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(202) 566-3100 (p), (202) 566-3127 (f), www.eac.gov 

Page 1 

U.S. Election Assistance Commission 

Testimony before the U.S. House Committee on Appropriations, 

Subcommittee on Financial Services and General Government 

March 7, 2007 

Good morning Chairman Serrano, Ranking Member Regula, and Members of the 

Subcommittee. I am pleased to be here this morning on behalf of the U.S. Election 

Assistance Commission (EAC) to discuss election integrity, the changes in voting that 

have been effectuated by the Help America Vote Act of 2002 (HAVA), and the role that 

EAC plays in supporting the States and local governments in implementing HAVAcompliant voting systems. 

INTRODUCTION

EAC is a bipartisan commission consisting of four members: Donetta Davidson, Chair; 

Gracia Hillman, Caroline Hunter, and Rosemary Rodriguez. EAC’s mission is to guide, 

assist, and direct the effective administration of Federal elections through funding, 

innovation, guidance, information and regulation. In doing so, EAC has focused on 

fulfilling its obligations under HAVA and the National Voter Registration Act (NVRA). 

EAC has employed four strategic objectives to meet these statutory requirements: 

Distribution and Management of HAVA Funds, Aiding in the Improvement of Voting 

Systems, National Clearinghouse of Election Information, and Guidance and Information 

to the States. The topic of this hearing involves our strategic efforts to aid in the 

improvement of voting systems and to provide guidance and information to States to 

assist in improving the voting process. These programs and EAC’s efforts to assist States 

with maintaining election integrity through the entire election process will be discussed in 

more detail below. 

ELECTION INTEGRITY: A COMPLEX EQUATION

While a quick Internet search of the phrase “election integrity” will produce hundreds of 

hits and links to websites discussing everything from ballot access to voting systems to 

proof of citizenship, there is very little, if any, information or agreement as to what the 

public believes constitutes “election integrity.” Integrity is a word that connotes 

“honesty” and “completeness” and “adherence to a moral or ethical code.” Applying this 

concept to elections, this would require us to have accurate, open, accessible and secure 

elections. 

Conducting elections is a complex process, involving many steps to ensure that eligible 

voters are able to cast a single ballot and that each of those votes is counted and reported 

accurately. As such, conducting an accurate, open, accessible and secure election 

requires integrity in several areas: voter registration, voting systems, and the voting 

process. No one of these steps alone will ensure the integrity of an election. Each must 

work in tandem with the other to create an entire election process in which all voters can 

have confidence. 

In addition to ensuring the integrity of the entire election administration process, the 

public must be given access to the each step of the process. Election officials can allow 
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U.S. Election Assistance Commission 

Testimony before the U.S. House Committee on Appropriations, 

Subcommittee on Financial Services and General Government 

March 7, 2007 

the public to observe the steps taken to ensure election integrity, including system set up 

and testing, vote tabulation and audits and recounts. After all, to achieve election integrity 

the public must be educated about and have confidence in the election administration 

process. 

VOTER REGISTRATION INTEGRITY

The first step to having a successful, accurate and reliable election is to ensure that only 

eligible voters cast ballots. In most States, this begins with the process of registering 

those persons to vote. The National Voter Registration Act establishes the standard by 

which persons are registered to vote for Federal elections. And, HAVA significantly 

changed the means of maintaining, verifying, and managing that information. 

Prior to HAVA, very few States administered the voter registration process. Voter 

registration was conducted by local election officials and voter registration lists were 

maintained by local election officials. HAVA required the establishment of a single, 

statewide voter registration list in each State. After HAVA, there is to be one list that 

contains the names of all of the registered voters in the State, removing the possibility of 

multiple and outdated registrations. 

States are required to maintain and administer these new voter registration lists, including 

the responsibility assigned in HAVA to verify voter registration information against other 

available State and Federal information. For example, new registrations must be verified 

against the information maintained by the Department of Motor Vehicles in the State and 

the Social Security Administration. State election officials are also required to compare 

the voter registration list against the death records maintained by the State’s office of 

vital statistics. 

