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entitled 'Bilingual Voting Assistance: Selected Jurisdictions' 
Strategies for Identifying Needs and Providing Assistance' which was 
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Report to Congressional Committees: 

United States Government Accountability Office: 

GAO: 

January 2008: 

Bilingual Voting Assistance: 

Selected Jurisdictions' Strategies for Identifying Needs and Providing 
Assistance: 

Bilingual Voting Assistance: 

GAO-08-182: 

GAO Highlights: 

Highlights of GAO-08-182, a report to congressional committees. 

Why GAO Did This Study: 

The Voting Rights Act of 1965, as amended, contains, among other 
things, provisions designed to protect the voting rights of U.S. 
citizens of certain ethnic groups whose command of the English language 
may be limited. The Department of Justice (DOJ) enforces these 
provisions, and the Election Assistance Commission (EAC) serves as a 
national clearinghouse for election information and procedures. The 
Fannie Lou Hamer, Rosa Parks, and Coretta Scott King Voting Rights Act 
Reauthorization and Amendments Act of 2006 mandated that GAO study the 
implementation of bilingual voting under Section 203 of the act. This 
report discusses (1) the ways that selected jurisdictions covered under 
Section 203 of the Voting Rights Act have provided bilingual voting 
assistance as of the November 2006 general election and any subsequent 
elections through June 2007, and the challenges they reportedly faced 
in providing such assistance; and (2) the perceived usefulness of this 
bilingual voting assistance, and the extent to which the selected 
jurisdictions evaluated the usefulness of such assistance to language 
minority voters. To obtain details about this voting assistance, GAO 
obtained information from election officials in 14 of the 296 
jurisdictions required to provide it, as well as from community 
representatives in 11 of these jurisdictions. These jurisdictions were 
selected to reflect a range of characteristics such as geographic 
diversity and varying language minority groups. 

What GAO Found: 

All but 1 of the 14 election jurisdictions GAO contacted reported 
providing some form of oral or written bilingual voting assistance 
through such things as the use of bilingual poll workers, and each of 
the 14 jurisdictions reported challenges in providing assistance. 
Election offices reported providing similar types of oral and written 
bilingual voting assistance at each stage of the voting process—from 
voter registration to Election Day—for the November 2006 and subsequent 
elections. In nine of the jurisdictions, this bilingual assistance was 
supplemented by efforts of community-based organizations. In part 
because DOJ guidance intentionally provides jurisdictions flexibility 
in how they implement bilingual voting requirements, election offices 
used varied strategies to implement bilingual programs. Election 
officials in each of the 14 jurisdictions reported challenges in 
implementing bilingual assistance programs, including difficulty in 
recruiting bilingual poll workers and effectively targeting where to 
provide bilingual voting assistance. Officials in nine jurisdictions 
also noted they would benefit from additional guidance for providing 
bilingual assistance. The EAC has taken steps to provide additional 
guidance to jurisdictions, including plans to develop a set of 
management guidelines for jurisdictions to use in implementing their 
programs. 

GAO identified little quantitative data measuring the usefulness of 
various types of bilingual voting assistance. Election officials and 
community-based organization representatives noted that certain forms 
of assistance, such as having bilingual poll workers, were more useful 
than others. Some jurisdictions stated that modifications, including 
outreach to language minority groups, would improve the usefulness of 
bilingual assistance. While none of the 14 jurisdictions had attempted 
to formally evaluate their assistance, most reported gathering 
information about the usefulness of certain aspects of the assistance. 
While formal evaluations have proven to be a successful means to 
improve program effectiveness, conducting formal evaluations of the 
usefulness and effect of bilingual voting assistance is difficult. Key 
difficulties include identifying the appropriate indicators of success 
and isolating the effects of bilingual assistance efforts on voters 
from other influences on election processes. We provided a draft of 
this report to DOJ and the EAC for comment. DOJ provided no comments, 
and the EAC’s comments described its recent activities on bilingual 
voting assistance. 

Figure: Examples of Bilingual Assistance: Polling Place Signage and 
Poll Worker Name Tag: 

This figure is a photo of two samples of bilingual assistance. One is a 
sign for a polling place, and the other is an example of a name tag 
that a bilingual worker wears. 

[See PDF for image] 

Source: ELection officials. 

[End of figure] 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.GAO-08-182]. For more information, contact 
William O. Jenkins, Jr. at (202) 512-8777 or jenkinswo@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Election Officials in All But One Jurisdiction Reported Providing 
Bilingual Voting Assistance, but Experienced Challenges: 

Some Forms of Bilingual Voting Assistance Were Perceived as More Useful 
than Others, but Formally Evaluating Its Usefulness Presented Many 
Challenges: 

Concluding Observations: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Section 203 Coverage Criteria Regarding Language Minority 
Groups and Covered Jurisdictions: 

Appendix III: DOJ Actions under Section 203 of the Voting Rights Act, 
1980-2007: 

Appendix IV: Examples of Bilingual Voting Written Assistance Materials: 

Appendix V: Additional Challenges to Evaluating the Usefulness of 
Bilingual Voting Assistance: 

Appendix VI: Comments from the U.S. Election Assistance Commission: 

Appendix VII: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Stages of the Election Process: 

Table 2: Types of Bilingual Voting Assistance Reportedly Provided by 
Election Offices, by Stage in the Election Process: 

Table 3: Examples of Bilingual Voter Registration Assistance Reportedly 
Provided by Election Offices: 

Table 4: Examples of Bilingual Absentee and Early Voting Assistance 
Reportedly Provided by Election Offices: 

Table 5: Examples of Bilingual Election Day Assistance Reportedly 
Provided by Election Offices: 

Table 6: Examples of Bilingual Assistance Reportedly Provided by CBOs: 

Table 7: Most Useful Types of Bilingual Voting Assistance, as Reported 
by Election Officials and CBO Representatives: 

Table 8: Suggestions on How Election Offices Can Improve the Usefulness 
of Bilingual Voting Assistance, according to Election Officials and CBO 
Representatives: 

Table 9: Jurisdictions Selected for GAO Site Visits and the Related 
Information Used to Make the Selections: 

Table 10: Jurisdictions Covered under Section 203 of the Voting Rights 
Act: 

Figures: 

Figure 1: Section 203 Coverage Criteria for Implementation of the 
Voting Rights Act Provisions Regarding Language Minority Groups: 

Figure 2: Excerpt of a Chinese Voter Registration Form - King County, 
Wash. 

Figure 3: English/Chinese Bilingual Absentee Ballot Request Form - King 
County, Wash. 

Figure 4: English/Vietnamese Bilingual Sample Ballot - Boston, Mass. 

Figure 5: English/Spanish Bilingual Official Ballot - Boston, Mass. 

Figure 6: Spanish Voting Instructions - Los Angeles, Calif. 

Figure 7: Bilingual Polling Place Signs - King County, Wash. 

Figure 8: Bilingual Poll Worker Nametags and Buttons - Orange County, 
Calif. 

Figure 9: Multilingual Tally Card - Los Angeles, Calif. 

Abbreviations: 

CBO: community-based organization: 

DOJ: U.S. Department of Justice: 

EAC: U.S. Election Assistance Commission: 

HAVA: Help America Vote Act of 2002: 

United States Government Accountability Office: 

Washington, DC 20548: 

January 18, 2008: 

Congressional Committees: 

The right to vote has been called one of the most fundamental rights in 
our democratic system of government because its effective exercise is 
preservative of all others. The Voting Rights Act of 1965, as amended, 
(Voting Rights Act) addressed the problem of denial of access to the 
right to vote by, among other things, outlawing specified practices and 
procedures such as literacy tests. In 1975, the Voting Rights Act was 
amended to include section 203, which requires certain 
jurisdictions[Footnote 1] to provide bilingual election materials and 
assistance to protect the voting rights of U.S. citizens of certain 
ethnic groups whose command of the English language may be limited. 
These provisions were initially set to expire in 1985 but have been 
extended several times. Debate about whether to require bilingual 
voting assistance includes advocates of bilingual voting assistance who 
assert that it allows language minority voters to more fully 
participate in our nation's electoral process, while critics contend 
that the costs incurred in providing such assistance are not warranted 
because the assistance is not being used by language minority voters. 

Enacted on July 27, 2006, the Fannie Lou Hamer, Rosa Parks, and Coretta 
Scott King Voting Rights Act Reauthorization and Amendments Act of 2006 
extended the bilingual provisions until 2032, and required GAO to study 
the implementation, effectiveness, and efficiency of current bilingual 
voting requirements under Section 203 of the Voting Rights 
Act.[Footnote 2] As discussed with your offices, this report does not 
address the efficiency of providing bilingual voting assistance because 
of the lack of cost data for providing such assistance. As noted in a 
March 2006 report, professors at Arizona State University surveyed 
jurisdictions covered by Section 203 and reported that a majority of 
the responding jurisdictions were unable to provide the costs of their 
bilingual assistance.[Footnote 3] Given this recent survey of 
jurisdictions, we focused on obtaining more detailed information about 
bilingual voting assistance from selected jurisdictions across the 
country. Our objectives were to determine: 

* the ways that selected jurisdictions covered under Section 203 of the 
Voting Rights Act have provided bilingual voting assistance as of the 
November 2006 general election and any subsequent elections through 
June 2007, and the challenges they reportedly faced in providing such 
assistance; and: 

* the perceived usefulness of this bilingual voting assistance, and the 
extent to which the selected jurisdictions evaluated the usefulness of 
such assistance to language minority voters. 

To meet our objectives, we visited or collected information from 14 
jurisdictions required to provide bilingual voting assistance under 
Section 203 of the Voting Rights Act (covered jurisdictions) in 12 
states. We considered surveying all of the 296 covered jurisdictions 
but decided against doing so for several reasons, including the March 
2006 report cited above on the results of a survey of these same 
jurisdictions about similar issues. (For a more detailed discussion of 
these considerations as well as a comprehensive description of our 
methodology, see app. I.) We chose the 14 jurisdictions because they 
reflected a variety of characteristics, such as size (i.e., voting age 
population), geographic diversity, and varying language minority 
groups. We wanted a diverse group of sites to allow us to report on a 
wide range of jurisdictions' experiences with providing bilingual 
voting assistance. We also obtained information from representatives of 
38 community-based organizations (CBO) in 11 of the 14 
jurisdictions.[Footnote 4] We either conducted on-site interviews with 
or obtained information from election officials, CBO representatives, 
and, to a limited extent, language minority voters in the 14 
jurisdictions regarding the bilingual voting assistance provided during 
the November 2006 general election and any subsequent elections through 
June 2007. In addition, we obtained and reviewed supporting 
documentation as evidence of the types of bilingual voting assistance 
(e.g., sample ballots, pamphlets, voter education materials, etc.) 
reportedly provided to language minority voters in these jurisdictions. 
We also obtained these election officials' and CBO representatives' 
perceptions about the usefulness of bilingual voting assistance to 
language minority voters as well as information on any efforts to 
evaluate its usefulness. Because we selected a nongeneralizable sample 
of election jurisdictions, the experiences and views discussed in this 
report cannot be generalized to all 296 jurisdictions required to 
provide bilingual voting assistance under Section 203 of the Voting 
Rights Act.[Footnote 5] 

In addition to the information we obtained from these jurisdictions, we 
conducted interviews with and obtained information from other sources. 
We interviewed officials and obtained pertinent documents from the U.S. 
Department of Justice (DOJ) Civil Rights Division, which is responsible 
for providing program guidance and enforcing compliance with the 
requirements under Section 203 of the Voting Rights Act. We also 
interviewed officials from the U. S. Election Assistance Commission 
(EAC), which was established by the Help America Vote Act of 2002 
(HAVA) to serve, among other things, as a clearinghouse and information 
resource for election officials with respect to the administration of 
federal elections. Additionally, we interviewed the Chief of the Census 
Bureau office that determines which jurisdictions are covered under 
Section 203 of the Voting Rights Act. We reviewed pertinent federal 
laws, regulations, and agency guidance pertaining to the Section 203 
bilingual voting provisions. We also reviewed prior GAO work,[Footnote 
6] other national studies, reports and news articles, attended several 
national conferences, and interviewed the secretary of state for one 
state with jurisdictions covered by Section 203 to gain further insight 
regarding these issues. We conducted this performance audit from 
October 2006 to January 2008 in accordance with generally accepted 
government auditing standards. Those standards require that we plan and 
perform the audit to obtain sufficient, appropriate evidence to provide 
a reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained provides a reasonable 
basis for our findings and conclusions based on our audit objectives. 

Results in Brief: 

All but 1 of the 14 election jurisdictions we contacted reported 
providing some form of oral or written bilingual voting assistance 
through such things as the use of bilingual poll workers and written 
translations of voting materials, and each of the 14 jurisdictions 
reported challenges in providing assistance. Election offices in most 
contacted jurisdictions reported providing similar types of oral and 
written bilingual voting assistance at each stage of the voting 
process--from voter registration to Election Day--for the November 2006 
and subsequent elections. In nine of the contacted jurisdictions, the 
bilingual voting assistance reportedly provided by the election offices 
was also supplemented by the voluntary efforts of community-based 
organizations. In part because DOJ guidance intentionally provides 
jurisdictions some flexibility in how they implement bilingual voting 
requirements, election offices reported using varied strategies to 
recruit bilingual poll workers, determine where to target bilingual 
voting assistance programs, and conduct outreach to the language 
minority community. Election officials in each of the 14 jurisdictions 
reported experiencing a variety of challenges in implementing bilingual 
assistance programs, but some key challenges were prevalent among most 
election offices contacted. For example, the majority of these election 
offices reported experiencing difficulty in recruiting bilingual poll 
workers, effectively targeting where to provide bilingual voting 
assistance, and designing and translating the bilingual assistance 
materials provided. Election officials in 11 jurisdictions also cited 
not allocating sufficient resources to their bilingual program as a 
challenge to providing more effective bilingual voting assistance. 
Officials in nine jurisdictions also told us that they would benefit 
from additional guidance or information on best practices for 
implementing bilingual assistance programs. The EAC has taken recent 
steps to provide additional guidance and information to jurisdictions 
on providing bilingual assistance, including plans to develop a set of 
management guidelines for jurisdictions to use in implementing their 
programs. 

Although we identified little data measuring the usefulness of various 
types of bilingual voting assistance, election officials in eight 
jurisdictions and community-based organization representatives in seven 
jurisdictions we contacted told us that they believed certain forms of 
assistance were more useful than others. While none of the 
jurisdictions reported conducting formal evaluations of the 
effectiveness of their bilingual assistance programs, the majority 
reported using various informal means to get information about the 
effectiveness of certain aspects of their bilingual voting assistance 
programs. Both election officials and CBO representatives generally 
agreed that having bilingual poll workers available on Election Day was 
a key form of assistance to voters. Election officials in four 
jurisdictions and community-based organization representatives in six 
jurisdictions believed that having translated written materials was 
also a key form of assistance. However, election officials in 10 
jurisdictions and community-based organization representatives in 9 
jurisdictions stated that modifications could be made that would 
improve the usefulness of the bilingual services provided to voters. 
For example, election officials in four jurisdictions and community- 
based organization representatives in nine jurisdictions stated that 
election offices' efforts to conduct additional outreach to individual 
voters and language minority groups would be key to improving the 
usefulness of the bilingual assistance provided to voters. Election 
officials in 12 of the jurisdictions as well as community-based 
organization representatives in 3 of the jurisdictions we included in 
our study reported gathering information about the usefulness of 
certain aspects of the bilingual voting assistance provided by the 
election offices. For example, election officials in four jurisdictions 
reported they had conducted post-election surveys of or obtained 
comments from poll workers to determine the number of voters who had 
used bilingual assistance at the polls or obtain voter feedback. While 
the use of formal program evaluation tools has proven to be a 
successful means for federal agencies to improve program effectiveness, 
accountability, and service delivery, conducting formal evaluations of 
the usefulness and effect of bilingual voting assistance is difficult. 
Three key difficulties include identifying the objectives and the 
appropriate indicators of success, determining how to measure these 
indicators once they have been identified, and isolating the effects of 
bilingual voter assistance efforts on language minority voters from 
more general voter outreach efforts or other influences on election 
processes. 

We provided a draft of this report to DOJ and the EAC for review and 
comment. DOJ did not provide comments on the draft of this report but 
did provide technical edits, which we incorporated where appropriate. 
EAC provided written comments that described its recent activities 
related to bilingual voting assistance. 

Background: 

Bilingual Voting Requirements and Covered Jurisdictions: 

The Voting Rights Act[Footnote 7] was intended, among other things, to 
protect the voting rights of U.S. citizens of certain ethnic groups 
whose command of the English language may be limited. Language minority 
provisions contained in Section 203 require covered states and covered 
jurisdictions--political subdivisions--that meet the act's coverage 
criteria to provide written materials and other assistance, in the 
language of certain "language minority groups," in addition to 
English.[Footnote 8] Section 203 defines these language minorities as 
persons who are of Alaskan Native, American Indian, Asian American, or 
Spanish heritage. (See app. II for the specific criteria for 
determining which jurisdictions are to be covered under Section 203 and 
a list of the covered jurisdictions.) 

