Elections
Federal Programs for Accrediting Laboratories That Test Voting Systems Need to Be Better Defined and Implemented Gao ID: GAO-08-770 September 9, 2008The 2002 Help America Vote Act (HAVA) created the Election Assistance Commission (EAC) and assigned both it and the National Institute of Standards and Technology (NIST) responsibilities for accrediting laboratories that test voting systems. NIST assesses a laboratory's technical qualifications and makes recommendations to EAC, which makes a final accreditation decision. In view of the continuing concerns about voting systems and the important roles that NIST and EAC play in accrediting the laboratories that test these systems, GAO was asked to determine whether each organization has defined an effective approach for accrediting laboratories that test voting systems and whether each is following its defined approach. To accomplish this, GAO compared NIST and EAC policies, guidelines, and procedures against applicable legislation and guidance, and reviewed both agencies' efforts to implement them.
NIST has largely defined and implemented an approach for accrediting voting system testing laboratories that incorporates many aspects of an effective program. In particular, its approach addresses relevant HAVA requirements and reflects relevant laboratory accreditation guidance, including standards accepted by the international standards community. However, NIST's defined approach does not, for example, cite explicit qualifications for the persons who conduct accreditation technical assessments, as called for in federal accreditation program guidance. Instead, NIST officials said that they rely on individuals who have prior experience in reviewing such laboratories. Further, even though the EAC requires that laboratory accreditation be based on demonstrated capabilities to test against the latest voting system standards, NIST's defined approach has not always cited these current standards. As a result, two of the four laboratories accredited to date were assessed using assessment tools that were not linked to the latest standards. Moreover, available documentation for the four laboratory assessments was not sufficient to determine how the checklists were applied and how decisions were reached. According to NIST officials, the four laboratories were consistently assessed. Moreover, they said that they intend to evolve NIST's accreditation approach to, for example, clearly provide for sufficient documentation of how accreditation reviews are conducted and decisions are reached. However, they had yet to develop specific plans for accomplishing this. EAC recently developed a draft laboratory accreditation program manual, but this draft manual does not adequately define all aspects of an effective approach, and it was not used in the four laboratory accreditations performed to date. Specifically, while this draft manual addresses relevant HAVA requirements, such as the requirement for the commissioners to vote on the accreditation of any laboratory that NIST recommends for accreditation, it does not include a methodology governing how laboratories are to be evaluated or criteria for granting accreditation. Because the manual was not approved at the time EAC accredited four laboratories, these accreditations were governed by a more broadly defined accreditation review process that was described in correspondence sent to each laboratory and a related document receipt checklist. As a result, these accreditations were based on review steps that were not sufficiently defined to permit them to be executed in a repeatable manner. According to EAC officials, including the official who conducted the accreditation reviews for the four laboratories, using the same person to conduct the reviews ensured that the steps performed on the first laboratory were repeated on the other three. However, given that both the steps and the results were not documented, GAO could not verify this. EAC officials stated that they intend to evolve the program manual over time and apply it to future accreditations and reaccreditations. However, they did not have specific plans for accomplishing this. Further, although EAC very recently approved an initial version of its program manual, this did not occur until after EAC provided comments, and GAO had finalized, this report.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-08-770, Elections: Federal Programs for Accrediting Laboratories That Test Voting Systems Need to Be Better Defined and Implemented
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Report to the Chairman, Committee on House Administration, House of
Representatives:
United States Government Accountability Office:
GAO:
September 2008:
Elections:
Federal Programs for Accrediting Laboratories That Test Voting Systems
Need to Be Better Defined and Implemented:
Accreditation of Voting System Testing Laboratories:
GAO-08-770:
GAO Highlights:
Highlights of GAO-08-770, a report to the Chairman, Committee on House
Administration, House of Representatives.
Why GAO Did This Study:
The 2002 Help America Vote Act (HAVA) created the Election Assistance
Commission (EAC) and assigned both it and the National Institute of
Standards and Technology (NIST) responsibilities for accrediting
laboratories that test voting systems. NIST assesses a laboratory‘s
technical qualifications and makes recommendations to EAC, which makes
a final accreditation decision. In view of the continuing concerns
about voting systems and the important roles that NIST and EAC play in
accrediting the laboratories that test these systems, GAO was asked to
determine whether each organization has defined an effective approach
for accrediting laboratories that test voting systems and whether each
is following its defined approach. To accomplish this, GAO compared
NIST and EAC policies, guidelines, and procedures against applicable
legislation and guidance, and reviewed both agencies‘ efforts to
implement them.
What GAO Found:
NIST has largely defined and implemented an approach for accrediting
voting system testing laboratories that incorporates many aspects of an
effective program. In particular, its approach addresses relevant HAVA
requirements and reflects relevant laboratory accreditation guidance,
including standards accepted by the international standards community.
However, NIST‘s defined approach does not, for example, cite explicit
qualifications for the persons who conduct accreditation technical
assessments, as called for in federal accreditation program guidance.
Instead, NIST officials said that they rely on individuals who have
prior experience in reviewing such laboratories. Further, even though
the EAC requires that laboratory accreditation be based on demonstrated
capabilities to test against the latest voting system standards, NIST‘s
defined approach has not always cited these current standards. As a
result, two of the four laboratories accredited to date were assessed
using assessment tools that were not linked to the latest standards.