To facilitate this type of review, voters are required to provide either a driver’s license 

number or the last four digits of his/her social security number. If the voter fails to 

provide this information, the election official is prohibited from processing the voter 

registration, unless the voter does not have either a social security number or a drivers’ 

license number. Further, for voters who register to vote by mail, they must provide some 

proof of identity –a copy of the voter’s driver’s license, a utility bill, or other government 

document bearing the name and address of the voter. If the voter does not provide this 

information and if the voter’s application cannot be verified using the social security 

number or driver’s license number, the voter will have to provide some form of 

identification upon voting for the first time. 

In 2005, EAC issued interpretive guidance concerning the construction and maintenance 

of these statewide voter registration lists. This guidance worked to assure that the 

requirements of HAVA were implemented properly and in a manner that maintained 

voter’s rights in the registration process. For example, when voter registration 
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U.S. Election Assistance Commission 

Testimony before the U.S. House Committee on Appropriations, 

Subcommittee on Financial Services and General Government 

March 7, 2007 

verification shows a discrepancy between information provided by the voter and 

information available through other State and Federal databases, it is critical to involve 

the voter in resolving the discrepancy. The voter is best equipped to determine whether 

the discrepancy is the result of a mistake, incorrect information in the other database, or 

some other problem. In 2007, EAC will continue its work to inform and educate the 

public on the interaction between HAVA and NVRA and to amend NVRA regulations, as 

necessary, to ensure the proper implementation of both Acts. 

Voter registration integrity can be accomplished by operating a voter registration system 

that complies with HAVA and that is updated frequently so that duplicate and fraudulent 

registrations can be caught and remedied. It is imperative to the election process to have 

an accurate list of persons who are eligible to cast ballots. 

VOTING SYSTEM INTEGRITY

Voting system integrity requires an accurate, reliable, accessible and auditable voting 

system. There are various opinions on what constitutes accurate, reliable, accessible and 

auditable, but one clear source of this meaning is the Help America Vote Act of 2002 

(HAVA). HAVA establishes a number of requirements for voting systems, including that 

the system: 

o Allow the voter the ability to change his or her selections prior to casting a vote; 

o Notify the voter of an overvote and the consequences of casting an overvote; 

o Provide a permanent paper record of the election that is auditable; 

o Provide accessibility to individuals with disabilities including persons who are 

blind or visually impaired; 

o Provide accessibility to persons for whom English is not their first language when 

required by Section 203 of the Voting Rights Act; and 

o Meet or exceed the error rate as established in the 2002 Voting System Standards 

developed by the Federal Election Commission. 

See HAVA Section 301; 42 U.S.C. Section 15481. This section requires that all voting 

systems used in an election for Federal office meet or exceed these requirements. States 

could use HAVA funding to purchase voting systems that meet or exceed these 

requirements. A chart showing the funds distributed to each State is found on EAC’s 

Web site, www.eac.gov. 

In addition, HAVA also required EAC to develop guidelines for testing voting systems 

and required EAC to establish a program for the testing of voting systems using 

accredited laboratories. These guidelines and testing and accreditation processes 

establish a means to determine whether voting systems meet the base-line requirements 

of HAVA and the more descriptive and demanding standards of the voluntary voting 

system guidelines developed by EAC. This process provides assurance to election 
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U.S. Election Assistance Commission 

Testimony before the U.S. House Committee on Appropriations, 

Subcommittee on Financial Services and General Government 

March 7, 2007 

officials and members of the public that the voting systems that they use will perform in a 

manner that is accurate, reliable, accessible and auditable. 

Voluntary Voting System Guidelines (VVSG)

One of EAC’s most important mandates is the testing, certification, decertification and 

recertification of voting system hardware and software. Fundamental to implementing 

this key function is the development of updated voting system guidelines, which 

prescribe the technical requirements for voting system performance and identify testing 

protocols to determine how well systems meet these requirements. EAC along with its 

Federal advisory committee, the Technical Guidelines Development Committee (TGDC), 

and the National Institute of Standards and Technology (NIST), work together to develop 

voluntary testing standards. 

