Issues and Gaps in the VVSG Usability and Accessibility Requirements

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VVSG 2.0 and Beyond:

Issues and Gaps in the Usability 

and Accessibility Requirements

Approved by the TGDC for transmittal to the EAC on

January 14, 2011
Issues and Gaps in the VVSG Usability and Accessibility Requirements

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More information can be found at http://www.vote.nist.gov

This document has been prepared by the National Institute of Standards and 

Technology (NIST) to present the work of the Usability and Accessibility 

Working Group of the Technical Guidelines Development Committee. It does 

not represent a consensus view or recommendation from NIST, nor does it 

represent any policy positions of NIST.

Certain commercial entities, equipment, or material may be identified in the 

document in order to describe an experimental procedure or concept 

adequately. Such identification is not intended to imply recommendation or 

endorsement by the National Institute of Standards and Technology, nor is it 

intended to imply that these entities, materials, or equipment are necessarily 

the best available for the purpose.
Issues and Gaps in the VVSG Usability and Accessibility Requirements

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VVSG 2.0 and Beyond: Issues and Gaps in the 

Usability and Accessibility Requirements

The purpose of this document is to identify issues and gaps in Chapter 

3, Usability, Accessibility, and Privacy, of the VVSG 2.0. This 

information will be used to guide and prioritize NIST research in 

support of improvements to requirements and associated conformance 

test methods for the VVSG 2.0 and subsequent updates. We focus 

here only on the usability and accessibility requirements.

The VVSG 2.0 was delivered by NIST to the EAC in August of 2007. In 

the past three years, voting system technology, other standards, and 

our understanding of the needs of voters, poll workers and election 

officials has deepened. While this “baseline” VVSG 2.0 was a clear 

improvement to prior versions of the VVSG in terms of organization 

and content, issues and gaps exist. They include:

1. Paper ballots and motor disabilities: Clarify requirements to 

ensure that an accessible voting system does not require a 

voter with motor disabilities to manually handle the paper ballot 

throughout the voting session, that is, to obtain, mark, verify, 

and cast the ballot). For example, a system must have an 

automatic paper handling mechanism or equivalent if paper 

ballots are part of the process.

2. Paper ballot usability and accessibility: Research and develop 

requirements to support better usability and accessibility of 

paper records for voters and for poll workers. 

3. Accessibility of verification: Clarify requirements to ensure that 

an accessible voting system provides mechanisms that enable a 

voter with a disability to verify the content of a paper ballot 

using the same input and output features they use to generate 

that ballot. For example, someone with low vision or who is 

blind must be able to vote and verify using the same method for 

both activities.

4. Alternative input/switch input: Clarify requirements to ensure 

that an accessible voting system provides switch input or 

alternative input that provides equivalent access for voters with 

motor disabilities
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5. New ADA accessibility technical standards: Harmonize VVSG 

requirements with other adopted accessibility technical 

standards, working closing with Access Board.

a. Update wheelchair reachability requirements, harmonizing 

with new technical standards and anthropometry research 

for motorized wheelchairs.

b. Harmonize with 2010 ADA and Section 508 refresh

technical standards as they apply to voting equipment.

6. Maximizing accessibility: Research the range of input and output 

access features currently available through both universal 

design and assistive technology. Determine which can/should 

be built-in (required of) an accessible voting system and which 

can/should be allowed as an add-on personal assistive 

technology option. Goal is to maximize reasonable access to 

the widest range of functional limitations (due to specific 

disabilities or age) while minimizing complexity. Research 

should be cross-disability, considering features that address 

multiple disabilities. This will reduce the cost and complexity of 

the systems. Features available to the voter should be easy to 

select and to use.

a. Personal assistive technology: develop requirements for 

plug and play, including input jack and scanning 

interoperability.

b. Manual dexterity: Research the range of manual dexterity 

capabilities and map to the most optimal solutions that 

address that range. Note that a more holistic approach is 

needed because individuals with dexterity problems often 

have other disabilities. Development of requirements 

based on that mapping is needed. This includes clear 

requirements that ensure usability for those individuals 

who do not have use of their hands.

c. Design for aging voters: Research the needs of an aging 

voter population and develop requirements as indicated 

by the research.

d. Universal design: Examine the latest research for 

universal design and determine what applies to voting 

systems.
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e. Built-in/personal assistive technology tradeoffs: Focus on 

how to maximize universal design requirements to 

support accessibility while at the same time increasing the 

personal assistive technology capability. Personal 

assistive technology should not be viewed as a substitute 

for built-in accessibility but as an enhancement. 

7. Accessibility of PCOS: Precinct count optical scanners (PCOS)

are growing in use by states. At the time VVSG 1.0 was 

written, it appeared that Direct Recording Electronic systems 

(DREs) would dominate and many of the voter interface 

requirements were written with the focus on the DRE. Analyze 

the VVSG 2.0 requirements for how they apply to voter 

interfaces on precinct count optical scanners, which now have 

multiple voter interface options (e.g. larger visual displays and 

paper feeding mechanisms). For voters to effectively cast their 

ballot without assistance, these interfaces require a variety of

motor and sensory skills.

8. Focus on required access features: The organization of access 

requirements by “disability” area has been problematic because 

access features do not necessarily fall neatly into one disability 

area (e.g. synchronized audio/visual output is an access feature 

used by individuals with vision, learning, information 

processing, cognitive, memory and other functional limitation). 

While this structure simplified the organization of VVSG 1.0 and 

reduced redundancy, it has led to misinterpretation of the 

requirements when it has been incorrectly assumed the access 

feature is meeting a particular disability need only. Clarify and 

reword/restructure as needed to better focus on required access 

features that must be delivered rather than “disability” areas 

addressed to ensure that all required access features can be 

readily identified. 

a. In addition, the VVSG should be organized either in a way 

that provides a central location for the “access 

requirements” or a way of readily identifying all the 

“access” features that must be available on the one legally 

mandated “accessible” system. The organization should 

at least provide a way to more easily identify and pull out 

the required access features so that election officials and 

others can use the requirements as the benchmark for 

determining what meets the legal requirement for 

"accessible". 
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9. Performance-based testing. The requirements for the 

manufacturers to report on usability testing and the test 

laboratory performance-based usability testing methods (those 

that involve test participants) need to be expanded to provide 

performance assessments for a reasonably wide range of 

functional limitations. In the case of manufacturer testing, 

without substantive definitions and descriptions of the functional 

limitations that should be included in such testing, terms like 

“blind and visually impaired” or “lacking fine motor control” do 

not ensure that a representative and reasonable range of 

individuals with vision loss nor a wide range of individuals with 

motor limitations will be included in functionality testing. 

Similarly, performance-based usability testing conducted by test 

laboratories need to include test participants across a 

sufficiently wide range of functional limitations to ensure the 

system is accessible and usable.

10. One integrated accessible system. It is the intention of VVSG 

2.0 that the accessible system is one, single, integrated system. 

The structure of VVSG 2.0 does not allow for separate 

components, which, when cobbled together address the various 

single disabilities. Clarify this intention with explanatory text 

and examine the structure of VVSG 2.0 to ensure that this 

intention is correctly represented.

11. Remote voting: The Election Assistance Commission should 

clarify and affirm the legal basis under HAVA, UOCAVA, ADA and 

for States for accessibility requirements as it pertains to the 

TGDC and NIST. Depending on scope, develop specific 

technical requirements addressing remote voting and the range 

of voting done outside of a polling place, absentee, and by mail.