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EAC HAVA PROGRESS REPORT PUBLIC COMMENT | EAC-2026-0232

PUBLIC COMMENT ON STANDARDIZED EAC PROGRESS
REPORT (EAC-PR)
Docket EAC-2026-0232 | OMB Control No. 3265-0026
U.S. Election Assistance Commission - Office of Grants Management
60-Day Paperwork Reduction Act information-collection comment
Submitted by Daron L. Davis
Independent Black Governance Researcher and Public Scholar
September 4, 2026
To the U.S. Election Assistance Commission Office of Grants Management:
I submit this comment on the Election Assistance Commission (EAC) request to extend the standardized EAC
Progress Report (EAC-PR), OMB Control No. 3265-0026. I support EAC's continued use of a standardized
progress report for HAVA grants. My recommendations are narrow: improve the quality, utility, clarity, and
auditability of the information already collected while using structured fields, conditional logic, and GLAS
automation to avoid unnecessary reporting burden.
The August 3, 2026 notice states that the EAC-PR is used for interim and final progress reports for grants issued
under HAVA authority, that the current format is unchanged from the approved November 2023 standard
request, and that EAC seeks comment on ways to improve information quality, utility, and clarity and to reduce
burden through information technology. The current form already captures program-category expenditures,
subaward information, issues encountered, significant program changes, final assessment, and certification.
These are strong foundations. The main opportunity is to make consequential changes, unresolved problems,
delegated implementation, and corrective actions easier to reconstruct from the record.

Research basis and analytical approach
I submit this comment as an independent Black governance researcher and public scholar developing the
Institutional Authority Dynamics research program. This submission applies a bounded set of components from
Institutional Authority and Governance Dynamics (IAGD 2.3) to the information architecture of federal grant
reporting. The analytical focus is not election policy or the merits of any state's election-administration choices. It
is whether the progress-report record gives EAC sufficient visibility into who exercised consequential grant
authority, what materially changed, how implementation problems were handled, and whether corrective action
can be traced.
• Authority-Control Alignment - assessed across locational, authorization, accountability, and corrective
dimensions.
• Authority Provenance - used here as an evidentiary layer tracing decisions, delegations, material changes,
retained responsibilities, and present standing.
• Institutional Boundary Enforcement (IBE) - used to distinguish EAC, state grantee, and subrecipient
responsibilities without treating distributed administration as a governance failure.
• This is a bounded public-policy application. It is not empirical validation of IAGD, a conclusion about election
outcomes, or an assertion that EAC has adopted the framework.

Executive summary of recommendations
Recommendation

Primary value

Burden control

Add a conditional material-deviation
record to Question 12.

Makes changes to State Plans or
Program Narratives traceable by
decision, authority, date, reason, and
approval status.

Appears only when a significant change
is reported; use structured fields and
prepopulation.

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Recommendation

Primary value

Burden control

Structure the unresolved-issue and
corrective-action portion of Question 11.

Separates issue detection, responsible
entity, corrective action, status, and
residual implication.

No additional entry when “no major
issues” is selected; reuse narrative
already required.

Add minimal subaward-governance fields
to Question 9.

Improves visibility into which entity
monitors subrecipients and who can
require correction or escalation.

Use role-based dropdowns/checkboxes
and one short field for exceptions only.

Add automated reconciliation and
exception prompts.

Links narrative categories, expenditure
tables, subaward totals, and Federal
Financial Report amounts.

GLAS performs validation automatically;
respondents explain only unresolved
mismatches.

Preserve report-version and certification
provenance.

Makes amendments, resubmissions, and
authoritative certification reconstructable.

System-generated version/date fields; no
repetitive narrative.

Use conditional logic and prior-period
carry-forward throughout GLAS.

Improves clarity and reduces repetitive
entry across recurring reports.

Auto-populate stable grant data, show
only fields triggered by current-period
activity, and benchmark changes against
EAC's one-hour-per-response estimate.

