While OMB
acknowledges the improvement in the quality and completeness of the
survey data that EAC collected in 2008, OMB remains concerned about
data quality. Since EAC is not employing statistical methods to
generate survey results that are representative of the surveyed
population, the 2010 UOCAVA Report to Congress should describe the
limits of the survey data and include conspicuous and appropriate
caveats about drawing conclusions from the data. Specifically, EAC
should (1) implement basic consistency checks (rather than publish
negative numbers in tables) and calculate percentages that have
numerators and denominators reflecting the same responding
jurisdictions and (2) acknowledge the limitations of each
conclusion in the report that cannot be supported by robust data.
EAC should also identify State-reported figures (by, for example,
stating that "States reported..."), distinguishing them from EAC
conclusions. OMB requests that EAC share a draft of the report
prior to its submission to Congress. In addition, OMB requests that
EAC coordinate with DoD to identify overlap between EAC's Election
Day Survey and DoD's "Post-Election Survey of Overseas and
Post-Election Survey of Local Election Officials" to avoid
duplicative efforts.
Inventory as of this Action
Requested
Previously Approved
05/31/2013
36 Months From Approved
165
0
0
22,499
0
0
147,930
0
0
The proposed information collection is
necessary to meet requirements of the Help America Vote Act (HAVA)
of 2002 (42 U.S.C. 15301). HAVA §241 requires the U.S. Election
Assistance Commission (EAC) to study and report on election
activities, practices, policies, and procedures, including methods
of voter registration, methods of conducting provisional voting,
poll worker recruitment and training, and such other matters as the
Commission determines are appropriate. In addition, HAVA §802
transferred to the EAC the Federal Election Commissions
responsibility of biennially administering a survey on the impact
of the National Voter Registration Act (NVRA) (42 U.S.C. 1973gg-1
et seq.). The information the States are required to submit to the
EAC for purposes of the NVRA report are found under Title 11 of the
Code of Federal Regulations (11 CFR 8.7). HAVA §703(a) also amended
§102 the Uniformed and Overseas Citizens Absentee Voters Act
(UOCAVA) (42 U.S.C. 1973ff-1) by requiring that not later than 90
days after the date of each regularly scheduled general election
for Federal office, each State and unit of local government which
administered the election shall (through the State, in the case of
a unit of local government) submit a report to the Election
Assistance Commission (established under the Help America Vote Act
of 2002) on the combined number of absentee ballots transmitted to
absent uniformed services voters and overseas voters for the
election and the combined number of such ballots which were
returned by such voters and cast in the election, and shall make
such a report available to the general public. In October 2009,
the President signed into law the MOVE Act (Military and Overseas
Voter Empowerment) as part of the National Defense Authorization
Act of FY 2010 (PL 111-84). MOVE is intended to make it easier for
absentee military troops and other overseas citizen voters to
register and vote, and to help ensure that their ballots arrive in
time to be counted. The MOVE Act requires state election officials
to provide a number of new services, including online access to
registration and ballot request forms, electronic options for blank
ballot delivery, downloadable write-in ballots in case of late
ballot arrival and voter status tracking services. Many of these
services must be implemented by the November 2010 election. MOVE
requires the EAC to report on the number of UOCAVA ballots
transmitted and received.
US Code:
42
USC 1973ff-1 Name of Law: Uniformed and Overseas Citizen
Absentee Voters Act
US Code:
42 USC 1973gg-1 et seq. Name of Law: National Voter
Registration Act
US Code: 42
USC 15301 Name of Law: Help America Vote Act of 2002
There is no change in the
number of burden hours between the 2008 and 2010 versions of the
survey (147 total hours per State response; 8,085 hours total
annual reporting burden). EACs interest is in reducing respondent
burden and maintaining as much consistency as possible in the
questions asked between 2008 and 2010. As such, one new question
was added to the Statutory Overview as a result of the MOVE Act.
The question asks about the States processes and procedures for
implementing the requirements of the MOVE Act and about capturing
data related to some of those requirements. On the quantitative
portion of the survey, question A4 was changed to ask for data
related only to new registrations. This reduces respondent burden
since the other categories in that question were duplicative of
question A5. We also added question A4b to help clarify the States
Election Day Registration/Same Day Registration status, which will
ensure that we are accurately capturing information about these
specific groups of States. This question will not increase
respondent burden, as it is a simple yes/no check-off. Also on the
quantitative portion of the survey, two questions related to the
automatic transmission of ballots for two election cycles were
removed. The MOVE Act eliminated States requirement to issue
automatically transmitted ballots; therefore, EAC has determined
that it no longer needs to ask those questions. Question F1g was
added as a sub-category to allow all vote-by-mail jurisdictions to
identify themselves as such. This will not increase respondent
burden, as it is merely a way to help better define the data
(distinguishing between absentee and all vote-by-mail) and only
applies to those jurisdictions that are all vote-by-mail. The
question wording in question F8 was slightly altered (machines
was changed to voting system) and the question now includes a
definition for voting system anomaly.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.