Where the applicable language minority groups have a commonly used 
written language, Section 203 requires covered jurisdictions to provide 
written election materials in the languages of the groups. Where the 
language of the applicable minority group is oral or unwritten, or in 
the case of American Indian and Alaskan Native languages if the 
predominant language is historically unwritten, only oral information 
and assistance is required. With respect to all covered jurisdictions, 
DOJ guidance provides that oral assistance and publicity (e.g., public 
information advertisements on the radio) should be provided to the 
extent needed to enable members of the applicable language minority 
group to participate effectively in the electoral process. Section 203 
requirements apply to the entire election process--from voter 
registration through Election Day--for all federal, state, and local 
elections in the covered jurisdictions. 

The DOJ Civil Rights Division is to enforce the covered states and 
jurisdictions' compliance with the Section 203 bilingual language 
requirements. Where covered states and jurisdictions fail to comply 
with the provisions, DOJ may bring a civil action to enforce compliance 
with the bilingual language provisions. DOJ may also choose to enter 
into a settlement agreement, memorandum of agreement, or consent decree 
with a jurisdiction to ensure compliance. These agreements, which may 
vary from jurisdiction to jurisdiction, outline the steps necessary to 
comply with the language provisions and may cover issues such as the 
number of bilingual poll workers needed or the materials to be 
translated. (See app. III for a list of jurisdictions that have been 
subject to DOJ actions related to Section 203 since 1980.) 

DOJ has published general guidance for election officials on how to 
comply with Section 203 in the Code of Federal Regulations[Footnote 9] 
and on its Web site. This guidance provides broad information about a 
number of topics, including determining the exact language covered 
within the Alaskan Native, American Indian, Asian American, or Spanish 
heritage language groups and the activities affected by the language 
provisions. For example, according to DOJ, jurisdictions should take 
all reasonable steps to allow members of applicable language minority 
groups to be effectively informed and participate effectively in the 
electoral process, but may also exercise some discretion as to where 
they focus their efforts. DOJ guidance notes that a jurisdiction need 
not, for example, provide bilingual assistance to all of its eligible 
voters if it effectively targets its bilingual program to those in 
actual need of assistance. In addition, DOJ guidance advises that 
compliance is more likely to be achieved when jurisdictions work with 
local language minority groups to determine the best methods to inform 
the language minority community about available assistance. 
Additionally, DOJ instructs that when evaluating whether a jurisdiction 
has provided a level of oral assistance needed to enable applicable 
language minority groups to participate effectively in the electoral 
process, DOJ will consider the number of bilingual poll workers 
utilized. It also stresses the importance of accurately translated 
materials. Furthermore, the DOJ Civil Rights Division states that its 
guidance cannot be prescriptive because election systems and the 
circumstances of language minority communities vary widely across the 
United States. Instead, DOJ provides guiding principles and practical 
suggestions to election officials. 

Apart from DOJ's compliance guidelines, election jurisdictions, 
including those covered by Section 203, may also receive information 
from the EAC designed to assist election officials in meeting the needs 
of limited-English proficient voters. The Help America Vote Act of 2002 
(HAVA) established the EAC to assist in the administration of federal 
elections and to otherwise provide assistance with the administration 
of certain federal election laws and programs, to establish minimum 
election administration standards for states and units of local 
government with responsibility for the administration of federal 
elections, and for other purposes. Section 202 of HAVA, in general, 
directs the EAC to serve as a national clearinghouse and resource for 
the compilation of information and review of procedures with respect to 
the administration of federal elections. In addition, Section 801 of 
HAVA transferred to the EAC all clearinghouse functions that the Office 
of Election Administration--established within the Federal Election 
Commission--exercised before the enactment of HAVA. These 
responsibilities included providing recommendations and tools so that 
election officials could provide materials in alternate languages for 
limited English proficiency voters. Furthermore, HAVA requires the EAC 
to conduct periodic studies, as the EAC may determine, to include: (1) 
methods of ensuring the accessibility of voting, registration, polling 
places, and voting equipment to all voters, including individuals with 
disabilities (including the blind and visually impaired), Native 
American or Alaska Native citizens, and voters with limited proficiency 
in the English language, and (2) the technical feasibility of providing 
voting materials in eight or more languages for voters who speak those 
languages and who have limited English proficiency. 

The U.S. Election System: 

The U.S. election system is highly decentralized, with primary 
responsibility for managing, planning, and conducting elections 
residing at the local jurisdiction level. As we reported in June 2006, 
there are about 10,500 local government jurisdictions responsible for 
conducting statewide and federal elections nationwide.[Footnote 10] Of 
these jurisdictions, only 296 are covered by Section 203.[Footnote 11] 
States can be divided into two groups according to how they delegate 
election responsibilities to local jurisdictions: 

* Most states delegate statewide and federal election responsibilities 
primarily to counties, with a few of these states delegating these 
responsibilities to some cities. One state, Alaska, is divided into 
four election regions comprised of boroughs, municipalities, and other 
census areas known by the U.S. Census Bureau as county equivalents. 
State personnel in these regions are responsible for conducting 
statewide and federal elections. This first group of states contains 
about one-fourth of the local election jurisdictions nationwide. 

* The remaining states delegate these election responsibilities to 
subcounty governmental units know by the U.S. Census Bureau as minor 
civil divisions. These include entities such as cities, towns, 
villages, and townships. This second group of states contains about 
three-fourths of the local election jurisdictions nationwide. 

Nearly all of the 296 jurisdictions covered under Section 203 are 
counties, but they also include county equivalents in some states and 
minor civil divisions. In addition to all elections conducted by these 
jurisdictions, the provisions of Section 203 also apply to the local 
elections conducted by sub-jurisdictions, such as cities, towns, school 
districts and other special purpose districts, contained within these 
listed jurisdictions. 

Local election jurisdictions vary widely in size and complexity, 
ranging from small New England townships to Los Angeles County, Calif., 
whose number of registered voters exceeds that of many states. Our 
election system is based upon a complex interaction of people (voters, 
election officials, and poll workers), processes (controls), and 
technology that must work effectively together to achieve a successful 
election. Every stage of the election process--registration, absentee 
and early voting, preparing for and conducting Election Day activities, 
and provisional[Footnote 12] voting--is affected by the interface of 
people, processes, and technology. (See table 1 for a discussion of the 
stages of the election process.) 

Table 1: Stages of the Election Process: 

Stage of the election process: Voter registration; 
Description and key elements: While voter registration is not a federal 
requirement, the District of Columbia and all states, except North 
Dakota, generally require citizens to register before voting. The 
deadline and requirements for registering vary, but at a minimum, state 
eligibility provisions typically require a person to be a U.S. citizen, 
at least 18 years of age, and a resident of the state, with some states 
requiring a minimum residency period. Citizens apply to register to 
vote in various ways, such as at motor vehicle agencies and public 
assistance and disability services offices, during voter registration 
drives, by mail, or at local voter registrar offices. Election 
officials process registration applications and compile and maintain 
the list of registered voters that is to be used throughout the 
administration of an election. 

Stage of the election process: Absentee and early voting; 
Description and key elements: All states and the District of Columbia 
have provisions allowing voters to cast their ballot before Election 
Day by voting absentee--with variations on who may vote absentee, 
whether the voter needs an excuse, and the time frames for applying for 
and submitting absentee ballots. In addition, some states also allow 
early voting, in which the voter goes to a specific location to vote in 
person prior to Election Day. As with absentee voting, the specific 
circumstances for early voting--such as the dates, times, and 
locations--are based on the state and local requirements. 

Stage of the election process: Conducting elections; 
Description and key elements: Election officials perform a broad range 
of activities in preparation for and on Election Day itself. Prior to 
an election, officials recruit and train poll workers to have the 
skills needed to perform their Election Day duties. Where needed and 
required, election officials must also recruit poll workers who speak 
languages other than English. Election officials also locate and 
reserve polling places, prepare ballots and seek to educate voters on 
topics such as what the ballot looks like, how to use a voting machine, 
and the location of their particular polling place. These outreach 
efforts may be conducted by attending CBO meetings or events, 
informational mailings to voters, or advertisements in the local media. 
Finally, election officials seek to ensure that voting equipment, 
ballots, and supplies are delivered to polling places; On Election Day, 
poll workers set up and open the polling places. This can include tasks 
such as setting up the voting machines or voting booths, readying 
supplies, testing equipment, posting required signs and voter education 
information, and completing paperwork. Before a voter receives a ballot 
or is directed to a voting machine, poll workers typically are to 
verify his or her eligibility. In some cases, poll workers may provide 
language assistance to language minority voters. 

Stage of the election process: Provisional voting; 
Description and key elements: Most states are required to permit 
individuals, under certain circumstances, to cast a provisional ballot 
in federal elections.[A] While states may choose to allow provisional 
ballots under other circumstances, HAVA requires that an individual be 
permitted to cast a provisional ballot upon the execution of a written 
affirmation before an election official at the polling place.b The 
written affirmation must state that the individual is registered to 
vote in that jurisdiction and eligible to vote in that election. HAVA 
specifies that either the provisional ballot or the written affirmation 
information be transmitted to an appropriate election official for a 
determination as to whether the individual is eligible to vote under 
state law. If individuals are determined to be eligible voters, their 
provisional ballots are to be counted as votes in accordance with state 
law. 

Source: GAO. 

[A] The United States Election Assistance Commission, 2004 Election Day 
Survey: "How We Voted: People, Ballots, and Polling Places" (Sept. 
2005). 

[B] Under HAVA, states that had either (1) no voter registration 
requirements for voters with respect to federal elections (e.g., North 
Dakota) or (2) polling place registration on Election Day with respect 
to federal elections (as in Idaho, Minnesota, New Hampshire, Wisconsin, 
and Wyoming) in effect on and after August 1, 1994, are not subject to 
HAVA's provisional voting requirements. 

[End of table] 

Prior Work Related to the Elections Process: 

Over the years we have completed a number of reviews related to 
elections. In 1986[Footnote 13] and 1997[Footnote 14] we issued reports 
addressing the types of bilingual assistance provided by covered 
jurisdictions, as well as the cost of this assistance.[Footnote 15] In 
our 1997 report, we found that most jurisdictions reportedly were 
providing both oral and written assistance. We also issued a series of 
reports following the November 2000 general election addressing a range 
of issues that emerged during that election and identifying challenges 
that election officials reported facing throughout the election 
process. In addition, we have issued reports since the November 2004 
general election on voter registration issues and security and 
reliability of electronic voting. In 2006, we reported on a wide array 
of election issues including discussing, at each major stage of the 
election process, changes to election systems since the 2000 election, 
and challenges encountered in the November 2004 general 
election.[Footnote 16] (See related GAO products at the end of this 
report for a list of our prior work.) 

In addition to our work on elections, professors at Arizona State 
University released a comprehensive study in March 2006 regarding 
language minority assistance practices in public elections.[Footnote 
17] Their study, based on survey data obtained from jurisdictions 
currently or previously covered by Section 203, updated the information 
from our 1986 and 1997 reports regarding the costs associated with 
providing language assistance and also discussed the types of 
assistance provided. About half of the surveyed jurisdictions 
responded, and of the respondents, a majority was unable to provide the 
costs of their bilingual assistance programs. Additionally, just over 
80 percent of responding jurisdictions reported providing some type of 
language assistance. 

Election Officials in All But One Jurisdiction Reported Providing 
Bilingual Voting Assistance, but Experienced Challenges: 

Election officials in 13 of the 14 jurisdictions included in our review 
reported providing some type of bilingual voting assistance at each 
stage of the election process but also reported challenges in providing 
this assistance. In part because DOJ's guidance intentionally provides 
jurisdictions some flexibility in how they implement bilingual voting 
requirements and the needs and preferences of language minority 
communities vary from jurisdiction to jurisdiction, election officials 
in these 13 jurisdictions reported using varying strategies to organize 
their bilingual voting assistance program staff and offices, work with 
CBOs, recruit bilingual poll workers, determine where to target their 
bilingual voting assistance programs, and conduct outreach to the 
language minority community. In addition, election officials in these 
13 jurisdictions also reported experiencing a variety of challenges in 
providing bilingual assistance, with the key challenges being: (1) 
recruiting and ensuring quality performance of bilingual poll workers; 
(2) targeting bilingual voting assistance; (3) designing and 
translating bilingual voting assistance materials; and (4) allocating 
sufficient resources to provide bilingual voting assistance. Although 
election officials in 12 jurisdictions reported receiving some degree 
of guidance or assistance for addressing Section 203 requirements from 
DOJ and other sources, officials in 9 jurisdictions reported wanting 
additional guidance or assistance. The EAC has taken recent steps to 
provide additional guidance and information to jurisdictions on 
providing bilingual assistance. 

All But One Jurisdiction Reported Providing Some Type of Bilingual 
Voting Assistance throughout the Election Process: 

Election officials in 13 of the 14 jurisdictions reported providing 
some type of written assistance and/or oral assistance for language 
minority voters.[Footnote 18] This assistance was provided throughout 
the election process--from voter registration to Election Day. Written 
assistance included such things as translated voter registration forms, 
ballots, sample ballots, instructions, and signs. Oral assistance 
included bilingual phone and in-office assistance, translated audio 
instructions and ballots, bilingual poll workers, and bilingual in- 
person outreach activities. The various types of bilingual voting 
assistance and the numbers of jurisdictions that reported providing 
each type of assistance at each stage of the election process are 
summarized in table 2. 

Table 2: Types of Bilingual Voting Assistance Reportedly Provided by 
Election Offices, by Stage in the Election Process: 

Stages of the election process: Voter registration; 
Types of assistance[A]: Written: * Bilingual or translated voter 
registration forms (10)[B]; 
Types of assistance[A]: Oral: * In-person outreach activities (12); 
* Bilingual in-office assistance (10); 
* Bilingual phone assistance (10). 

Stages of the election process: Absentee and early voting; 
Types of assistance[A]: Written: * Bilingual or translated ballots 
(12); 
* Bilingual or translated absentee voter registration forms (8); 
* Translated voting instructions (7); 
* Bilingual signs (5); 
* Translated sample ballots (4); 
Types of assistance[A]: Oral: * Bilingual phone assistance (11); 
* Bilingual in-office assistance (10); 
* In-person outreach activities (10); 
* Translated audio ballots (7); 
* Bilingual in-person early voting assistance (5). 

Stages of the election process: Election Day voting (includes 
provisional voting); 
Types of assistance[A]: Written: * Bilingual or translated ballots 
(12); 
* Translated voting instructions (11); 
* Bilingual signs and buttons (11); 
* Translated sample ballots (10); 
Types of assistance[A]: Oral: * Bilingual poll workers (13); 
* Recorded audio ballots (12) and instructions (11); 
* Bilingual phone assistance (9); * Special interpreters (6) and non-
paid assistants (2). 

Source: GAO analysis of responses from election officials. 

[A] For each of the election offices contacted, there was little 
variation between the types of assistance provided in the 2006 General 
Election and in other subsequent elections. Thus, we did not 
distinguish between the 2006 General Election and other subsequent 
elections in this table. 

[B] The number of jurisdictions where each type of assistance was 
reportedly provided is in parentheses. 

[End of table] 

Voter Registration Assistance Reported by Jurisdictions: 

Election officials in 12 jurisdictions reported providing some type of 
bilingual voter registration assistance and 11 of these jurisdictions 
reported offering both oral and written assistance. All but four 
election offices included in our study reported providing translated 
voter registration forms and all but two reported conducting in-person 
voter registration outreach activities targeted at the language 
minority community. Election offices reported a wide range of venues 
and methods--such as staff participation in community parades and at 
swearing in ceremonies for new citizens--to conduct voter registration 
outreach to the language minority community. In addition to these 
outreach activities, representatives of most election offices also 
reported offering bilingual voter registration assistance to 
individuals who phoned or visited the election office. (See table 3 for 
examples of written and oral bilingual assistance reportedly provided 
to assist language minority community voters with voter registration.) 

Table 3: Examples of Bilingual Voter Registration Assistance Reportedly 
Provided by Election Offices: 

Written assistance: Miami-Dade County, FL, election officials reported 
providing all voter registration applications in English, Spanish, and 
Creole, though they were only required under Section 203 to provide 
written bilingual voting assistance for the Hispanic community. 

Written assistance: The Secretary of State produces the Chinese version 
of the voter registration form for residents of King County, WA.[A] The 
translated form did not ask registrants whether they would prefer to 
receive future election materials in Chinese, but a King County 
elections official reported assuming that registrants who used a 
Chinese registration form would also want a Chinese ballot. 

Written assistance: In Suffolk County, NY, the Board of Elections 
reportedly conducted widespread bilingual information mailings to 
explain the voter registration process to language minority voters 20- 
30 days prior to Election Day. 

Oral assistance: In Harris County, TX, the Tax Assessor's Office, which 
is responsible for voter registration, told us they had two community 
outreach staff that conducted voter outreach to various Hispanic and 
Vietnamese CBOs, attended community events to encourage people to 
register to vote, and selected deputies within the language communities 
to register voters. 

Oral assistance: Election officials in Los Angeles County, CA, reported 
having a multilingual phone line with live bilingual staff 2 weeks 
prior to major elections and a language line translator during non-
election season. 