History of Voting System Standards (VSS) and Guidelines

The first set of national voting system standards was created in 1990 by the Federal 

Election Commission (FEC). In 2002, FEC updated the standards and HAVA mandated 

that the EAC develop a new iteration of the standards—which would be known as the 

Voluntary Voting System Guidelines (VVSG)—to address advancements in information 

and computer technologies. The law also stated that EAC assume responsibility for 

certifying voting systems and accrediting testing laboratories approved by NIST. 

HAVA mandated a 9-month period for the TGDC to develop the initial set of VVSG. The 

TGDC, working with NIST, technology experts, accessibility experts, and election 

officials, completed the first draft and delivered it to EAC in May 2005. In addition to 

providing technical support to the TGDC, NIST also reviewed the 2002 Voting System 

Standards (2002 VSS) to identify issues to be addressed in the 2005 guidelines, drafted 

core functional requirements, categorized requirements into related groups of 

functionality, identified security gaps, provided recommendations for implementing a 

voter-verifiable paper audit trail, and provided usability requirements. NIST also updated 

the VVSG’s conformance clause and glossary. 

On December 13, 2005, EAC adopted the first iteration of the Voluntary Voting System 

Standards (VVSG). Before the adoption of the VVSG, the EAC conducted a thorough 

and transparent public comment process. After conducting an initial review of the draft 

VVSG, EAC released the two-volume proposed guidelines for a 90-day public comment 

period; during this period, the EAC received more than 6,000 comments. Each comment 

was reviewed and considered before final adoption. The agency also held public hearings 

about the VVSG in New York City, NY, Pasadena, CA, and Denver, CO. 

The VVSG was an initial update to the 2002 Voting System Standards focusing primarily 

on improving the standards for accessibility, usability and security. The VVSG also 
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U.S. Election Assistance Commission 

Testimony before the U.S. House Committee on Appropriations, 

Subcommittee on Financial Services and General Government 

March 7, 2007 

establishes the testing methods for assessing whether a voting system meets the 

guidelines. In several areas, these guidelines are a step beyond HAVA. For example, 

these testing guidelines incorporated standards for reviewing voting systems equipped 

with voter verifiable paper audit trails (VVPAT) in recognition of the many States that 

now require this technology. Likewise, in the area of accessibility, the guidelines require 

that where the VVPAT is used as the official ballot, the paper record be made accessible 

to persons with disabilities, including persons with visual impairments or disabilities. 

Volume I of the VVSG, Voting System Performance Guidelines, includes new 

requirements for accessibility, usability, voting system software distribution, system 

setup validation, and wireless communications. It provides an overview of the 

requirements for independent verification systems, including requirements for a voterverified paper audit trail for States that require this feature for their voting systems. 

Volume I also includes the requirement that all voting system vendors submit software to 

a national repository, which will allow local election officials to make sure the voting 

system software that they purchase is the same software that was certified. 

Volume II of the VVSG, National Certification Testing Guidelines, describes the 

components of the national certification testing process for voting systems, which will be 

performed by independent voting system test labs accredited by EAC. EAC is mandated 

by HAVA to develop a national program to accredit test laboratories and certify, 

decertify, and recertify voting systems. The VVSG and the comments received from the 

public about the guidelines are available at www.eac.gov. 

The Future of the Voluntary Voting System Guidelines

Significant work remains to be done to fully develop a comprehensive set of guidelines 

and testing methods for assessing voting systems and to ensure that they keep pace with 

technological advances. TGDC and NIST have been working since the development of 

the initial iteration of the VVSG in 2005 to revise that version and to completely review 

and update the 2002 Voting System Standards that were developed by the FEC. EAC 

expects to receive a draft of this document from NIST in July 2007. 

