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                      IMPLEMENTATION OF THE
                   NATIONAL VOTER REGISTRATION
                     ACT BY STATE VOCATIONAL
                     REHABILITATION AGENCIES

                  NATIONAL COUNCIL ON DISABILITY

                         October 1, 1999

                  National Council on Disability
                  1331 F Street, NW, Suite 1050
                    Washington, DC 20004-1107

                        202-272-2004 Voice
                        202-272-2074 TTY
                        202-272-2022 Fax

  This report is also available in braille and large print, on
 diskette and audiocassette, and on the Internet at the National
          Council on Disability's award-winning Web page
                      (http://www.ncd.gov).

The views contained in this executive summary do not necessarily
 represent those of the Administration because this document has
 not been subjected to the A-19 Executive Branch review process.


                      LETTER OF TRANSMITTAL

                         October 1, 1999

                          The President
                         The White House
                      Washington, DC 20500

                       Dear Mr. President:

   On behalf of the National Council on Disability (NCD), I am
   pleased to submit the report Implementation of the National
    Voter Registration Act by State Vocational Rehabilitation
                            Agencies.

  Voting is one of the most fundamental rights in a democratic
  society. In order to promote the exercise of this right, the
   National Voter Registration Act (NVRA) was enacted in 1993.
 Section 7 of NVRA specifies that each state shall designate, as
    voter registration agencies, all offices in the state that
  provide state-funded programs primarily engaged in providing
    services to persons with disabilities. One of the largest
   agencies serving people with disabilities in a state is the
                vocational rehabilitation agency.

       To date, no study has been undertaken regarding the
    implementation of NVRA by state vocational rehabilitation
agencies. The purpose of this report is to assess the experience
of these agencies in implementing this critical legislation. NCD
  finds that state agency implementation is inconsistent and not
     well coordinated. The report offers recommendations for
      improving implementation of this critical law by state
               vocational rehabilitation agencies.

  NCD stands ready to work with you and stakeholders outside the
  government to address the issues identified in this report and
    to empower persons with disabilities by facilitating their
             participation in the political process.

                            Sincerely,

                          Marca Bristo
                           Chairperson

  (This same letter of transmittal was sent to the President Pro
    Tempore of the U.S. Senate and the Speaker of the House of
                        Representatives.)


                      NCD MEMBERS AND STAFF

                             Members

                    Marca Bristo, Chairperson
             Kate P. Wolters, First Vice Chairperson
              Hughey Walker, Second Vice Chairperson

                     Yerker Andersson, Ph.D.
                          Dave N. Brown
                          John D. Kemp
                         Audrey McCrimon
                          Gina McDonald
                       Bonnie O'Day, Ph.D.
                       Lilliam Rangel-Diaz
                          Debra Robinson
                         Shirley W. Ryan
                        Michael B. Unhjem
                         Rae E. Unzicker
                         Ela Yazzie-King

                              Staff

               Ethel D. Briggs, Executive Director
    Andrew J. Imparato, General Counsel and Director of Policy
            Mark S. Quigley, Public Affairs Specialist
          Kathleen A. Blank, Attorney/Program Specialist
            Lois T. Keck, Ph.D., Research Specialist
       Moira Shea, Senior Legislative and Economic Advisor
                  Allan W. Holland, Accountant
               Brenda Bratton, Executive Secretary
                Stacey S. Brown, Staff Assistant


                            CONTENTS

                      NCD Members and Staff

                             Preface

                         Acknowledgments

                        Executive Summary

                          Introduction

                            Background
                      Purpose of the Report
                       Scope of the Report
                Research Approach and Activities
                        Report Structure

   Part I. Description of the Major Provisions of the National
                      Voter Registration Act

          Findings, Objectives, and Primary Strategies
                    Applicability of the Law
                          Effective Date
                  The Role of Federal Agencies
            Designation of a State Election Official
            National Procedures for Voter Registration
                      for Federal Elections
            Specific Agency Registration Provisions,
              Including Procedures for Persons with
                Disabilities to Register to Vote
            Agencies serving people with disabilities
              General requirements and prohibitions
                applicable to agency registration
            The form to be used in applying for voter
                    registration in an agency
              The transmittal of voter registration
               applications from agency offices to
               appropriate state election official
            Recordkeeping and Reporting Requirements

       Part II. Findings, Conclusions, and Recommendations

                          Introduction
                Overall Approach to Implementation
          Adoption of Policies and Procedures Mandated
                             by NVRA
           Monitoring, Data Collection, Recordkeeping,
                          and Reporting
                Appointing Coordinators to Oversee
                          Implementation
                    Training Incentive System

                            Conclusion

                            Appendix

          Mission of the National Council on Disability


                             PREFACE

  Historically, people with disabilities have been subjected to
  discrimination and denied equal opportunity to participate in
  many aspects of American society. Segregation, exclusion, and
 denial of meaningful opportunities to participate in activities
  fundamental to living in a democratic society too often have
 relegated people with disabilities to second-class citizenship.

    Discrimination is sometimes based on fear, ignorance, or
  prejudice; other times it is based on indifference or benign
 neglect. Still other times, discrimination is the result of the
        failure to make programs or services accessible.

     In recognition of the need to ensure equal justice, the
  Americans with Disabilities Act (ADA) was signed into law on
    July 26, l990, by President Bush. ADA, as an omnibus civil
   rights statute, reflects our nation's commitment to include
  people with disabilities in all aspects of American society.

The National Voter Registration Act (NVRA) extends the vision of
      ADA by requiring that voter registration be simple and
   convenient for all citizens, particularly for citizens with
    disabilities. By enacting NVRA, Congress has significantly
   increased the likelihood that people with disabilities will
  exercise the right to vote--one of the most fundamental rights
                    in a democratic society.

  NVRA has been in effect for most states since January 1, 1995.
  To date there has been no study of the implementation of NVRA.
    This report assesses the experience of a sample of state
    vocational rehabilitation agencies in implementing NVRA.

     It is hoped that this report will help promote the full
    implementation of this landmark legislation by vocational
rehabilitation agencies as well as other agencies serving people
                        with disabilities.


                         ACKNOWLEDGMENTS

  All research, data collection, and analysis for this study was
 conducted under contract for the National Council on Disability
by the Center for the Study and Advancement of Disability Policy
 at The George Washington University School of Public Health and
  Health Services, Washington, DC. The principal researcher and
  lead author for this report is Robert Silverstein, J.D., with
      administrative assistance provided by Melanie Gabel.

        We wish to thank the state directors of vocational
      rehabilitation who agreed to participate in the study,
   particularly those directors who agreed to provide detailed
  information concerning the administration of the programs in
their states. These states are California, Connecticut, Georgia,
   Iowa, Michigan, New Jersey, New Mexico, New York, Oklahoma,
Pennsylvania, Rhode Island, South Carolina, Tennessee, Virginia,
                         and Washington.

  We also wish to thank Jim Dickson of the National Organization
    on Disability for his continued interest in advancing the
      empowerment of persons with disabilities through voter
  registration. In addition, we wish to thank Jo-Anne Chasnow of
HumanSERVE, whose expertise in the technical details of National
Voter Registration Act implementation provided critical insights
 regarding best practices for achieving the purposes of the Act.


                        EXECUTIVE SUMMARY

 On May 20, 1993, President Clinton signed into law the National
  Voter Registration Act (NVRA). In a nutshell, the purpose of
  NVRA is to make registration convenient and accessible for all
      eligible voters, including persons with disabilities.