Oral assistance: In Sandoval County, NM, one election official believed 
the most effective form of bilingual voter registration outreach to 
Native American communities was staff attendance at Native American 
events and visits to individual voters' homes. Sandoval County, NM, 
election officials also reported speaking to Tribal Councils of the 
Pueblos and the Navajo Chapters. 

Source: GAO analysis of responses from election officials. 

[A] An example of Washington State's Chinese voter registration form is 
provided in appendix IV. 

[End of table] 

Bilingual Absentee and Early Voting Assistance Reported by 
Jurisdictions: 

Election officials in 13 of the 14 jurisdictions included in our study 
reported providing some form of bilingual voting assistance for 
absentee and/or early voting.[Footnote 19] The most common type of 
assistance (12 jurisdictions) was bilingual ballots or separate 
translated ballots for absentee or early voters. Other types of 
assistance provided by varying numbers of jurisdictions included 
bilingual or separate translated absentee voter registration forms; 
sample ballots and voting instructions; bilingual phone assistance; 
bilingual in-office assistance; and bilingual poll workers at early 
voting locations. (See table 4 for examples of written and oral 
bilingual assistance reportedly provided to minority language absentee 
and early voters.) 

Table 4: Examples of Bilingual Absentee and Early Voting Assistance 
Reportedly Provided by Election Offices: 

Written assistance: City of Boston election officials reported 
providing English-Spanish bilingual absentee ballots. 

Written assistance: Orange County, CA, election officials reported 
mailing translated sample ballots to language minority absentee voters 
before mailing official paper ballots. Orange County, CA, election 
officials also reported that bilingual voting signs and instructions 
were posted at each early voting site in Spanish, Chinese, Korean, and 
Vietnamese. 

Written assistance: Bilingual absentee ballot request forms in King 
County, WA, allowed registrants to indicate if they would like to 
receive future election materials in Chinese.[A] This feature allowed 
election officials to identify voters desiring bilingual voting 
assistance. 

Oral assistance: Los Angeles County, CA, election officials reported 
having bilingual poll workers at 17 touch screen early voting sites 
with voting systems in 7 languages (including English). 

Oral assistance: A Jackson County, SD, election official reported 
offering Lakota[B] audio assistance on electronic voting machines 2-3 
weeks before the November 2006 General Election. 

Oral assistance: City of Boston election officials reported offering 
language minority voters bilingual absentee voting assistance if they 
called the Boston Election Department's telephone line or walked into 
the office. These officials also reported working with staff in elderly 
housing communities to help them provide assistance to elderly voters 
who were disabled, ill, or otherwise not able to vote on Election Day. 

Source: GAO analysis of responses from election officials. 

[A] A copy of King County's bilingual absentee ballot request form is 
provided in appendix IV. 

[B] Election officials we met with in South Dakota stated that Lakota 
was not historically a written language. However, two community leaders 
we met with noted that written Lakota was being taught in at least some 
schools. 

[End of table] 

Election Day Assistance Reported by Jurisdictions: 

Election officials in 13 of the 14 jurisdictions reported providing 
some type of written and/or oral assistance for language minority 
voters on Election Day. As with absentee and early voting assistance, 
one of the most common types of written assistance reportedly provided 
on Election Day was bilingual ballots or separate translated written 
ballots, which were reportedly provided in 12 of the jurisdictions. The 
most common form of oral bilingual voting assistance reportedly 
provided on Election Day was bilingual poll workers, who were provided 
in 13 jurisdictions. Two jurisdictions reportedly provided audio 
translations for largely unwritten Native American languages. (See 
table 5 for examples of written and oral bilingual assistance 
reportedly provided on Election Day.) 

Table 5: Examples of Bilingual Election Day Assistance Reportedly 
Provided by Election Offices: 

Written assistance: Miami-Dade County, FL, election officials reported 
that all ballots (absentee ballots, paper, and electronic DRE ballots) 
were available in English, Spanish, and Creole, though they were only 
required by Section 203 to provide written assistance for the Hispanic 
community. 

Written assistance: Montgomery County, MD, election officials reported 
that all written Montgomery County, MD, voting materials (including 
bilingual sample ballots posted in the polling place or booth, 
bilingual voting instructions, bilingual posters at the polling 
locations, and bilingual "I voted" buttons) were bilingual Spanish- 
English to prevent anyone from failing to make the Spanish language 
materials accessible. 

Written assistance: King County, WA, election officials reported 
posting bilingual signs in their polling places.[A]. 

Oral assistance: In Orange County, CA, election officials reported that 
poll workers wore a badge stating the language he or she spoke and were 
instructed to actively provide bilingual assistance by approaching 
voters to ask if they need assistance.[B]. 

Oral assistance: Cook County, IL, city election officials reported that 
they had multiple phone lines available on Election Day that language 
minority voters used to obtain oral assistance in multiple languages. 

Oral assistance: A Sandoval County, NM, election official reported 
providing "translation tapes" for minority-language voters to listen to 
before they voted. (In addition to Spanish, Sandoval County, NM, 
election officials reportedly provide bilingual voting assistance for 
speakers of Keresan, Towa, and Navajo--languages that are historically 
unwritten.) 

Source: GAO analysis of responses from election officials. 

[A] Examples of bilingual polling place signs reportedly posted in King 
County, WA, are provided in appendix IV. 

[B] Examples of the badges reportedly worn by bilingual poll workers in 
Orange County, CA, are provided in appendix IV. 

[End of table] 

See appendix IV for examples of bilingual materials reportedly 
available to voters in some of the locations we visited. 

Bilingual Assistance Reported by Community-Based Organizations: 

CBOs reported providing various types of bilingual voting assistance in 
nine of the jurisdictions included in our study. Seven key types of 
assistance that CBOs reported providing were: 

* Informing the language minority community about voting (reportedly 
provided by CBOs in nine jurisdictions); 

* Registering language minority voters (8); 

* Providing assistance to language minority voters on Election Day (7); 

* Helping determine the types of bilingual voting assistance needed and 
which voters need it (7); 

* Informing language minority voters about early and/or absentee voting 
(6); 

* Recruiting and training bilingual poll workers (6); and: 

* Helping translate or design the bilingual or translated ballot (4). 

The bilingual voting assistance provided by CBOs generally took one of 
three forms: supplementing election office efforts, working with 
election offices to provide assistance, or providing assistance that 
otherwise was not provided by the election office. For example, some 
CBO representatives reported providing types of assistance similar to 
those offered by election offices, such as registering language 
minority citizens to vote or answering voters' questions. Other CBO 
representatives reported helping election officials provide assistance, 
such as helping to recruit bilingual poll workers or translating 
official election materials. Finally, some CBO representatives reported 
conducting activities related to bilingual voting assistance that 
election officials did not do, such as employing poll monitors and 
providing language minority voters with transportation to the polls on 
Election Day. Some examples of the specific activities the 38 CBOs 
included in our study reported undertaking as part of their bilingual 
voting assistance efforts are summarized in table 6. 

Table 6: Examples of Bilingual Assistance Reportedly Provided by CBOs: 

Efforts to supplement bilingual voting assistance provided by election 
offices: A CBO serving the Chinese American community in the City of 
Boston, MA, reported holding voter education workshops in local low 
income housing units or community buildings to register people to vote 
and provide information about both the voting process and the bilingual 
assistance available. 

Efforts to supplement bilingual voting assistance provided by election 
offices: A CBO serving the Spanish-speaking community in Montgomery 
County, MD, reported conducting significant media outreach, including 
partnering with a Spanish radio station to promote voter registration 
and hosting press conferences and events to attract Spanish language 
media and all local television and major newspapers' attention to voter 
education. 

Efforts to supplement bilingual voting assistance provided by election 
offices: One Los Angeles County, CA, CBO serving the Asian American 
community reported hosting a toll-free hotline to take calls and answer 
questions from prospective voters around Election Day. According to CBO 
representatives, most of the calls to the phone line were in Mandarin 
and many calls were from citizens who had not voted before. 

Efforts to collaborate with election offices in providing assistance: 
In King County, WA, representatives of a coalition of CBOs serving the 
Chinese American community reported being very involved in recruiting 
bilingual poll workers. They reported sending out e-mails and 
soliciting volunteers. The coalition also reported organizing a phone 
survey of bilingual poll workers to learn about their experience on 
Election Day. They then used this information to create a video used to 
train poll workers. 

Efforts to collaborate with election offices in providing assistance: 
One representative of a CBO in Harris County, TX, reported reviewing 
and commenting on the accuracy of a demographic map that county 
election officials used to determine where to target resources. 

Efforts to collaborate with election offices in providing assistance: 
Representatives of various Asian American CBOs in Cook County, IL, 
reported that they translated election materials in the past but the 
demand became overwhelming. Thus, the election office started using a 
private company for the translations or did the translations itself. 
However, these CBOs reported that they still occasionally checked 
translations and provided the election office with feedback on 
transliteration. 

Efforts to provide assistance not otherwise provided by the election 
office: A representative with one CBO reported monitoring around 50- 
100 polling sites in Los Angeles County, CA, for the November 2006 
election. This CBO compiled poll monitoring reports, sent them to 
election officials, and walked through these reports with election 
officials at post-election debrief meetings. 

Efforts to provide assistance not otherwise provided by the election 
office: A CBO representing the Filipino community in Los Angeles 
County, CA, reportedly provided voters with transportation to the polls 
because some polling places were difficult to locate and not convenient 
to public transportation. 

Source: GAO analysis of responses from CBO representatives. 

[End of table] 

Jurisdictions Reported Using Various Strategies to Implement Their 
Bilingual Voting Assistance Programs: 

Election officials in jurisdictions included in our review reported 
using varying strategies to implement their bilingual voting assistance 
programs. These strategies included combinations of (1) employing 
bilingual voting assistance coordinators; (2) working with CBOs; (3) 
recruiting bilingual poll workers; (4) determining where to 
target[Footnote 20] their bilingual voting assistance programs; and (5) 
conducting outreach to the language minority community. The range of 
election office strategies may be due in part to the flexibility of the 
guidance that the DOJ Civil Rights Division provides to help covered 
jurisdictions address the requirements of Section 203, as the guidance 
places the responsibility of determining how best to provide the 
required assistance with the individual jurisdictions. DOJ states that 
its guidance is intentionally flexible because the needs and 
preferences of language minority communities vary from jurisdiction to 
jurisdiction. This flexibility allows election offices to tailor their 
programs to try to meet their jurisdiction's unique needs. 

Nine Jurisdictions Employed Bilingual Voting Assistance Coordinators: 

Election officials in nine of the jurisdictions included in our study 
reported that they employed dedicated coordinators to manage their 
bilingual voting assistance programs. Officials in two of these offices 
noted that employing a bilingual voting assistance coordinator who was 
familiar with the demographics of the local language minority 
communities was particularly helpful in effectively determining where 
to target their bilingual voting assistance. In addition, election 
offices in four of the six jurisdictions that were required to provide 
assistance in more than one language reported having at least one 
designated staff for each covered language minority group. For example, 
the Orange County, Calif., registrar of voters reported having one or 
two bilingual "community program specialists" devoted to bilingual 
voting assistance in each of its covered languages--Chinese, Korean, 
Spanish, and Vietnamese. 

Most Jurisdictions We Contacted Worked with Community-Based 
Organizations but Differed in Their Approach and Extent of Activities: 

Election officials in 10 of the 14 jurisdictions reported that they 
worked with CBOs in providing bilingual voting assistance. Of these, 
officials in seven reported having formal election advisory committees 
or task forces that included CBO representatives. Election officials 
reported that some of these advisory committees provided input such as 
feedback on elections, comments on translated election materials, and 
suggestions for targeting bilingual voting assistance. For example, in 
King County, Wash., the election office reportedly received guidance 
and assistance from a "Section 203 Community Coalition," which was 
comprised of five CBOs representing the Chinese community. According to 
coalition members, the coalition worked closely with the election 
office, meeting as often as twice a month. In one example of their 
collaboration, King County's "Section 203 Community Coalition" 
reportedly introduced the idea of conducting surname analysis to 
identify Chinese-speaking potential voters and then mail the identified 
individuals a postcard notifying them about bilingual voting assistance 
and encouraging them to return the postcard to the King County 
Elections Department if they would like to receive future elections 
materials in Chinese. The coalition conducted the analysis, the county 
paid for the mailing, and both parties told us it was a very successful 
collaborative effort. 

The three elections offices that reported working with CBOs but did not 
report having formal advisory committees reportedly worked with CBOs in 
other ways. For example, Seward County, Kans., election officials 
reported working with CBOs on voter outreach to minority language 
voters by distributing bilingual voter registration cards. Similarly, 
Suffolk County, N.Y., election officials reported working and 
communicating regularly with a network of CBOs to disseminate election 
information to language minority voters through churches, community 
centers, and households. Suffolk County election officials stated that 
their relationships with CBOs were very helpful because they 
facilitated voter outreach and expanded the Bureau of Elections' access 
to people in the language minority community. 

Most Jurisdictions We Contacted Had Bilingual Poll Workers and Used 
Multiple Methods to Recruit Them: 

Election officials in 13 jurisdictions we contacted reported recruiting 
bilingual poll workers through a combination of efforts. These efforts 
included: (1) contacting CBOs and language minority media, (2) posting 
recruitment materials in language minority neighborhoods, (3) 
contacting potential poll workers directly, (4) recruiting from the 
public and private sector employers, and (5) conducting direct 
mailings. According to officials in nine jurisdictions, one method of 
recruiting bilingual poll workers was communication with 
representatives of CBOs or the minority community who facilitated 
contacting and recruiting bilingual poll workers. In addition, election 
officials in some jurisdictions reported using language minority media 
such as in-language radio, television, and newspapers to encourage 
members of the language minority community to serve as bilingual poll 
workers. For example, an election official in King County, Wash., 
reported success with a televised public service announcement featuring 
a Chinese American former Governor of Washington State encouraging 
other Chinese Americans to volunteer as bilingual poll workers. Five 
elections offices reported posting signs in language minority 
neighborhoods--in schools, libraries, stores, and civic associations-- 
to recruit bilingual poll workers. In the City of Los Angeles, election 
officials reported posting signs in ethnic grocery stores in language 
minority neighborhoods to recruit bilingual poll workers. Election 
officials in five jurisdictions also reported recruiting bilingual poll 
workers through in-person contact with potential applicants at language 
minority community events, through e-mail messages, and by making 
targeted phone calls. Other jurisdictions reported more success in 
recruiting either high school or college students to be bilingual poll 
workers than did those who tried recruiting bilingual poll workers from 
the private sector. Representatives of several election offices 
reported supplementing these efforts by recruiting local government 
employees to be bilingual poll workers. Finally, in three of the 
election offices we contacted, officials stated that direct mailings 
were used to recruit bilingual poll workers. 

Jurisdictions' Targeting of Bilingual Voting Assistance Efforts 
Involved a Combination of Approaches: 

To determine where to target their bilingual voting assistance efforts, 
election officials in many of the jurisdictions we contacted reported 
using some combination of surname analysis, reviews of U.S. Census 
Bureau and other demographic data, input from CBOs, and analysis of 
voter requests for bilingual voting information. Specifically, these 
efforts included the following: 

* Analyzing surnames: Election officials in eight jurisdictions 
reported using surname analysis to try to identify those areas within a 
jurisdiction that contain a higher concentration of voting age citizens 
with surnames indicative of the covered minority language. A few 
election officials stated that surname analysis was most helpful in 
identifying language minority individuals in largely homogeneous 
communities or in identifying neighborhoods that were undergoing 
demographic transitions and experiencing an influx of new language 
minority communities. Other election officials reported that although 
surname analysis may not have been an accurate tool, it was an approach 
prescribed in a legal agreement negotiated with the DOJ Civil Rights 
Division. As a result, officials chose to use surname analysis, but in 
combination with other targeting approaches. Officials with the DOJ 
Civil Rights Division noted that in many of the agreements reached 
between the Civil Rights Division and local election officials, surname 
analysis was used--in the absence of other reliable data--as a starting 
point for determining appropriate sites for bilingual poll workers. 

* Analyzing demographic data: Election officials in some jurisdictions 
reported using demographic data and information from the U.S. Census 
Bureau and other sources to identify language minority communities 
within their jurisdictions. For example, due to concerns that surname 
analysis alone was not allowing them to effectively target assistance, 
election officials in Harris County, Tex., told us they hired a 
contractor to use Census data to identify areas with population 
concentrations of language minority individuals within their 
jurisdiction. Election officials in Montgomery County, Md., reported 
using a combination of Census data and other data sources such as 
demographic statistics on students in the jurisdiction's public school 
system to target those precincts with the greatest need for bilingual 
voting assistance. 

* Obtaining input from CBOs: Election officials in nine jurisdictions 
reported obtaining input from CBOs to better target their bilingual 
voting assistance programs. Officials in seven of the election offices 
we contacted reported seeking targeting guidance from their language 
minority advisory committees. For example, an election official in 
Montgomery County, Md., reported that their multicultural outreach 
committee has been very helpful in identifying which voters need 
bilingual voting assistance, the types of assistance to be provided, 
and at which precincts assistance needs to be provided. In Los Angeles 
County, Calif., election officials stated that they obtained input from 
CBOs as part of their systematic targeting process to identify 
precincts that may need bilingual voting assistance--if a community 
partner organization indicated that a neighborhood should be targeted 
for a particular language, the polling places in that neighborhood were 
considered "targeted." 