Moreover, available documentation for the four laboratory assessments
was not sufficient to determine how the checklists were applied and how
decisions were reached. According to NIST officials, the four
laboratories were consistently assessed. Moreover, they said that they
intend to evolve NIST‘s accreditation approach to, for example, clearly
provide for sufficient documentation of how accreditation reviews are
conducted and decisions are reached. However, they had yet to develop
specific plans for accomplishing this. EAC recently developed a draft
laboratory accreditation program manual, but this draft manual does not
adequately define all aspects of an effective approach, and it was not
used in the four laboratory accreditations performed to date.
Specifically, while this draft manual addresses relevant HAVA
requirements, such as the requirement for the commissioners to vote on
the accreditation of any laboratory that NIST recommends for
accreditation, it does not include a methodology governing how
laboratories are to be evaluated or criteria for granting
accreditation. Because the manual was not approved at the time EAC
accredited four laboratories, these accreditations were governed by a
more broadly defined accreditation review process that was described in
correspondence sent to each laboratory and a related document receipt
checklist. As a result, these accreditations were based on review steps
that were not sufficiently defined to permit them to be executed in a
repeatable manner. According to EAC officials, including the official
who conducted the accreditation reviews for the four laboratories,
using the same person to conduct the reviews ensured that the steps
performed on the first laboratory were repeated on the other three.
However, given that both the steps and the results were not documented,
GAO could not verify this. EAC officials stated that they intend to
evolve the program manual over time and apply it to future
accreditations and reaccreditations. However, they did not have
specific plans for accomplishing this. Further, although EAC very
recently approved an initial version of its program manual, this did
not occur until after EAC provided comments, and GAO had finalized,
this report.
What GAO Recommends:
GAO is making recommendations to NIST and EAC aimed at further defining
and implementing their respective accreditation programs in a way that
better ensures that voting system laboratory accreditations are
performed consistently and are verifiable. NIST and EAC generally
agreed with the need for their respective programs to continuously
improve and both sought clarification on the report‘s recommendations,
which GAO has added.
To view the full product, including the scope and methodology, click on
[hyperlink,http://www.gao.gov/cgi-bin/getrpt?]. For more information,
contact Randolph C. Hite at (202) 512-3439 or hiter@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
NIST Has Defined and Implemented an Accreditation Approach That
Reflects Relevant Standards but Is Missing Details Needed for
Consistent and Verifiable Implementation:
EAC's Recently Drafted Accreditation Approach and Its Earlier Performed
Laboratory Accreditations Lack Key Effectiveness Factors and Features:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Comments from the National Institute of Standards and
Technology:
Appendix III: Comments from the Election Assistance Commission:
Appendix IV: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: EAC and NIST Responsibilities under HAVA:
Table 2: Summary of Extent to Which EAC Draft Approach Addresses NIST-
Identified Accreditation Factors:
Table 3: Summary of Extent to Which EAC Satisfies Features Common to
Federal Accreditation Programs:
Figures:
Figure 1: A Voting System Life Cycle Model:
Figure 2: Overall NIST and EAC Accreditation Processes:
Figure 3: VSTL Accreditation Program Activities:
Abbreviations:
EAC: Election Assistance Commission:
HAVA: Help America Vote Act:
ISO: International Organization for Standardization:
NIST: National Institute of Standards and Technology:
NVLAP: National Voluntary Laboratory Accreditation Program:
VSTL: voting system testing laboratory:
VSS: Voting Systems Standards:
VVSG: Voluntary Voting System Guidelines:
United States Government Accountability Office:
Washington, DC 20548:
September 9, 2008:
The Honorable Robert A. Brady:
Chairman:
Committee on House Administration:
House of Representatives:
Dear Mr. Chairman:
In the wake of the 2000 and 2004 general elections, we issued a series
of reports and testified[Footnote 1] on virtually every aspect of our
nation's overall election system, including the many challenges and
opportunities associated with various types of voting systems. In this
regard, we emphasized that voting systems alone were neither the sole
contributor nor solution to the problems that were experienced during
the 2000 and 2004 elections, and that the overall election system
depended on the effective interplay of people, process, and technology
and involved all levels of government. Among many things, we
specifically reported in 2001[Footnote 2] that no federal entity was
responsible for accrediting the laboratories that tested voting
systems, and we raised the establishment of such an entity as a matter
for congressional consideration.
Subsequently, Congress passed the Help America Vote Act (HAVA), which
created the Election Assistance Commission (EAC) and assigned both it
and the National Institute of Standards and Technology (NIST) separate
but related responsibilities for accrediting laboratories that test
voting systems.[Footnote 3] In general, NIST is responsible for
assessing a laboratory's technical qualifications and making an
accreditation recommendation to EAC, while EAC is to use the assessment
results and recommendation, along with its own review of related
laboratory capabilities, to reach an accreditation decision. In 2004
and 2007, NIST and EAC established voting system testing laboratory
accreditation programs, respectively. To date, EAC has accredited four
laboratories. In view of the continuing concerns about voting systems
and the important roles that both NIST and EAC play in accrediting the
laboratories that test these systems, you asked us to determine whether
NIST and EAC have each defined an effective laboratory accreditation
approach and whether each is following its defined approach.