In addition to this work, NIST is working to develop a uniform set of test methods that 

can be applied to the testing of voting equipment. Currently, accredited laboratories 

develop their own test methods to test voting equipment. After the completion of these 

uniform test methods, every accredited lab will use the same test to determine if a voting 

system conforms to the VVSG. This is a long and arduous process as test methods must 

be developed for each type and make of voting system. Work is beginning in 2007 on 

these methods, but will likely take several years to complete. 
This information is property of the U.S. Election Assistance Commission, 

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U.S. Election Assistance Commission 

Testimony before the U.S. House Committee on Appropriations, 

Subcommittee on Financial Services and General Government 

March 7, 2007 

Voting system testing and certification and laboratory accreditation program

Accreditation of Voting System Testing Laboratories

HAVA Section 231 requires EAC and NIST to develop a national program for 

accrediting voting system testing laboratories. The National Voluntary Laboratory 

Accreditation Program (NVLAP) of NIST provides for the initial screening and 

evaluation of testing laboratories and will perform periodic re-evaluation to verify that 

the labs continue to meet the accreditation criteria. When NIST has determined that a lab 

is competent to test systems, the NIST director recommends to EAC that a lab be 

accredited. EAC then makes the determination to accredit the lab. EAC issues an 

accreditation certificate to approved labs, maintains a register of accredited labs and posts 

this information on its website. 

In July 2005, NVLAP advertised for the first class of testing laboratories to be reviewed 

under the NVLAP program and accredited by EAC. Five laboratories have applied for 

the accreditation program. Pre-assessments of these laboratories began in April 2006. 

Because testing of voting systems could not be delayed, there had to be an interim review 

and accreditation of laboratories. In late 2005, EAC invited laboratories that were 

accredited through the National Association of State Election Directors (NASED) 

program as Independent Testing Authorities (ITAs) to apply for interim accreditation. 

All three ITAs applied for interim accreditation. Interim accreditation reviews by EAC 

contractors began in the spring 2006. Two of the ITAs were accredited on an interim 

basis. One laboratory is still under consideration for accreditation in the interim program. 

However, on February 8, 2007, EAC voted to terminate the interim laboratory 

accreditation program as EAC has received a recommendation from NIST regarding the 

accreditation of two laboratories that had undergone review through NVLAP. 

On January 18, 2007, EAC received recommendations from NIST to accredit two test 

laboratories under the EAC’s new Voting System Certification and Laboratory 

Accreditation Program. NIST recommended that EAC accredit iBeta Quality Assurance 

and SysTest Labs to test voting systems against both the 2002 Voting System Standards 

and the 2005 Voluntary Voting System Guidelines. EAC conducted additional review of 

the recommended labs to address non-technical issues such as conflict of interest policies, 

organizational structure, and recordkeeping protocols. On February 21, 2007, EAC voted 

at a public meeting to accredit these two laboratories under its Voting System 

Certification and Laboratory Accreditation Program. 
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U.S. Election Assistance Commission 

Testimony before the U.S. House Committee on Appropriations, 

Subcommittee on Financial Services and General Government 

March 7, 2007 

Voting System Certification

In 2007, EAC assumed the responsibility of certifying voting systems according to 

national testing guidelines. Previously, the National Association of State Election 

Directors (NASED) qualified voting systems to both the 1990 and 2002 Voting System 

Standards. EAC’s certification process constitutes the Federal government’s first efforts 

to standardize the voting system industry. 

In July 2006, EAC implemented its pre-election certification program, which focused on 

reviewing changes or modifications that were necessary for modifications to systems that 

would be used during the November 2006 elections. Three modifications were reviewed 

and approved under the pre-election program. Those modifications were approved only 

conditionally. The condition was that the authorization for the modification expired after 

the 2006 election. A permanent modification of the same sort would have to be reviewed 

through EAC’s Voting System Certification Program. 

In October 2006, EAC published for public comment its post-election certification 

program. This program encompasses an expanded and detailed review of voting systems, 

utilizing accredited laboratories and technical reviewers. On December 7, 2006, EAC 

adopted its Voting System Certification Program. The program became effective on 

January 1, 2007. Since that time, EAC has received three requests for manufacturer 

registration. Manufacturer registration is a process that is antecedent and required prior 

to a manufacturer submitting a system for testing. Once the manufacturer is registered, it 

may submit systems for testing to an EAC-accredited testing laboratory. Reports from 

that laboratory’s assessment are provided to EAC for review and action. The reports are 

reviewed by EAC technical reviewers. If the report is in order and the system is in 

conformance with the applicable voting system standards or guidelines, the technical 

reviewers will recommend that EAC grant the system certification. EAC’s executive 

director will consider the recommendation and make the final decision regarding 

certification. Once certified, a system may bear an EAC certification sticker and may be 

marketed as having obtained EAC certification. The EAC process also allows for 

assessment of quality control, field monitoring, decertification of voting systems, and 

enhanced public access to certification information. For more information concerning 

EAC’s Voting System Testing and Certification Program, see the program manual for 

this program, which is available on the EAC Web site. 