  Section 7 of NVRA specifies that each state shall designate as
voter registration agencies, all offices in the state that offer
state-funded programs primarily engaged in providing services to
persons with disabilities. One of the largest agencies providing
   services to persons with disabilities in every state is the
      state vocational rehabilitation agency, which provides
    assistance to persons with disabilities to prepare them to
engage in gainful employment. In 1998, vocational rehabilitation
agencies provided services to more than 1.2 million persons with
  disabilities, of whom 623,000 were new recipients of services.

  These designated voter registration agencies are required to
 verbally or in writing offer an opportunity to register to vote
 to each person who is served, including providing services such
    as mailing voter registration application forms, assisting
 applicants in completing voter registration forms, accepting of
    completed forms, and transmitting of forms to appropriate
                       election officials.

  NVRA has now been in effect for most states since January 1,
        1995. To date no survey has been undertaken of the
    implementation of NVRA by state vocational rehabilitation
agencies. The purpose of this report is to assess the experience
of state vocational rehabilitation agencies in implementing NVRA
                      in a sample of states.

  In keeping with the National Council on Disability's (NCD's)
  mission to advise the President and Congress on public policy
that affects people with disabilities, NCD has taken an interest
 in the ability of Americans with disabilities to participate in
    the electoral process. NCD is hopeful that aggressive and
      coordinated implementation of NVRA by state vocational
      rehabilitation agencies will result in greater voter
            participation by people with disabilities.

          Key Findings and Conclusions, Recommendations

             Six topics are analyzed in this report:

      * Overall approach to implementation of NVRA by state
               vocational rehabilitation agencies
  * Adoption of NVRA-mandated policies and procedures by state
               vocational rehabilitation agencies
  * Monitoring, data collection, recordkeeping, and reporting
  * Appointing coordinators to oversee implementation of NVRA
                           * Training
        * Incentive systems to encourage implementation

              1. Overall Approach to Implementation

                    Findings and Conclusions

   States included in the survey reported a range of attitudes
  about and approaches to implementation of NVRA. Some embraced
  the objectives of NVRA; others resented NVRA as simply another
   "unfunded federal mandate" and adopted a minimal compliance
approach; and still others were forced to comply by court order.

                         Recommendations

   To ensure that all state vocational rehabilitation agencies
   provide the opportunities to register to vote envisioned by
              NVRA, NCD recommended the following:

    * The Rehabilitation Services Administration (RSA) should
              monitor states' compliance with NVRA.
    * The Client Assistance Programs and State Rehabilitation
  Councils established under title I of the Rehabilitation Act
    of 1973, as amended, should undertake ongoing oversight of
                            the NVRA.

           2. Policies and Procedures Mandated by NVRA

                    Findings and Conclusions

 All the vocational rehabilitation agencies surveyed incorporate
  in their forms and written materials the specific requirements
mandated by NVRA, such as the content of the registration forms,
   services that must be provided to clients, and prohibitions
                      regarding influence.

  There are, however, significant variations among states in the
 options applicants are provided on forms for describing whether
  or not they want to register to vote. The choices registrants
                    are offered are unclear.

                         Recommendations

    To help address these inconsistencies, NCD recommends the
                            following:

      * In its next report to Congress, the Federal Election
    Commission (FEC) should address the lack of clarity in the
                choices registrants are offered.
  * States should adopt the following five categories from which
    applicants may describe their preferences (based on South
                      Carolina's system):
            * Yes, I would like to register to vote.
            * I am not eligible to register to vote.
               * I am already registered to vote.
  * Registration assistance is offered, but I choose to register
                    by mail (form provided).
    * No, I would not like to register to vote at this time.

  3. Monitoring, Data Collection, Recordkeeping, and Reporting

                    Findings and Conclusions

                   Insufficient Data Reporting

  Policies and procedures regarding monitoring, data collection,
  recordkeeping, and reporting vary considerably among states.
  Overall, there is a lack of meaningful aggregate data reported
by vocational rehabilitation agencies regarding basic results of
      voter registration efforts. Without such data, it is
difficult--perhaps impossible--to ascertain to what extent state
  vocational rehabilitation agencies are implementing NVRA. In
states in which lawsuits have been filed and won, state agencies
          have been required to collect aggregate data.

  Inclusion of NVRA Data in Agencies' Computerized Information
                             Systems

    Several states surveyed report that they have successfully
  included data reporting about implementation of NVRA in their
              computerized case management systems.

   Single Combined Application Form for Voter Registration and
                Vocational Rehabilitation Services

To facilitate the voter registration process, FEC recommends use
    of a single integrated voter registration form that is a
  perforated or pressure-sensitive part of the agency's own form
      for services. Most states surveyed do not use a single
application form for vocational rehabilitation services and thus
            have not adopted the FEC recommendation.

                Use of Site Identification Codes

    Only a few states use site identification codes that allow
  election officials to ascertain how many persons registered or
          declined to register at a particular agency.

                         Recommendations

  To improve recordkeeping and facilitate implementation of NVRA
 by state vocational rehabilitation agencies, NCD recommends the
                            following:

  * Every state vocational rehabilitation agency that has or is
     planning to adopt a computerized case management system
    should implement NVRA as a core component of the system.
  * State vocational rehabilitation computer systems should be
    linked with statewide systems used by election officials.
    * All states, whether or not a state adopts a computerized
      system, should collect the following data and tabulate
                       results by agency:
      * number of clients served during the reporting month
    * number of clients who were offered a voter registration
                          application
   * number of clients who declined to apply for registration
      * number of clients who declined to apply because they
       indicated that they are already registered to vote
    * number of applications taken by clients to be mailed or
                            delivered
   * number of applications mailed or delivered by the agency
    * Vocational rehabilitation agencies that adopt a single
    integrated application form for vocational rehabilitation
    services should include voter registration as a perforated
       or pressure-sensitive part of their agency's form.
  * Vocational rehabilitation agencies should use site codes to
     report data to state election officials, enabling these
   officials and other stakeholders to ascertain the extent to
            which each agency is implementing NVRA.
      * To monitor the effectiveness of agency registration
    programs, state election officials should be required to
    account for the number of voter registration applications
                received from each agency office.

      4. Appointing Coordinators to Oversee Implementation

                    Findings and Conclusions

  Research indicates that a principal component of a successful
 agency registration program is the appointment of a coordinator
      in each agency office to be responsible for all voter
                    registration activities.

  All states reported that they appointed a coordinator at the
     state level; many states reported that they appointed a
  coordinator at the district level. A few states specified the
       responsibilities of coordinators in policy manuals.

                         Recommendations

                  NCD recommends the following:

  * Every state should designate a coordinator within the state
   office who is responsible for monitoring the implementation
    of NVRA. The coordinator's job responsibilities should be
    described and documented so that expectations are clear.
  * States that have district offices and private agency sites
      should designate a coordinator who is responsible for
    implementing NVRA, and the coordinator's responsibilities
                should be specified in writing.

                           5. Training

                    Findings and Conclusions

  Research indicates that training is a significant factor in a
  successful agency voter registration program. The results of
    this study indicate that initial training occurred in most
  states shortly before NVRA went into effect or after a court
  decree was handed down or a legal settlement was reached. Some
   states report that training is ongoing. In other states the
        nature and extent of ongoing training is unclear.