To accomplish this, we reviewed NIST and EAC policies, guidelines, and
procedures governing voting system testing laboratory accreditation,
deaccreditation, and reaccreditation and compared them, as appropriate,
to applicable statute, such as HAVA, and guidance published by NIST,
the International Organization for Standardization, and us. We then
compared NIST and EAC actions and artifacts that were used for
accrediting four voting system testing laboratories to their respective
policies, guidelines, and procedures. We did not review a fifth
laboratory because NIST was in the process of assessing it when we
started our review, and had yet to recommend the laboratory to EAC for
final accreditation. In addition, we interviewed officials from NIST,
EAC, and the four laboratories to understand and clarify approaches
taken, documentation provided, and decisions reached.
We conducted this performance audit at EAC and NIST offices in
Washington, D.C., and Gaithersburg, Maryland, respectively, from
September 2007 to September 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.
Further details of our objective, scope, and methodology are included
in appendix I.
Results in Brief:
NIST has largely defined and implemented an approach for accrediting
voting system testing laboratories that incorporates many aspects of an
effective program. In particular, its approach addresses relevant HAVA
requirements and reflects relevant laboratory accreditation standards
that have been accepted by the international community. However, NIST's
defined approach does not cite explicit qualifications or training
requirements for accreditation technical assessors, which, according to
NIST, is a characteristic of an effective accreditation program.
Instead, the program has relied, in part, on a small and specialized
field of potential assessors in the voting system arena. Further, until
recently, NIST's laboratory accreditation guidance cited different
versions of required standards. As a result, two of the four accredited
laboratories were assessed using checklists linked to the current
standards and two were not. Moreover, NIST's documentation of these
assessments was not sufficient to determine how the checklists were
applied and how decisions were reached. According to NIST officials,
the four laboratories were consistently assessed, and they intend to
ensure that sufficient documentation is produced to show how
assessments are conducted and decisions are reached. However, they said
that they do not have a documented plan for accomplishing this.
EAC recently developed a draft of a voting system testing laboratory
accreditation program manual, but the draft manual does not adequately
define all aspects of an effective approach and was not used in
accrediting the four laboratories. EAC's draft manual addresses
applicable HAVA requirements, but does not include either a methodology
governing how laboratories are to be reviewed or certain criteria
relevant to granting accreditation. Because the draft manual was not
available for laboratory assessments until recently, EAC instead used a
more broadly defined accreditation review process contained in
correspondence with the laboratories and a related checklist that were
not specific enough to ensure that review steps were executed in a
repeatable manner. According to EAC officials, using the same person to
conduct the reviews ensured that the reviews were consistently
performed. However, because both the steps and the results were not
documented, we could not verify this. In addition, EAC officials told
us that they intend to evolve the program manual over time and apply it
to future accreditations and reaccreditations; however, they do not
have a documented plan for accomplishing this.[Footnote 4]
To assist NIST and EAC in evolving their respective voting system
testing laboratory accreditation programs, we are making
recommendations to NIST and EAC to develop and execute plans, with
specific tasks, milestones, resources, and measures, which are aimed at
adding consistency and specificity to their defined approaches and
ensuring that the approaches are fully implemented and documented.
NIST and EAC provided written comments on a draft of this report,
signed by the Deputy Director of NIST and the Executive Director of
EAC, respectively. More specifically, NIST stated that it appreciated
our careful review of its voting system testing laboratory
accreditation program and added that it generally concurs with our
findings that this program must continue to evolve and improve. NIST
also provided comments that were intended to clarify the current status
of the program relative to three of our findings. For various reasons
discussed in the agency comments section of this report, we do not
believe that these comments affect any of the three findings.
Therefore, we have not modified the report's presentation of them. In
light of NIST's recent actions to address one of the findings, we
updated our report to reflect these actions and have removed the
associated recommendation from our final report. Further, in order to
avoid the possibility of any misunderstanding about the actions needed
to address one other finding, we have slightly modified the
recommendation associated with it.
With respect to EAC's comments, the commission described our review and
report as helpful to the commission as it works to fully develop and
implement its voting system testing laboratory accreditation program.
It also stated that it agrees with the report's conclusions that
additional written internal procedures, standards, and documentation
are needed to ensure more consistent and repeatable implementation of
the program. Further, it stated that it generally accepts our
recommendations, adding that it will work hard to implement them.
However, it sought clarification about two of the recommendations. In
response, we have slightly modified both recommendations to avoid any
confusion as to their intent. Both the NIST and EAC comments are
discussed in detail in the agency comments section of this report, and
are reprinted in their entirety in appendixes II and III, respectively.
Background:
All levels of government share responsibility in the overall U.S.
election system. At the federal level, Congress has authority under the
Constitution to regulate presidential and congressional elections and
to enforce prohibitions against specific discriminatory practices in
all federal, state, and local elections. Congress has passed
legislation that addresses voter registration, absentee voting,
accessibility provisions for the elderly and persons with disabilities,
and prohibitions against discriminatory practices.[Footnote 5] At the
state level, individual states are responsible for the administration
of both federal elections and their own elections. States regulate the
election process, including, for example, the adoption of voluntary
voting system guidelines, the state certification and acceptance
testing of voting systems, ballot access, registration procedures,
absentee voting requirements, the establishment of voting places, the
provision of election day workers, and the counting and certification
of the vote.