* Analyzing voter requests: Officials in four election offices reported 
utilizing records of past voter requests for or use of bilingual voting 
assistance to target future bilingual voting assistance efforts. For 
example, some officials reported collecting data on requests for 
bilingual assistance noted on voter registration cards, absentee ballot 
request forms, and phone calls to the elections office. In addition, 
election officials in three jurisdictions reported asking poll workers 
to record the number of requests for bilingual voting assistance on 
Election Day. Election officials in Los Angeles County, Calif., for 
example, reported that they tracked requests for language assistance by 
precinct and had poll workers use a "multilingual tally card" to keep 
track of the numbers of voters requesting language assistance on 
Election Day. (An example of a multilingual tally card used in Los 
Angeles County is provided in app. IV.) Election officials in five 
jurisdictions, however, stated that they did not or could not track 
voter requests for assistance. For example, Seward County, Kans., 
election officials stated that Kansas state law forbids the election 
office from tracking individuals' requests for bilingual voting 
assistance. Similarly, an election official in Montgomery County, Md., 
reported that due to personal privacy concerns, the county did not 
track usage of bilingual voting assistance. Election officials in 
Harris County, Tex., noted that their state-issued voter registration 
forms did not have a place for registrants to indicate their preferred 
language; therefore, it was not possible for the local jurisdictions to 
track requests for assistance using voter registration forms. 

Most Jurisdictions Conducted Outreach but Reportedly Used Diverse 
Methods to Engage Language Minority Communities: 

Election officials in 13 jurisdictions told us that they used various 
strategies to reach out to language minority voters to inform them of 
the availability of bilingual voting assistance and to educate them 
about the election process. These strategies included working with 
CBOs; using ethnic media outlets; conducting in-person contacts; and 
posting bilingual voting information on the Internet. Specifically, 
these efforts included the following: 

* Working with CBOs: Election officials in nine jurisdictions reported 
working with representatives of CBOs to conduct bilingual outreach and 
voter education. For example, Suffolk County, N.Y., election officials 
stated that they worked closely with the network of organizations 
active in their language minority communities to disseminate election 
information to churches, community centers, and households in their 
efforts to reach language minority voters. Election officials in the 
City of Boston reported that they communicated regularly with the CBO 
representatives that participate in the city's Voter Outreach and 
Education Task Force, and that the CBOs played an active, necessary 
role in disseminating bilingual voting assistance information. 
Similarly, election officials in King County, Wash., reported that CBOs 
provided substantial amounts of outreach, workshops, and seminars 
informing and educating language minorities of the availability of 
election materials and how to use the new voting system implemented in 
the jurisdiction. 

* Using media outlets: Jurisdictions reported using a variety of media 
outlets to conduct bilingual outreach and voter education. Election 
officials in most of the jurisdictions included in our study reported 
using print media, radio or televised public service announcements to 
conduct bilingual outreach, and the types of media used sometimes 
varied among the targeted language minority communities. For example, 
election officials in Orange County, Calif., reported using Spanish- 
speaking television stations to target information to the Latino 
community but that using Vietnamese radio stations and newspapers were 
more effective for reaching the Vietnamese community. Election 
officials in the City of Boston reported that they worked with the 
Ethnic Media Studies Department at the University of Massachusetts to 
determine what ethnic media outlets were most used by the language 
minority community in their jurisdiction. Finally, election officials 
in six jurisdictions also reported using targeted translated mailings 
to inform the covered language minority community about election 
processes and important voter information. These included translated 
voter registration forms, sample ballots, and voting instructions. 

* Using in-person contact: Election officials in 11 jurisdictions 
reported using in-person contact with the language minority community 
as another means to inform targeted individuals about the availability 
of bilingual voting assistance and to educate them on election 
processes. For example, election officials for the City of Boston 
reported that in-person contact was the most effective outreach method 
in their jurisdiction. As a result, their staff attended and registered 
voters at language minority community forums and swearing-in ceremonies 
for new citizens. Election officials in other jurisdictions also 
reported that they visited language minority community events or 
locations such as festivals and libraries to conduct voter outreach and 
education. For example, an election official in King County, Wash., 
stated that she participated in voter education forums held by a CBO to 
talk through the voter's pamphlet with Chinese-speaking voters, provide 
instructions on how to fill out the ballot, and encourage participants 
to share their knowledge with others in the language minority 
community. 

* Posting information on the Internet: Officials in 11 of the election 
offices we contacted reported posting bilingual voting assistance 
materials and information on their websites, though to varying extents. 
For example, election officials in Harris County, Tex., told us they 
translated aspects of their Web site to provide language minority 
individuals with essential voting information, including important 
dates, early voting and Election Day information, sample ballots, and 
information on how to operate the jurisdiction's voting system. In 
contrast, Orange County, Calif., election officials reported that 
nearly all of the web content provided in English is available in each 
of the four covered languages. Los Angeles County, Calif., election 
officials reported focusing their Web site's language content on 
frequently utilized materials while working to make more election 
procedures available in the county's required minority languages. 

All 14 Jurisdictions Reported Challenges in Providing Bilingual Voting 
Assistance: 

All 14 jurisdictions we contacted reported experiencing challenges in 
providing bilingual assistance, with the key challenges related to: (1) 
recruiting and ensuring quality performance of bilingual poll workers, 
(2) targeting bilingual voting assistance, (3) designing and 
translating bilingual voting assistance materials, and (4) allocating 
sufficient resources to bilingual voting assistance. In addition to 
identifying these key challenges, officials in nine jurisdictions 
expressed a desire for more guidance or assistance on providing 
bilingual voting assistance. 

Many Jurisdictions Reported Difficulties Recruiting Bilingual Poll 
Workers and with Bilingual Poll Worker Performance: 

Election officials in nine of the jurisdictions stated that they had 
difficulty recruiting bilingual poll workers for a variety of reasons. 
For example, five jurisdictions reported that recruiting was difficult 
because of the long hours and minimal pay provided to bilingual poll 
workers--they believed that many individuals in the language minority 
communities had multiple jobs and could not afford to commit to the 
long hours required of a bilingual poll worker on Election Day. 
Election officials in five jurisdictions also added that it was a 
challenge to recruit bilingual poll workers who were willing to serve 
at a polling place outside their home precinct. In their experience, 
some bilingual poll workers either did not have the means to travel to 
other polling sites or were reluctant to do so. In addition, 
demographic shifts in some jurisdictions reportedly created recruiting 
challenges. For example, representatives of four election offices 
stated that recruiting was especially challenging for new language 
minority communities with only a very limited pool of potential 
bilingual volunteers or when members of the language minority community 
that are fluent in the covered language are decreasing in numbers due 
to aging. In one jurisdiction, an election official reported that some 
voters who reside in areas that are not historically language minority 
communities do not want to be identified as language minority speakers; 
therefore, they hesitate to volunteer. 

In addition to recruiting problems, representatives of election offices 
from two jurisdictions reported that they experienced challenges 
related to bilingual poll worker performance. For example, election 
officials in Los Angeles County, Calif., stated that, in their 
experience, the performance of bilingual poll workers has been 
adversely affected by poor treatment by other poll workers that did not 
recognize the importance of providing bilingual voting assistance. 
Election officials in this jurisdiction also stated that CBOs have 
complained in the past that some of the bilingual poll workers were 
unwilling to assist language minority voters due to differences in 
their personal and cultural backgrounds, noting that acculturating new 
bilingual poll workers into the election environment was an issue they 
needed to address. In addition, election officials in this jurisdiction 
mentioned that while cultural sensitivity and diversity training was 
included in their general poll worker training, it was very difficult 
to spend sufficient time on the topic when there was a great deal of 
material to cover during the brief poll worker training time available. 
Similarly, election officials in the City of Boston reported difficulty 
managing some veteran poll workers who were reticent to use the 
training associated with the bilingual voting aspects of their job. 
According to these officials, expanding the length of training to 
address these issues has not been an option because trainees' attention 
to the material covered was limited to a certain amount of time, 
attendance is not required, and it could increase costs associated with 
the training. 

Some Jurisdictions Reported Difficulties Targeting Those Voters Who 
Needed Bilingual Voting Assistance: 

Election officials in eight of the jurisdictions we contacted reported 
that limitations in surname analysis, U.S. Census Bureau data, or 
demographic shifts in their jurisdictions made it difficult to 
effectively target bilingual voting assistance. Election officials in 
several jurisdictions reported that surname analysis did not accurately 
indicate whether individuals were actually limited-English proficient 
or proficient in the covered language, and added that surname analysis 
may overstate the need for bilingual assistance in particular 
precincts. Election officials in Los Angeles County, Calif., also noted 
that surname analysis was not useful in jurisdictions containing 
multiple language minority groups, especially those with many 
overlapping surnames. For example, these officials reported that it was 
very difficult to correctly distinguish between members of the Filipino 
and Spanish-speaking communities using surname analysis because 
Filipino surnames overlap with Spanish surnames. 

Election officials in some jurisdictions also asserted that U.S. Census 
Bureau data are not accurate or detailed enough to enable them to 
effectively target language minority voters or, in some cases, 
determine the precise dialect a covered language minority community 
speaks. For example, Suffolk County, N.Y., election officials reported 
that they have had challenges targeting language minority individuals 
who are eligible to register and vote due to the number of undocumented 
persons included in Census data who are not registered to vote. In 
addition, election officials for Kenai Peninsula Borough, Alaska, 
explained that while the Census data identified the jurisdiction as 
requiring bilingual voting assistance in American Indian and Aleut 
languages, it is not clear what specific languages or dialects 
officials should target.[Footnote 21] Some election officials also 
explained that targeting bilingual voting assistance can be more 
difficult when the language minority communities are not concentrated 
in discrete geographic areas within the jurisdiction. For example, Los 
Angeles County, Calif., election officials reported that the diversity 
of the county's population and its constant demographic shifts require 
their office to modify their targeted precincts every 2 years, whereas 
Census data for jurisdictions covered under Section 203 are currently 
updated every 10 years. 

Many Jurisdictions Reported Difficulties Designing or Translating 
Bilingual Voting Assistance Materials: 

Election officials in nine jurisdictions reported difficulties 
designing or translating their bilingual voting assistance materials. 
Election officials reported that translating ballot language was 
particularly challenging because of differences in the meanings of 
words in various dialects of a given language or difficulties finding 
comparable phrasing in the covered language. Some election officials 
reported that this challenge was exacerbated by the limited time they 
had to review and correct errors before printing and distributing the 
election materials. For example, election officials in Montgomery 
County, Md., reported that they operated under short time frames with 
the vendors that produced their materials and had just 7 days to proof 
the ballot layout, design, spelling, audio pronunciation, touch screen 
text, and optical scan text before the materials had to be printed. In 
addition, some election officials noted that a translated ballot in a 
minority language is often longer than the English version--this 
difference in text length made it difficult to design a user-friendly 
bilingual ballot. 

Some Jurisdictions Reported Difficulty Allocating Sufficient Resources 
to Their Bilingual Voting Assistance Efforts: 

Election officials in 11 jurisdictions reported that they had 
difficulty allocating either sufficient staff or financial resources to 
their bilingual voting assistance efforts. Election officials in five 
jurisdictions stated that additional staff would allow them to more 
effectively conduct outreach to the language minority communities. For 
example, an election official from Miami-Dade County, Fla., stated that 
having limited staff available to send to language minority communities 
has made it more difficult to educate language minority voters about 
the election process. Additionally, election officials in two 
jurisdictions stated that having sufficient staff would allow them to 
more effectively translate and review the written and oral assistance 
provided. In Montgomery County, Md., election officials reported that 
they rely heavily on unpaid community volunteers but with additional 
funding the county could conduct more outreach activities. 

Many Election Officials We Contacted Desired Additional Guidance and 
Information on Providing Bilingual Assistance: 

Although officials in 12 jurisdictions reported receiving some degree 
of guidance or assistance from DOJ or other sources, officials in 9 
jurisdictions also reported that more guidance or assistance may be 
helpful. For example, election officials in the City of Boston stated 
that they received some assistance from DOJ in the past, but that 
additional guidance and greater coordination among jurisdictions that 
provide bilingual voting assistance would also be beneficial. These 
officials told us they had taken the initiative to communicate with 
other covered jurisdictions to learn about their approaches to 
providing bilingual voting assistance but believed that a more 
organized system for information sharing between jurisdictions would be 
useful. These same views were echoed by election officials 
participating in discussion sessions we held on bilingual voting 
assistance during two national election conferences on election issues 
sponsored by the Election Center in 2007. Specifically, in both 
discussion sessions, several election officials noted that additional 
guidance and greater coordination among jurisdictions that provide 
bilingual voting assistance would be beneficial. In addition, an 
official from a jurisdiction included in our study stated that the 
Secretary of State's Office and DOJ had offered assistance, but little 
to none had been received. Election officials in five jurisdictions 
that reported receiving guidance or assistance from DOJ stated that 
some of the assistance was not helpful, accurate, or reliable. 
Officials with the DOJ Civil Rights Division stated that their office 
offers guidance and assistance to local election officials on how to 
comply with Section 203, but it is the responsibility of covered 
jurisdictions to determine what languages, forms of languages, or 
dialects will be effective in their jurisdictions. Furthermore, these 
officials stated that its guidance is intentionally flexible because 
election systems and the circumstances of language minority communities 
vary widely across the United States. Instead, DOJ states that it 
provides guiding principles and practical suggestions for election 
officials to use. DOJ officials also noted that they have taken steps 
to make covered jurisdictions aware of this guidance, including 
conducting in-person visits with newly-covered jurisdictions as well as 
making presentations to state and local election officials through 
national groups and associations. 

The U.S. Election Assistance Commission Has Taken Recent Steps to 
Provide Additional Guidance and Information to Jurisdictions on 
Providing Bilingual Assistance: 

The EAC has taken steps to provide guidance on bilingual voting 
assistance as part of its responsibilities under HAVA to serve as a 
national clearinghouse and resource for information with respect to the 
administration of federal elections. For example, the EAC formed a 
Language Accessibility Program that has taken steps to provide 
recommendations and tools to election officials on providing bilingual 
voting assistance. In April 2007, the EAC published English-to-Spanish 
and Spanish-to-English versions of a glossary of over 1,800 election 
terms and phrases used in the administration of elections. The glossary 
was designed to assist state and local election officials in providing 
translated election materials that are culturally and linguistically 
appropriate. In addition, in September 2007, the EAC awarded a contract 
to translate this glossary into five additional languages covered under 
Section 203: Chinese, Japanese, Korean, Tagalog, and Vietnamese, with 
an anticipated glossary publication date of May 2008. The EAC also 
issued two guidebooks on recruiting and training poll workers that 
included suggestions on serving the needs of language minority voters. 
For example, one of the guidebooks included a section on partnering 
with civic organizations to recruit bilingual poll workers, and the 
other guidebook included a chapter on recruiting bilingual college 
students to serve as poll workers. 

In addition to its completed publications, the EAC has other assistance 
efforts planned in response to recent concerns voiced by election 
officials to the EAC regarding the need for additional guidance and 
information on providing bilingual assistance. For example, the EAC 
plans to dedicate a future chapter of its set of Election Management 
Guidelines to the topic of language accessibility. EAC officials 
reported that this language accessibility chapter (and accompanying 
brochure) will address strategies for election officials to consider 
and implement when providing elections services to voters with limited 
English proficiency throughout the election process. The EAC plans to 
develop this guidance by consulting election officials and 
professionals with first-hand experience managing elections in order to 
identify and develop the key content the publications should address. 
EAC officials noted that this process should begin in April 2008, and 
final publications should be released to the public by the end of that 
year. After its initial set of Election Management Guidelines has been 
completed, the EAC plans to regularly assess the need to cover other 
topic areas and update previous materials to maintain current and 
relevant information in the guidelines. 

Some Forms of Bilingual Voting Assistance Were Perceived as More Useful 
than Others, but Formally Evaluating Its Usefulness Presented Many 
Challenges: 

Although we identified little data measuring the usefulness of various 
types of bilingual voting assistance, election officials in eight 
jurisdictions and CBO representatives in seven jurisdictions in our 
study told us that they believed certain forms of assistance were more 
useful than others. In addition, none of the jurisdictions had formally 
evaluated the effectiveness of their bilingual voting assistance 
programs, although most had used some means of gathering information 
about elements of the assistance provided. Election officials in 10 
jurisdictions and CBO representatives in 9 jurisdictions also stated 
that modifications could be made that would improve the usefulness of 
the bilingual services provided to voters. While the use of formal 
program evaluation tools has proven to be a successful means for 
federal agencies to improve program effectiveness, accountability, and 
service delivery,[Footnote 22] conducting formal evaluations of the 
usefulness and effect of bilingual voting assistance is difficult for a 
variety of reasons. Three key difficulties include (1) identifying the 
objectives and appropriate indicators of success, (2) determining how 
to measure these indicators once they have been identified, and (3) 
isolating the effects of bilingual voting assistance efforts on 
language minority voters from more general voter outreach efforts or 
other influences on election processes. 