                         Recommendations

                  NCD recommends the following:

    * State policies should require that new employees receive
      training from either agency staff or the state agency
              responsible for voter registration.
  * Existing employees should also receive periodic training.

                       6. Incentive System

                    Findings and Conclusions

   Research indicates that good management includes the use of
    "carrots" as well as "sticks." Pennsylvania has adopted an
      incentive program that rewards agencies that register
         significant numbers of voters at their offices.

                         Recommendations

                  NCD recommends the following:

     * Every state should consider establishing an incentive
     program. Pennsylvania's model of public recognition and
     award for agency performance is one possible approach.
        * Evaluations of employees who provide vocational
   rehabilitation services should include their implementation
                            of NVRA.


                          INTRODUCTION

                            Background

  Voting is one of the most fundamental rights in a democratic
    society. Yet in 1993 Congress found that almost 70 million
  eligible citizens did not participate in the electoral process
    because they were not registered to vote. [Senate Report
                       No.103-6 at page 2]

   To promote the exercise of this right, Congress enacted and
      President Clinton signed into law the National Voter
  Registration Act (NVRA) on May 20, 1993. [Public Law 103-31]

 The purpose of NVRA is to make voter registration as simple and
    convenient as possible for all eligible voters, including
 persons with disabilities. NVRA accomplishes this objective for
people with disabilities by requiring each state to designate as
voter registration agencies all offices of state-funded programs
     primarily engaged in providing services to persons with
   disabilities, including state agencies providing vocational
                    rehabilitation services.

  NVRA is significant to persons with disabilities. According to
   data from the U.S. Bureau of the Census' Current Population
    Survey, only six out of ten adults with disabilities (62
    percent) were registered to vote in the 1996 presidential
  elections, compared with almost eight out of ten (78 percent)
    among the nondisabled population, a significant gap of 16
    percent. This finding was recently reported in a National
 Organization on Disability (NOD)/Lou Harris Survey of Americans
  with Disabilities (1998). The NOD/Lou Harris survey also found
 that only one in four adults with disabilities (25 percent) has
  been offered voter registration services from a government or
            community agency in the last five years.

    A recent report prepared by Douglas L. Kruse, Ph.D., Kay
   Schriner, Ph.D., Lisa Schur, J.D., Ph.D., and Todd Shields,
Ph.D. for the Disability Research Consortium, Bureau of Economic
  Research, Rutgers University, and the New Jersey Developmental
      Disabilities Council titled Empowerment Through Civic
 Participation: A Study of the Political Behavior of People with
Disabilities (April 1999) surveyed a random sample of 700 people
   with disabilities and 540 people without disabilities about
   voting in 1996 and 1998 and voter registration, among other
                             things.

      The major findings of the 1998 survey are as follows:

      * People with disabilities were, on average, about 20
        percentage points less likely than those without
      disabilities to vote and 10 points less likely to be
      registered to vote, after adjusting for differences in
   demographic characteristics (age, sex, race, education, and
                        marital status).
  * If people with disabilities voted at the same rate as those
     without disabilities, there would have been 4.6 million
   additional voters in 1998, raising the overall turnout rate
                    by 2.5 percentage points.
  * The one-third of people with disabilities who are employed
    were as likely as employed people without disabilities to
     vote, while the two-thirds who are not employed were 17
      percentage points less likely to be registered, and 30
    percentage points less likel y to vote, than nonemployed
                  people without disabilities.
  * Close to one-fourth of respondents have registered to vote
    since NVRA took effect, close to one-tenth have registered
     at a state department of motor vehicles, and close to 1
     percent have registered at a disability agency or other
      public assistance agency, in both the disability and
                     nondisability samples.

 Another recent report (1998) prepared by the Office of Election
  Administration of the Federal Election Commission (FEC) titled
  Implementing the National Voter Registration Act: A Report to
  State and Local Election Officials on Problems and Solutions
  Discovered 1995-1996 [FEC Report at pages 1-4] found that over
    24,600 separate sites in 41 states provided agency voter
  registration opportunities for their service recipients during
   the period studied by the report. Registration applications
received at all agency sites combined repres ented 11.12 percent
of the total number of applications in the United States. Public
  assistance agencies accounted for 6.33 percent of this figure,
  agencies designated by the state accounted for 4.18 percent,
   disability service agencies accounted for 0.43 percent, and
  armed forces recruitment offices accounted for 0.18 percent.

  In National Disability Policy: A Progress Report November 1,
 1997-October 31, 1998, the National Council on Disability (NCD)
   encouraged the President and Congress to recognize that the
 ability of a person with a disability to vote should not depend
 on the goodwill of the state election agency but instead should
  be guaranteed as a federa lly protected civil right, with real
  consequences when the right is violated. Accordingly, NCD also
 encouraged the President and Congress to enact legislation that
    would amend the Voting Accessibility for the Elderly and
  Handicapped Act to recognize the right of all people to vote
   independently; guarantee accessibility to all stages of the
    electoral process (from voter registration to election day
    procedures); require the Architectural and Transportation
     Barriers Compliance Board ("Access Board") to establish
    standards for the accessibility of polling places, polling
    methods, and registration materials; strengthen the law's
  enforcement mechanisms to ensure that private individuals are
able to enforce their rights; and require regular and meaningful
  monitoring of access to elections for people with disabilities
               by FEC or other appropriate entity.

                        Purpose of Report

 This report by NCD, an independent federal agency, analyzes the
    experience of state vocational rehabilitation agencies in
  implementing NVRA. NCD decided to focus on the experience of
     state vocational rehabilitation agencies because of the
 substantial number of persons with disabilities served by these
  agencies--well over 1.2 million persons on an annual basis. Of
    this number, approximately 623,000 are new recipients of
                            services.

      Topics analyzed in this report include the following:

  * overall approach toward implementation adopted by the state
                vocational rehabilitation agency
    * agency's adoption of policies and procedures mandated by
                              NVRA
  * monitoring, data collection, recordkeeping, and reporting
  * appointing coordinators to oversee implementation of NVRA
                           * training
         * incentive system to encourage implementation

                       Scope of the Report

  This report describes policies and procedures related to the
 implementation of NVRA reported by a sample of state vocational
    rehabilitation agencies. The analysis did not attempt to
 ascertain whether the policies and procedures reported by these
    agencies are in fact being used or whether agency staff is
 implementing the policies and following the procedures. Nor did
 the analysis include interviews of persons with disabilities to
 ascertain their perspective. In other words, this report is not
                       a compliance audit.

                Research Approach and Activities

  For 1996, 1997, and 1998, all state vocational rehabilitation
    agencies in the nation were asked to submit aggregate data
  regarding the numbers of persons they served and the number of
    persons who registered or declined to register to vote. In
  addition, 15 states (based on geographic diversity, size, and
 the extent to which aggregate data was available) were asked to
    share copies of written policies, procedures, forms, and
   training materials used to implement NVRA, describe quality
     assurance procedures used, and describe any problems or
successes in implementing NVRA. The states providing information
    were California, Connecticut, Georgia, Iowa, Michigan, New
   Jersey, New Mexico, New York, Oklahoma, Pennsylvania, Rhode
  Island, South Carolina, Tennessee, Virginia, and Washington.

                        Report Structure

This report has two parts. Part I describes the major provisions
        in NVRA applicable to implementation by vocational
rehabilitation agencies. Part II describes the major findings of
the study undertaken by NCD to determine what is known about the
experience of state vocational rehabilitation agencies regarding
  the implementation of NVRA and then sets out NCD's conclusions
                      and recommendations.