In total, the overall U.S. election system can be seen as an assemblage
of 55 distinct election systems--those of the 50 states, 4 U.S.
territories, and the District of Columbia. Further, although election
policy and procedures are legislated primarily at the state level,
states typically have decentralized election systems, so that the
details of administering elections are carried out at the city or
county levels, and voting is done at the local level. As we reported in
2001,[Footnote 6] local election jurisdictions number more than 10,000,
and their sizes vary enormously--from a rural county with about 200
voters to a large urban county, such as Los Angeles County, where the
total number of registered voters for the 2000 elections exceeded the
registered voter totals in 41 states. Further, these thousands of
jurisdictions rely on many different types of voting methods that
employ a wide range of voting system makes, models, and versions.
Because of the prominent role played by electronic voting systems,
testing these systems against national standards is critical to
ensuring their security and reliability. Equally critical is ensuring
that the laboratories that perform these tests are competent to carry
out testing activities.
The Overall U.S. Election System Depends on Effective Interactions
among People, Processes, and Technology:
In the United States today, most votes are cast and counted by
electronic voting systems, and many states require use of systems that
have been certified nationally or by state authorities. However, voting
systems are but one facet of a multifaceted, continuous overall
election system that involves the interplay of people, processes, and
technology during the entire life of a system. All levels of
government, as well as commercial voting system manufacturers and
system testing laboratories, play key roles in ensuring that voting
systems perform as intended.
Electronic voting systems are typically developed by manufacturers,
then purchased as commercial, off-the-shelf products and operated by
state and local election administrators. Viewed at a high level, these
activities make up three phases of a system life cycle: product
development, acquisition, and operations. (See fig. 1.) Key processes
that span these life cycle phases include managing the people,
processes, and technologies within each phase and across phases, and
testing the systems and components during and at the end of each phase.
Additionally, voting system standards are important through all of the
phases because they provide criteria for developing, testing, and
acquiring voting systems, and they specify the necessary documentation
for operating the systems.
Figure 1: A Voting System Life Cycle Model:
This figure is a horizontal flow chart showing a voting system life
cycle model.
[See PDF for image]
Source: GAO analysis of EAC, NIST, and Institute of Electrical and
Electronics Engineers (IEEE) publications.
[End of figure]
* The product development phase includes activities such as
establishing requirements for the system, designing a system
architecture, developing software, and integrating components.
Activities in this phase are performed by the system vendor.
* The acquisition phase includes activities such as publishing a
solicitation, evaluating offers, choosing a voting technology and a
vendor, and awarding and administering contracts. For voting systems,
activities in this phase are primarily the responsibility of state and
local governments but entail some responsibilities that are shared with
the system vendor (e.g., entering into the contract).
* The operations phase consists of activities such as ballot design and
programming, setup of systems before voting, pre-election testing, vote
capture and counting during elections, recounts and system audits after
elections, and storage of systems between elections. Responsibility for
activities in this phase typically resides with local jurisdictions,
whose officials may, in turn, rely on or obtain assistance from system
vendors for aspects of these activities.
* Standards for voting systems, as will be discussed in a later
section, were developed at the national level by the Federal Election
Commission in 1990 and 2002 and were updated by EAC in 2005. In the
product development phase, voting system standards serve as
requirements to meet for developers to build systems. In the
acquisition phase, they also provide a framework that state and local
governments can use to evaluate systems. In the operations phase, they
specify the necessary documentation for operating the systems.
* Testing processes are conducted throughout the life cycle of a voting
system. Voting system vendors conduct product testing during
development of the system and its components. Federal certification
testing of products submitted by system vendors is conducted by
national voting system testing laboratories (VSTL). States may conduct
evaluation testing before acquiring a system to determine how well
products meet their state-specific specifications, or they may conduct
certification testing to ensure that a system performs its functions as
specified by state laws and requirements. Once a voting system is
delivered by the system vendor, states and local jurisdictions may
conduct acceptance testing to ensure that the system satisfies
functional requirements. Finally, local jurisdictions typically conduct
logic and accuracy tests related to each election and sometimes subject
portions of the system to parallel testing during each election to
ensure that the system components perform accurately.
* Management processes ensure that each life cycle phase produces a
desirable outcome. Typical management activities that span the system
life cycle include planning, configuration management, system
performance review and evaluation, problem tracking and correction,
human capital management, and user training. These activities are
conducted by the responsible parties in each life cycle phase.
In 2004, we reported[Footnote 7] that the performance of electronic
voting systems, like any type of automated information system, can be
judged on several bases, including their security, accuracy, ease of
use, efficiency, and cost. We also reported that voting system
performance depends on how the system was designed, developed, and
implemented.
