end, an obligation rate of 99.55% 

according to Treasury’s financial system. Additionally, the EAC completed a 99.84% obligation 

target of its two-year relocation funding provided by Congress that also expired in FY 2021.

Additionally, in the spring of FY 2021, the White House submitted to Congress its Fiscal Year 

2022 Budget for the EAC which came in a $122.8 million, including $100 million in Election 

Security Grants, the largest amount since the first President’s Budget for the Agency in 2004. The 

Finance Division continues to coordinate with all appropriate stakeholders on proper budget 

execution and general funds administration for the agency.

Program Area: Grants

The Office of Grants Management (Grants Office) supports the agency’s mission by delivering 

and managing federal funds that help election officials procure modern election systems and 

improve the administration of federal elections. The Grants Office issues grant awards, provides

guidance on the appropriate use of funds, oversees and monitors all state grant activities, provides 

technical assistance to the states, tracks activities, monitors expenses, prepares financial reports for 

Congress, resolves audits conducted by the OIG and closes out grants when all revenue is 

expended. 

This program primarily supports the strategic goals listed below:

Current Strategic Plan (2018-2022) Goals:

• Distribute: Help election officials improve the administration of American elections 

through the distribution of EAC assistance and products.

FY 2021 Accomplishments

HAVA CARES Funding

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) included $400 million in 

new Help America Vote Act (HAVA) emergency funds, made available to states to prevent, 

prepare for, and respond to the coronavirus for the 2020 federal election cycle. This supplemental 

appropriation funding, distributed by the EAC to 56 states and U.S. territories, and the District of 

Columbia, provided additional resources to protect the 2020 elections from the effects of the novel 

coronavirus’s effects. The grants totaled $397,205,287. Some states requested only the amount of 

funds they were sure they could match at the 20% required state share level. 
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In FY 2021, the grants office provided technical assistance to states as they used the funding for 

primaries, runoffs and the general election. Multiple training events were held to support the 

reporting requirements for CARES, including 20-day reports, twice a year submission of Federal 

Financial reporting and Progress reporting. After the federal expenditure deadline of December 31, 

2020 passed, EAC began the process with individual grantees to closeout grants for which 

activities had concluded and financials were reconciled. EAC closed 21 CARES grants in FY

2021; 10 of these states spent all their funding. Sixteen states have returned federal funds, many of 

which also returned federal interest on those funds. The funds returned in FY 2021 totaled

$38,093,657.

HAVA Election Security Funding

The HAVA Election Security funds appropriated in 2018 and 2020 totaled $805 million, $380 

million in 2018, and $425 million in 2020. Congress authorized HAVA Election Security funds 

under Title I Section 101 of the Help America Vote Act (HAVA) of 2002. These funds marked the 

first new appropriations for HAVA grants since FY 2010. EAC made grants to states to improve 

the administration of federal elections, including to enhance technology and make election security 

improvements. The grants to 56 states and territories, and the District of Columbia total 

$804,978,602. In FY 2021, the grants office provided technical assistance to states as they used the 

funding for improving the administration of federal elections, including responding to the 

pandemic’s influence on the 2020 federal election cycle. Multiple training events were held to 

support the increase in reporting requirements from once-a-year annual reporting to twice a year 

with reports required at mid-year. 

HAVA Section 251 Requirements Payments

Requirements Payments are used to meet the requirements of Title III Uniform and 

Nondiscriminatory Election Technology and Administration Requirements of HAVA. Title III 

requirements include voting system standards, voting information requirements, provisional 

voting, statewide voter registration lists, and identification requirements for voters who register by 

mail. In FY 2021, the grants office monitored Section 251 Requirements Payment grants of 

$1,859,828,523 to 36 states. EAC also closed 6 grants that were fully expended. 

HAVA Section 101 Funding

Section 101 funds are more generally available for activities “to improve the administration of 

federal elections.” Activities include educating voters on voting rights, voting procedures and 

voting technology, training election officials and poll workers, improving, acquiring, leasing or 

replacing voting equipment, improving the accessibility and quality of polling places (including 

for voters with limited English proficiency), and hotlines for voters to obtain election information 

and/or report complaints of fraud or voting rights violations.

The grants office monitored Section 101 grants in the amount of $166,273,394 to 20 states. EAC 

also closed three grants that were fully expended.
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Agency Capacity Building 

In FY 2021, the EAC decided to make the Grants program into a standalone office to reflect the 

importance of the function at the agency. The Office of Grants Management now reports directly 

to the Executive Director. Additional personnel changes included hiring a full-time Grants 

Specialist to oversee and support the increased grantmaking responsibilities for the agency and 

recruiting a second Grants Management Specialist with a start date anticipated in FY 2022.

The agency received electronic submissions for its required grant reports. Report frequency was 

increased in FY 2021 with both an annual and mid-year Federal Financial Report (FFR) and 

Progress Report due for each HAVA grant.

The agency renewed its agreement to work with HHS for the negotiation of Indirect Cost Rate 

Agreement for its grantees. 

The agency also selected HHS’ GrantSolutions grants administration software as a service to 

improve and automate its grants administration functions so more time can be spent for strategic 

activities and technical support to grantees. Utilization of a grant system will reduce grantee time 

spent on administrative activities; freeing up staff time to execute and oversee grant activities. The 

GrantSolutions award management system will allow EAC to standardize financial assistance 

management procedures and increase transparency, accountability, and oversight for financial 

assistance funding. With a grant system, staff can develop better technical assistance trainings for 

award management, best practices, audit readiness, and education on federal assistance grants 

administration. The EAC conducted a fit gap analysis with GrantSolutions in September 2021 to 

assess current business processes against system capabilities and options. The EAC anticipates 

fully deploying the system by FY 2023 ahead of the next annual report deadline of December 29, 

2022.

