In 1975 Congress created the FEC to administer and enforce the Federal Election Campaign Act. To carry out this role, FEC discloses campaign finance information, enforces provisions of the law such as limits and prohibitions on contributions, and oversees the public funding of presidential elections. Within FEC, the Office of Election Administration (OEA) serves as a national clearinghouse for information regarding the administration of federal elections. As such, OEA assists state and local election officials by developing voluntary voting equipment standards, responding to inquiries, publishing research on election issues, and conducting workshops on all matters related to election administration. In addition, it answers questions from the public and briefs foreign delegations on the U.S. election process, including voter registration and voting statistics. FEC consists of six voting members, appointed by the President and confirmed by the Senate. To encourage nonpartisan decisions, no more than three commissioners can be members of the same political party, and at least four votes are required for most official Commission actions. FEC’s budget for fiscal year 2001 is $40.4 million, and of that amount, $804,000 is allocated to support OEA functions. FEC has 357 full-time staff, of which 5 are allocated to OEA functions. The voting methods used in the United States can be placed into five categories: paper ballots, mechanical lever machines, punch cards, optical scan, and direct recording electronic. The last three methods use computer-based equipment. Three of the five—paper ballots, punch cards, and optical scan—use some kind of paper ballot to record voters’ choices. Paper Ballot. Voters use a paper ballot listing the names of the candidates and issues and record their choice by placing a mark in a box next to the candidate’s name or issue. After making their choices, the ballots are dropped into a sealed ballot box to be manually tabulated. Mechanical Lever. Voters pull a lever next to the candidate’s name or issue and the machine records and tallies the votes using a counting mechanism. Write-in votes must be recorded on a separate document. Election officials tally the votes by reading the counting mechanism totals on each lever voting machine. Punch Card. Voters can use one of two basic types of punch cards— Votomatic or Datavote. In both instances, voters use a computer-readable card to cast their vote. The Votomatic uses a computer-readable card with numbered boxes that correspond to a particular ballot choice. The choices corresponding to those numbered boxes are indicated to the voter in a booklet attached to a vote recording machine, with the appropriate places to punch indicated for each candidate and ballot choice. The voter uses a simple stylus to punch out the box corresponding to each candidate and ballot choice. In the Datavote, the names of the candidates and issues are printed on the card itself—there is no ballot booklet. The voter uses a stapler-like punching device to punch out the box corresponding to each candidate and ballot choice. To tally the votes in both instances, the ballots are fed into a computerized tabulation machine that records the vote by reading the holes in the ballots. Optical Scan. Voters use a computer-readable paper ballot listing the names of the candidates and issues. The voters record their choices by using an appropriate writing instrument to fill in a box or oval, or complete an arrow next to the candidate’s name or issue. The ballot is then fed into a computerized tabulation machine, which senses or reads the marks on the ballot, and records the vote. Direct Recording Electronic. Voters use a ballot that is printed and posted on the voting machine or displayed on a computer screen listing the names of the candidates and issues. Voters record their choices by pushing a button or touching the screen next to the candidate’s name or issue. When a voter is finished, the vote is submitted by pressing a vote button, which stores the vote in a computer memory chip. Election officials tally the votes by reading the votes totaled on each machine’s computer chip. While neither FEC nor any other federal agency has explicit statutory responsibility to develop voting equipment standards, the Congress has appropriated funds for FEC to develop and update the standards. FEC first issued voting equipment standards in 1990. These standards identify minimum functional and performance requirements for punch card, optical scan, and direct recording electronic voting equipment, and specify test procedures to ensure that the equipment meet these requirements.The functional and performance requirements address what voting equipment should do and delineate minimum performance thresholds, documentation provisions, and security and quality assurance requirements. The test procedures describe three stages of testing: qualification, certification, and acceptance. According to FEC’s standards document: Qualification testing is the process by which a voting equipment is shown to comply with the requirements of its own design specification and with the requirements of FEC standards. Certification testing, generally conducted by individual states, determines how well voting equipment conform to individual state laws and requirements. Acceptance testing is generally performed by the local jurisdictions procuring voting equipment and demonstrates that the equipment, as