                             PART I:

    DESCRIPTION OF THE MAJOR PROVISIONS OF THE NATIONAL VOTER
                        REGISTRATION ACT

          FINDINGS, OBJECTIVES, AND PRIMARY STRATEGIES

In enacting NVRA, Congress cited three critical findings. First,
     the right of citizens of the United States to vote is a
 fundamental right. Second, it is the duty of federal, state and
 local governments to promote the exercise of that right. Third,
 disc riminatory and unfair registration laws and procedures can
   have a direct and damaging effect on voter participation in
                federal elections. [Section 2(a)]

        The overall objectives of NVRA are the following:

    * To establish procedures that will increase the number of
     eligible citizens who register to vote in elections for
                        federal office;
      * To protect the integrity of the electoral process by
   ensuring that accurate and current voter registration rolls
                      are maintained; and
  * To enhance the participation of eligible citizens as voters
        in elections for federal office. [Section 2(b)]

   Congress devised three primary strategies for accomplishing
 these objectives. The first strategy is to expand the number of
locations and opportunities where eligible citizens may apply to
    register to vote. The second strategy is to require voter
 registration file maintenance procedures that, in a uniform and
 nondiscriminatory manner, identify and remove the names of only
    those people who are no longer eligible to vote. The third
  strategy is to provide certain fail-safe voting procedures to
 ensure that an individual's right to vote prevails over current
bureaucratic or legal technicalities. [Implementing the National
      Voter Registration Act of 1993: Requirements, Issues,
Approaches, and Examples, prepared by the National Clearinghouse
    on Election Administration, Federal Election Commission,
             Washington, DC. [FEC Guide at page I-1]

                    APPLICABILITY OF THE LAW

  NVRA applies to all states except those that satisfy specified
 criteria. NVRA includes two categories of exemptions. The first
category includes states in which voter registration for federal
  elections is not required (so long as such a law was in effect
  continuously on and after March 11, 1993). The second category
  is for states that permit, in federal elections, election day
  registration at the polls (so long as such a law was in effect
continuously on and after March 11, 1993, or else was enacted on
  or prior to March 11, 1993 and by its terms came into effect
           upon the enactment of NVRA). [Section 4(b)]

  According to FEC, six states consider themselves exempt from
 NVRA: Idaho, Minnesota, New Hampshire, North Dakota, Wisconsin,
            and Wyoming. [1998 FEC Report at page 1-1]

                          EFFECTIVE DATE

 In most states, the effective date of NVRA was January 1, 1995.
   [Section 13(2)] Some states, however, needed to amend their
  state constitutions in order implement NVRA. In these states,
the effective date was extended either to January 1, 1996, or to
 120 days after the date by which a constitutional amendment was
    legally possible without having to hold a special election
           (whichever date was later). [Section 13(1)]

                  THE ROLE OF FEDERAL AGENCIES

       NVRA directly involves four federal agencies in its
                         administration.

  The Department of Justice is responsible for civil enforcement
    of NVRA [Section 10(a)] as well as criminal enforcement.
                          [Section 12]

 FEC is responsible for providing technical assistance to states
      describing their responsibilities and suggesting "best
 practices," developing a mail-in voter registration application
  form for federal elections, and submitting biennial reports to
                          the Congress.

  The U.S. Postal Service is directed to encourage states to use
     the National Change of Address files for the purpose of
 identifying voter registrants who have changed their addresses.
                      [Section 8(c)(1)(A)]

   NVRA requires that each state and the Department of Defense
  jointly develop voter registration application procedures at
                Armed Forces recruitment offices.

  According to FEC, in addition to these four federal agencies,
    NVRA indirectly involves the Department of Education, the
  Department of Health and Human Services, and the Department of
    Agriculture because these departments oversee many of the
  agencies providing assistance to persons with disabilities and
      the public assistance agencies that must provide voter
          registration services. [FEC Guide at page I-5]

            DESIGNATION OF A STATE ELECTION OFFICIAL

    NVRA requires each state to "designate a state officer or
 employee as the chief state election official to be responsible
   for coordination of state responsibilities under this Act."
[Section 10] NVRA also assigns the chief state election official
  the duty of making national and state mail registration forms
  "available for distribution through governmental and private
 entities, with particular emphasis on making them available for
      organized voter registration programs." [Section 6(b)]

NATIONAL PROCEDURES FOR VOTER REGISTRATION FOR FEDERAL ELECTIONS

    NVRA directs states to establish three broad categories of
   procedures to register people to vote in federal elections.

      The first procedure allows voter registration with an
 application made simultaneously with an application for a motor
              vehicle driver's license. [Section 5]

  The second procedure allows voter registration to vote by mail
                    application. [Section 6]

    The third procedure allows voter registration at specified
  federal, state, or nongovernmental offices. [Section 7] This
third procedure was included in NVRA because Congress wanted the
 states to reach out to those sectors of the population that are
  not likely to have driver's licenses or other identification
cards issued by a motor vehicle agency. [Senate Report No. 103-6
  at pages 14, 28; House Report No. 103-9 at page 12; Conference
                  Report No. 103-66 at page 19]

SPECIFIC AGENCY REGISTRATION PROVISIONS, INCLUDING PROCEDURES TO
          REGISTER TO VOTE FOR PEOPLE WITH DISABILITIES

  Agencies serving people with disabilities. NVRA mandates that
    states give people the opportunity to register to vote in
    elections for federal office or change their registration
address when applying for or receiving services or assistance at
any office in the state that provides public assistance [Section
    7(a)(2)(A)] or at or through any office in the state that
  provides state-funded programs primarily engaged in providing
   services to persons with disabilities. [Section 7(a)(2)(B)]
  State vocational rehabilitation agencies are included in this
        category. [See House Report No. 103-9 at page 12]

 This provision of NVRA is intended to encompass not only people
    with physical disabilities but also people with cognitive
   disabilities and people with mental illness or other mental
   disabilities--state law permitting. [FEC Guide at page 4-3]

 Congress also recognized that many people with disabilities are
    less likely to visit offices in order to obtain service or
          benefits. [House Report No. 103-9 at page 12]

  As a result, NVRA requires that if a voter registration agency
  designated by the state provides services to a person with a
 disability at the person's home, the agency shall provide voter
  registration services at the person's home, as well. [Section
                           7(a)(4)(B)]

   Congress mandated that these agencies provide assistance in
voter registration because if the states are required to include
    these programs, "we will be assured that almost all of our
citizens will come into contact with an office at which they may
  apply to register to vote with the same convenience as will be
 available to most other people under the motor voter program of
       the Act." [Conference Report No. 103-66 at page 19]

    In addition, a state may, at its discretion, offer voter
    registration at offices providing services to persons with
     disabilities that are not within the mandatory category
                        described above.

    General requirements and prohibitions applicable to agency
  registration. NVRA includes a number of specific requirements
   and prohibitions applicable to agency- based registrations.