Certain Types of Assistance Were Viewed as More Useful than Others: 

Although the election jurisdictions and CBOs we met with had not 
conducted any formal evaluations of the bilingual assistance they 
provided, the majority of both believed that the assistance that the 
election offices provided was useful to language minority voters. 
Specifically, election officials we met with in 12 of 14 jurisdictions 
and leaders of CBOs in 10 of 11 jurisdictions believed that the 
bilingual voting assistance provided by the election offices was useful 
to language minority voters and helped improve their participation in 
the voting process. However, some types of bilingual assistance were 
viewed as more useful than others. (See table 7 for the types of 
bilingual voting assistance identified as most useful.) 

Table 7: Most Useful Types of Bilingual Voting Assistance, as Reported 
by Election Officials and CBO Representatives: 

Type of bilingual voting assistance provided by the election office: 
Bilingual poll workers; 
Number of jurisdictions in which election officials viewed this as the 
most useful type of assistance: 6; 
Number of jurisdictions in which CBO representatives viewed this as the 
most useful type of assistance: 5. 

Type of bilingual voting assistance provided by the election office: 
Translated voting materials (i.e., voter guides, registration forms, 
sample ballots, ballots); 
Number of jurisdictions in which election officials viewed this as the 
most useful type of assistance: 4; 
Number of jurisdictions in which CBO representatives viewed this as the 
most useful type of assistance: 6. 

Type of bilingual voting assistance provided by the election office: 
Community outreach and education activities; 
Number of jurisdictions in which election officials viewed this as the 
most useful type of assistance: 2; 
Number of jurisdictions in which CBO representatives viewed this as the 
most useful type of assistance: 3. 

Type of bilingual voting assistance provided by the election office: 
Media in-language (i.e., newspapers, tv, radio, mailings); 
Number of jurisdictions in which election officials viewed this as the 
most useful type of assistance: 2; 
Number of jurisdictions in which CBO representatives viewed this as the 
most useful type of assistance: 2. 

Type of bilingual voting assistance provided by the election office: 
Web site; 
Number of jurisdictions in which election officials viewed this as the 
most useful type of assistance: 2; 
Number of jurisdictions in which CBO representatives viewed this as the 
most useful type of assistance: 0. 

Type of bilingual voting assistance provided by the election office: 
Translated polling place signage; 
Number of jurisdictions in which election officials viewed this as the 
most useful type of assistance: 1; 
Number of jurisdictions in which CBO representatives viewed this as the 
most useful type of assistance: 0. 

Type of bilingual voting assistance provided by the election office: 
All forms of bilingual assistance; 
Number of jurisdictions in which election officials viewed this as the 
most useful type of assistance: 1; 
Number of jurisdictions in which CBO representatives viewed this as the 
most useful type of assistance: 0. 

Type of bilingual voting assistance provided by the election office: 
Designated bilingual coordinator; 
Number of jurisdictions in which election officials viewed this as the 
most useful type of assistance: 0; 
Number of jurisdictions in which CBO representatives viewed this as the 
most useful type of assistance: 3. 

Type of bilingual voting assistance provided by the election office: 
Use of community advisory committees; 
Number of jurisdictions in which election officials viewed this as the 
most useful type of assistance: 0; 
Number of jurisdictions in which CBO representatives viewed this as the 
most useful type of assistance: 2. 

Type of bilingual voting assistance provided by the election office: 
Voting machines bilingual ballots; 
Number of jurisdictions in which election officials viewed this as the 
most useful type of assistance: 0; 
Number of jurisdictions in which CBO representatives viewed this as the 
most useful type of assistance: 2. 

Type of bilingual voting assistance provided by the election office: 
Phone assistance to intermediaries on behalf of language minority 
voters; 
Number of jurisdictions in which election officials viewed this as the 
most useful type of assistance: 0; 
Number of jurisdictions in which CBO representatives viewed this as the 
most useful type of assistance: 1. 

Source: GAO analysis of responses from election officials and CBO 
representatives. 

Note: Officials may have designated more than one type of assistance as 
most useful. Election officials and CBO representatives may be in the 
same jurisdiction. 

[End of table] 

Both election officials and CBO representatives generally agreed that 
having bilingual poll workers available on Election Day was among the 
most useful forms of assistance to voters. As noted above, election 
officials and CBO representatives in some jurisdictions also believed 
that having translated written materials was among the most useful 
forms of assistance. For example, a CBO representative in Harris 
County, Tex., told us that having bilingual voting guides, sample 
ballots, and other election materials was more useful to voters than 
having bilingual poll workers available on Election Day. He explained 
that members of the community preferred to have translated written 
materials that they could study in their homes and discuss with family 
members prior to the election rather than waiting to get assistance 
from bilingual poll workers on Election Day. 

In limited instances, bilingual voting assistance was not viewed as 
useful. In two jurisdictions, the limited use of the bilingual voting 
assistance by voters led election officials to question its usefulness. 
For example, officials with the Harris County, Tex., tax assessor's 
office (which is responsible for voter registration in the county) 
provided us with some data that indicated a low usage of translated 
voter registration applications. During calendar year 2006 and through 
June 2007, the office distributed roughly 97,000 voter registration 
applications in Vietnamese and roughly 173,000 in Spanish by placing 
them at branches of the tax assessor's office, public libraries, and 
Texas Department of Public Safety locations, as well as distributing 
them during community outreach events. However, the office received 
back only 2 of the Vietnamese and 309 of the Spanish registration 
applications. While the officials did not speculate as to the reasons 
for the low usage of the translated forms, they noted that since they 
are required to provide the forms in both languages they would continue 
doing so. CBO representatives in two jurisdictions also told us that 
they did not believe that the bilingual voting assistance provided by 
the election offices was always useful. For example, a CBO 
representative in Jackson County, S. Dak., noted that bilingual voting 
assistance was not needed because about 95 percent of people in the 
covered language group can read and understand English. This opinion 
was also similar to that of a group of senior citizen Filipino voters 
we met with through a CBO in Los Angeles County, Calif. These voters 
had mixed views on the usefulness of the bilingual voting assistance 
they received. Some of these voters indicated that the quality of the 
translated ballots was poor; therefore, they instead voted using the 
English version of the ballots. However, these voters also noted that 
Filipinos generally know how to read and speak English; thus, the 
assistance was not necessary. Yet, these voters also wanted the same 
benefits (i.e., translated election materials) provided to them that 
other language minority groups received under Section 203. 

Election officials and CBO representatives in some jurisdictions stated 
that modifications could be made that would improve the usefulness of 
the bilingual assistance currently provided to language minority 
voters. For example, election officials in four jurisdictions and CBO 
representatives in nine jurisdictions believed that the usefulness of 
bilingual voting assistance provided by the election office could be 
improved through additional community outreach and education efforts. 
Election officials in five jurisdictions and CBO representatives in six 
jurisdictions noted that improvements in the translation of bilingual 
voting materials would improve their usefulness to language minority 
voters. Finally, election officials in three jurisdictions and CBO 
representatives in seven jurisdictions believed that improvements in 
the recruiting and training of bilingual poll workers would improve the 
usefulness of bilingual voting assistance. (See table 8 for a list of 
specific suggestions from election officials and CBO representatives 
for improving the usefulness of bilingual voting assistance.) 

Table 8: Suggestions on How Election Offices Can Improve the Usefulness 
of Bilingual Voting Assistance, according to Election Officials and CBO 
Representatives: 

Community outreach and education: 
* Following-up on community outreach events to determine their impact 
(i.e., whether new voters registered); 
* Seeking additional members of the language community for 
participation in advisory committees; 
* Having community leaders volunteer to work in election offices to 
better understand the election process; 
* Surveying or otherwise soliciting feedback from language minority 
voters about the bilingual assistance they received; 
* Placing more public service announcements about the election process 
in language media (i.e., radio, tv, or newspapers); 
* Hiring more permanent bilingual staff; 
* Issuing bilingual voting guides; 
* Providing financial assistance to CBOs so that they could provide 
additional bilingual voting assistance; 
* Using high-profile spokespeople to raise awareness of the importance 
of voting among language minority voters; 
* Having dedicated phone lines, answered in- language, to provide 
assistance or information about voting to language minority voters. 

Translating election materials: 

* Ensuring that all materials are translated; 
* Placing additional translated materials on election office Web sites; 
* Using bilingual ballots versus separate translated ballots; 
* Translating candidate debates and forums as well as materials into 
the covered language; 
* Asking members of the language minority community to proofread 
translations; 
* Providing audio ballots in the covered language; 
* Tracking voter language preferences (via registration forms) to 
provide mailings in the preferred language; 
* Using standardized translated terms; 
* Working with the language minority community to identify specific 
dialects of a language that are needed, if any. 

Recruiting, training, and placing bilingual poll workers: 

Community outreach and education: * Hiring additional bilingual poll 
workers; 
* Ensuring bilingual poll workers are placed at the polling places that 
need them; 
* Improving poll worker training to emphasize bilingual assistance as a 
regular part of doing business; 
* Reducing bilingual poll worker training class size to allow more in-
depth discussions; 
* Increasing oversight of bilingual poll workers to ensure they are 
actually providing assistance; 
* Having bilingual poll workers wear name tags--in the relevant 
language--to identify the language they speak; 
* Asking CBOs to assist with conducting poll worker training; 
* Recruiting bilingual poll workers from the business community; 
* Using bilingual city employees as poll workers; 
* Increasing poll worker pay. 

Source: GAO analysis of responses from election officials and CBO 
representatives. 

[End of table] 

Some Election Officials and Community-Based Organization 
Representatives Attempted to Measure Aspects of Bilingual Assistance: 

None of the jurisdictions we included in our study had formally 
evaluated the effectiveness of their bilingual voting assistance 
programs, although most had used some means of gathering information 
about the assistance provided.[Footnote 23] Election officials in two 
jurisdictions told us that formal evaluations of their bilingual voting 
assistance programs were unnecessary, since even if they discovered 
that voters had not used the assistance or did not find it useful, the 
jurisdictions were still required to provide it. Further, officials in 
one of these jurisdictions said it is inappropriate for the 
jurisdiction to conduct such a study because of the risk of perceived 
political motivations to do away with bilingual voting assistance, as 
well as the potential for legal action if the evaluation results were 
used to try to justify not providing bilingual voting assistance. 

Election officials in 12 of the 14 jurisdictions reported they used 
various informal means to get information about the effectiveness of 
certain aspects of their bilingual voting assistance programs. For 
example, election officials in six jurisdictions told us they used 
feedback from voters, community groups, advisory committees, phone 
calls to a language telephone hotline, and other public contacts to 
determine if the bilingual assistance was useful and whether any 
modifications were needed. Election officials in one jurisdiction said 
their CBO partners were their "eyes and ears"--providing significant 
input if the bilingual voting assistance they provided was not 
effective or needed improvement. These officials commented that they 
believed obtaining feedback from CBOs was the best way to know how they 
were doing, and told us that DOJ had acknowledged that using CBOs for 
feedback is a good idea. Election officials in another jurisdiction 
reported that they reviewed Election Day call-center logs to determine 
whether voters or others had reported any problems related to bilingual 
voting assistance, and that if any problems were identified the 
jurisdiction worked to address them. Election officials in four 
jurisdictions reported they had conducted post-election surveys of or 
obtained comments from poll workers, either to determine the number of 
voters who had used bilingual assistance at the polls on Election Day 
or to obtain feedback about election judges' and poll workers' 
experiences concerning the assistance provided. Finally, election 
officials in two jurisdictions noted that they reviewed changes in the 
numbers of language minority voters voting or requesting non-English 
ballots to gauge the effectiveness of their efforts. 

Representatives from CBOs in three jurisdictions reported that their 
organizations had conducted some type of evaluation of the bilingual 
assistance provided by their election jurisdiction in the November 2006 
general election or had collected other information about the bilingual 
voting assistance provided in their jurisdictions. For example, 
representatives of a CBO in one jurisdiction told us they had conducted 
exit polling with all voters, not just language minority voters, in the 
November 2006 general election. Leaders from CBOs in another 
jurisdiction reported conducting focus groups with county leaders, 
voters, and callers to a phone bank regarding the usefulness of the 
bilingual voting assistance provided in their jurisdiction. In 
addition, representatives of a CBO that was involved in two 
jurisdictions noted that their organization collected data on Election 
Day regarding the presence and activity of bilingual poll workers and 
the display of translated voting materials in polling places. 
Representatives with one CBO told us their method of evaluation relied 
on informal feedback from community members. 

Conducting Formal Evaluations of the Usefulness and Effect of Bilingual 
Voting Assistance Is Difficult: 

While formal program evaluation tools have proven to be successful 
means for federal agencies to improve program effectiveness, 
accountability, and service delivery, election offices face many 
difficult issues in evaluating the effectiveness, or outcomes, of the 
bilingual voting assistance they provide.[Footnote 24] Among these, 
three key issues are (1) identifying the objectives of the bilingual 
voting assistance program and criteria for achieving these objectives, 
(2) determining how to measure these criteria once they have been 
identified, and (3) isolating the effects of the bilingual assistance 
from other influences on language minority voters when they vote. (See 
app. V for a discussion of additional challenges to evaluating the 
usefulness of bilingual voting assistance.) 

* Identifying the objectives and criteria: The identification of 
appropriate objectives and criteria for achieving them is basic to any 
evaluation of effectiveness, as an effective program must move toward 
the achievement of an identified purpose. Examples of objectives for 
bilingual assistance could be (1) increased language minority voter 
turnout, (2) increased independence demonstrated by language minority 
voters when voting, and (3) language minority voters who are better 
informed when casting their ballots. 

* Determining how the objectives and criteria will be measured: Once 
objectives and criteria have been established, it is then necessary to 
determine how they will be measured. For a number of reasons, measuring 
the effectiveness of bilingual voting assistance is difficult. For 
example, to measure the effectiveness of bilingual voting assistance on 
language minority voter turnout, if a jurisdiction keeps records on 
which voters have indicated needing bilingual assistance, poll books 
can be checked to see whether these voters have voted and the numbers 
of such voters can be tracked across elections. However, officials in 
one jurisdiction told us that state law prohibited them from indicating 
either a person's race or their primary language in their voter 
registration records. Additionally, a jurisdiction could track the 
number of ballots printed in a covered language that had been used by 
voters. However, the number of ballots would not be a useful measure if 
both English as well as the covered language are printed on the same 
ballot. Measuring other potential indicators could be even more 
difficult. For example, one objective of bilingual voting assistance 
could be to enable language minority voters to cast their ballots 
independently--for example, without the need for someone to accompany 
them into the polling booth to provide language assistance. However, 
without information on the number and percentage of voters who needed 
assistance to cast their ballot prior to the implementation of 
bilingual voting assistance, jurisdictions could not measure the effect 
of the assistance on this indicator accurately. 

* Isolating the effects from other influences: Isolating the effects of 
bilingual assistance on voter behavior would be extremely difficult 
because a number of factors influence voter behavior--such as age, 
party affiliation, or social organizations to which voters belong. For 
example, turnout among Hispanic voters could increase in the first 
election following the implementation of bilingual assistance. This 
same election could feature one or more Hispanic candidates on the 
ballot or one of the candidates could have taken a position deemed as 
"anti-immigrant." It could be difficult to determine the contribution 
of each of these factors to the increased Hispanic voter turnout. 

The two general approaches that are often used to help isolate the 
effects, or impact, of a program would be difficult to use in 
evaluating bilingual voting assistance. The first approach involves 
having baseline data--data from the period before a program is 
implemented--along with data collected from the period after a program 
is implemented and comparing the two periods to determine whether there 
are differences in the indicators being measured. However, this 
approach could be very difficult, if not impossible, to use because 
jurisdictions might not have collected the relevant data from previous 
elections. Also, as mentioned earlier, unless there is some ability to 
determine the contribution of other factors that might influence voter 
behavior, it could be difficult to determine the specific effect 
bilingual assistance has had. 

The second approach is to have a comparison or control group and 
involves collecting data from a separate group of individuals who do 
not participate in the program but have characteristics similar to 
those who do participate in the program to determine whether there are 
any differences between these groups on the indicators being measured. 
With bilingual voting assistance, this would mean collecting data on 
groups of language minority voters who do not receive any bilingual 
assistance, and comparing the results to data collected from language 
minority voters who received the assistance. However, it would be very 
difficult, if not impossible, to keep a control group of language 
minority voters from hearing or seeing pre-election bilingual 
assistance provided through the media. Further, unless conducted in a 
simulated way, such as in a mock election, a jurisdiction covered under 
Section 203 seeking to use such a methodology with respect to language 
minority voters would appear to face the additional challenge of 
meeting the Section 203 requirements as well as complying with other 
applicable federal and state voting rights protections. 

Concluding Observations: 

Most election officials we met with supported providing bilingual 
voting assistance and took actions to implement this assistance in 
their respective jurisdictions; however, many of them also expressed 
uncertainty on how best to assess and meet the needs of language 
minority voters. DOJ provides guidance on bilingual assistance under 
Section 203, and it is intentionally flexible in nature to allow 
covered election jurisdictions to tailor their bilingual voting 
assistance programs to the specific needs and resources of their 
communities. At the same time, this flexibility has led to uncertainty 
among election officials as to whether their bilingual programs are 
actually meeting requirements or the needs of language minority voters. 
Moreover, although we have noted in prior work that federal agencies 
have successfully used formal program evaluation tools to improve 
federal program effectiveness, accountability, and service delivery, 
the methodological difficulties election officials and others would 
likely face in trying to formally assess the effectiveness of their 
bilingual assistance programs for language minority voters make formal 
evaluations of these programs very difficult. As a result, the extent 
to which bilingual voting assistance programs are meeting the needs of 
language minority voters is unknown. 