I. Preserve standardization while strengthening reconstructability
The EAC-PR already reduces burden by standardizing the categories in which grantees describe activities and
expenditures. Standardization should remain the controlling design principle. The next improvement should not
be a longer narrative form; it should be a more reconstructable record. A reviewer should be able to identify, from
the report itself, when a material implementation decision occurred, who possessed the relevant grantadministration responsibility, whether the decision required EAC approval or a plan amendment, what corrective
action followed a material problem, and whether the matter remains unresolved.
This distinction matters because narrative sufficiency and governance traceability are not the same thing. A
report can accurately describe that an issue occurred without identifying who had authority to resolve it, whether
the resolution changed an approved program arrangement, or which institution remains responsible for an
unresolved condition.

II. Add a conditional material-deviation record to Question 12
Question 12 currently asks grantees to describe significant program changes, including changes to the original
State Plan or Program Narrative and favorable developments that improve efficiency or service delivery. The
accompanying guidance identifies changes to scope, delivery, timeline, or goals and directs grantees to describe
how a plan will be amended when a material change requires revision.
For each material change reported, I recommend that GLAS conditionally request the following structured fields:
• affected State Plan or Program Narrative element;
• date or reporting-period point at which the change became operative;
• decision-making entity or official role;
• whether EAC approval, notification, or formal amendment was required;
• approval/amendment status and date, if applicable;
• brief reason for the change; and
• current implementation status.
These fields would improve Authority Provenance without asking grantees to repeat the narrative they already
provide. They would also make later final reports easier to reconcile with the approved program baseline.

III. Structure Question 11 around issue, correction, and unresolved status
Question 11 appropriately asks what issues arose, whether they were resolved, and what implications remain. I
recommend preserving that scope while separating the record into four short elements when a major issue is
reported: (1) issue; (2) entity responsible for response; (3) corrective action taken or planned; and (4) current
status - resolved, partially resolved, unresolved, or escalated.

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Where an issue is unresolved, a short conditional field should identify the next responsible action or the reason
no corrective action is presently available. This is the minimum information necessary to distinguish a problem
that has merely been described from one that has entered a defined corrective pathway.

IV. Make subaward responsibility visible without increasing narrative burden
Section III currently asks grantees to describe the subaward program, number of subawards, local-community
needs, and whether funds were advanced or reimbursed. Because HAVA administration frequently operates
through state-local relationships, EAC should also be able to identify the monitoring and corrective relationship
without requiring a new narrative essay.
For subaward programs, add short structured fields identifying:
• the grantee office or role responsible for subrecipient monitoring;
• the principal monitoring method (for example, reports, reimbursement review, audit, site review, or another
specified method);
• the role authorized to require correction, withhold reimbursement, suspend activity, or escalate a material
issue under the award terms; and
• whether any material subaward issue remains unresolved at the end of the reporting period.
These fields do not presume that distributed implementation is defective. They make the state-subrecipient
accountability boundary visible and allow EAC to focus follow-up on exceptions rather than requiring more
reporting from every subaward.
This recommendation also translates responsibilities already embedded in 2 CFR 200.332 rather than creating a
new governance obligation. Pass-through entities must monitor subrecipient activities, review financial and
performance reports, ensure corrective action on significant developments that negatively affect the subaward,
and consider enforcement action where noncompliance persists. A small number of structured Question 9 fields
would make those existing monitoring and corrective relationships visible to EAC without requiring grantees to
narrate the full subrecipient-management process.

V. Use GLAS automation to reconcile financial and narrative records
The current instrument already auto-fills current-period expenditure amounts into the cumulative expenditure
table and requires consistency with the Federal Financial Report. That design should be extended. GLAS should
automatically compare the activity categories in Question 6, the subaward expenditure table in Question 10, the
cumulative table in Question 13, and applicable Federal Financial Report totals. A respondent should receive a
pre-submission exception prompt only when the records do not reconcile or when expenditures appear in a
category for which “no activity” was selected.
This would improve data quality and reduce post-submission correction traffic while minimizing respondent
burden: the system performs the comparison and the grantee explains only actual exceptions.

VI. Preserve version and certification provenance
Section VII identifies the authorized certifying official. EAC already describes GLAS as an award-management
system designed to improve data integrity and provides a workflow for updating an approved progress report. To
the extent GLAS already preserves submission, version, correction, and certification history internally, EAC
should ensure that the authoritative version and material correction history remain reconstructable in the
administrative record and, where appropriate, in the public-facing record. Where those elements are not
presently captured, GLAS should generate them automatically: initial submission date, certifying official, version
number, amendment/resubmission date, and a short coded reason for resubmission.
The objective is not to duplicate functionality GLAS already provides. It is to ensure that a reviewer can
determine which report version is authoritative and reconstruct material corrections or resubmissions without
requiring grantees to supply repetitive narrative.