Oversight and Monitoring

The EAC is mandated to monitor and provide oversight for all HAVA grants. The CARES Act 

requires states to submit reports on expenditures within 20 days of each primary and the general 

election. The EAC developed an efficient process to review and aggregate those reports and 

submit them to Congress within three days of the grantees’ deadline, as required by the CARES 

Act. During FY 2021, the grants office submitted reports to Congress related to the states’ 

primaries between October 1, 2020 – December 30, 2020. The EAC continues to oversee the grant

expenditures and developed a process to identify funds remaining unspent to return to the U.S. 

Treasury after December 31, 2020, and closeout CARES grants that had completed activities and 

associated spending

During FY 2021, staff reviewed Federal Financial Reports (FFRs) and Progress Reports submitted 

by the states for their HAVA Section 101 grants for activities to improve the administration of 

elections, 251 Requirements Payment funds, and Election Security grants. Information from the 

FFRs as of September 30, 2020, was used to compile the annual grant expenditure report during 

FY 2021. The report is available on www.EAC.gov. 
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The EAC’s Inspector General audits the states’ use of the funds, and EAC grants team has worked 

with the OIG to resolve and close out audit findings.

Training and Technical Assistance 

EAC staff members provide technical assistance to the states as they plan and implement federal

funds. During FY 2021, staff conducted remote technical assistance to states and developed 

tailored guidance around the CARES funding and use of other HAVA funding during the 

pandemic.

Specifically, EAC developed Frequently Asked Questions (FAQs), written guidance, and webinars 

to train grantees on the use of CARES funding and Election Security funds. The team responded to 

a high volume of inquiries regarding allowable, allocable, reasonable, and necessary expenditures 

and funding activities. 

Additionally, EAC staff created guidance and training to support the change in reporting 

requirements and mechanism for the grantee progress and financial reports and coordinated

indirect cost rate negotiations for states with the Department of Health and Human Services. 

Program Area: Research 

The Research Division supports the agency’s mission by providing useful resources that assist 

state and local election officials in administering elections and help voters participate in the 

process. Among the products created and managed by this program is the EAC’s Election 

Administration and Voting Survey (EAVS). The Research Division primarily supports the 

strategic goals listed below.

Current Strategic Plan (2018-2022) Goals:

• Analyze: Expand the nation’s comprehensive understanding of American election 

administration. 

• Build: Proactively and responsively create products that help election officials improve 

elections administration and help voters more easily participate in elections.

• Distribute: Help election officials improve the administration of American elections 

through the distribution of EAC assistance and products. Research is responsible for 

gathering and creating election administration resources to assist election officials and 

voters.

FY 2021 Accomplishments

Election Administration and Voting Survey

On a biennial basis, the EAC administers the EAVS, the most comprehensive survey on the 

administration of U.S. elections. The survey collects data on more than 400 variables from all 50 

states, the District of Columbia, American Samoa, Guam, Puerto Rico, the Virgin Islands and the 

Northern Mariana Islands. The EAVS dataset is usable by other federal agencies, election officials, 

academics and researchers to understand and improve the administration of U.S. elections. 
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Additionally, through the successful administration of EAVS, the EAC meets numerous legislative 

mandates related to the Uniformed and Overseas Citizens Absentee Voting Act and the National 

Voter Registration Act for the collection of information pertaining to the administration of U.S. 

elections.

Following the November 2020 election, the EAC administered the 2020 EAVS. In the summer of 

2021, the EAC for the first time conducted a second round of data review with states prior to the 

publication of the 2020 EAVS Comprehensive Report. In late FY 2021, the EAC initiated a needs 

assessment review by interviewing 27 states about their experiences completing the 2020 EAVS 

and gathered input from participants for implementation in 2022. Usability testing of the survey 

instruments also continued in preparation for 2022. Through this user-centered testing, EAVS and 

Policy Survey navigation is evaluated by real users under the observation of a trained researcher to 

improve user experience. EAC continues to work to improve data quality of these survey 

instruments. The EAC is currently planning for the December 2021 start of the 60-day public 

comment period for the 2022 EAVS, with the 30-day public comment period to follow in February 

2022. OMB approval of the 2022 survey instruments is anticipated for March 2022.

In FY 2021, EAC Research acquired the Statistical Analysis System (SAS) software to facilitate 

easier and more complex data analysis. Using this analytical tool in combination with the existing 

tool, MS Excel, EAC research staff was able to respond to approximately 100 data and information 

requests from voters, election officials and researchers representing 29 states and the District of 

Columbia. On average, research staff worked 2 hours per request to ensure accuracy. Staff also use 

these tools to conduct proactive analysis of EAVS data misuse in the news media, prepare factcheck briefs and develop presentations.

Conducting Original Research

In FY 2021, the EAC contracted with the American Enterprise Institute (AEI) and MIT’s Election 

Data and Science Lab to conduct a study titled, Lessons Learned from the 2020 Election. The 

report provides an account of how the American system of election administration responded to 

the significant barriers erected by the pandemic challenges. Takeaways from the Lessons Learned 

report provide insight for implementation in future elections. The EAC also worked with Rutgers 

University to conduct a study on voting accessibility. Disability and Voting Accessibility in the 

2020 Elections: Final Report on Survey Results is a study that examines progress in voting 

accessibility since the last EAC study conducted on this topic in 2012. The EAC works to ensure 

that elections are fully accessible for all people with disabilities.