Laboratory Accreditation Plays an Important Role in Ensuring Accurate,
Reliable, and Secure Voting Systems:
Since the passage of HAVA, the use of electronic voting systems has
increased and become the predominant method of voting. However,
concerns have been raised about the security and reliability of these
systems. As we have previously reported,[Footnote 8] testing and
certifying voting systems is one critical step in acquiring, deploying,
operating, and administering voting systems, which better ensures that
they perform securely and reliably. Among other things, rigorous
execution and careful documentation of system testing is a proven way
to help ensure that system problems are found before the systems are
deployed and used in an election. To accomplish this, it is vital that
the organizations that test the systems be qualified and competent to
do so. For voting systems, a key testing organization is a federally
accredited, national VSTL.
In general, accreditation is the formal recognition that a laboratory
is competent to carry out specific types of tests or calibrations.
Federally accredited laboratories perform many different types of
testing and related activities on various products, ranging from
inspecting grain to certifying maritime cargo gear. The genesis of
laboratory accreditation programs owes largely to agencies' need to
assure themselves of the competency of the organizations responsible
for testing products or services that involve the use of federal funds.
To provide national recognition for competent laboratories, the NIST
Director established the National Voluntary Laboratory Accreditation
Program (NVLAP) in 1976 at the request of the private sector. Under
this program, which is based on internationally accepted standards,
NIST accredits laboratories that it finds competent to perform specific
types of tests or calibrations. In June 2004, NVLAP announced the
establishment, in accordance with HAVA, of an accreditation program for
laboratories that test voting systems using standards determined by
EAC.
HAVA Assigned EAC and NIST Responsibility for Accrediting VSTLs:
Enacted in October 2002, HAVA affected nearly every aspect of the
voting process, from voting technology to provisional ballots and from
voter registration to poll worker training.[Footnote 9] In particular,
the act authorized $3.86 billion in funding over several fiscal years
to replace punch card and mechanical lever voting equipment, improve
election administration and accessibility, train poll workers, and
perform research and pilot studies. HAVA also established EAC, provided
for the appointment of four commissioners, and specified the process
for selecting an executive director. Generally speaking, EAC is to
assist in the administration of federal elections and provide
assistance in administering certain federal election laws and programs.
Since the passage of HAVA in 2002, the federal government has taken
steps to implement the act's provisions. For example, after beginning
operations in January 2004, EAC updated the existing federal voluntary
standards for voting systems, including strengthening provisions
related to security and reliability. Additionally, EAC established an
interim VSTL accreditation program that leveraged a predecessor program
run by the National Association of State Elections Directors, and EAC
and NIST then established companion accreditation programs that
replaced the interim program.
EAC Updated the Federal Voluntary Standards for Voting Systems:
Federal standards for voting systems were first issued in 1990 when the
Federal Election Commission published standards.[Footnote 10] These
federal standards identified minimum functional and performance
requirements, which states were free to adopt in whole, in part, or not
at all, for electronic voting equipment, and specified test procedures
to ensure that the equipment met those requirements. In 2002, the
Federal Election Commission issued its Voting System Standards (VSS),
which updated the 1990 standards to reflect more modern voting system
technologies. In 2005, we reported[Footnote 11] that these standards
identified minimum functional and performance requirements for voting
systems but were not sufficient to ensure secure and reliable voting
systems. As a result, we recommended that EAC work to define specific
tasks, measurable outcomes, milestones, and resource needs to improve
the voting system standards. Until then, election administrators were
at risk of relying on voting systems that were not developed, acquired,
tested, operated, or managed in accordance with rigorous security and
reliability standards--potentially affecting the reliability of future
elections and voter confidence in the accuracy of the vote count.
Following the enactment of HAVA in 2002 and the establishment of EAC in
2004, EAC adopted the Voluntary Voting System Guidelines (VVSG) in
2005.[Footnote 12] The VVSG specify the functional requirements,
performance characteristics, documentation requirements, and test
evaluation criteria for the national certification of voting systems.
Accredited testing laboratories are to use the VVSG to develop test
plans and procedures for the analysis and testing of systems in support
of EAC's voting system certification program.[Footnote 13] The VVSG are
also used by voting system manufacturers as the basis for designing and
deploying systems that can be federally certified.
EAC Established an Interim Accreditation Program:
We reported in 2001[Footnote 14] that the National Association of State
Elections Directors was accrediting independent test authorities to
test voting equipment against the Federal Election Commission
standards. Under this program, three laboratories were accredited.
Under HAVA, NIST is to recommend laboratories for EAC accreditation. In
2006, NIST notified EAC that its initial recommendations might not be
available until sometime in 2007. As a result, EAC initiated an interim
accreditation program and invited the three laboratories accredited by
the state elections directors to apply.[Footnote 15] As part of the
interim program, laboratories were required to attest to a set of EAC-
required conditions and practices, including certifying the integrity
of personnel, the absence of conflicts of interest, and the financial
stability of the laboratory. In August and September 2006, EAC granted
interim accreditation to two of the three laboratories invited to
apply. EAC terminated its interim program in March 2007.
EAC and NIST Have Established Separate but Related Laboratory
Accreditation Programs:
HAVA assigned responsibilities for laboratory accreditation to both EAC
and NIST. In general, to reach an accreditation decision, NIST is to
focus on assessing laboratory technical qualifications, while EAC is to
use those assessment results and recommendations and augment them with
its own review of related laboratory capabilities. See table 1 for the
two agencies' HAVA responsibilities.