delivered and installed, satisfies all the jurisdiction’s functional and performance requirements. The standards are voluntary; states are free to adopt them in whole, in part, or reject them entirely. To date, 38 states require that voting equipment used in the state meet FEC standards either in total or in part.Figure 1 shows these states. In September 1997, FEC initiated efforts to evaluate its voting equipment standards and identify areas to be updated, and in July 1999, FEC initiated efforts to revise the standards. As part of this revision, FEC has been working closely with state and local election officials and vendors to incorporate industry comments on the draft standards. FEC plans to issue the revised standards in multiple volumes: volume I is to include the functional and performance requirements for voting equipment; volume II is to provide the detailed test procedures, including information to be submitted by the vendor, tests to be conducted to ensure compliance with the standards, and the criteria to be applied to pass the individual tests. Figure 2 depicts FEC’s time frames for revising the standards. Organizations such as the Department of Defense and the Institute of Electrical and Electronics Engineers have developed guidelines for various types of systems requirements and for the processes that are important to managing the development of any system throughout its life cycle. These types of systems requirements and processes include, for example: Security and Privacy Protection. Requirements defining the security/privacy environment, types of security needed (e.g., data confidentiality and fraud prevention), risks the system must withstand, safeguards required to withstand those risks, security/privacy policies that must be met, accountability (i.e., audit trails), and criteria for security certification. Human Factors. Requirements defining the usability of the system, including considerations for human capabilities and limitations, and the use and accessibility of the system by persons with disabilities. Documentation. Processes for recording information produced during the system development life cycle, which includes identifying documents to be produced; identifying the format, content, and presentation items for each document; and developing a process for reviewing and approving each document. Configuration Management. Processes to establish and maintain the integrity of work products through the system development life cycle, including developing a configuration management plan, identifying work products to be maintained and controlled, establishing a repository to maintain and control them, evaluating and approving changes to the work products, accounting for changes to the products, and managing the release and delivery of products. Quality Assurance. Processes to provide independent verification of the requirements and processes used to develop and produce the system, which include developing a quality assurance plan, determining what system development product and process standards are supposed to be followed, and conducting reviews to ensure that the product and process standards are followed. While FEC’s 1990 standards satisfy most of these areas, they do not satisfy all. For example, in the area of security, the standards do not address the security/privacy environment in which the voting equipment must operate, the types of security to be provided, the risks the equipment must withstand, the security/privacy policies that must be met, or the criteria for security certification. Further, the standards do not specify requirements for voting equipment usability, taking into account human capabilities and limitations, or the use and accessibility of the voting equipment by persons with disabilities. Table 1 summarizes the types of requirements and processes satisfied in FEC’s 1990 voting equipment standards. As part of FEC’s current effort to revise the 1990 standards, it has made improvements in all five of the areas in which we identified missing types of requirements and processes. For example, in the area of human factors, the draft standards now include requirements for the use and accessibility of voting equipment by persons with disabilities. Further, for documentation, the draft standards include requirements for identifying documents to be produced; defining the format, content, and presentation items for each document; and developing a process for reviewing and approving each document. In addition, in the area of security, the standards now address security types, risks, safeguards, policies, accountability, and certification. While FEC has made improvements, the draft standards do not satisfy two areas—human factors and quality assurance. For example, in the area of human factors, the draft standards do not address requirements for equipment usability, including considerations for human capabilities and limitations. Finally, the draft standards do not yet specify the development of a quality assurance plan or the performance of quality assurance reviews to ensure that the equipment development process requirements are being met. Table 2 summarizes the types of requirements and processes not satisfied in FEC’s 1990 voting equipment standards but satisfied in the draft standards. Appendix III provides a detailed description of the requirements and process types and our complete analysis of FEC’s 1990 voting standards and draft standards.