However, the difficulty in conducting formal evaluations does not mean 
that election jurisdictions would not benefit from additional feedback 
or information about their own or other jurisdictions' bilingual voting 
assistance programs. The EAC's recent efforts to develop and provide 
guidance to election jurisdictions regarding the translation of 
election terminology and recruiting bilingual poll workers address two 
of the challenges we identified in this report. Similarly, the EAC's 
planned development of additional management guidelines for election 
officials on how to provide bilingual voting assistance might also help 
jurisdictions in providing this type of assistance. However, because 
the specific content of these management guidelines has yet to be 
determined, whether they will provide election officials with the 
information they seek is unknown. Nonetheless, while these guidelines 
may not provide election officials with feedback about their specific 
language assistance programs, making such information available from a 
central, easily accessible source could help jurisdictions address 
challenges they face in determining how to provide bilingual voting 
assistance that will be useful to the language minorities in their 
communities. Finally, although it is difficult to evaluate the effect 
of bilingual assistance, in the absence of better data on the extent to 
which the assistance is both used and helpful to voters with limited- 
English proficiency, there is likely to continue to be debate about the 
merits of bilingual voting assistance. 

Agency Comments: 

We provided a draft of this report to DOJ and the EAC for review and 
comment. DOJ did not provide comments on the draft of this report but 
did provide technical edits, which we incorporated where appropriate. 

The EAC provided written comments on December 21, 2007, which are 
presented in appendix VI. The EAC presented additional details on its 
efforts to provide election officials and the public with information 
on bilingual voting assistance. 

We are sending copies of this report to interested congressional 
committees, the Attorney General, the Commissioners of the U.S. 
Election Assistance Commission, and other interested parties. In 
addition, the report will be available at no charge on the GAO Web site 
at [hyperlink, http://www.gao.gov]. Please contact William Jenkins at 
202-512-8777 or jenkinswo@gao.gov if you or your staff have any 
questions concerning this report. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. Key contributors to this report are listed in 
appendix VII. 

Signed by: 

William O. Jenkins, Jr.: 

Director, Homeland Security and Justice Issues: 

List of Congressional Committees: 

The Honorable Patrick J. Leahy: 
Chairman: 
The Honorable Arlen Specter: 
Ranking Member: 
Committee on the Judiciary: 
United States Senate: 

The Honorable Dianne Feinstein: 
Chairman: 
The Honorable Robert Bennett: 
Ranking Member: 
Committee on Rules and Administration: 
United States Senate: 

The Honorable John Conyers, Jr.: 
Chairman: 
The Honorable Lamar S. Smith: 
Ranking Member: 
Committee on the Judiciary: 
House of Representatives: 

The Honorable Robert A. Brady: 
Chairman: 
The Honorable Vernon J. Ehlers: 
Ranking Member: 
Committee on House Administration: 
House of Representatives: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This review examined the provision of bilingual voting assistance by 
selected jurisdictions covered under Section 203 of the Voting Rights 
Act. Specifically, our objectives were to provide information on: 

* the ways that selected jurisdictions covered under Section 203 of the 
Voting Rights Act have provided bilingual voting assistance as of the 
November 2006 general election, and the challenges they reportedly 
faced in providing such assistance; and: 

* the perceived usefulness of this bilingual voting assistance, and the 
extent to which the selected jurisdictions evaluated the usefulness of 
such assistance to language minority voters. 

For both objectives, we conducted site visits or obtained information 
electronically from 14 selected jurisdictions covered by Section 203. 
However, before opting for this approach, we considered other options: 
(1) a survey of all 296 covered Section 203 jurisdictions along with a 
probability sample of all local government jurisdictions, including 
cities, towns, school districts and relevant special districts, 
contained within these covered jurisdictions that conduct their own 
local elections; and (2) a survey of only the 296 jurisdictions listed 
in the Federal Register, an option similar to the methodology we used 
in our 1997 report. 

We chose to focus on the efforts of selected jurisdictions and not to 
survey all jurisdictions for several reasons. First, while we had a 
list of the 296 jurisdictions covered by Section 203, we were unable to 
locate an inventory of the complete population of the sub-jurisdictions 
contained within these jurisdictions that conducted their own elections 
from either the Department of Justice (DOJ) or the Census Bureau. The 
Chief of the Census Bureau office that prepares the determinations for 
Section 203 of the Voting Rights Act told us that it might be possible 
to develop an inventory of all sub-jurisdictions contained within the 
296 covered jurisdictions through a complicated merge of Census' 
Topologically Integrated Geographic Encoding and Referencing (TIGER) 
system data files with its Census of Local Government data files. 
However, she said the Census of Local Government data do not indicate 
whether local governments hold elections or, if they do, who 
administers the elections. Therefore, to identify sub-jurisdictions 
that conduct their own elections and contacts within these entities, we 
would have needed to either canvass election officials in all 296 
counties or other covered areas, as well as state elections officers, 
or construct a population of all sub-jurisdictions from Census Bureau 
data and then select a probability sample of sub-jurisdictions to 
survey and develop our own contact information. We believed this 
approach would have been very difficult, costly, and time consuming. In 
addition, we learned that prior to testimony given at the summer 2006 
hearings for the reauthorization of the Voting Rights Act, a team of 
researchers at the University of Arizona had already surveyed all 296 
jurisdictions listed in the Federal Register, in addition to hundreds 
of other jurisdictions, about similar issues.[Footnote 25] We were 
reluctant to resurvey jurisdictions about related matters so soon 
thereafter. 

For our chosen methodology, we selected a sample of 14 covered 
jurisdictions in 12 states. We selected these jurisdictions because 
they reflected a variety of characteristics, such as size (i.e., voting 
age population), geographic diversity, varying language minority groups 
and their size relative to the voting age population, early voting 
provisions, and the longevity of each jurisdiction's coverage under the 
Section 203 bilingual voting provisions; and, we wanted a diverse group 
of sites to allow us to report on a wide range of jurisdictions' 
experiences with providing bilingual voting assistance. (See table 9 
for a listing of the jurisdictions included in our study and the 
criteria used to select them.) Because we selected a nongeneralizable 
sample of election jurisdictions, the experiences and views discussed 
in this report cannot be generalized to all 296 jurisdictions required 
to provide bilingual voting assistance under Section 203 of the Voting 
Rights Act or to the community-based organizations (CBO) in these 
jurisdictions. 

Table 9: Jurisdictions Selected for GAO Site Visits and the Related 
Information Used to Make the Selections: 

Election jurisdiction: Boston (Suffolk County), MA; 
Jurisdiction covered under Sec. 203 in year 2000 for the first time?: 
No; 
Current covered language group(s): Spanish-heritage; 
Current language minority subgroup(s): Hispanic; 
Census region: Northeast. 

Election jurisdiction: Cook County, IL; 
Jurisdiction covered under Sec. 203 in year 2000 for the first time?: 
No; 
Current covered language group(s): Spanish-heritage, Asian American; 
Current language minority subgroup(s): Hispanic, Chinese; 
Census region: Midwest. 

Election jurisdiction: Harris County, TX; 
Jurisdiction covered under Sec. 203 in year 2000 for the first time?: 
No; 
Current covered language group(s): Spanish- heritage, Asian American; 
Current language minority subgroup(s): Hispanic, Vietnamese; 
Census region: South. 

Election jurisdiction: Jackson County, SD; 
Jurisdiction covered under Sec. 203 in year 2000 for the first time?: 
Yes; 
Current covered language group(s): American Indian; 
Current language minority subgroup(s): Sioux; 
Census region: Midwest. 

Election jurisdiction: King County, WA; 
Jurisdiction covered under Sec. 203 in year 2000 for the first time?: 
Yes; 
Current covered language group(s): Asian American; 
Current language minority subgroup(s): Chinese; 
Census region: West. 

Election jurisdiction: Los Angeles County, CA; 
Jurisdiction covered under Sec. 203 in year 2000 for the first time?: 
No; 
Current covered language group(s): Spanish- heritage, Asian American; 
Current language minority subgroup(s): Hispanic, Chinese, Filipino, 
Japanese, Korean, Vietnamese; 
Census region: West. 

Election jurisdiction: Miami-Dade County, FL; 
Jurisdiction covered under Sec. 203 in year 2000 for the first time?: 
No; 
Current covered language group(s): Spanish- heritage; 
Current language minority subgroup(s): Hispanic; 
Census region: South. 

Election jurisdiction: Montgomery County, MD; 
Jurisdiction covered under Sec. 203 in year 2000 for the first time?: 
Yes; 
Current covered language group(s): Spanish- heritage; 
Current language minority subgroup(s): Hispanic; 
Census region: South. 

Election jurisdiction: Orange County, CA; 
Jurisdiction covered under Sec. 203 in year 2000 for the first time?: 
No; 
Current covered language group(s): Spanish- heritage, Asian American; 
Current language minority subgroup(s): Hispanic, Chinese, Korean, 
Vietnamese; 
Census region: West. 

Election jurisdiction: Kenai Peninsula Borough, AK; 
Jurisdiction covered under Sec. 203 in year 2000 for the first time?: 
No; 
Current covered language group(s): Alaskan Native, American Indian; 
Current language minority subgroup(s): Aleut, American Indian; 
Census region: West. 

Election jurisdiction: Sandoval County, NM; 
Jurisdiction covered under Sec. 203 in year 2000 for the first time?: 
No; 
Current covered language group(s): American Indian; 
Current language minority subgroup(s): Navajo, Pueblo; 
Census region: West. 

Election jurisdiction: Seward County, KS; 
Jurisdiction covered under Sec. 203 in year 2000 for the first time?: 
Yes; 
Current covered language group(s): Spanish- heritage; 
Current language minority subgroup(s): Hispanic; 
Census region: Midwest. 

Election jurisdiction: Starr County, TX; 
Jurisdiction covered under Sec. 203 in year 2000 for the first time?: 
No; 
Current covered language group(s): Spanish- heritage; 
Current language minority subgroup(s): Hispanic; 
Census region: South. 

Election jurisdiction: Suffolk County, NY; 
Jurisdiction covered under Sec. 203 in year 2000 for the first time?: 
No; 
Current covered language group(s): Spanish- heritage; 
Current language minority subgroup(s): Hispanic; 
Census region: Northeast. 

Jurisdiction citizen voting age population in 2000: 388,580; 
Covered language group(s) voting age limited-English proficient 
population in 2000: 11,820; 
Percent limited-English proficient in 2000: 3.0; 
Subject of DOJ action?: Yes; 
Uses early voting?: No; 
Recommended by advocacy groups for study?: Yes. 

Jurisdiction citizen voting age population in 2000: 3,429,235; 
Covered language group(s) voting age limited-English proficient 
population in 2000: 143,175; 
Percent limited-English proficient in 2000: 4.2; 
Subject of DOJ action?: No; 
Uses early voting?: Yes; 
Recommended by advocacy groups for study?: Yes. 

Jurisdiction citizen voting age population in 2000: 1,964,970; 
Covered language group(s) voting age limited-English proficient 
population in 2000: 124,885; 
Percent limited-English proficient in 2000: 6.4; 
Subject of DOJ action?: Yes; 
Uses early voting?: Yes; 
Recommended by advocacy groups for study?: Yes. 

Jurisdiction citizen voting age population in 2000: 655[A]; 
Covered language group(s) voting age limited-English proficient 
population in 2000: 25[A]; 
Percent limited-English proficient in 2000: 3.8[A]; 
Subject of DOJ action?: No; 
Uses early voting?: No; 
Recommended by advocacy groups for study?: No. 

Jurisdiction citizen voting age population in 2000: 1,220,300; 
Covered language group(s) voting age limited-English proficient 
population in 2000: 10,535; 
Percent limited-English proficient in 2000: 0.9; 
Subject of DOJ action?: No; 
Uses early voting?: Yes; 
Recommended by advocacy groups for study?: Yes. 

Jurisdiction citizen voting age population in 2000: 4,992,965; 
Covered language group(s) voting age limited-English proficient 
population in 2000: 644,505; 
Percent limited-English proficient in 2000: 12.9; 
Subject of DOJ action?: Yes[B]; 
Uses early voting?: Yes; 
Recommended by advocacy groups for study?: Yes. 

Jurisdiction citizen voting age population in 2000: 1,164,345; 
Covered language group(s) voting age limited-English proficient 
population in 2000: 273,975; 
Percent limited-English proficient in 2000: 23.5; 
Subject of DOJ action?: Yes; 
Uses early voting?: Yes; 
Recommended by advocacy groups for study?: Yes. 

Jurisdiction citizen voting age population in 2000: 539,745; 
Covered language group(s) voting age limited-English proficient 
population in 2000: 10,055; 
Percent limited-English proficient in 2000: 1.9; 
Subject of DOJ action?: No; 
Uses early voting?: No; 
Recommended by advocacy groups for study?: No. 

Jurisdiction citizen voting age population in 2000: 1,631,415; 
Covered language group(s) voting age limited-English proficient 
population in 2000: 137,160; 
Percent limited-English proficient in 2000: 8.4; 
Subject of DOJ action?: No; 
Uses early voting?: Yes; 
Recommended by advocacy groups for study?: Yes. 

Jurisdiction citizen voting age population in 2000: [A]; 
Covered language group(s) voting age limited-English proficient 
population in 2000: [A]; 
Percent limited-English proficient in 2000: [A]; 
Subject of DOJ action?: No; 
Uses early voting?: Yes; 
Recommended by advocacy groups for study?: No. 

Jurisdiction citizen voting age population in 2000: 6,670; 
Covered language group(s) voting age limited-English proficient 
population in 2000: 2,525; 
Percent limited-English proficient in 2000: 37.9; 
Subject of DOJ action?: Yes; 
Uses early voting?: Yes; 
Recommended by advocacy groups for study?: Yes. 

Jurisdiction citizen voting age population in 2000: 11,715; 
Covered language group(s) voting age limited-English proficient 
population in 2000: 1,160; 
Percent limited-English proficient in 2000: 9.9; 
Subject of DOJ action?: No; 
Uses early voting?: Yes; 
Recommended by advocacy groups for study?: Yes. 

Jurisdiction citizen voting age population in 2000: 22,600; 
Covered language group(s) voting age limited-English proficient 
population in 2000: 10,050; 
Percent limited-English proficient in 2000: 44.5; 
Subject of DOJ action?: No; 
Uses early voting?: Yes; 
Recommended by advocacy groups for study?: No. 

Jurisdiction citizen voting age population in 2000: 978,075; 
Covered language group(s) voting age limited-English proficient 
population in 2000: 16,685; 
Percent limited-English proficient in 2000: 1.7; 
Subject of DOJ action?: Yes; 
Uses early voting?: No; 
Recommended by advocacy groups for study?: No. 

Source: GAO analysis of data from U.S. Census Bureau, DOJ, local/state 
officials, and national advocacy groups. 

[A] For jurisdictions covered because of the American Indian 
Reservation approach, population data are provided on citizens who are 
American Indians or Alaska Natives in the part of the jurisdiction that 
is contained within the Indian Reservation. A discussion of these 
criteria is provided in appendix II. 

[B] The DOJ actions involved subjurisdictions within Los Angeles 
County, not the county itself. 

[C] Population data were not provided by the Census Bureau when the 
total number of voting age citizens is less than 50. 

[End of table] 

Generally, we obtained information from the single office responsible 
for conducting elections in each of these jurisdictions. However, in 
two jurisdictions--Cook County, Ill., and Harris County, Tex.--we met 
with officials in two separate offices because each office had separate 
responsibilities for statewide and federal elections held in the 
jurisdiction. In Cook County, the Chicago Board of Elections 
Commissioners is responsible for administering these elections in the 
portion of Cook County that is Chicago, and the Cook County Clerk is 
responsible for administering elections in the remainder of Cook 
County. In Harris County, the tax assessor/collector is responsible for 
voter registration, and the County Clerk is responsible for the 
remainder of election activities. Due to numerous scheduling conflicts, 
we were unable to arrange a visit to Sandoval County, N. Mex; however, 
we did obtain written responses to our questions from an election 
official in Sandoval County via electronic means. In one jurisdiction-
-Kenai Peninsula Borough, Alaska--we interviewed not only a local 
government official who has responsibility for local elections but also 
state officials, as the state has responsibility for overseeing federal 
and statewide elections in Alaska jurisdictions. Also, we selected 2 
sub-jurisdictions among the 14 covered jurisdictions to learn about the 
bilingual voting assistance these localities provided in local 
elections. We identified these sub-jurisdictions by asking election 
officials about what localities within their jurisdictions conducted 
their own local elections. These localities were: Los Angeles City, 
Calif., and Kadoka City, S. Dak. 