Serving Voters

In FY 2021, the EAC processed eight state-requested updates to the National Mail Voter 

Registration form instructions and accompanying language translations. The EAC began to process 

two additional state updates at the end of the fiscal year. The EAC offers a Braille translation of 

the form’s content alongside 15 other language translations. In late FY 2021, the EAC began the 

OMB renewal process for the form and is currently collecting the first round of public comments 

during a 60-day period. The EAC understands it must not only help election officials improve the 

administration of their elections but must also directly help voters. Voter resources is one of the 
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most frequently visited portions of the agency’s website. Voters can find a Voter’s Guide to 

Federal Elections, resources for overseas and military voters and information on registering to vote 

– including the National Mail Voter Registration Form.

Program Area: Testing and Certification 

The Testing and Certification Division supports the mission of the agency by providing project 

management and subject matter expertise in the modification of the Voluntary Voting System 

Guidelines (VVSG), overseeing the testing and certification of voting systems to the VVSG, 

running a quality monitoring program to ensure that EAC-registered voting system manufacturers 

and EAC-accredited voting system test laboratories (VSTL) comply with VVSG and EAC 

policies, and assisting election administrators. This program primarily supports the strategic goals 

listed below. 

Current Strategic Plan (2018-2022) Goals:

• Build: Proactively and responsively create products that help election officials improve the 

administration of elections and help voters more easily participate in elections

• Distribute: Help election officials improve the administration of American elections

through the distribution of EAC assistance and products.

FY 2021 Accomplishments 

The EAC administers and manages the only national standard-setting program to build, test, and 

certify voting systems. States’ use of this program and its standards is voluntary. Most, if not all, 

states use the program in some way. The program operates by creating and modifying the VVSG, 

accrediting test laboratories to test against these guidelines and administering voting system test 

campaigns. Manufacturers submit voting systems to the test laboratories for testing. If a voting 

system meets all the requirements established in the guidelines, then the EAC certifies the voting 

system. Election officials use this information to help them know that they are procuring highquality, reliable voting systems. Some states only allow their officials to procure and use voting 

systems that have been certified to the VVSG. Other states use the standard by itself, and still,

others use the testing program’s labs to help with their certifications. 

The Testing and Certification Division completed drafting the VVSG 2.0 and associated program 

documentation, which were unanimously approved by the EAC Commissioners in February 2021.

With its adoption, manufacturers may begin designing and building new voting equipment to 

comply with the new guidelines. The VVSG 2.0 includes significant improvements to 

accessibility, usability, and cybersecurity requirements. Also supported are various audit methods 

and software independence to confirm the accuracy of the vote which will serve to increase voter 

confidence.

Since adoption of the VVSG 2.0, the Testing and Certification Division has worked to implement 

the new standard by working with NIST’s NVLAP (National Voluntary Lab Accreditation 

Program) on updates to their program for accreditation of labs for VVSG 2.0. A draft VVSG 

Lifecycle Policy has been created that will establish a regular update process for the VVSG and

procedures for deprecation of older versions of the standard. Testing and Certification is also in the 
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process of working with NIST on establishing an end-to-end cryptographic protocol evaluation 

plan 

In addition to the work on VVSG 2.0, the EAC’s Testing and Certification program tested and 

certified one voting system and 27 engineering change orders (ECOs). Currently there are four 

active voting system test campaigns.

The Testing and Certification Division is also working on developing a testing pilot program for 

election supporting technology. This initial pilot program will include standards for accessibility, 

usability, and security for electronic pollbooks. Program processes and procedures are also being 

developed. This program will be expanded to other technologies such as voter registration 

databases and remote ballot delivery systems.

These ongoing, regular efforts to assist election officials are critical to the successful operation of 

the program. Thousands of election jurisdictions nationally are continually researching and 

procuring voting equipment, and the EAC’s Testing and Certification Division helps them 

navigate this process with confidence.

Program Area: Cyber Access and Security Program 

The Cyber Access and Security program (CAS) was launched in 2020 and supports the agency

mission by making timely and relevant cybersecurity information available to election officials and 

others involved in election administration. Additionally, the program supports internal training, 

compliance, and monitoring to ensure the agency’s cybersecurity posture remains at consistently 

high levels. This program primarily supports the strategic goals listed below. 

Current Strategic Plan (2018-2022) Goals:

• Build: Proactively and responsively create products that help election officials improve the 

administration of elections and help voters more easily participate in elections

• Distribute: Help election officials improve the administration of American elections

through the distribution of EAC assistance and products.

FY 2021 Accomplishments 

The Cyber Access and Security Program (CAS) is an integral part of the EAC’s clearinghouse 

mission. CAS maintains an Election Security Preparedness page on the EAC website with 

cybersecurity, risk management, training, best practice, and other resources to support this key 

mission objective. CAS coordinates closely with other agencies such as NIST, CISA, and FBI to 

produce relevant and timely products that complement other agency offerings. Examples of this 

include the publishing of guidance on hash validation, contributions to the EAC’s chain of custody 

best practices guidance, and the continued hosting of CISA’s Election Risk Management online 

tool.

CAS also engages with private partners to produce high-quality cybersecurity training materials 

for use by state, local, tribal, and territorial election administrators. In partnership with the Center 
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for Tech and Civic Life (CTCL), the EAC continued to make available no-cost, self-paced online 

cybersecurity training focused on election officials. 