Table 1: EAC and NIST Responsibilities under HAVA:
HAVA responsibility: Provide for the testing, certification,
decertification, and recertification of voting system hardware and
software by accredited laboratories;
Responsible entity: EAC: X;
Responsible entity: NIST: [Empty].
HAVA responsibility: Conduct evaluations of independent, nonfederal
laboratories and submit to EAC a list of those laboratories proposed
for accreditation;
Responsible entity: EAC: [Empty];
Responsible entity: NIST: X.
HAVA responsibility: Vote on the accreditation of any laboratory,
taking into consideration the NIST recommendation for it. No laboratory
may be accredited unless its accreditation is approved by a vote of
EAC;
Responsible entity: EAC: X;
Responsible entity: NIST: [Empty].
HAVA responsibility: Publish an explanation for the accreditation of
any laboratory not included on the list submitted for recommendation by
NIST;
Responsible entity: EAC: X;
Responsible entity: NIST: [Empty].
HAVA responsibility: Monitor and review the performance of laboratories
accredited by EAC and make recommendations to EAC with respect to the
continuing accreditation of laboratories, including recommendations to
revoke the accreditation of laboratories;
Responsible entity: EAC: [Empty];
Responsible entity: NIST: X.
HAVA responsibility: Revoke the accreditation of a laboratory only when
approved by a vote of EAC;
Responsible entity: EAC: X;
Responsible entity: NIST: [Empty].
Source: GAO analysis of United States Code.
[End of table]
The tasks that NIST is to perform in meeting HAVA's requirements are
addressed in an annual interagency agreement executed between the
institute and EAC each year. For example, the 2008 interagency
agreement states that NVLAP will continue to assess VSTLs and will
coordinate with EAC to continually monitor and review the performance
of the laboratories. Additionally, the agreement states that the two
agencies will coordinate to maintain continuity between their
respective accreditation programs.
The NIST and EAC accreditation programs can be viewed together as
forming a federal VSTL accreditation process that consists of a series
of 12 complementary steps. These steps are depicted in figure 2, where
the numbers correspond to a detailed narrative description below.
Figure 2: Overall NIST and EAC Accreditation Processes:
This figure is a flowchart of overall NIST and EAC accreditation
processes.
[See PDF for image]
Source: GAO analysis.
[End of figure]
1. Laboratory Application to NIST:
The accreditation process begins when a laboratory submits a completed
application to NIST, along with administrative information about the
laboratory, the scope of accreditation being applied for, and an
agreement to the conditions of accreditation (i.e. practices that must
be followed to obtain and maintain accreditation). In addition, the
laboratory submits documentation that supports the application,
including the laboratory's quality control manual.
2. NIST Preassessment:
Using the application and supporting documentation, NIST conducts a
preassessment review. Among other things, this review includes
comparing the quality control manual against the requirements in NIST
accreditation program guidance. If deficiencies in the documentation
are found, NIST requests corrections to satisfy program requirements.
3. NIST On-site Assessment:
Following satisfactory completion of the preassessment review, a NIST
team visits the laboratory facilities to conduct an on-site assessment.
This assessment includes staff interviews, reviews of laboratory
records and audit reports, and demonstrations of staff competence to
execute planned test methods and procedures. It concludes with the NIST
team presenting its findings to laboratory management. While conducting
the on-site assessment, the team records its observations and comments.
4. NIST Nonconformity Resolution:
NIST prepares a final report, including a list of any nonconformities,
and provides it to the laboratory. The laboratory has 30 days to
respond as to how it will address the areas of nonconformity. NIST
evaluates the laboratory's response and determines whether the
nonconformities have been sufficiently addressed. If so, NIST renders
an accreditation decision. If not, NIST may contact the laboratory for
additional information or may deny accreditation. If a laboratory is
denied accreditation, it may reapply to NIST.
5. NIST Accreditation Decision:
When a laboratory has no areas of nonconformity, the voting systems
program manager makes an accreditation recommendation to the Chief of
NVLAP, who is responsible for all NVLAP accreditation decisions and
issues all NVLAP accreditation certificates.
6. NIST Recommendation to EAC:
In addition to granting the NVLAP accreditation, the Chief provides a
recommendation to the Director of NIST. The recommendation is reviewed
by NIST's general counsel, and then a letter is sent to EAC that
recommends the laboratory for accreditation as a VSTL in accordance
with HAVA.
7. Accreditation Application to EAC:
After receiving the NIST recommendation, EAC sends the recommended
laboratory an invitation to apply to the EAC accreditation program. In
the letter, EAC specifies a list of information and documentation that
the laboratory must provide.
8. EAC Accreditation Review:
The laboratory submits an application and supporting information to
EAC. EAC staff review the application package for completeness. In
addition, staff review the supporting materials vis-a-vis accreditation
program requirements. During the course of the review, staff may
contact the laboratory to clarify the information provided or to inform
the laboratory of requirements that are not sufficiently addressed.
9. EAC Nonconformity Resolution:
EAC submits correspondence (generally through e-mail) to the laboratory
identifying areas of nonconformity. The laboratory then provides the
missing and/or clarifying documentation. EAC staff determines if the
provided information adequately addresses the nonconformity issues,
contacting the laboratory as needed.