  NVRA specifies that people must be provided the opportunity to
  register to vote at the time of their original application for
   services or assistance and when filing any recertification,
    renewal, or change of address relating to such services or
                assistance. [Section 7(a)(6)(A)]

  Those who decline to register to vote must do so in writing or
 by not checking a box on a form that contains wording specified
            in the Act. [Section 7(a)(6)(A) and (B)]

If an individual does register to vote, the particular agency at
which the applicant submits a voter registration application may
    not be publicly disclosed. [Section 8(a)(6) and 8(I)(1)]

  Agencies providing voter registration services must offer the
    same degree of assistance to people in completing a voter
   registration form as they offer to people in completing the
      agency's own forms, unless the applicant refuses such
        assistance. [Section 7(a)(4)(ii) and 7(a)(6)(C)]

      The person who provides such services in the agency is
                        prohibited from:

    * seeking to influence an applicant's party preference or
                      party registration,
   * displaying any political preference or party allegiance,
  * making any statement or taking any action whose purpose or
    effect is to discourage the applicant from registering to
                            vote, or
  * making any statement or taking any action whose purpose or
    effect is to lead the applicant to believe that a decision
        whether or not to register has any bearing on the
    availability of services or benefits. [Section 7(a)(5)]

  The form to be used in applying for voter registration in an
     agency. NVRA specifies that agencies distribute to each
    applicant a mail-in registration form that is either the
 national mail registration form or the "office's own form if it
  is equivalent to" the national mail registration form, unless
 the applicant declines in writing to register to vote. [Section
              7(a)(4)(A)(I) and Section 7(a)(6)(A)]

  NVRA also specifies some of the language that must appear as
 part of the declination form. [Section 7(a)(6)(B)] In addition,
NVRA specifies that "no information relating to a declination to
  register to vote in connection with an application made at an
  agency office...may be used for any purpose other than voter
                registration." [Section 7(a)(7)]

    NVRA specifically requires the following components of the
                          declination:

  * "If you are not registered to vote where you live now, would
       you like to apply to register to vote here today?"
    * if the agency provides public assistance, "Applying to
    register or declining to register to vote will not affect
    the amount of assistance that you will be provided by this
                            agency."
  * "IF YOU DO NOT CHECK EITHER BOX, YOU WILL BE CONSIDERED TO
  HAVE DECIDED NOT TO REGISTER TO VOTE AT THIS TIME" (with yes
                    and no boxes provided).
  * "If you would like help filling out the voter registration
   application form, we will help you. The decision whether to
        seek or accept help is yours. You may fill out the
                  application form in private."
  * "If you believe that someone has interfered with your right
  to register or to decline to register to vote, your right to
    privacy in deciding whether to register or in applying to
  register to vote, or your right to choose your own political
      party or other p olitical preference, you may file a
    complaint with______.. (the blank being the name, address,
  and phone number of the appropriate officials to whom such a
                complaint should be addressed)."

 The transmission of voter registration applications from agency
  offices to the appropriate state election official. There are
  two ways in which agency voter registration can be transmitted
  to the appropriate election official--by the agency itself or
      directly by the applicant. If applicants submit voter
  registration applications to the state agency, NVRA specifies
  that the agency must transmit the registration applications to
    the appropriate election officials within ten days after
acceptance, or, if accepted within five days before the close of
  registration, within five days of acceptance. [Section 7(d)]

            RECORDKEEPING AND REPORTING REQUIREMENTS

  NVRA requires voter registration officials to maintain for at
least two years and to make available for public inspection (and
  where available, for photocopying at a reasonable cost), "all
records concerning the implementation of programs and activities
 conducted for the purpose of ensuring the accuracy and currency
 of official lists of eligible voters, except to the extent that
  such records relate to a declination to register to vote or to
  the identity of a voter registration agency through which any
        particular voter is registered." [Section 8(I)(1)]

    According to FEC, in addition to retaining the documents
    described above, election officials may also want to have
retained for their own purposes declination statements completed
by applicants for public assistance. [FEC Guide at page 7-4] The
     Election Crimes Branch of the Department of Justice has
    indicated that declination statements may fall under the
 22-month document retention requirements of 42 USC 1974 et seq.
                     [FEC Guide at page 7-4]

  According to FEC, ideally, the declination statement completed
  by each applicant for public assistance--whether it indicates
 that the applicant wishes to register to vote or declines to do
  so--would contain the name of the applicant and the date the
  statement was completed. This could be accomplished preferably
by having the applicant sign and date the completed statement or
  else by having the service agent note the name and date on the
  statement. If the name and date are affixed to the declination
  statement, it could then be removed from the applicant's case
   file and retained separately by the agency under secure and
        confidential conditions. [FEC Guide at page 7-4]


                            PART II:

            FINDINGS, CONCLUSIONS, AND RECOMMENDATIONS

                          INTRODUCTION

      Part II of this report is divided into six sections:

              * Overall Approach to Implementation
     * Adoption of Policies and Procedures Mandated by NVRA
  * Monitoring, Data Collection, Recordkeeping, and Reporting
      * Appointing Coordinators to Oversee Implementation
                           * Training
                       * Incentive System

  Each section addresses a specific topic and includes findings,
                conclusions, and recommendations.

                OVERALL APPROACH TO IMPLEMENTATION

Findings. NCD finds that the overall attitude about and approach
  to implementation of NVRA varied significantly among the state
    vocational rehabilitation agencies included in the survey.
  Several agency officials expressed support for and endorsement
    of the primary objective of NVRA--to empower people with
   disabilities by expanding the number and range of locations
    where eligible citizens may obtain and complete the voter
registration process. On the other hand, some states viewed NVRA
    as "an unfunded federal mandate" and as an intrusion on a
           state's right to set its own policy agenda.

  In fact, after enactment, some states refused to implement the
law and were forced to comply by court action (e.g., California,
  Michigan, Pennsylvania, South Carolina, and Virginia). As one
   state official explained to staff members at his vocational
                     rehabilitation program,

            We do not have any options nor can we say
            "no" to doing it (the governor tried this
            already, the state was sued, and the court
          ordered us to get with it), and so it [voter
          registration] needs to become a routine part
           of every intake because it is here to stay.

   For some states and their vocational rehabilitation agency,
    implementation of NVRA is a low priority. One vocational
          rehabilitation official expressed the opinion:

            We have not devoted a lot of resources to
            staff development or quality assurance to
            this program. We do not track anything in
              our vocational rehabilitation database
            pertaining to voter registration. We have
            not established an incentive system. While
                we respect the importance of voter
              registration, we do not feel we have
            resources to commit to intensive efforts
            [regarding] recordkeeping and tracking of
           this ancillary function that is not part of
                      our primary business.

  When NVRA was initially enacted, there was some concern that
   implementation would create significant problems for public
       agencies, such as agencies administering vocational
  rehabilitation programs. According to the Office of Election
 Administration of FEC in the 1998 FEC Report (page 4-1), states
  reported "experiencing far fewer problems than were forecast."

 These general findings are consistent with the findings of this
                             study:
      * "No difficulties have been reported." (California)
    * "We have had minimal difficulty implementing NVRA and we
       were able to work through initial difficulties with
                   accessibility." (Oklahoma)
          * "No significant problems." (Pennsylvania)
       * "No problems are known at this time." (Virginia)

   Where problems were identified, they related to counselors'
acceptance of voter registration as part of the responsibilities:

   * "The only difficulty we have is getting counselors to ask
    clients if they want to register to vote." (Rhode Island)
  * "The most problem is getting counselors to make this a part
              of their normal procedures." (Iowa)

 Conclusions and Recommendations. It is critical that vocational
  rehabilitation agencies implement NVRA in a manner that will
    maximize the likelihood that all applicants for vocational
  rehabilitation services and all current clients are provided a
    meaningful and effective opportunity to register to vote.

