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Proposed Changes to Federal Reporting Requirements Regarding UOCAVA Voters

High Priority
July 22, 2013
Wisconsin County Clerks
Wisconsin Municipal Clerks
City of Milwaukee Election Commission
Milwaukee County Election Commission
Michael Haas, Elections Division Administrator
Brian Bell, Elections Data Manager
Proposed Changes to Federal Reporting Requirements - High Priority final.pdf39.61 KB

On July 17, 2013, the Government Accountability Board learned that the U.S. Election Assistance Commission (EAC) posted proposed changes to the Election Administration and Voting Survey (EAVS) for 2014.  We want to make sure that all clerks are aware of these proposed changes, have the opportunity to provide feedback – both to the EAC and to the G.A.B., and suggest ideas of how we can together best accomplish these additional reporting requirement if they are approved.


States are required to complete the EAVS within 90 days after each general election (November of even-numbered years). The G.A.B. uses GAB-190 information entered into WEDCS and information from SVRS to complete this federal reporting requirement on behalf of all Wisconsin municipalities and counties.

Following the 2012 Presidential and General Election, the Federal Voting Assistance Program (FVAP) conducted a voluntary survey of select municipalities in all states. For the State of Wisconsin, FVAP wanted to survey about 300 municipalities.  G.A.B. staff completed the FVAP survey using information from WEDCS and SVRS on behalf of all Wisconsin municipalities, which prevented clerks from having to provide information already reported to the G.A.B. – either through SVRS or WEDCS.  However, the G.A.B. was not able to answer all questions on the FVAP survey due to certain information we currently do not track (e.g., the number of rejected Federal Write-In Absentee Ballots, or FWABs, because the official ballot was counted).  EAC’s proposed additional 17 questions to the EAVS incorporate the questions from FVAP’s survey that were not already included in the EAVS.

Proposed Additional Questions

The EAC has proposed adding 17 additional questions to the EAVS as a federal reporting requirement, to measure compliance with the Help America Vote Act of 2002 (HAVA), the Uniformed and Overseas Civilians Absentee Voting Act (UOCAVA), and the Military and Overseas Voter Empowerment Act (MOVE). Some of these questions may seem similar to those included in the 2012 Federal Move Act consent decree reporting requirements which each municipality was required to complete.  These additional questions include the following, most of which are not currently reported through the GAB-190, SVRS, or Absentee Lite:

1. Number of UOCAVA voters in the jurisdiction by UOCAVA status
2. FPCAs received by UOCAVA status
3. FPCAs rejected by UOCAVA status
4. FPCAs rejected-late
5. First date transmitting UOCAVA ballots
6. Number of ballots sent before/after 45-day deadline and by transmission method
7. Number of ballots returned undeliverable by transmission method
8. Number of total UOVAVA ballots received, excluding FWABs
9. Number of ballots received by UOCAVA status
10. Number of ballots received based on being transmitted before/after 45-day deadline and transmission method of return
11. Number of rejected ballots by UOCAVA status
12. Number of ballots rejected-late based on transmitted before/after the 45-day deadline and transmission method
13. Number of FWABs received by UOCAVA status
14. Number of FWABs rejected by UOCAVA status
15. Number of FWABs rejected-late total
16. Number of FWABs rejected because the official ballot was counted
17. Number of FWABs counted by UOCAVA status

EAC Seeking Public Comment

The EAC is looking for public comment on the proposed additional questions by September 16, 2013.  The EAC is encouraging comments specifically related to four major questions:

• Whether the proposed data collection is necessary for the proper performance of the functions of the EAC, including whether the information shall have practical utility;
• The accuracy of the EAC’s estimate of the burden of the proposed data collection;
• Ways to enhance the quality, utility, and clarity of the information to be collected; and
• Ways to minimize the burden of the information collection on respondents, including through the use of information technology.

Comments on the proposed information collection should be submitted electronically to Written comments on the proposed information collection can also be sent to:

                              The U.S. Election Assistance Commission
                              1201 New York Avenue NW, Suite 300
                              Washington, DC 20005
                              Attn: Election Administration and Voting Survey

The G.A.B. is also interested in feedback from clerks on implementing these proposed changes. In particular:

• If these proposed changes are approved, how can we together meet these federal reporting requirements (e.g., changes to SVRS or the GAB-190 and WEDCS)?
• Would implementing these additional reporting requirements create additional burdens on providers/self-providers/reliers? If so, how much of a burden?

Please contact the GAB Help Desk with any questions or feedback regarding the contents of this memo by email at, or by phone at (608) 261-2028.