10. Recommendation to EAC Commissioners:
The EAC accreditation program director, through the EAC executive
director, makes a recommendation to the EAC commissioners as to whether
the laboratory should be accredited by EAC. Along with the
recommendation, the program director provides the review results, as
well as laboratory-provided materials.
11. Vote by EAC Commissioners:
The commissioners review the material provided and may request
additional clarification, as needed. At a public meeting, the
commissioners vote on whether to accredit the laboratory. Should the
EAC commissioners vote to deny the accreditation, the laboratory must
wait for EAC to invite the laboratory to reapply.
12. EAC Accreditation Granted:
When the commissioners vote to accredit a laboratory, EAC's executive
director issues an accreditation certificate identifying the scope and
effective dates of the VSTL accreditation. In addition, the program
director makes information about the laboratory's accreditation
publicly available via the EAC Web site. At this point, the laboratory
is authorized to operate as a VSTL under EAC's testing and
certification program.
Postaccreditation Monitoring Activities:
Once a laboratory has been accredited, both NIST and EAC are to monitor
its compliance with the terms of its accreditation. In doing so, NVLAP
staff may visit a laboratory at any time, whether for cause or on a
random selection basis, and these visits can be either scheduled in
advance with the laboratory or unannounced. If a laboratory is found to
not be in compliance, the accreditation may either be
suspended[Footnote 16] or revoked, depending on the nature of the
issues involved. A suspension provides the opportunity for the
laboratory to address the identified issues. EAC also monitors the
procedures and practices of accredited laboratories through
documentation reviews and visits. If a VSTL is unable to remedy
identified compliance issues, the EAC program director can propose that
the accreditation be suspended and ultimately revoked. As provided for
under HAVA, the EAC commissioners would vote on any proposed
revocation.
Status of Completed VSTL Accreditation Activities:
As of May 2008, EAC has accredited four laboratories. These
laboratories are SysTest Labs, LLC; Wyle Laboratories, Inc; iBeta
Quality Assurance; and InfoGard Laboratories, Inc. A fifth laboratory,
CIBER Inc., has been granted NVLAP accreditation and has been
recommended to, but not yet accredited by, EAC. InfoGard Laboratories,
Inc., whose NVLAP accreditation expires in June 2008, has recently
notified NIST and EAC that it would not apply to renew its
accreditation, citing the volatility of the voting system environment
as one reason. The timeline for each of these accreditations, and other
accreditation program activities, is found in figure 3.
Figure 3: VSTL Accreditation Program Activities:
This figure is a chart depicting VSTL accreditation program activities.
[See PDF for image]
Source: GAO based on NIST: and EAC-provided data.
[End of figure]
NIST Has Defined and Implemented an Accreditation Approach That
Reflects Relevant Standards but Is Missing Details Needed for
Consistent and Verifiable Implementation:
NIST's defined approach to accrediting voting system laboratories
largely reflects applicable HAVA requirements and relevant
international standards, both of which are necessary to an effective
program. However, this approach is continuing to evolve based on issues
realized during NIST's implementation experience to date. In
particular, because NIST's defined program does not, for example,
specify the nature and extent of assessment documentation to generate
or retain or specify the version of the voting system standards to be
used, our analysis of NIST's efforts in accrediting four laboratories
could not confirm that the agency has consistently followed its defined
accreditation program. NIST officials stated that these limitations are
due in part to the relative newness of the program and that they will
be addressed by updating the accreditation program handbook. However,
they said that they do not have documented plans to accomplish this.
Until these limitations are addressed, NIST will be challenged in
accrediting voting system laboratories in a consistent and verifiable
manner.
NIST Voting System Accreditation Program Reflects HAVA Requirements:
NIST has defined its voting system accreditation program to address
relevant HAVA requirements. According to HAVA, NIST is to:
* conduct reviews of independent, nonfederal voting system testing
laboratories and submit to EAC a list of proposed voting system testing
laboratories and:
* monitor and review the performance of those proposed laboratories
that EAC accredits, including making recommendations to EAC regarding
accreditation continuance and revocation.
NIST's defined voting system accreditation program satisfies both of
these requirements. With respect to the first, NIST announced in June
2004 the establishment of its voting system testing laboratory
accreditation program as part of NVLAP, a statutorily created program
for unbiased, third parties to establish the competence of national
independent laboratories. As such, NIST adopted its NVLAP
handbook[Footnote 17] as the basis for its defined approach to
reviewing VSTLs and has supplemented it with a handbook that is
specific to voting system testing.[Footnote 18]
With respect to the second HAVA requirement, the supplemental handbook
cited above states that the NIST Director will recommend NVLAP-
accredited VSTLs to EAC for subsequent commission accreditation.
Additionally, NIST's handbooks provide for both monitoring accredited
laboratories and for making recommendations regarding a laboratory's
continued accreditation. For example, the handbook states that a
monitoring visit may occur at both scheduled and unscheduled times and
the scope may be limited to a few items or include a full review. It
also states that a reaccreditation review shall be conducted in
accordance with the procedures used to initially accredit laboratories.
Further, the handbook also identifies accreditation or reaccreditation
decision options, including granting, denying, or modifying the scope
of an accreditation.