In 2021, the program brought additional focus to the EAC’s internal security in response to 

Executive Order 14028, Improving the Nation’s Cybersecurity, by establishing plans to move our 

information technology assets toward a zero-trust architecture. Related directives also saw the 

program standing up a vulnerability disclosure program for all publicly accessible EAC assets and 

signing a memorandum of understanding with CISA to begin participation in their continuous 

diagnostics and monitoring program. The program added a cyber analyst in 2021 to further support 

its mission.

The EAC and CAS continue to seek new and innovative ways to deliver high-quality information 

and training to election officials. As the federal agency tasked with distributing election 

administration best practices, the EAC is well positioned to expand its leadership in this area in 

coordination with our public and private partners.
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Additional Information Regarding Agency Management and Operations

EAC leadership regularly works to further the agency’s mission by providing EAC staff the 

necessary resources to improve performance and strengthen internal controls that will maximize 

the agency’s operations. This program primarily supports the strategic goals listed below.

Current Strategic Plan (2018-2022) Goals:

• Operate: Ensure continued effective operation of the EAC in order to achieve its goals 

while acting as good stewards of public funds. 

During FY 2020, the EAC held a virtual Standards Boards and Board of Advisors meeting in June 

pursuant to the Help America Vote Act. The Advisory Boards reviewed the next generation of 

VVSG, discussed the intent and application process for newly appropriated HAVA funding, 

examined election security efforts, and tackled other timely election-related issues, such as disaster 

recovery contingency planning. 

The EAC focuses on establishing sound systems and policies and procedures, working with 

managers on the relationship between budget and performance, maximizing efficient use of staff 

and financial resources, and training the EAC staff on financial management processes and their 

specific, individual responsibilities. Budget holders complete assessable unit risk and fraud 

assessment questionnaires. The risk and fraud assessments are reviewed by the Executive Director 

and the Financial Director and rolled into the agency’s Annual Statement of Assurance that is 

presented in this report.

In FY 2021, the EAC continued to provide financial management tools and support to staff. 

Agency staff can utilize five automated systems (procurement, travel, purchase card, invoice, and 

time and attendance) via interagency agreements with the General Services Administration and the 

U.S. Department of Treasury Bureau of the Fiscal Service. The EAC staff Contracting Officer’s 

Representatives (CORs) were provided annual training and have access to free online COR and 

invoice approval training via the procurement service provider agency. 
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FY 2021 Performance Summary

The following table presents key EAC FY 2021 program performance results data.

 Performance Indicator

Type of 

Indicator Outcome

Program Area: Communications and Clearinghouse

Regularly issue information on EAC 

activities.

Output Distributed about 25 press releases

Generated about 15,400 print and broadcast

press mentions.

290 Facebook posts with over 293,000 

impressions

441 Tweets with about 2.4 million 

impressions

EAC quarterly and monthly newsletters to 

about 4,500 state and local election officials

Produce the annual report of EAC activities 

to Congress by January 31 of each year for 

the preceding year ending September 30, 

and other original documents.

Output Annual report transmitted to Congress 

January 31, 2021

Produced best practices documents on the 

following topics:

• Chain of Custody

• Best Practices FAQ Toolkit

• Best Practices: Accessible Voter 

Registration

• EAC’s Testing and Certification 

Program

• Local Election Officials’ Guide to 

Redistricting

Updated the Glossary of Election 

Terminology with nearly 1,300 terms

Program Area: Grants Management 

CARES Grant Oversight and Monitoring Output Continuous monitoring of grant reporting 

and activities including closing out grants 

on a rolling basis. Closed 18 CARES 

grants.

Election Security Grant Oversight and 

Monitoring

Output Continuous monitoring of grant reporting 

and activities

Section 251 Requirements Payments Grant 

Oversight and Monitoring

Output Continuous monitoring of grant reporting 

and activities
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Section 101 Grant Oversight and 

Monitoring

Output Continuous monitoring of grant reporting 

and activities

Modernize and automate the administration 

of grants at EAC.

Executed an IAA with the Health and 

Human Services (HHS) GrantSolutions for 

SAAS services. Began process to identify 

fit and gaps in EAC grant administration

business processes by mapping them to the 

Grants Management Module (GMM) in 

GrantSolutions.

Review Progress and Financial Reports and 

follow up with failure to file.

Output EAC reviewed all submitted Federal

Financial Reports (FFRs) and Progress 

Reports across the four streams of funding, 

HAVA Section 101, 251 Requirement 

Payments, Election Security and CARES.

DATA Act – USASpending.gov Grants 

Reporting 

Output EAC is compliant with requirements to post 

grant funding in USA Spending and has 

updated policies and procedures for 

submission of the data.

Training and Technical Assistance Output Provided training and technical assistance 

over email, phone, webinars and written 

guidance in the form of Frequently Asked 

Questions and online guidance.

Program Area: Research 

Effectively and efficiently distribute 

federal resources to EAC stakeholders.

Output Updated 9 state requests to the NVRA form.

Distributed electronic version of the EAVS 

report to about 6,500 state and local election 

officials, Congressional staff, and press. 

Published 2 original research studies.

Serve as an expert on the 

administration of American elections.

Output Performed EAVS data fact checks 

originating from press requests and inquiries 

from the general public.

Program Area: Testing and Certification

Test and certify voting systems. Output Certified 1 voting system with 4 currently in 

progress.

Approved 27 engineering change orders 

(ECOs).

Produce voting system guidance for use 

in the field.

Output Completed public comment review of 

VVSG draft requirements and updating 

relevant EAC documentation.