  NCD recommends that the Rehabilitation Services Administration
include compliance with NVRA in its monitoring of states carried
     out in accordance with the provisions of title I of the
             Rehabilitation Act of 1973, as amended.

In addition, Client Assistance Programs and State Rehabilitation
 Councils established under title I of the Rehabilitation Act of
    1973, as amended, should be required to undertake ongoing
  oversight to ensure that all state vocational rehabilitation
      agencies provide the opportunities to register to vote
  envisioned by NVRA. These oversight efforts should include a
  review of state policies and procedures and data documenting
  implementation, as well as interviews with a random sample of
    people with disabilities applying for assistance under the
      vocational rehabilitation program, to determine their
   perspectives about the opportunities the agency provided to
                        register to vote.

      ADOPTION OF POLICIES AND PROCEDURES MANDATED BY NVRA

Background. As explained in Part I of this report, NVRA includes
specific requirements governing the implementation of the Act by
  state registration agencies, including agencies administering
               vocational rehabilitation programs.

  Requirements specified in NVRA govern, among other things, the
    content of registration forms, the services that must be
      provided to clients (e.g., distributing mail-in voter
      registration application forms, offering assistance to
     applicants in completing forms, and accepting forms and
  transmitting them to state election officials), prohibitions
   regarding influence, assurances of confidentiality, and the
                    right to file complaints.

    Findings. All the state vocational rehabilitation agencies
  surveyed incorporated in their forms or written materials the
  policies required by NVRA pertaining to voter registration. In
 some states, the policies were set out in policy directives; in
          other states, the policy appeared in manuals.

  As described in Part I of this report, NVRA specifies that a
     registration form developed by a state must include the
question, "If you are not registered to vote where you live now,
  would you like to apply to register to vote here today?" The
  form must also include boxes to indicate whether the applicant
 would like to register or declines to register to vote (failing
  to check either box is considered a declination to register),
together with the following statement in prominent type: "IF YOU
 DO NOT CHECK EITHER BOX, YOU WILL BE CONSIDERED TO HAVE DECIDED
              NOT TO REGISTER TO VOTE AT THIS TIME."

  There was, however, significant variation reported among the
 states concerning the options on forms applicants were provided
  for describing whether or not they wanted to register to vote.
 The variation concerned how to characterize three categories of
                             people:

              * persons already registered to vote
    * persons ineligible (e.g., because of age, competency, or
                        criminal record)
  * persons who take a voter registration form home rather than
                     register at the office

  For example, the voter registration form used in Connecticut
   adopts the language included in NVRA. In addition, the form
  includes a separate space for use by agency personnel only to
indicate, by checking a box, whether or not a voter registration
  form was completed, or whether a voter registration form was
  given to applicant for later mailing at applicant's request.

  In New York, applicants who are already registered to vote or
    who requested and received a mail-in registration form are
        considered to have "declined" to register to vote.

In California and Virginia, applicants are offered three choices:

  * I am already registered to vote at my current address or I
      am not eligible to register to vote and do not need an
                application to register to vote.
   * Yes I would like to register to vote (please fill out the
                        attached form).
            * No, I do not want to register to vote.

  Note: If you do not check any box, you will be considered to
        have decided not to register to vote at this time.

   In California, the form also includes a line for the agency
     employee to complete, stating, "Voter Registration form
 completed Yes _____ No _____," followed by space for employee's
initials. A note on the form to the agency employees states that
  if the employee gives the applicant a form to register to vote
   but the applicant decides to take it home, fill it out, and
  return it him or herself, the employees should check the box
indicating that no registration form has been completed since it
    will not be possible to determine whether or not the voter
            follows through with completing the form.

   In Virginia, the form includes a space for agency use only,
stating, "Voter registration form completed: Yes _____ No _____.
Voter registration form given to applicant for later mailing (at
    applicant's request)." But state policy specifies that if
  clients indicate to their caseworkers a desire to complete the
   application at a later date, they are counted under "Yes, I
            would like to apply to register to vote."

      In Pennsylvania, applicants are offered four choices:

          * Yes, customer mailed/delivered application
           * Yes, agency mailed/delivered application
                    * No, already registered
                        * No, no reason

If no box is checked, you will be considered to have decided not
                to register to vote at this time.

     In South Carolina, applicants are offered five choices:

          * A. I am not eligible to register to vote.
              * B. I am already registered to vote.
      * C. Registration assistance is offered but I chose to
                register by mail, form provided.
                            * D. Yes.
                            * E. No.

If no box is checked, you will be considered to have decided not
                to register to vote at this time.

  Conclusions and Recommendations. All of the state vocational
rehabilitation agencies surveyed incorporated in their forms and
      written materials the requirements specified in NVRA.
  Significant variation among the states, however, was reported
    regarding the options describing whether or not applicants
    wanted to register to vote. The variation related to three
    categories of people--persons already registered to vote,
    persons ineligible to vote, and persons who take a voter
  registration form home with them rather than register at the
                             office.

 The categories "Yes, I want to register" and "No, I declined to
  register" specifically included in NVRA are too broad and as a
    result are confusing. In addition, these categories do not
  provide sufficient information for policy makers to determine
    whether or not the objectives of NVRA are being achieved.

NCD recommends that FEC address this issue in its next report to
Congress. NCD also recommends that states adopt South Carolina's
   five questions from which applicants may choose to describe
                        their preference:

            * Yes, I would like to register to vote.
            * I am not eligible to register to vote.
               * I am already registered to vote.
  * Registration assistance is offered, but I chose to register
                    by mail (form provided).
    * No, I would not like to register to vote at this time.

    MONITORING, DATA COLLECTION, RECORDKEEPING, AND REPORTING

 Background. As explained in Part I of this report, NVRA and the
  implementing regulations specify mandatory policies governing
  data collection, recordkeeping, and reporting. Of particular
       relevance to this report are policies governing the
implementation of NVRA by state registration agencies, including
               vocational rehabilitation agencies.

   The final regulations promulgated by FEC require that every
  state report the number of registration applications received
 by, among other categories, all state-funded agencies primarily
  serving persons with disabilities. The federal report does not
  require that the state disaggregate the data among particular
 agencies serving people with disabilities within the state. Nor
 does the federal report require information about the number of
                          declinations.

FEC, however, concludes, "information regarding the total number
  and rate of persons registered by each social service agency
   might prove valuable to local election officials and public
    interest groups even if such detailed information is not
  requested by FEC". [FEC Guide at page 7-5] FEC also explains
    that each agency should retain declination information to
  provide an audit trail of all agency transactions should there
  be subsequent official or legal inquiries. [FEC Guide at page
                              7-5]

    FEC also recommends that states that have not yet done so
voluntarily develop and implement a statewide computerized voter
    registration database, ensure that all local registration
  offices are computerized, and link the statewide system, where
  feasible, with the systems of public agencies relevant to NVRA
 (e.g., vocational rehabilitation agencies). [1998 FEC Report at
                           Appendix A]

   Furthermore, FEC found that to monitor the effectiveness of
  agency registration programs, many jurisdictions have found it
  useful to account for the number of registration applications
  received from various agency offices. [1998 FEC Report at page
                              4-5]

Findings regarding aggregation of data and computerization. This
    report surveyed all 50 states' vocational rehabilitation
agencies to ascertain their experience in implementing NVRA. For
  1996, 1997, and 1998, aggregate data was requested regarding
 five items described below. "Aggregate data" is defined as data
 that currently exists or is stored in a computerized system and
 can easily be retrieved by the vocational rehabilitation agency
  or state election official. To the extent aggregation was not
    implemented in a state, the agency was asked to inform the
   researchers that such data did not exist in aggregate form.

