CEC Urges EAC to Adopt Improvements to Anomaly Report Form

The Center for Election Confidence (CEC) filed a comment today with the U.S. Election Assistance Commission, urging the EAC to adopt improvements to its Anomaly Report Form to improve transparency and consistency with respect to the reporting of both anomalies and resolutions. CEC’s comment was submitted in response to the EAC’s Request for Public Comment, Voting System Manufacturer Registration, Application for Testing, Anomaly Reporting and Root Cause Analysis, Survey and Submission to OMB of Proposed Collection of Information (90 F.R. 34854).

The Anomaly Report Form is used to collect information concerning the unexpected operation of voting equipment (or its failure to operate). The reports collected by this Form contain valuable information for improving the administration of federal elections. Further, the transparent investigation and resolution of such reports serves to build voters’ confidence in election processes and outcomes.

CEC encourages the Commissioners to consider the underlying purpose of the Form, which ultimately is to provide information to the EAC, election officials, vendors and manufacturers, and the public concerning possible election administration issues and their resolution. While the existing form provides ample space for the collection of information concerning the reporting individual, the product in question, and the anomaly itself, the Form lacks space to describe explanations of or any expected, intended, or even completed resolutions of such anomalies, as well as the name, title, and affiliation of any individuals contacted or involved with the same.

Even if anomalies are not resolved before the time to submit the Form expires, the inclusion of additional identifying and explanatory information,

the inclusion of such identifying and explanatory information on the Form would assist the public in understanding any identified anomalies and their explanation or resolution in a more complete manner by coupling the information provided with the form with any ultimate report on the matter, if available.

Specifically, CEC would suggest that the EAC consider adding the following fields to the Form:

  1. Diagnosis of the anomaly’s source by technical personnel.
  2. Resolution of the anomaly, if any.
  3. Name, title, and affiliation of any technical experts involved in resolution of the anomaly.

In general, CEC finds that voters are less concerned with the existence of problems—issues with any system are a fact of life, after all—than they are with the identification of such problems and their clear and transparent resolution.

Reforms to improve both the consistency and transparency of anomaly reports and their ultimate explanation or resolution will “ensure that the Form serves its ultimate purpose of bolstering the public’s confidence in elections.” CEC urges the EAC to adopt the reforms it suggests.