Adopted new VVSG requirements.
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Portfolio Analysis

Since 2004, EAC has received funds in four appropriations: Salaries and Expenses, Election 

Reform Programs, Election Data Collection Grants (for FY 2008 only), and CARES (for FY 2020 

only). In FY 2021, EAC received funds in the Salaries and Expenses (S&E) appropriation of $17

million. The S&E appropriation was used for a $1.5 million transfer to NIST, agency relocation 

expenses, payroll, travel, rent, telecommunications, printing, contracts, supplies, subscriptions, 

equipment and software. 

Published significant updates to Testing and 

Certification Program manuals and new 

VVSG test assertions.

Drafted VVSG Lifecycle policy based on 

feedback from EAC FACA boards and 

posted for public comment.

Program Area: IT & Cyber

Provide timely cybersecurity training 

information to election officials

Output The EAC provided no-cost, self-paced 

training via online content delivery for 

cybersecurity 101, 201, 301.

Increase the cybersecurity capabilities 

of the agency for both internal and 

external customers

Output The EAC hired one staff with a technical 

cybersecurity background. Additionally, a 

vulnerability disclosure program was 

launched for all publicly accessible EAC IT 

assets. A plan was developed and work 

started toward moving to a zero-trust 

architecture for EAC systems.

Continue to modernize EAC IT 

infrastructure

Output The EAC began a project to create an 

interactive portal for election officials that 

will include new tools for data visualization 

and collaboration. New laptop computers 

were procured and deployed to ensure EAC 

personnel are able to continue working 

efficiently with the latest technology.

Provide support to other EAC departments Output The office of the Chief Information Officer 

personnel provided critical support toward 

advancing VVSG 2.0 for adoption, drafting 

the VVSG Lifecycle policy, and input to the 

chain of custody best practice guidance.
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I.C. FINANCIAL RESULTS

The following analysis is intended to provide information on EAC’s financial results, position, and 

condition as portrayed in the financial statements and the notes to the statements presented in 

Sections II.D and II.E of this report. Changes in assets, liabilities, costs, revenues, obligations, and 

outlays are explained; comparisons are made between amounts in FY 2020 to FY 2021; and the 

relevance of balances and amounts in the financial statements and notes are discussed. The 

changes provide context as to how the year’s activities impacted the agency’s financial position. 

Budgetary Resources 

Budgetary resources are the amounts made available and their status at the end of the fiscal year. 

The majority of EAC’s available budgetary resources are in the one-year Salaries and Expenses 

appropriation. Budgetary resources include new Budget Authority from annual Salaries and 

Expenses appropriations, unpaid obligations, recoveries, offsetting collections, carryover no year 

grant funds, and unobligated balances. 

FY 2021, the available budgetary resources were $17 million, down from $843.61 million in FY

2020. In FY 2021, as mentioned previously, EAC’s appropriations totaled $17 million for Salaries 

and Expenses, including a $1.5 million non-expenditure transfer to NIST.

Obligations Incurred decreased from $837.8 million in FY 2020 to $16.7 million in FY 2021 (due 

to no appropriation for grant funding). The Unobligated Balance – Apportioned decreased from 

$1.2 million in FY 2020 to $73k in FY 2021. 

Financial Position

Assets

EAC had $55.9 million in total assets (Fund Balance with Treasury; Accounts Receivable; 

Property, Equipment, and Software; and Other Assets) as of September 30, 2021, compared to 

$15.1 million in FY 2020. 

Liabilities

EAC had total liabilities (Accounts Payable, accrued salaries and benefits, and unfunded leave) of 

$2,845,558 as of September 30, 2020. Liabilities increased to 4,419,851 as of September 30, 2021. 

Net Position

Net position (Unexpended Appropriations and Cumulative Results of Operations) increased from 

$15.1 million in FY 2020, to $55.9 million in FY 2021. 
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Results of Operations

The EAC, as presented in the Statement of Net Costs, reports the results of operations within four 

programs: Analyze; Build; Distribute; and Operate. Costs specifically identified with each of the 

programs, such as direct personnel costs and specific program contract expenses, are allocated to 

the programs directly. Other general agency overhead costs, such as rent, information technology, 

and financial management, are allocated on a per employee basis. The methodology is outlined in 

EAC’s Cost Allocation Model and is reviewed by the financial statement auditors each year to 

ensure the accurate allocation of expenses to each program. 

The Total Net Cost of Operations (expenses in the Salaries and Expenses, and Election Reform 

Programs appropriations) for the EAC was -$24 million due to unexpended appropriated CARES 

grant funds being returned in FY 2021, a decrease from $834 million in FY 2020.

Limitations of the Financial Statements 

The principal financial statements have been prepared to report the financial position and results of 

operations of the entity, pursuant to the requirements of 31 U.S. Code 3515(b). The statements 

have been prepared from the books and records of EAC in accordance with Generally Accepted 

Accounting Principles (GAAP) for federal entities and the formats prescribed by the Office of 

Management and Budget. The statements are in addition to the financial reports that are used to 

monitor and control budgetary resources during execution of the budget, which are prepared from 

the same books and records. 

The statements should be read with the understanding that they are for a component of the U.S. 

Government, a sovereign entity. 
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I.D. ANALYSIS OF CONTROLS, MANAGEMENT SYSTEMS, AND LEGAL 

COMPLIANCE

Internal Control Environment

EAC is subject to numerous legislative and regulatory requirements that promote and support 

effective internal controls. EAC believes that maintaining integrity and accountability in its 

programs and operations is critical for good government, demonstrates responsible stewardship 

over assets and resources, helps ensure high-quality and responsible leadership, allows for 

effective delivery of services to customers, and maximizes desired program outcomes. 