          The five data items sought were the following:

      * The total number of persons served by the vocational
             rehabilitation agency (new referrals).
  * The total number of persons who check the box on the voter
  registration application form saying that they would like to
                        register to vote.
  * The total number of persons who check the box on the voter
    registration application form saying that they decline to
                        register to vote.
  * The total number of persons who do not check either box on
            the voter registration application form.
  * The total number of completed voter registration application
       forms accepted by the agency for transmittal to the
              appropriate state election official.

Responses were received from 30 states. Of the states responding
  to the survey, only five reported aggregate data for the items
requested (California, Michigan, New Jersey, New York, and South
    Carolina). In other words, there is a lack of meaningful
  aggregate data in most states regarding the basic results of
  voter registration efforts. Without such data, it is difficult
    and perhaps impossible to ascertain to what extent state
  vocational rehabilitation agencies are implementing NVRA. In
states in which lawsuits have been filed and won, state agencies
          have been required to collect aggregate data.

 There seem to be two recordkeeping and reporting trends: First,
  a number of states are computerizing their voter registration
  systems. For example, in 1997 Pennsylvania developed new forms
    that include voter registration options and shifted to an
               electronic data collection process.

Second, several states have decided to include implementation of
   NVRA in their new computerized case management systems. For
      example, in New Jersey, when applicants for vocational
rehabilitation services reach a certain stage in the application
process for vocational rehabilitation services and the counselor
    has not yet documented whether or not an individual with a
 disability was offered the opportunity to register to vote, the
                    computer rejects the case.

  In South Carolina, the voter registration process is handled
      through their computer system. In Michigan, a new case
       management system will be going online in 1999, and
implementation of NVRA will be included as part of the system. A
            similar effort is under way in New York.

  In contrast, some states that have computerized their system
 have not included items to allow for NVRA implementation (e.g.,
                          California).

    Findings regarding scope of the data elements included in
    reports. As explained in this report, there is a need to
       fine-tune the type of information included in voter
  acceptance/declination forms. New monthly reports developed by
    several states reflect best practice for collecting this
 information. For example, in Pennsylvania every agency must now
                    report the following data:

      * number of clients served during the reporting month
    * number of clients who were offered a voter registration
                          application
   * number of clients who declined to apply for registration
  * number of clients who decline to apply because they indicate
              they are already registered to vote
    * number of applications taken by client to be mailed or
                            delivered
   * number of applications mailed or delivered by the agency

  South Carolina now requires collection of the following data:

      * number of clients served during the reporting month
      * number of persons not eligible to register to vote
         * number of persons already registered to vote
  * number of persons to whom registration assistance is offered
        but who chose to register by mail, form provided
  * number of persons who would like to register to vote at the
                             agency
  * number of persons who declined to register to vote at this
                              time

  Findings regarding single combined form for voter registration
    and application for vocational rehabilitation services. To
   facilitate the voter registration process, FEC recommends a
      single integrated form to be used in which the voter
 registration form is a perforated or pressure-sensitive part of
the agency's own form for services. [FEC Guide at page 4-5] Most
 of the states surveyed currently do not use a single integrated
  form. For example, in California an applicant for vocational
    rehabilitation services fills out seven separate forms to
  qualify for vocational rehabilitation services and a separate
                    voter registration form.

     Findings regarding use of site identification codes for
disaggregation. An additional issue concerns disaggregating data
  by each agency serving people with disabilities. Agencies must
report data without breaching NVRA confidentiality requirements.
    These include the prohibition against public disclosure of
  information regarding any individual's declination to register
or regarding the specific public assistance agency through which
              any particular individual registered.

  Some states do not include any information that permits state
  election officials to ascertain the source of the registration
   (e.g., California and Connecticut). In contrast, vocational
   rehabilitation sites in New Jersey, New York, Virginia, and
 Pennsylvania have specified codes to identify agencies while at
    the same time maintaining confidentiality for individual
                          registrants.

  Findings regarding accountability of agency forms. Several of
  the states included in the survey reported that to monitor the
effectiveness of agency registration programs, they are required
    by their election officials to account for the number of
  registration applications that are received from the various
                         agency offices.

  Conclusions and recommendations. To improve monitoring, data
collection, recordkeeping and reporting, NCD makes the following
  recommendations. First, every state vocational rehabilitation
  agency that has computerized or is planning to computerize its
 case management system should include implementation of NVRA as
   a core component in the system, including an automatic case
  "reject" element if applicants for vocational rehabilitation
 services have not been offered voter registration assistance as
                      of a specified time.

  Second, whether or not the state adopts a computerized system,
states should include the data elements in their reports used by
                Pennsylvania and South Carolina.

  Third, vocational rehabilitation agencies that adopt a single
    integrated application form for vocational rehabilitation
    services should include the voter registration form as a
   perforated or pressure-sensitive part of the agency's form.

Fourth, vocational rehabilitation agencies should report data to
  state election officials by using site codes to enable state
  election officials and stakeholders to ascertain the extent to
      which each agency serving persons with disabilities is
                        implementing NVRA.

    Fifth, to monitor the effectiveness of agency registration
  programs, election officials should be required to account for
  the number of registration applications that are received from
                   the various agency offices.

        APPOINTING COORDINATORS TO OVERSEE IMPLEMENTATION

Background. According to FEC, research suggests that a principal
  component of a successful agency voter registration program is
  appointing a coordinator in each agency office to be in charge
  of, responsible for, and enthusiastic about voter registration
  activities, i ncluding ensuring an adequate supply of forms,
      monitoring voter registration activities, training new
  employees, and resolving questions and problems that arise in
coordination with state or local election officials. Such a task
  need not be full time, but it must be ongoing. (FEC Guide at
                            page 4-9)

      Findings. All the states surveyed designated statewide
  coordinators to be responsible for implementing NVRA. Many of
   the states appointed coordinators at district offices to be
  responsible for NVRA implementation. In Pennsylvania, specific
    responsibilities of coor dinators at district offices are
  specified in manuals (e.g., maintaining an adequate supply of
   applications, recordkeeping and reporting, monitoring voter
    registration activities, training new employees, resolving
  questions and problems). The manual also describes counselors'
  responsibilities (do's and don'ts) and the responsibilities of
 district offices. In New York there is a program coordinator at
        each district office and 33 private agency sites.

Conclusions and recommendations. NCD recommends that every state
      designate a coordinator within the state office who is
   responsible for monitoring implementation of NVRA. NCD also
  recommends that the specific responsibilities be described and
  documented so that expectations are clear. When coordinators
    leave their jobs, replacements can refer to documents to
              understand the job responsibilities.

   Similarly, in states that have district offices and private
 agency sites, a coordinator should be designated as responsible
        for implementation of NVRA, and the coordinator's
        responsibilities should be specified in writing.