State voting system testing

The requirements that States place on the type of voting equipment that can be used in 

each State are very important to the concept of voting system integrity. EAC’s Voluntary 

Voting System Guidelines and its testing and certification program are voluntary. These 

programs were established in HAVA to allow States to voluntarily adopt the programs 
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U.S. Election Assistance Commission 

Testimony before the U.S. House Committee on Appropriations, 

Subcommittee on Financial Services and General Government 

March 7, 2007 

and thereby make those programs mandatory in the States that adopt them. Thus, it is 

State action that requires this important testing and certification process. 

In addition to adopting the VVSG and testing and certification requirements, many States 

implement another layer of protection and voting integrity. Many States have their own 

testing and certification process that they pair with the Federal (previously National) 

testing and certification process. The degree of intensity of these programs varies. Some 

test only to additional State requirements, while others essentially re-test to the same 

standards that were required under the Federal or National testing and certification 

program. 

In addition to this type of testing and certification, States also conduct acceptance testing 

on voting systems when they are received from the manufacturer. This testing should 

determine that the voting system functions properly and that it has been configured in the 

way that the State requested through its purchase contract. Last, but certainly not least, 

States and local governments also conduct logic and accuracy testing on voting 

equipment prior to each election. In this testing, the voting system is loaded with the 

actual ballot and a test is performed to determine that the system is accurately recording 

votes on that ballot. This test is conducted using a controlled sample of votes, often times 

referred to as a “test deck.” While test deck technically refers to a deck of optical scan or 

other paper ballots, the same concept applies to testing direct record electronic (DRE) 

voting systems by using a known series of votes. 

Achieving Voting System Integrity

In our opinion, a State or local government can achieve voting system integrity by 

choosing to require the processes that we have discussed. First, only use systems that 

have been tested and certified as meeting the requirements of HAVA and the applicable 

voting system standards or guidelines. Second, require that the manufacturer keep pace 

with changing technology and standards. Include in contract terms provisions that 

require manufacturers to upgrade systems at a reasonable price. Third, to add another 

level of scrutiny, States should implement their own voting system testing and 

certification procedures. Even if it is only for those requirements that are unique to the 

State, the State should assure that the system can perform as desired. Fourth, conduct 

rigorous and independent acceptance testing. States and local governments should 

conduct their own testing, if necessary with the assistance of a third party technical 

advisor, to ensure that the acceptance testing process is independent. Acceptance tests 

should also be rigorous and put the equipment through the type of work that it is intended 

to perform in an election environment. If the equipment does not perform properly it 

should be rejected. Last, conduct logic and accuracy testing on every piece of voting 

equipment that is to be used in the election. All systems should be checked to assure that 

they are accurately counting votes. Where discrepancies arise, the system, programming, 
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U.S. Election Assistance Commission 

Testimony before the U.S. House Committee on Appropriations, 

Subcommittee on Financial Services and General Government 

March 7, 2007 

and paper and printing (where paper is used) should be checked and the problem resolved 

before the voting equipment is placed in service for the election. 

While we state these suggested requirements emphatically, EAC wants to assure that it is 

clear that many States and local election jurisdictions have already implemented each and 

every one of these steps to ensure that their elections are conducted accurately and 

reliably. This commitment to detail by the nation’s election officials is why exit polls 

showed that 88 percent of voters were reported to have confidence that their votes were 

counted accurately. And continued vigilance in this and other areas impacting election 

integrity will help to improve confidence in a process that already enjoys overwhelming 

success. 