EAC has developed and implemented management, administrative and financial system controls 

with the aim of ensuring that: 1) programs and operations achieve intended results efficiently and 

effectively, 2) resources are used in accordance with the mission of the agency, 3) programs and 

resources are protected from waste, fraud and abuse, 4) program and operational activities are in 

compliance with laws and regulations, and 5) reliable, complete and timely data are maintained 

and used for decision-making. 

The agency can provide unqualified assurance that internal control over financial reporting is 

effective, ensuring that transactions are executed in accordance with budgetary and financial laws 

and other requirements, consistent with the purposes authorized, and recorded in accordance with 

federal accounting standards. EAC ensures that assets are properly acquired and used, and 

safeguarded to deter theft, accidental loss or unauthorized disposition, and fraud. 

Laws that help the EAC improve the management of its financial operations and programs are as 

follows: 

Federal Manager’s Financial Integrity Act

The Federal Manager’s Financial Integrity Act (FMFIA) of 1982 requires Executive Branch 

agencies to establish, maintain, and assess internal controls to ensure that agency program and 

financial operations are performed effectively and efficiently. To help ensure that controls have 

been identified and implemented, the heads of agencies must annually evaluate and report on the 

effectiveness of internal controls (FMFIA Section 2) and financial management systems (FMFIA 

Section 4) that protect the integrity of federal programs. 

Entity-Wide Security Program 

The EAC’s Information Technology (IT) staff explores innovations to update and improve 

network services for security, availability, efficiency, and productivity. Currently, EAC operates 

its own infrastructure. The EAC IT staff of four maintains personal computers, smart phones, and 

servers; provides software requested by EAC staff, remote access services, Voice Over Internet 

Protocol and Interactive Voice Response telecommunications tools; and performs vulnerability 

scans (in addition to DHS Cyber Hygiene scans). IT staff remediates and updates security patches 

so that staff is equipped to perform work both on- and off-site in a secure environment. 
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The EAC manages firewalls, intrusion detection, Trusted Internet Connections (TIC) compliant T1 

lines, and routers and switches for Federal Information Security Management Act (FISMA) 

compliance. The EAC’s cybersecurity management needs are managed by three staff members 

with extensive cybersecurity backgrounds as part of a newly created cybersecurity program. The 

program, in conjunction with IT personnel, continuously monitors the EAC's IT systems security 

as described in OMB M-10-15, FY 2010 Reporting Instructions for the FISMA and Agency

Privacy Management, dated April 21, 2010. 

Federal Information Security Management Act

EAC was overall in compliance with the Federal Information Security Management Act at the end 

of FY 2021. The audit will be available on EAC’s website.

Audit Follow-Up

EAC’s Office of the Inspector General (OIG) conducts audits and reviews of the agency’s 

operations. The Office of the Chief Financial Officer (OCFO) works closely with EAC 

management and the OIG to complete actions necessary to respond to audit findings. EAC’s 

Inspector General’s statement of major management and performance challenges are documented 

in Section III.A. of this report. EAC also considers and responds to recommendations from audits 

and reviews conducted by the Government Accountability Office. 

Federal Financial Management Improvement Act

Per OMB Bulletin No. 14-02, “Audit Requirements for Federal Financial Statements,” EAC as an 

Accountability of Tax Dollars Act of 2002-covered agency, is not subject to the requirements of 

the Federal Financial Management Improvement Act. 

Accountability of Tax Dollars Act of 2002 

The FY 2021 financial statement audit report identified no material weaknesses in internal control 

over financial reporting.

Inspector General Act Amendments of 1988

The EAC Office of the Inspector General audits HAVA funds administered by recipients of 

HAVA payments and grants, and transmits OMB Circular A-133 single audit reports that present 

findings on HAVA funds to EAC. The principal recipients of HAVA payments and grant funds are 

state governments.

Fraud Reduction Report

Pursuant to the Fraud Reduction and Data Analytics Act of 2015 (Public Law 114-186, 32 U.S. 

Code 3321 note), EAC is reporting on its fraud reduction efforts since the final quarter of FY 2021

in three key areas:
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I. Implementation of financial and administrative controls

Financial and administrative controls are described in the EAC’s Annual Accounting Handbook,

Annual Financial Statement Preparation Guide, Procurement Handbook, Budget Policy, 

Administrative Control of Funds Policy, Internal Control Procedures, Grants Handbook, and 

Travel Handbook. Standard Forms 49 Requisitions are used for credit card approvals. The forms 

are used to reconcile monthly purchase card statements in the Citi system, entered by cardholders 

and reviewed and approved by the Financial Manager as cardholder agency point of contact.

Financial and administrative controls are further described in annual cycle memoranda prepared as 

part of the annual financial statement audit, which lasts from April through mid-November. The 

memos are in the areas of: Fund Balance with Treasury, Accounts Receivable, Accounts Payable, 

Payroll, Budget, Cash Receipts and Disbursements, and Undelivered Orders.

II. The fraud risk principle in the Standards for Internal Control in the Government (the GAO 

Green Book)

Principle 8 of the Green Book requires agency management, “to consider the potential for fraud 

when identifying, analyzing, and responding to risks.” The Green Book defines fraud as “obtaining 

something of value through willful misrepresentation.” Historically, EAC has not experienced 

willful fraud. Management views the risk of fraud as minimal given the agency’s size, budget, 

existence of shared service providers, and a culture of zero tolerance for fraud. Further, 

management signed a document stating that they are not aware of instances of fraud in FY 2021.