In addition to obtaining information from election officials, we also 
selected 38 CBOs that represent relevant language minority communities 
in 11 of the 14 jurisdictions.[Footnote 26] We selected the CBOs 
through inquiries with election officials, contacts with national level 
advocacy groups to learn of local counterparts, contacts with the CBOs 
themselves to learn of additional groups in their communities, and 
Internet searches. In our discussions with representatives with a few 
CBOs, we were able also to speak with a few language minority voters 
(in one case with the help of an interpreter) who said they had used 
the bilingual assistance provided by their jurisdiction. 

We either conducted on-site interviews with or obtained information 
electronically from election officials and CBO representatives 
regarding the bilingual voting assistance provided in the November 2006 
general election and any subsequent elections through June 2007. Using 
a semi-structured interview guide, we obtained information from the 
election offices about: 

* office staff assigned to provide bilingual assistance; 

* the office's strategy for identifying needs and providing bilingual 
assistance; 

* the type(s) and availability of bilingual assistance provided at 
different stages of the election process for the November 2006 general 
election and any subsequent elections, including voter education 
efforts, voter registration, early voting and absentee voting, 
recruiting and training poll workers, ballot design and voting systems, 
Election Day activities, and the usefulness of this assistance to 
voters; and: 

* supporting documentation as evidence of the types of bilingual voting 
assistance (e.g., sample ballots, pamphlets, voter education materials, 
etc.) provided to language minority voters in these jurisdictions. 

Using a semi-structured interview guide, we also obtained information 
from CBO representatives about their roles in providing bilingual 
voting assistance in the November 2006 general election and any 
subsequent elections; their views about the bilingual assistance 
provided by the election office in these elections; and the usefulness 
of this assistance. 

We also interviewed officials and obtained documents from other 
relevant parties. Interviews and documents were obtained from the DOJ 
Civil Rights Division, which is responsible for providing program 
guidance and enforcing compliance with the requirements under Section 
203 of the Voting Rights Act. We also interviewed officials from the 
EAC, which was established by the Help America Vote Act of 2002 to, 
among other things, act as a clearinghouse and resource for information 
and review of procedures with respect to the administration of federal 
elections. Additionally, we interviewed the Chief of the Census Bureau 
office that prepares the determinations for Section 203 of the Voting 
Rights Act. We reviewed pertinent federal laws, regulations, and agency 
guidance pertaining to the bilingual voting provisions. We also 
reviewed extensive prior GAO work, other national studies, reports, and 
news articles; attended several national conferences; and interviewed 
the secretary of state for one state with jurisdictions covered by 
Section 203 to gain further insight regarding these issues. We 
conducted this performance audit from October 2006 to January 2008 in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

[End of section] 

Appendix II: Section 203 Coverage Criteria Regarding Language Minority 
Groups and Covered Jurisdictions: 

Section 203 of the Voting Rights Act provides specific criteria for 
determining which states and jurisdictions are covered by the Section 
203 language minority provisions. The Director of the Census Bureau has 
responsibility for making the official determinations regarding which 
political subdivisions are covered under section 203. To make its 
determinations, the Census Bureau reevaluates the jurisdictions covered 
by Section 203 every 10 years using new Census data as they become 
available. [Footnote 27] The number of covered jurisdictions has risen 
from 227 in 1975, the first year jurisdictions were required to comply 
with Section 203,[Footnote 28] to 296 jurisdictions in 30 states in 
2002, the year of the most recent determination.[Footnote 29] The 
Census Bureau uses classifications--states, counties, minor civil 
divisions, or tribal areas--and variables such as voter age, language 
proficiency, and citizenship as self-reported on Census forms to 
determine the jurisdictions to be covered under Section 203. The 
following material in figure 1 describes the coverage criteria. 

Figure 1: Section 203 Coverage Criteria for Implementation of the 
Voting Rights Act Provisions Regarding Language Minority Groups: 

This figure lists Section 203 coverage criteria for implementation of 
the Voting Rights Act provisions regarding language minority groups. 

§55.6 Coverage Under Section 203(c).

(a) Coverage formula. There are four ways in which a political 
subdivision can become subject to section 203(c).[A] 

(1) Political subdivision approach. A political subdivision is covered 
if: 
(i) More than 5 percent of its voting age citizens are members of a 
single language minority group and are limited-English proficient; and: 
(ii) The illiteracy rate of such language minority citizens in the 
political subdivision is higher than the national illiteracy rate. 

(2) State approach. A political subdivision is covered if: 
(i) It is located in a state in which more than 5 percent of the voting 
age citizens are members of a single language minority and are limited-
English proficient; 
(ii) The illiteracy rate of such language minority citizens in the 
state is higher than the national illiteracy rate; and: 
(iii) Five percent or more of the voting age citizens of the political 
subdivision are members of such language minority group and are limited-
English proficient. 

(3) Numerical approach. A political subdivision is covered if: 
(i) More than 10,000 of its voting age citizens are members of a single 
language minority group and are limited-English proficient; and: 
(ii) The illiteracy rate of such language minority citizens in the 
political subdivision is higher than the national illiteracy rate. 

(4) Indian reservation approach. A political subdivision is covered if 
there is located within its borders all or any part of an Indian 
reservation: 
(i) In which more than 5 percent of the voting age American Indian or 
Alaska Native citizens are members of a single language minority group 
and are limited-English proficient; and: 
(ii) The illiteracy rate of such language minority citizens is higher 
than the national illiteracy rate. 

(b) Definitions. For the purpose of determinations of coverage under 
section 203(c), "limited-English proficient" means unable to speak or 
understand English adequately enough to participate in the electoral 
process; "Indian reservation" means any area that is an American Indian 
or Alaska Native area, as defined by the Census Bureau for the purposes 
of the decennial census; and "illiteracy" means the failure to complete 
the fifth primary grade. 

(c) Determinations. Determinations of coverage under section 203(c) are 
made with regard to specific language groups of the language minorities 
listed in section 203(e).

[See PDF for image] 

Source: 28 C.F.R. §55.6. 

[A] The criteria for coverage are contained in Section 203(b). 

[End of figure] 

The Director of the Census Bureau applied these criteria to the data 
obtained from the 2000 census (the most recent census) to determine 
which jurisdictions are covered under Section 203. The Director of the 
Census Bureau identifies the relevant language groups for the covered 
jurisdictions. Because the Census Bureau data used to determine the 
covered language are self-reported, the specific language an individual 
speaks is not always identified and thus jurisdictions may not know the 
specific language for which they are to provide assistance. For 
example, an individual may identify their language as "Indian 
language," but this does not clarify for the jurisdiction what specific 
Indian language assistance it is to provide. Also, some Section 203 
covered jurisdictions have more than one language group for which they 
are required to provide voting assistance. (See table 10 for the list 
of jurisdictions covered under Section 203 and the respective language 
groups, as of July 2002.) 

Table 10: Jurisdictions Covered under Section 203 of the Voting Rights 
Act: 

[See PDF for image] 

Source: Federal Register (67 Fed. Reg. 48,871-48,877 (2002) (codified 
in appendix to 28 C.F.R. Part 55)). 

Note: In the cases where a state is identified as covered, those 
counties or county equivalents not displayed in the table are exempt 
from the obligation. 

[End of table] 

[End of section] 

Appendix III: DOJ Actions under Section 203 of the Voting Rights Act, 
1980-2007: 

Jurisdiction: County and City of San Francisco; 
State: CA; 
Date: 1980; 
Type of action: Consent decree. 

Jurisdiction: San Juan County; 
State: UT; 
Date: 1984; 
Type of action: Memorandum of agreement[A]. 

Jurisdiction: McKinley County; 
State: NM; 
Date: 1986; 
Type of action: Consent decree[B]. 

Jurisdiction: State of Arizona; 
State: AZ; 
Date: 1989; 
Type of action: Consent decree[C]. 

Jurisdiction: New Mexico and Sandoval County; 
State: NM; 
Date: 1990; 
Type of action: Consent decree[D]. 

Jurisdiction: Dade (Metropolitan) County; 
State: FL; 
Date: 1993; 
Type of action: Consent decree. 

Jurisdiction: Cibola County; 
State: NM; 
Date: 1993; 
Type of action: Stipulation and order[E]. 

Jurisdiction: Socorro County; 
State: NM; 
Date: 1993; 
Type of action: Consent decree. 

Jurisdiction: Alameda County; 
State: CA; 
Date: 1996; 
Type of action: Settlement agreement and order. 

Jurisdiction: San Juan County; 
State: NM; 
Date: 1996; 
Type of action: Memorandum of agreement. 

Jurisdiction: Bernalillo County; 
State: NM; 
Date: 1998; 
Type of action: Consent decree[F]. 

Jurisdiction: City of Lawrence; 
State: MA; 
Date: 1999; 
Type of action: Settlement agreement and order. 

Jurisdiction: County and City of Passaic; 
State: NJ; 
Date: 1999; 
Type of action: Consent decree[G]. 

Jurisdiction: Orange County; 
State: FL; 
Date: 2002; 
Type of action: Consent decree. 

Jurisdiction: Brentwood Union Free School District; 
State: NY; 
Date: 2003; 
Type of action: Consent decree. 

Jurisdiction: San Benito County; 
State: CA; 
Date: 2004; 
Type of action: Consent decree. 

Jurisdiction: San Diego County; 
State: CA; 
Date: 2004; 
Type of action: Consent decree. 

Jurisdiction: Ventura County; 
State: CA; 
Date: 2004; 
Type of action: Consent decree. 

Jurisdiction: Suffolk County; 
State: NY; 
Date: 2004; 
Type of action: Consent decree. 

Jurisdiction: Harris County; 
State: TX; 
Date: 2004; 
Type of action: Memorandum of agreement. 

Jurisdiction: Yakima County; 
State: WA; 
Date: 2004; 
Type of action: Consent decree. 

Jurisdiction: City of Azusa; 
State: CA; 
Date: 2005; 
Type of action: Consent decree. 

Jurisdiction: City of Paramount; 
State: CA; 
Date: 2005; 
Type of action: Consent decree. 

Jurisdiction: City of Rosemead; 
State: CA; 
Date: 2005; 
Type of action: Consent decree. 

Jurisdiction: City of Boston; 
State: MA; 
Date: 2005; 
Type of action: Memorandum of agreement. 

Jurisdiction: Westchester County; 
State: NY; 
Date: 2005; 
Type of action: Consent decree. 

Jurisdiction: Cochise County; 
State: AZ; 
Date: 2006; 
Type of action: Consent decree. 

Jurisdiction: Maricopa County; 
State: AZ; 
Date: 2006; 
Type of action: Memorandum of agreement. 

Jurisdiction: Broward County; 
State: FL; 
Date: 2006; 
Type of action: Memorandum of agreement. 

Jurisdiction: City of Springfield; 
State: MA; 
Date: 2006; 
Type of action: Consent decree. 

Jurisdiction: City of Philadelphia; 
State: PA; 
Date: 2006; 
Type of action: Complaint. 

Jurisdiction: Hale County; 
State: TX; 
Date: 2006; 
Type of action: Consent decree. 

Jurisdiction: Kane County; 
State: IL; 
Date: 2007; 
Type of action: Consent decree. 

Jurisdiction: City of Walnut; 
State: CA; 
Date: 2007; 
Type of action: Complaint. 

Jurisdiction: City of Earth; 
State: TX; 
Date: 2007; 
Type of action: Complaint. 

Jurisdiction: Seagraves Independent School District; 
State: TX; 
Date: 2007; 
Type of action: Complaint. 

Jurisdiction: Littlefield Independent School District; 
State: TX; 
Date: 2007; 
Type of action: Complaint. 

Jurisdiction: Post Independent School District; 
State: TX; 
Date: 2007; 
Type of action: Complaint. 

Jurisdiction: Smyer Independent School District; 
State: TX; 
Date: 2007; 
Type of action: Complaint. 

Source: DOJ officials. 

[A] Consent decree was amended in 1990. 

[B] Consent decree was amended in 1990. 

[C] Consent decree amended in 1993. 

[D] Consent decree modified in 1994 and again in 2004. 

[E] Agreement was extended in 2004. 

[F] Consent decree extended in 2003. 

[G] Additional criteria set forth in supplemental consent decree in 
2001. 

[End of table] 

[End of section] 

Appendix IV: Examples of Bilingual Voting Written Assistance Materials: 

The following are excerpted examples of bilingual voting materials 
provided by election officials in covered jurisdictions. 

Figure 2: Excerpt of a Chinese Voter Registration Form - King County, 
Wash. 

This figure is a picture of a Chinese voter registration form from King 
County, Washington. 

[See PDF for image] 

Source: Election officials. 

[End of figure] 

Figure 3: English/Chinese Bilingual Absentee Ballot Request Form - King 
County, Wash. 

This figure is a copy of the English and Chinese language absentee 
ballot request from King County, Washington. 

[See PDF for image] 

Source: Election officials. 

[End of figure] 

Figure 4: English/Vietnamese Bilingual Sample Ballot - Boston, Mass. 

This figure is a copy of the English and Vietnamese language sample 
ballot from Boston, Massachusetts. 

[See PDF for image] 

Source: Election officials. 

[End of figure] 

Figure 5: English/Spanish Bilingual Official Ballot - Boston, Mass. 

This figure is a copy of an English and Spanish language official 
ballot from Boston, Massachusetts. 

[See PDF for image] 

Source: Election officials. 

[End of figure] 

Figure 6: Spanish Voting Instructions - Los Angeles, Calif. 

This figure is a copy of two pages of voting instructions written in 
Spanish from Los Angeles, California. 

[See PDF for image] 

Source: Election officials. 

[End of figure] 

Figure 7: Bilingual Polling Place Signs - King County, Wash. 

This figure is a combination of two voting signs with the words written 
in two languages from King County, Washington. 

[See PDF for image] 

Source: Election officials. 

[End of figure] 

Figure 8: Bilingual Poll Worker Nametags and Buttons - Orange County, 
Calif. 

This figure are copies of nametags and buttons work by bilingual poll 
workers in Orange County, California. 

[See PDF for image] 

Source: Election officials. 

[End of figure] 

Figure 9: Multilingual Tally Card - Los Angeles, Calif. 

This figure is a copy of a multilungial tally card from Los Angeles, 
California. 

[See PDF for image] 

Source: Election officials. 

[End of figure] 

[End of section] 

Appendix V: Additional Challenges to Evaluating the Usefulness of 
Bilingual Voting Assistance: 

In addition to the three key issues discussed earlier in this report, 
other difficult issues also face election offices in evaluating the 
bilingual voting assistance they provide, including: (1) how to 
appropriately sample, or select, polling places and language minority 
voters to include in an evaluation; (2) the receptivity of language 
minority voters to participation in a study; (3) having data collectors 
who can speak fluently the specific language, and possibly dialect, of 
language minority voters in a jurisdiction; (4) having the necessary 
staff and technical expertise to conduct a methodologically sound 
evaluation; and (5) the likely expense of an evaluation. 

* Determining how to sample: When determining how to gather data from 
the language minority voting population, a jurisdiction must decide 
whether to conduct a census (collect data from everyone) or to select a 
sample of the population from whom to get information. Depending on 
various factors, including the numbers of precincts and the numbers of 
voters in the jurisdiction, collecting information from all members of 
a given population, such as all language minority voters could be very 
costly, as well as logistically difficult to do in evaluating the 
usefulness of bilingual voting assistance. Therefore, selecting a 
probability or nonprobability sample can be a more cost-effective 
alternative.[Footnote 30] For example, if a jurisdiction was unable to 
collect data from all voters on Election Day, it could select a 
probability sample of voters in an exit poll. To be able to generalize 
the results to all language minority voters, such an exit poll would 
need to be based on a probability sample of precincts in the 
jurisdiction and voters voting within each selected precinct throughout 
Election Day. Alternatively, jurisdictions could collect information 
from language minority voters through methods such as comment cards 
soliciting feedback about bilingual voting placed on tables in 
precincts on Election Day, or they could log individuals' calls to a 
telephone hotline to report voting problems. While useful information 
could be obtained, there would be no guarantee that the voters who 
completed the cards or called the hotline were statistically 
representative of all voters who used the bilingual voting assistance. 
As a result, a jurisdiction would need to be cautious about 
interpreting the information obtained from this source because the 
information could be biased. 

* Identifying willing participants: It is necessary to have language 
minority voters who are receptive to participation in an evaluation. In 
some locations, language minority voters may be sensitive about their 
English language skills, and consequently, there may be some 
embarrassment about needing to use bilingual voting assistance or about 
the extent to which the assistance is helpful. In these instances, it 
may be difficult to get language minority voters to cooperate, or, if 
they do cooperate, difficult to obtain accurate information about their 
experiences in using the assistance provided. 

* Obtaining data collectors with language skills: Any evaluation of 
bilingual voting assistance must use individuals trained in data 
collection methods. These individuals would also need to speak fluently 
the specific language, and possibly dialect, spoken by language 
minority voters in a jurisdiction in order to effectively communicate 
with language minority voters asked to participate in a study. 

* Having the necessary staff: Election offices face the difficult 
issues of having the necessary staff and technical expertise to conduct 
methodologically sound evaluations in evaluating the effectiveness of 
the bilingual voting assistance provided. Since the purpose of election 
offices is to conduct elections, it is unlikely that election offices 
will have staff available who either have the time or professional 
expertise to conduct an evaluation. Therefore, election offices would 
likely need to seek outside professional assistance, such as through a 
contract with a consultant, to do so. 