VOTING PROCESS INTEGRITY

Once a State or local election jurisdiction has purchased a new voting system, there is 

still a great deal of work to be done to assure that elections are conducted with integrity. 

Purchasing the right system is in many ways the easy part. Using it properly takes time, 

planning, and persistent attention to detail. 

Election officials must keep in mind that to successfully compromise a voting system 

during an election, a person must have knowledge of the system and access to the system 

while the election is taking place – a scenario that applies to ballot boxes or e-voting 

machines. Any discussion or policy surrounding ensuring the integrity of a voting system 

must examine all aspects of the voting process. The bottom line is that real security for 

any type of voting system – electronic or paper-based – comes from systematic 

preparation: 

• Prepare systems to prevent tampering; 

• Prepare people to detect tampering; 

• Prepare poll workers and law enforcement to react to tampering; and 

• Prepare election officials to recover by auditing and investigating tampering. 

These fundamental election administration processes to protect the entire voting process 

will always be important, even as voting technology evolves. Focusing solely on the 

reliability of voting systems is not enough, and a Federal certification for the system 

cannot take the place of solid, thorough management procedures at the State and local 

levels to ensure the system is managed, tested, and operated properly. Achieving 

accurate and reliable election results will always be the combination of thorough testing 

of the equipment at multiple levels, training and resources for election officials and poll 

workers, and through election management guidelines for every aspect of election 

administration. 
This information is property of the U.S. Election Assistance Commission, 

 1225 New York Avenue, NW, Suite 1100, Washington, DC 20005 

(202) 566-3100 (p), (202) 566-3127 (f), www.eac.gov 

Page 10 

U.S. Election Assistance Commission 

Testimony before the U.S. House Committee on Appropriations, 

Subcommittee on Financial Services and General Government 

March 7, 2007 

Management Guidelines

EAC is working to assist States and local election jurisdictions with identifying and 

managing all of details surrounding the successful administration of elections. In 2005, 

EAC began work on a comprehensive set of management guidelines, collaborating with a 

group of experienced State and local election officials to provide subject matter expertise 

and to help develop the guidelines. The project focuses on developing procedures related 

to the use of voting equipment and procedures for all other aspects of the election 

administration process. These publications are intended to be a companion to the VVSG

and assist States and local election jurisdictions with the appropriate implementation and 

management of their voting systems. The first set of election management guidelines will 

be completed in FY 2007; they will be available to all election officials to incorporate 

these procedures at the State and local levels. 

Four Quick Start Guides were distributed to election officials prior to the 2006 election. 

These guides are summaries of more extensive chapters of the Management Guidelines 

that will be released this year. The guides were sent to election officials throughout the 

Nation and covered topics such as introducing a new voting system, ballot preparation, 

voting system security, and poll worker training. All Quick Start guides are available at 

www.eac.gov. A brief description of each Quick Start guide is provided below. 

Quick Start Guide for New Voting Systems 

The guide provides a snapshot of processes and procedures 

election officials should use when introducing a new voting 

system. It covers receiving and testing of equipment; 

implementation tips, such as conducting a mock election 

and developing contingency plans; and programming. The 

guide also offers Election Day management strategies, 

including opening the polls, processing voters, and closing 

the polls. 
This information is property of the U.S. Election Assistance Commission, 

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Testimony before the U.S. House Committee on Appropriations, 

Subcommittee on Financial Services and General Government 

March 7, 2007 

Quick Start Guide for Ballot Preparation/ Printing and Pre-Election Testing

Ballot preparation and logic and accuracy testing are 

essential steps to ensure Election Day runs smoothly. 

The guide offers tips on preparing and printing ballots, 

which includes confirming that ballots conform to all 

applicable State laws as well as requiring a multilayered 

ballot proofing process at each stage of the design and 

production process. The guide also covers pre-election 

testing for hardware and software logic and accuracy. 