The Green Book identifies three types of fraud:

1. Fraudulent financial reporting (intentional misstatements or omissions or disclosures)

2. Misappropriation of assets (theft, embezzlement, fraudulent payments)

3. Corruption (bribery and other illegal acts)

Another fraud risk is misconduct (e.g., waste or abuse of government resources). 

The EAC, has built-in segregation of duties with a contractual financial, travel and procurement 

services provider at another federal agency via interagency agreement, a second federal agency

provider for payroll and human resources services, a third interagency for a large contract, and a 

full-time Inspector General. Most financial transactions involve three individuals. 

EAC is assessed to have a low risk of fraud in these areas: 

• Fraudulent financial reporting risk: financial reporting is provided by one of the four OMBauthorized financial service providers. All financial reporting, including financial statements 

and necessary journal entries, is reviewed and approved by the EAC Finance Office prior to 

publication. Further, the EAC has undergone a financial statement audit by an independent 

financial auditor each year since FY 2008. The auditors’ working papers are reviewed by the 

agency’s Inspector General.

• Misappropriation of assets: assets are recorded in the general ledger, inventoried and tagged 

by two offices within the EAC, and schedules of depreciation of the assets are maintained by 
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the financial services provider. The EAC’s building and its assets are secured by the Federal

Protective Service via interagency agreement. Property removed from the building requires 

presentation of a signed property pass to a guard.

• Bribery: contracting officers are located at other agencies, the EAC staff serves as vendor 

contract proposal evaluation panel reviewers, funds for procurements are certified by the 

Finance Office, and staff is made aware in mandatory training and at all staff meetings that 

taking gifts valued over $20 is prohibited.

• Illegal acts: staff are encouraged to report perceived illegal acts to the General Counsel as 

Ethics Officer, supervisors, and the Inspector General. The EAC’s Human Resource 

Handbook provides thorough descriptions of standards of conduct, fitness for duties based on 

character and conduct, disciplinary and adverse actions for misconduct, and ethics. 

• Waste of government resources and abuse of authority or position: the IG maintains a fraud, 

waste, abuse hotline. Staff and the public can call the hotline anonymously to report perceived 

cases of fraud, waste, or abuse. Further, staff are provided with Whistleblower training, so 

they know how to protect themselves from repercussions related to reporting wrongdoing. 

Other EAC mandatory training includes Privacy Act and IT security training. Standards of 

conduct are laid out in the EAC’s Office of Human Resources Handbook, available on the 

agency’s shared drive, and reviewed at New Employee Orientation. The manual specifies that 

the agency’s General Counsel serves as the Designated Agency Ethics Officer, who should be 

consulted on specific issues of concern. 

Fraud risk factors in the Green Book are incentive/pressure, opportunity (e.g., absence of or 

ineffective controls, override of controls), and attitude/rationalization. The risk factors are used by 

management to identify fraud risks. As mentioned above, the EAC relies on Inspector General and 

internal auditors and other internal and external individuals to provide information about suspected 

fraud or allegations of fraud.

The risk of opportunity is greatly reduced with financial staff at the EAC separate from the 

accounting and procurement service provider. Independent auditors’ recommendations are taken 

seriously and implemented timely, at times in conjunction with the service providers’ controls. The 

EAC does not have identified material weaknesses in internal controls over operations in FY 2021. 

Any management override of controls would necessarily involve staff at two federal agencies since 

the EAC does not have “write” access to the core financial system.

Management communicates the consequences of committing fraud in mandatory Ethics, 

Prohibited Practices and Whistleblower Protection, Information Technology Security, Privacy Act, 

and Privacy Rules of Behavior training. 

III. OMB Circular A-123 with respect to leading practices for managing fraud risk

The EAC management and its independent financial statement and Federal Information Security 

Management Act (FISMA) auditors are responsible for disclosing detected risks. This and other 

information help management identify and assess risks. Assessment of fraud risk is crucial so that 

it can be mitigated or prevented and does not adversely impact agency mission and operations 

objectives by affecting its ability to effectively and efficiently use its resources.
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The EAC is required to report on progress in identifying risks and vulnerabilities to fraud, 

including the areas of: payroll, beneficiary payments (such as life insurance), grants, large 

contracts, information technology and security, asset safeguards, purchase cards, and travel cards. 

The EAC has assessed its vulnerabilities to fraud in these areas as low, taking into account use of 

another federal agency for payroll, IT and human resources services, and a second federal agency

for accounting services, disbursement of grant funds, and purchase and travel card programs. Via 

interagency agreement, two agencies award EAC’s large contracts. As mentioned, assets are 

protected by Federal Protective Service guards assigned to the building, and by a key card system 

protecting the EAC’s suite within the building.

Due to its size and relationship with federal service providers, where the majority of financial 

transactions involve separation of duties and involvement by at least three staff, the risks within 

the agency are assessed to be low. Grant risks are remediated by Inspector General audits and 

agency assistance to grantees on technical assistance and audit resolution. The EAC controls 

include controls related to its use of service organizations. Separation of duties between federal

entities is laid out in the roles and responsibilities sections of their interagency agreements.

The EAC utilizes automated time and attendance, procurement, contract payments, and travel and 

purchase card systems housed at other agencies. EAC has agency points of contact for purchase

and travel cards, as does the financial service provider. Travel service provider accountants 

reconcile EAC’s Central Billing Account each month. Agency-specified types of vendors allowed 

for use are established under the procurement card program via the use of Master Contract Codes. 