VII. Burden-minimization design rule
I recommend that EAC apply the following implementation rule to every added field:

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If information can be derived from existing GLAS data, a prior-period report, the Notice of Award, an approved
amendment, or another EAC-held record, the system should prepopulate it. If a field is relevant only after a
respondent reports a material change, unresolved issue, subaward exception, or reconciliation mismatch, the
field should remain hidden unless triggered.
That approach is consistent with the Paperwork Reduction Act objective identified in the notice: improve the
utility of the information while reducing administrative effort through automated collection techniques and
information technology.
The notice estimates 194 annual burden hours at one hour per response and $5,028.48 in annualized cost. EAC
should test any added structured fields against that existing one-hour-per-response estimate and revise the
estimate if implementation materially changes respondent time. Where prepopulation, conditional logic, and
automated reconciliation offset additional fields, the final clearance package should document that burden offset
rather than assume it.

Consolidated recommendations
1. Retain the standardized EAC-PR and current program-category structure.
2. Add a conditional material-deviation record to Question 12 linking significant changes to the affected
approved plan element, decision role, date, approval/amendment status, and current standing.
3. Structure Question 11 so material issues identify the responsible entity, corrective action, current status, and
unresolved implication.
4. Add minimal subaward monitoring and corrective-authority fields to Question 9.
5. Automate reconciliation among narrative categories, subaward expenditures, cumulative expenditures, and
Federal Financial Report amounts.
6. Preserve system-generated report version, correction, resubmission, and certification provenance.
7. Use conditional logic, prepopulation, and exception-only prompts so stronger oversight information does not
become repetitive reporting burden, and test any added fields against EAC's existing one-hour-per-response
burden estimate.

Conclusion
The EAC Progress Report already provides a workable standardized record for HAVA grant administration. The
strongest improvement is not to require substantially more narrative. It is to make material changes, unresolved
problems, delegated implementation, financial reconciliation, and corrective responsibility more visible within the
information EAC already collects.
A durable reporting principle follows: grant reporting should make consequential changes and corrective
responsibility easier to reconstruct than to infer. Structured, conditional, and automated fields can strengthen
oversight while preserving the burden-reduction purpose of the standardized EAC-PR.
Respectfully submitted,
Daron L. Davis
Independent Black Governance Researcher and Public Scholar

References
1. U.S. Election Assistance Commission. “Agency Information Collection Activities,” 60-Day Request for Public
Comment on Standardized EAC Progress Report, FR Doc. 2026-15611, published August 3, 2026.
https://www.federalregister.gov/d/2026-15611
2. U.S. Election Assistance Commission. HAVA Formula Progress Report, updated July 2023.
https://www.eac.gov/sites/default/files/2023-08/HAVA_Formula_Progress_Report_2023_%28collection_instr
ument%29.pdf
3. U.S. Election Assistance Commission. HAVA Progress Report (PR) Guidance, updated July 2023.
https://www.eac.gov/sites/default/files/2023-08/EAC_HAVA_Progress_Report_Guidance_2023.pdf
4. U.S. Election Assistance Commission. Financial & Progress Reports. https://www.eac.gov/grants/financialprogress-reports
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EAC HAVA PROGRESS REPORT PUBLIC COMMENT | EAC-2026-0232

5. U.S. Election Assistance Commission. Grants Lifecycle Application System (GLAS).
https://www.eac.gov/grants/eac-glas
6. 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal
Awards, including § 200.332, Requirements for pass-through entities.
https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200
7. Davis, Daron L. Institutional Authority and Governance Dynamics (IAGD 2.3): Construct Boundary and Visual
Semantics Harmonization. 2026. DOI: 10.5281/zenodo.21987181.
8. Davis, Daron L. IAGD Conceptual Vocabulary and Construct Boundaries: Public Edition v1.2. 2026. DOI:
10.5281/zenodo.21385641.
9. Davis, Daron L. Institutional Boundary Enforcement: A Theory of Authority Preservation under Distributed
Administrative Execution. 2026. DOI: 10.5281/zenodo.21399430.

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