Quick Start Guide for Voting System Security

The introduction of new equipment also ushered in concerns 

regarding voting system security. To address some of those 

concerns and to help election officials implement effective 

management procedures, the guide highlights priority items 

essential to securing these systems. It addresses software 

security, advising officials to be sure that the software 

installed on the systems is the exact version that has been 

certified. The guide advises officials to not install any 

software other than the voting system software on the vote 

tabulating computer; to verify that the voting system is not 

connected to any network outside the control of the election 

office; and to consider any results transmitted electronically to 

be unofficial and verify them against results contained on the 

media that are physically transported to the central office. 

Also included in the guide are recommendations regarding 

password maintenance, physical security, personnel security, 

and procedures to secure the equipment. 
This information is property of the U.S. Election Assistance Commission, 

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U.S. Election Assistance Commission 

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Quick Start Guide for Poll Workers

One of the most challenging tasks for 

election officials is recruiting and training 

poll workers. The guide contains 

information about identifying potential 

poll workers, effective training programs 

and techniques, as well as procedures to 

implement on Election Day. 

A full range of Management Guideline documents will be developed to cover topics 

related to election administration, including: 

o Pre-Election Testing 

o Ballot Design 

o Contingency/Disaster Planning 

o Vote by Mail/Absentee Voting 

o Military/Overseas Voting 

o Polling Place/Vote Center Management 

In addition, new Quick Start guides are planned for 2007, including guides on the 

following topics: 

o Change Management 

o Public Relations 

o Contingency/Disaster Planning 

o Certification 

o Developing an Audit Trail

Proper management of elections is key to conducting a reliable, accurate, open and 

accessible election. Buying state of the art voting equipment with the latest security 

features is meaningless unless the door to the storehouse where the voting systems are 

kept is secured and locked. Similarly, equipment used to program voting systems should 

never be connected to the Internet. It is EAC’s goal to communicate these suggestions 

and requirements to the election officials to help them increase the security and accuracy 

of their voting equipment by their practices and procedures. 
This information is property of the U.S. Election Assistance Commission, 

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U.S. Election Assistance Commission 

Testimony before the U.S. House Committee on Appropriations, 

Subcommittee on Financial Services and General Government 

March 7, 2007 

Review of voting system operation

Good election management and administration includes a review of the voting system 

operation before, during and after the election. Whether using a recount, audit or parallel 

testing, it is critical to take steps to make sure that voting equipment performed properly 

and calculated votes properly. 

Recounts and Audits

Recounts are a common method for reviewing the performance of voting equipment. 

Many States have laws that require recounts when certain conditions exist, such as a 

close race. Others have mandatory recounts of a certain percentage of ballots after every 

election regardless of the outcome. Some States refer to automatic recounts as audits. 

Regardless of whether it is an audit or a recount, the review of an election should be 

conducted with as much care as the election. 

Whether optical scan or electronic, all voting systems produce a form of paper record that 

can be audited or recounted, a requirement of HAVA. Optical scan systems, obviously, 

use the paper ballots as the paper record that can be audited or recounted. Conversely, 

direct record electronic systems can use one of two paper sources for recounting or 

auditing the election. Every DRE is required to produce a paper record that shows every 

vote that was cast on the voting system. This record is produced in a randomized order to 

avoid association with a voter and is obtained from the internal memory of the DRE. 

Some DREs also have the ability to produce a voter verifiable paper audit trail (VVPAT). 

This paper record is produced from the computer’s internal memory but is generated 

contemporaneously prior to the voter casting his/her ballot. It is verifiable by the voter; 

meaning that the voter can verify that the computer generated image on the screen is the 

same as the computer generated print out. 

It is critical in a recount or audit situation to assure that the quality of the paper record is 

considered. With paper ballots, there may be a question of the intent of the voter if the 

ballot is not marked according to the ballot instructions. Similarly, because VVPATs are 

contemporaneously recorded, there can be paper jams, a lack of ink or other printer 

problems that result in the degradation of the paper record. The State or local election 

jurisdiction must take these realities into account and provide a means by which problems 

can be solved when they arise during a recount or audit. 