All other vendors will result in a card decline until the type of procurement is reviewed and access 

is given temporarily for the purchase.

Grantees, as well as vendors, are required to be registered in the federal System for Award 

Management (SAM). Grantee requests for payment are reviewed by several staff at the EAC and 

recorded on route slips prior to sending the requests to the service provider’s Accounts Payable 

office. Further, grantee Federal Financial Reports are reviewed and analyzed each year. The 

process includes confirmation of period of performance of the award, report type (annual or final), 

Dun & Bradstreet Number and Employer Identification Number. Total award, Required Match, 

and Program Incomes are reviewed for accuracy. The reports are reconciled against prior year 

submission to analyze spending rates over time. Questions and errors are relayed back to the 

grantee timely. EAC creates reports tracking key metrics related to expenditure of federal funds 

and state match. Grant expenditure reports are provided to Congress and posted on EAC.gov.

Requests for payments to vendors are reviewed by trained and certified Contracting Officer’s 

Representatives. Payments are made by service provider staff for interagency agreements, and in 

the Internet Payment Platform for the two federal agencies that award contracts on EAC’s behalf 

for commercial vendors by EAC CORs. If a vendor claims nonpayment of bills, Treasury reports 

are requested to provide banking information confirming payment with banking information. It 

should be noted that grantees and vendors contact the agency if a payment is not received timely, 

which could be an indicator of fraud, so misdirection of funds is considered low risk. Financial 

system controls prevent vendor overpayment.
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Further, CORs and the EAC Finance Division provide quarterly accruals and deobligations to the 

financial service provider on all open obligations. The Finance Office is required to certify that the 

open obligations are valid. The certification is reviewed by the financial statement auditors each 

year.

Each year, the EAC performs an Improper Payments Elimination and Recovery Improvement Act 

review for the financial statement audit. 

Strategies, Procedures and Other Steps

The EAC is required to report progress to curb fraud by establishing strategies, procedures, and 

other steps. Steps include agency requirement for ethics training for all staff, which includes how 

to avoid a conflict of interest. Several staff members complete confidential and public Financial 

Disclosure reports annually. The reports are reviewed by the Ethics Officer for conflicts of interest. 

Further, Contracting Officer’s Representatives are required to take Ethics in Contracting training, 

which further reinforces the need to avoid conflicts of interest in procurements. Contracting 

Officer’s Representative can also take a free online course entitled Procurement Fraud Indicators.

Cards and system access are cancelled for exiting employees. The financial service provider asks 

for annual certification from the Finance Office on all systems access by EAC staff. The process 

includes review of roles and transaction amount limits for authorized staff.

The EAC undergoes annual financial statement and Federal Information Security Management Act 

audits. The EAC reviews grant audit findings and works with grantees pre- and post-audit. The 

EAC reviews financial transactions for error and potential fraud, and the financial service provider 

has staff accountants with CPAs who review financial transactions. Generally, the requestor of a 

transaction, his or her supervisor, and the EAC funds certifier sign off on transactions. The service 

providers obligate procurement funds. The EAC analyzes its shared service provider’s regular 

audits throughout the year including purchase card payment timeliness, completeness of card logs, 

and accuracy of payments; Internet Payment Platform invoice post-payment audits of timeliness 

and accuracy, prompt pay reports; accounts payable delinquencies; and travel audits of compliance 

with the Federal Travel Regulation, attachment of required receipts to vouchers, and accuracy and 

timeliness of payment amounts.
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GONE Act 

CATEGORY 2-3 Years 3-5 Years More than 5 Years

Number of 

Grants/Cooperative 

Agreements with Zero

Dollar Balances

0 0 3

Number of 

Grants/Cooperative

Agreements with 

Undisbursed Balances

0 0 0

Total Amount of

Undisbursed Balances

0 0 0

In FY 2021, EAC closed five grants. The three grants remaining to be closed require additional 

data from the grantees and final Federal Financial Reports before EAC can close them. EAC 

expects to receive the required data by the end of the calendar year for the remaining grants. The 

EAC is currently working with the states to submit the required reports
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Annual Assurance Statement on Internal Control
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SECTION II

 Financial Section
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I. Audit Report

II.A. Inspector General’s Assessmen
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Independent Auditor’s Report on the Financial Statements
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Notes to the Financial Statement
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SECTION III

Other Accompanying Information
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III.B. IMPROPER PAYMENTS

The Improper Payments Act requires each federal agency to assess all programs and identify 

which, if any, may be subject to high risk with respect to improper payments. For Fiscal Year 

2021, the EAC does not believe that it has any programs where the erroneous payments could 

exceed 1.5 percent of program payments or $10.0 million threshold (set in OMB Guidance) to 

trigger further agency action. Additionally, the agency is in compliance as per the last IG 

compliance review, and the EAC did not have any improper payments identified for FY 2021 in its 

annual review by Treasury’s Bureau of Fiscal Service.

III.C. SUMMARY OF FINANCIAL STATEMENT AUDIT AND 

MANAGEMENT ASSURANCES

SUMMARY OF FISCAL YEAR 2021 FINANCIAL STATEMENT AUDIT

Audit Opinion Unmodified

Material Weaknesses

Beginning 

Balance New Resolved Consolidated

Ending 

Balance

Financial Accounting & Reporting 0 0

Total Material Weaknesses 0 0

Summary of Management Assurances

Statement of Assurance 

(FMFIA§ 2) Unmodified

No. Summary

Beginning 

Balance New Resolved Consolidated

Ending 

Balance

1 Material Weaknesses 

(FMFIA§ 2) 0 0

Total 0 0