* Having sufficient resources: Efforts to evaluate program 
effectiveness can be expensive. Unless an election office received 
special funding to evaluate its bilingual assistance program, it would 
likely have to rely on existing operating budgets that may already be 
limited. Officials in five jurisdictions said they had no money or 
staff to evaluate the assistance they provided. The election 
administrator in one jurisdiction stated that their top funding 
priorities were for operational needs, not for conducting such a study. 

[End of section] 

Appendix VI: Comments from the U.S. Election Assistance Commission: 

U.S. Election Assistance Commission: 
Office Of The Executive Director: 
1225 New York Avenue, NW, Suite 1100: 
Washington, DC. 20005: 

December 21, 2007: 

Mr. William O. Jenkins, Jr.: 
Director, Homeland Security and Justice Issues: 
U.S. Government Accountability Office: 
Washington, DC 20548: 

RE: Comments regarding proposed GAO-08-182 Report: 

Dear Mr. Jenkins: 

The U.S. Election Assistance (EAC) is grateful for the opportunity to 
comment on GAO's report, Bilingual Voting Assistance: Selected 
Jurisdictions' Strategies for Identifying Needs and Providing 
Assistance submitted to the U.S. Election Assistance Commission (EAC) 
on December 13, 2007. The EAC appreciates GAO's research into the area 
of election language accessibility and plans to make use of the report 
in planning future EAC studies and research activities. The EAC is 
committed to providing election officials with resources that address 
the needs of voters with limited English proficiency. 

As noted in your report, the EAC supports State and local election 
officials in the area of bilingual voting assistance through its 
Language Accessibility Program (LAP), Election Management Guidelines 
Program (EMG), and research activities under Section 241 of the Help 
America Vote Act of 2002 (HAVA). These programs have already produced 
resources that are available to election officials and the public, 
including: 

* Glossary of Key Election Terminology [English/Spanish – 
Spanish/English] - This glossary contains more than 1,800 terms and 
phrases used in elections across the United States. The glossary 
assists election officials in providing culturally and linguistically 
appropriate translations to voters with limited English proficiency. It 
also contains a Spanish to English section as a tool for voters seeking 
to familiarize themselves with election terminology in English. 

* Spanish version of the National Mail-In Voter Registration Form 
prescribed by the National Voter Registration Act (NVRA). 

* Successful Practices for Poll Worker Recruitment, Training, and 
Retention – This guidebook presents a variety of field-tested 
techniques, which can be adapted by election jurisdictions of varying 
sizes and demographics, to aid in recruitment, training, and management 
of bilingual poll workers. 

* A Guidebook for Recruiting College Poll Workers – The guidebook 
includes a chapter on recruitment of minority and bilingual students to 
serve as poll workers on Election Day. 

* Effective Designs for the Administration of Federal Elections – This 
report provides best practice samples for the design of ballots and 
voter information materials, including best practices for developing 
materials in multiple languages. 

All of these publications and reports are available on the EAC's Web 
site at [hyperlink, http://www.eac.gov]. 

Additionally, the EAC is in the process of developing a number of new 
tools for elections officials. These include: 

* Translation of the Glossary of Key Election Terminology into Chinese, 
Japanese, Korean, Tagalog, and Vietnamese (expected May 2008). 

* Translation of the National Voter Registration Form prescribed by 
NVRA into Chinese, Japanese, Korean, Tagalog, and Vietnamese. 

* Development of the brochure A Voter's Guide to Federal Elections - 
The goal of this publication is to inform voters about the Federal 
election process, providing information concerning voter registration, 
polling places, absentee ballots, provisional ballots, poll workers, 
and similar topics. This brochure will be available initially in 
English, Spanish, Chinese, Japanese, Korean, Tagalog, and Vietnamese; 
the EAC will also examine the feasibility of providing this information 
in audio format to Native American and Alaska Native voters.

* Development of a chapter (and accompanying brochure) on language 
accessibility in the EAC's Election Management Guidelines. The chapter 
will seek to provide election officials recommendations for addressing 
the particular challenges jurisdictions face in providing bilingual 
assistance throughout voter registration and election activities, 
including assistance to Native Americans and Alaska Natives. 

These recent and upcoming activities are just the beginning of the 
EAC's efforts to be the source for information on bilingual voting 
assistance. The EAC will continue to seek feedback from election 
officials, interest groups, Federal agencies, and the general public to 
identify resources and materials the EAC may provide in this area. 

GAO's final report will be an invaluable resource to election officials 
as they strive to meet the needs of all voters. The EAC sincerely 
appreciates the opportunity to provide information for this report. If 
you need further information or have any questions regarding EAC's 
language accessibility activities, please do not hesitate to contact us 
at your earliest convenience. 

Sincerely yours,

Signed by:

Thomas R. Wilkey:
Executive Director: 

[End of section] 

Appendix VII: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

William O. Jenkins, Jr. (202) 512-8777 or jenkinswo@gao.gov: 

Staff Acknowledgments: 

In addition to those named above, Dawn E. Hoff, Assistant Director; 
David Alexander, Assistant Director; Claudia K. Becker; Natalie Chaney; 
Geoffrey Hamilton; Linda Miller; Hugh C. Paquette; Deena D. Richart; 
and Clarence Tull, Sr., made key contributions to this report. 

[End of section] 

Related GAO Products: 

Elections: Further Testing Could Provide Increased but Not Absolute 
Assurance That Voting Systems Did Not Cause Undervotes in Florida's 
13th Congressional District. GAO-08-97T. Washington, D.C.: October 2, 
2007. 

Elections: Status of GAO's Review of Voting Equipment Used in Florida's 
13th Congressional District. GAO-07-1167T. Washington, D.C.: August 3, 
2007. 

Elections: Action Plans Needed to Fully Address Challenges in 
Electronic Absentee Voting Initiatives for Military and Overseas 
Citizens. GAO-07-774. Washington, D.C.: June 14, 2007. 

Elections: All Levels of Government Are Needed to Address Electronic 
Voting System Challenges. GAO-07-741T. Washington, D.C.: April 18, 
2007. 

Elections: All Levels of Government Are Needed to Address Electronic 
Voting System Challenges. GAO-07-576T. Washington, D.C.: March 7, 2007. 

Elections: DOD Expands Voting Assistance to Military Absentee Voters, 
but Challenges Remain. GAO-06-1134T. Washington, D.C.: September 28, 
2006. 

Elections: The Nation's Evolving Election System as Reflected in the 
November 2004 General Election. GAO-06-450. Washington, D.C.: June 6, 
2006. 

Elections: Absentee Voting Assistance to Military and Overseas Citizens 
Increased for 2004 General Election, but Challenges Remain. GAO-06-521. 
Washington, D.C.: April 7, 2006. 

Election Reform: Nine States' Experiences Implementing Federal 
Requirements for Computerized Statewide Voter Registration Lists. GAO- 
06-247. Washington, D.C.: February 7, 2006. 

Elections: Views of Selected Local Election Officials on Managing Voter 
Registration and Ensuring Eligible Citizens Can Vote. GAO-05-997. 
Washington, D.C.: September 27, 2005. 

Elections: Federal Efforts to Improve Security and Reliability of 
Electronic Voting Systems Are Under Way, but Key Activities Need to Be 
Completed. GAO-05-956. Washington, D.C.: September 21, 2005. 

Elections: Additional Data Could Help State and Local Elections 
Officials Maintain Accurate Voter Registration Lists. GAO-05-478. 
Washington, D.C.: June 10, 2005. 

Department of Justice's Activities to Address Past Election-Related 
Voting Irregularities. GAO-04-1041R. Washington, D.C.: September 14, 
2004. 

Elections: Electronic Voting Offers Opportunities and Presents 
Challenges. GAO-04-975T. Washington, D.C.: July 20, 2004. 

Elections: A Framework for Evaluating Reform Proposals. GAO-02-90. 
Washington, D.C.: October 15, 2001. 

Elections: Perspectives on Activities and Challenges across the Nation. 
GAO-02-3. Washington, D.C.: October 15, 2001. 

Elections: Statistical Analysis of Factors That Affected Uncounted 
Votes in the 2000 Presidential Election. GAO-02-122. Washington, D.C.: 
October 15, 2001. 

Elections: Status and Use of Federal Voting Equipment Standards. GAO- 
02-52. Washington, D.C.: October 15, 2001. 

Voters with Disabilities: Access to Polling Places and Alternative 
Voting Methods. GAO-02-107. Washington, D.C.: October 15, 2001. 

Elections: Voting Assistance to Military and Overseas Citizens Should 
Be Improved. GAO-01-1026. Washington, D.C.: September 28, 2001. 

Comparison of Voting Age Population to Registered Voters in the 40 
Largest U.S. Counties. GAO-01-560R. Washington, D.C.: March 23, 2001. 

Elections: The Scope of Congressional Authority in Election 
Administration. GAO-01-470. Washington, D.C.: March 13, 2001. 

Bilingual Voting Assistance: Assistance Provided and Costs. GAO/GGD-97- 
81. Washington, D.C.: May 9, 1997. 

Puerto Rico: Confusion over Applicability of the Electoral Law to 
Referendum Process. HRD-93-84. Washington, D.C.: May 28, 1993. 

Voting: Some Procedural Changes and Informational Activities Could 
Increase Turnout. PEMD-91-1. Washington, D.C.: November 2, 1990. 

Bilingual Voting Assistance: Costs of and Use during the November 1984 
General Election. GGD-86-134BR. Washington, D.C.: September 15, 1986. 

Justice Can Further Improve Its Monitoring of Changes in State/Local 
Voting Laws. GGD-84-9. Washington, D.C.: December 19, 1983. 

[End of section] 

Footnotes: 

[1] There are 296 jurisdictions required to provide bilingual 
assistance under Section 203. For the specific criteria for determining 
which jurisdictions are to be covered under Section 203, see appendix 
II. 

[2] Section 9 of Pub. L. No. 109-246, 120 Stat. 577 (2006). 

[3] Dr. James Tucker and Dr. Rodolfo Espino, "Minority Language 
Assistance Practices in Public Elections" (Arizona State University: 
Mar. 7, 2006). 

[4] For purposes of this report, CBO is defined as community leaders, 
educators, business groups, labor groups, parent-teacher organizations, 
senior citizen groups, church groups, social and fraternal 
organizations, veterans groups, and others who are knowledgeable about 
bilingual voting issues affecting the relevant language minority 
community. 

[5] A nongeneralizable, or nonprobability, sample is when 
nonstatistical judgment is used to select members of the sample, 
usually using specific characteristics of the population as criteria. 
Results from a nongeneralizable sample cannot be used to make 
inferences about a population, because in a nongeneralizable sample 
some elements of the population being studied have no chance or an 
unknown chance of being selected as part of the sample. 

[6] See related GAO products at the end of this report for a list of 
our prior work. 

[7] Pub. L. No 89-110, 79 Stat. 437 (codified as amended at 42 U.S.C. 
§§1973 to 1973bb-1). 

[8] Another language provision is contained in Section 4(f)(4) of the 
Voting Rights Act but is not included in the scope of this report. Both 
of these provisions require covered jurisdictions to provide certain 
voting materials and assistance in the language of the applicable 
minority group but Section 4(f)(4) requires covered jurisdictions to 
submit specified types of proposed election law changes to the 
Department of Justice for preclearance under Section 5 of the Voting 
Rights Act. The formulas that trigger coverage are distinct for the two 
provisions. DOJ took actions under Section 4(f)(4) against Ector 
County, R.I. (2005), Brazos County, Tex. (2006), and Galveston County, 
Tex. (2007). 

[9] 28 C.F.R. Part 55. 

[10] GAO, Elections: The Nation's Evolving Election System as Reflected 
in the November 2004 General Election, GAO-06-450 (Washington, D.C.: 
June 6, 2006). 

[11] There are 296 covered jurisdictions listed in the Federal 
Register, but the exact number of elections offices tasked with 
providing bilingual voting assistance is much higher. We do not know 
this exact number because for each of the 296 covered jurisdictions, 
there may be many covered sub-jurisdictions such as cities or utility 
districts that are required to comply with Section 203 for any of the 
elections they administer. 

[12] Provisional voting is the use of provisional ballots (subject to 
later verification of registration) in elections in certain 
circumstances where a voter's eligibility is unclear. 

[13] GAO, Bilingual Voting Assistance: Costs of and Use during the 
November 1984 General Election, GAO/GGD-86-134BR (Washington, D.C.: 
Sept. 15, 1986). 

[14] GAO, Bilingual Voting Assistance: Assistance Provided and Costs, 
GAO/GGD-97-81 (Washington, D.C.: May 9, 1997). 

[15] Our prior efforts to determine the costs associated with providing 
bilingual voting assistance revealed that because jurisdictions and 
states are not required to maintain such cost data, information 
available on their costs was scant. 

[16] GAO, Elections: The Nation's Evolving Election System as Reflected 
in the November 2004 General Election, GAO-06-450 (Washington, D.C.: 
June 6, 2006). 

[17] Dr. James Tucker and Dr. Rodolfo Espino, "Minority Language 
Assistance Practices in Public Elections" (Arizona State University: 
Mar. 7, 2006). 

[18] The one election jurisdiction included in our study where election 
officials did not report actively providing any bilingual voting 
assistance is the Kenai Peninsula Borough in Alaska. The Kenai 
Peninsula Borough Clerk is responsible for the administration of local 
elections whereas the State of Alaska, Division of Elections, is 
responsible for the administration of statewide and federal elections. 
A local Kenai Peninsula Borough election official reported that while 
they were aware that the Kenai Peninsula Borough was covered under 
Section 203, they maintained that bilingual voting assistance wasn't 
needed and provided documentation that one Native Alaskan community 
declined the assistance. In addition, state election officials in one 
region, who are responsible for the administration of statewide and 
federal elections in Kenai Peninsula Borough such as the November 2006 
election, did not report making any special arrangements to provide 
bilingual voting assistance in this particular area of the state. 
However, we learned that local poll workers in at least two targeted 
communities took the initiative to provide bilingual voting assistance 
to those who sought it for this election. Senior officials with 
Alaska's Division of Elections reported that they were, at the time of 
the 2006 election, unaware that Kenai Peninsula Borough was covered 
under Section 203. These officials also told us that they are in the 
process of reviewing their bilingual voting assistance program. 

[19] All 14 of the election offices we contacted reported offering 
eligible voters an absentee voting option and 9 of the 14 election 
offices reported offering an early voting option. 

[20] "Targeting" refers to a system in which the minority language 
materials or assistance are provided to fewer than all persons or 
registered voters. It is the view of the U.S. Attorney General that a 
targeting system will normally fulfill the minority language 
requirements if it is designed and implemented in such a way that 
language minority group members who need minority language materials 
and assistance receive them. 

[21] Aleut is one branch of the Eskimo-Aleut language family and has 
multiple dialects. 

[22] GAO, Results-Oriented Government: GPRA Has Established a Solid 
Foundation for Achieving Greater Results, GAO-04-38 (Washington, D.C.: 
Mar. 10, 2004). 

[23] By formal evaluation, we mean a systematic examination of the 
extent to which the provided bilingual voting assistance successfully 
achieved its intended purpose(s). 

[24] Evaluations of effectiveness, or outcomes, can be distinguished 
from process or implementation evaluations, which are designed to 
assess the extent to which a program is operating as intended. As we 
have stated before, effectiveness evaluations are difficult to design 
and execute because optimal conditions for the scientific study of 
complex social programs almost never exist. Attributing results to a 
particular intervention can be difficult when such programs are 
evaluated in real world settings that pose numerous methodological 
challenges. 

[25] Dr. James Tucker and Dr. Rodolfo Espino, "Minority Language 
Assistance Practices in Public Elections" (Arizona State University: 
Mar. 7, 2006). 

[26] After repeated attempts, we were unable to make contact with any 
CBOs in Sandoval County, N. Mex., and Suffolk County, N.Y. 
Additionally, we were unable to locate any CBOs in Starr County, Tex. 

[27] The long form census, which had been used in coverage 
determinations, will no longer be used by the Census Bureau after 2010. 
The American Community Survey has replaced the long form and will be 
administered by the Census Bureau annually. As a result, future 
determinations for coverage under Section 203 will be made by the 
Director of the Census based upon information compiled by the ACS on a 
rolling 5-year average. 

[28] 40 Fed. Reg. 41827 (1975). In addition to the 227 jurisdictions 
identified in the 1975 determinations, the state of Alaska was also 
listed as having statewide coverage for Native Alaskans but with no 
specific jurisdictions identified as being covered. 

[29] 67 Fed. Reg. 48,872 (2002). 

[30] A probability sample, sometimes referred to as a statistical or 
random sample, is a sample in which each member in the population has a 
known chance, or probability, of being selected. If the objective of an 
evaluation is to make generalizations or draw conclusions about an 
entire population, without using a census, a probability sample could 
be used to do this. In a nonprobability sample, members in the 
population have no chance, or an unknown chance, of being selected. The 
major limitation of nonprobability samples is that the results cannot 
be used to make inferences, or generalizations, about a population. 

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