Audits and recounts are frequently conducted on a manual basis. The ballots or paper 

records are hand counted by people. Another reality that must be addressed is that people 

make mistakes. There must be procedures and processes in place to reduce and catch the 

number of human counting errors. 
This information is property of the U.S. Election Assistance Commission, 

 1225 New York Avenue, NW, Suite 1100, Washington, DC 20005 

(202) 566-3100 (p), (202) 566-3127 (f), www.eac.gov 

Page 14 

U.S. Election Assistance Commission 

Testimony before the U.S. House Committee on Appropriations, 

Subcommittee on Financial Services and General Government 

March 7, 2007 

Parallel testing

Parallel testing is a relatively new practice in monitoring the accuracy of an election. It is 

done simultaneously with the conduct of the election. Several voting systems are set up 

as “sample systems” and are voted on by election personnel during the course of the 

regularly scheduled election. Some States and local governments conduct parallel testing 

prior to the election. However, the process is the same. The machines are voted with a 

known set of votes, such as using a set of paper ballots from the absentee voting process. 

These votes are entered onto the DRE system and counted. The system is deemed to be 

operating properly if the hand count of the ballots and the computer tally are the same. 

Transparency and Accountability for the Public

Implementing extensive management procedures for the entire election administration 

process is crucial to accurate and secure elections. The public must be informed about 

how elections are conducted to ensure they have confidence in the process, or all efforts 

to achieve election integrity will be lost. 

Most voters are not familiar with the entire election administration process. Their 

interaction is usually limited to Election Day when they show up, in some cases provide 

identification, and are escorted to the booth where they cast their vote on a paper or 

electronic system. The public is not engaged in the “behind the scenes” work that goes 

on to make the election that they are participating in run smoothly. They have not been 

involved in the months of planning that go into a smooth election. They never see the 

processes that are involved such as: 

o qualifying candidates, 

o laying out ballots, 

o programming voting equipment, 

o checking and double checking the ballots, 

o training poll workers on the various election laws and voters rights, as well as the 

intricacies of how the voting equipment works, 

o delivering the voting equipment, 

o tabulating the results, 

o reporting the results, 

o recounting or auditing, and 

o certifying the final totals. 

Good and efficient election administration requires election officials to educate the public 

about the election process. One easy way to do that is for election officials to provide the 

public access to the process. Officials can make processes such as voting system set up, 

logic and accuracy testing, vote tabulation and recounts open to the public. This way the 

public can learn about the process while it is ongoing. 
This information is property of the U.S. Election Assistance Commission, 

 1225 New York Avenue, NW, Suite 1100, Washington, DC 20005 

(202) 566-3100 (p), (202) 566-3127 (f), www.eac.gov 

Page 15 

U.S. Election Assistance Commission 

Testimony before the U.S. House Committee on Appropriations, 

Subcommittee on Financial Services and General Government 

March 7, 2007 

Another means is to provide educational materials to the media, government agencies, 

and to organizations that educate the public about voting. When implementing a new 

voting system it is critical to get information to the public about the new systems and how 

they work. In 2006, EAC distributed a Voter’s Guide to Election Day for the public to 

provide information about election processes. The guide included information about: 

o registering to vote, 

o polling place information, 

o absentee and early voting, 

o provisional voting, 

o voting systems, 

o poll workers, and 

o Election Day procedures. 

This guide was generalized in order to be applicable to all 50 States, the District of 

Columbia and the four territories in terms of the way in which they conduct elections. 

The guide can also be used by States and local governments to develop similar, more 

specific pieces geared toward the way that elections are conducted in their jurisdiction, 

including localized information about registration and voting procedures, as well as the 

type of voting equipment that is used there. 

EAC is also conducting a 2006 Voting Administration and Election Survey, which will 

include data from each State about registration, provisional voting, voting system usage 

and other election data sets to inform the public about how, where, and when we vote. 

CONCLUSION

Election integrity is a complex equation of voter registration, voting equipment and 

voting process. All three pieces work together to ensure a successful, accurate and 

reliable election. Addressing one of these elements of the equation will not ensure 

election integrity. HAVA was careful to address them all. Future work in elections must 

consider all aspects of election administration in order to result in increased confidence in 

the election process. 

EAC appreciates the opportunity to provide this testimony regarding election integrity. If 

you have any questions, I will be happy to address them.