                            TRAINING

     Background. According to FEC, in addition to appointing
   coordinators to be in charge of implementing NVRA, a second
  component to a successful agency registration program is the
   adequate training of all agency employees involved in voter
 registration. [FEC Guide at page 4-9] Training includes helping
  employees know how to ensure that voter registration forms are
    completed and signed correctly, how to offer and provide
  assistance to registrants, how to transmit applications to the
  state official responsible for voter registration, and how to
    complete periodic reports. FEC also explains that after an
  initial training of all current employees, the training of new
    employees can be the responsibility of the agency person
appointed to be in charge of the program. [FEC Guide at page 4-9]

   Findings. It appears that initial training occurred in most
  states immediately before or after the law went into effect or
after a court decree was handed down or settlement reached. Some
states, such as California, have comprehensive training manuals.
In New York, comprehensive training is provided at least twice a
  year by the state official responsible for voter registration.
  Other states appear to have few if any training materials, and
  it is difficult to ascertain the extent to which training is
ongoing. One state reported "no ongoing training and no specific
                      training materials."

Conclusions and recommendations. The extent to which training is
  occurring on an ongoing basis for new employees in most states
  is uncertain. NCD recommends that state policies be amended to
  require that new employees receive training either from agency
      staff or from the state agency responsible for voter
 registration. In addition, NCD recommends that current staff be
            required to undergo periodic retraining.

                        INCENTIVE SYSTEM

       Background. In addition to using "sticks" to ensure
  implementation of NVRA, good management practice includes the
                        use of "carrots."

Findings. Only one state, Pennsylvania, has adopted an incentive
  program under which voter registration agency offices earn a
  Voter Registration Certificate of Achievement Award. The award
is called the "Secretary of the Commonwealth's Outstanding Voter
                   Registration Agency Award."

    The award is given in three categories: Gold, Silver, and
  Bronze. The state has adopted criteria for making awards, of
  which the most significant is the number of people the agency
  assisted in registering to vote by completing the form in the
 agency's office. Gold is awarded for 75 percent or more, Silver
      for 50 to 74 percent and Bronze for 25 to 49 percent.

   Conclusions and recommendations. NCD recommends that states
 implement creative approaches that reward employees who embrace
their responsibilities under NVRA, such as the incentive program
 described above. Pennsylvania's model of public recognition and
  award for agency performance is one approach that both rewards
and gives visibility to NVRA implementation effort. In addition,
  evaluations of employees' performance in providing vocational
     rehabilitation services should also evaluate employees'
                     implementation of NVRA.


                            CONCLUSION

  Registering people with disabilities to vote, in a simple and
   convenient manner, is of critical importance to ensure full
       participation in our democracy. By increasing voter
      registration, state employees will empower people with
  disabilities as full citizens to exercise their right to vote.
 The purpose of the National Voter Registration Act (NVRA) is to
                      help reach this goal.

    This report examines the implementation of NVRA by state
   vocational rehabilitation agencies and includes a number of
   specific recommendations for improving aspects of the Act's
                implementation by these agencies.

Although this report is limited to a review of implementation by
  state vocational rehabilitation agencies, the recommendations
 will also be helpful in improving implementation by other state
      and local agencies serving people with disabilities.


                            APPENDIX

          MISSION OF THE NATIONAL COUNCIL ON DISABILITY

                      Overview and Purpose

  NCD is an independent federal agency with 15 members appointed
 by the President of the United States and confirmed by the U.S.
                             Senate.

  The overall purpose of NCD is to promote policies, programs,
  practices, and procedures that guarantee equal opportunity for
  all individuals with disabilities, regardless of the nature or
   severity of the disability; and to empower individuals with
  disabilities to achieve economic self-sufficiency, independent
    living, and inclusion and integration into all aspects of
                            society.

                         Specific Duties

  The current statutory mandate of NCD includes the following:

  * Reviewing and evaluating, on a continuing basis, policies,
    programs, practices, and procedures concerning individuals
        with disabilities conducted or assisted by federal
   departments and agencies, including programs established or
    assisted under the Rehabilitation Act of 1973, as amended,
   or under the Developmental Disabilities Assistance and Bill
      of Rights Act; as well as all statutes and regulations
   pertaining to federal programs that assist such individuals
    with disabilities, in order to assess the effectiveness of
    such policies, programs, practices, procedures, statutes,
    and regulations in meeting the needs of individuals with
                          disabilities.

    * Reviewing and evaluating, on a continuing basis, new and
  emerging disability policy issues affecting individuals with
   disabilities at the federal, state, and local levels and in
   the private sector, including the need for and coordination
    of adult services, access to personal assistance services,
     school reform efforts and the impact of such efforts on
    individuals with disabilities, access to health care, and
    policies that act as disincentives for individuals to seek
                      and retain employment.

    * Making recommendations to the President, Congress, the
      secretary of education, the director of the National
    Institute on Disability and Rehabilitation Research, and
    other officials of federal agencies about ways to better
      promote equal opportunity, economic self-sufficiency,
    independent living, and inclusion and integration into all
       aspects of society for Americans with disabilities.

    * Providing Congress, on a continuing basis, with advice,
    recommendations, legislative proposals, and any additional
       information that NCD or Congress deems appropriate.

        * Gathering information about the implementation,
  effectiveness, and impact of the Americans with Disabilities
              Act of 1990 (42 U.S.C. 12101 et seq.).

   * Advising the President, Congress, the commissioner of the
      Rehabilitation Services Administration, the assistant
   secretary for Special Education and Rehabilitative Services
   within the Department of Education, and the director of the
  National Institute on Disability and Rehabilitation Research
    on the development of the programs to be carried out under
           the Rehabilitation Act of 1973, as amended.

    * Providing advice to the commissioner with respect to the
       policies and conduct of the Rehabilitation Services
                         Administration.

    * Making recommendations to the director of the National
   Institute on Disability and Rehabilitation Research on ways
      to improve research; service; administration, and the
    collection, dissemination, and implementation of research
          findings affecting persons with disabilities.

  * Providing advice regarding priorities for the activities of
       the Interagency Disability Coordinating Council and
        reviewing the recommendations of this council for
    legislative and administrative changes to ensure that such
      recommendations are consistent with NCD's purpose of
        promoting the full integration, independence, and
          productivity of individuals with disabilities.

   * Preparing and submitting to the President and Congress an
   annual report titled National Disability Policy: A Progress
                            Report.

                          International

In 1995, NCD was designated by the Department of State to be the
 U.S. government's official contact point for disability issues.
  Specifically, NCD interacts with the special rapporteur of the
  United Nations Commission for Social Development on disability
                            matters.

             Consumers Served and Current Activities

  While many government agencies deal with issues and programs
   affecting people with disabilities, NCD is the only federal
      agency charged with addressing, analyzing, and making
  recommendations on issues of public policy that affect people
 with disabilities regardless of age, disability type, perceived
    employment potential, economic need, specific functional
 ability, status as a veteran, or other individual circumstance.
 NCD recognizes its unique opportunity to facilitate independent
 living, community integration, and employment opportunities for
people with disabilities by ensuring an informed and coordinated
approach to addressing the concerns of persons with disabilities
    and eliminating barriers to their active participation in
                    community and family life.

    NCD plays a major role in developing disability policy in
    America. In fact, it was NCD that originally proposed what
  eventually became the Americans with Disabilities Act (ADA).
  NCD's present list of key issues includes improving personal
  assistance services, promoting health care reform, including
  students with disabilities in high-quality programs in typical
  neighborhood schools, promoting equal employment and community
  housing opportunities, monitoring the implementation of ADA,
  improving assistive technology, and ensuring that persons with
      disabilities who are members of minority groups fully
                     participate in society.

                        Statutory History

    NCD was initially established in 1978 as an advisory board
   within the Department of Education (Public Law 95-602). The
    Rehabilitation Act Amendments of 1984 (Public Law 98-221)
           transformed NCD into an independent agency.

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