According to NIST officials, these HAVA requirements are relevant and
important to defining an effective voting system testing laboratory
accreditation program. By incorporating them, NIST has reflected one
key aspect of an effectively defined program.
NIST Has Incorporated Relevant International Accreditation Standards
into Its VSTL Accreditation Program:
NIST's VSTL accreditation program reflects internationally recognized
standards for establishing and conducting accreditation activities.
These standards are published by the International Organization for
Standardization (ISO), and the two that are germane to this
accreditation program are (1) ISO/IEC 17011,[Footnote 19] which
establishes general requirements for accreditation bodies and (2) ISO/
IEC 17025,[Footnote 20] which establishes the general requirements for
reviewing the competence of laboratories. According to NIST program
documentation, this allows NVLAP to both operate as an unbiased, third
party accreditation body and to utilize a quality management system
compliant with international standards. As a result, NIST has
incorporated key aspects of an effective accreditation body into its
voting system accreditation program.
NIST Program Meets ISO Accreditation Body Requirements:
ISO/IEC 17011 requires that an accrediting body have, among other
things, (1) a management system for accreditation activities, (2) a
policy defining the types of records to be retained and how those
records will be maintained, (3) a clear description of the
accreditation process that covers the rights and responsibilities of
those seeking accreditation, and (4) a clear description of the
accreditation activities to be performed.
NIST VSTL accreditation program-related documentation, including its
program handbooks, satisfies each of these requirements. In fact, NIST
has cross-referenced its documentation to each ISO/IEC 17011
requirement. Specifically, the first requirement is cross-referenced to
the NVLAP Management System Manual,[Footnote 21] which describes the
overall accreditation program's management policies and control
structure, and the second is cross-referenced to the program's record
keeping policy, which specifies what types of records should be
maintained and how they should be maintained. The third and fourth
requirements are cross-referenced to the accreditation process
descriptions in both the Management System Manual and the general
handbook. Together, these documents contain, for example, (1) the
rights of laboratories applying for accreditation and (2) the scope of
accreditation activities to be performed, including a preassessment
review, an on-site review, and a final on-site assessment report.
NIST Program Meets ISO Laboratory Accreditation Review Requirements:
ISO/IEC 17025 requires that accreditation reviews cover specific
topics. These include (1) laboratory personnel independence and
conflicts of interest; (2) a laboratory system for quality control
(i.e., a framework for producing reliable results and continuous
improvement to laboratory procedures); and (3) a laboratory mechanism
for collecting and responding to customer complaints. Additionally, the
standard establishes basic technical requirements that a laboratory has
to meet, and thus that reviews are to cover, including (1) competent
laboratory personnel who are capable of executing the planned tests,
(2) appropriate tests and test methods, and (3) clear and accurate test
result documentation.
NIST voting system testing laboratory accreditation program-related
documents, including its program handbooks, satisfy these requirements.
First, the general handbook defines the requirement for a laboratory to
have personnel that are independent and free of any conflict of
interest. Second, the handbook requires that a laboratory have a
management quality control system and that this system provide for
reliable results and continuous improvement to laboratory procedures.
Third, the handbook requires that a laboratory have a mechanism for
receiving and responding to customer complaints. Last, the handbook
establishes certain technical requirements that a laboratory must meet,
such as having competent laboratory personnel capable of executing the
planned tests, using appropriate tests and test methods, and
documenting test results in a clear and accurate manner.
For several of these requirements, NIST's voting-specific supplemental
handbook augments the general handbook. For example, this supplemental
handbook requires laboratories to submit a quality control manual, as
well as information to demonstrate the competence of laboratory
administrative and technical staff. Further, it requires that a
laboratory's training program be updated so that staff can be retrained
as new versions of voting system standards are issued.
NIST Voting System Accreditation Program Does Not Reflect Its Own
Findings on the Need for Assessor Qualifications and Training and Key
Assessment Criteria:
NIST has reported on the importance of ensuring that those persons who
perform accreditation assessments are sufficiently qualified and that
the assessments themselves are based on explicitly defined criteria and
are adequately documented. Nevertheless, NIST has not fully reflected
key aspects of these findings in its defined approach to accrediting
voting system testing laboratories. For example, it has not specified
the basis for determining the qualifications of its accreditation
assessors, and while a draft update to its handbook now includes the
specific voting system standards to be used when performing an
accreditation assessment, this handbook was only recently approved.
According to NIST officials, these gaps are due to the newness of the
accreditation program and will be addressed in the near future. Because
these gaps have confused laboratories as to what standards they were to
meet, and may have resulted in differences in how accreditations have
been performed to date, it is important that the gaps be addressed.
NIST Has Not Specified Requirements for Assessor Qualifications and
Training:
NIST has reported[Footnote 22] on the importance of having competent
and qualified human resources to support accreditation programs.
According to these findings, an accreditation program should, among
other things, provide for:
* having experienced and qualified assessors to perform accreditation
activities;
* demonstrating an assessors' qualifications using defined
documentation and explicit criteria that encompass the person's
education, experience, and training; and:
* training (initial and continuing) for assessors.
NIST's defined approach to VSTL accreditation does not provide for all
these requirements. To its credit, its program handbook identifies the
need for experienced and qualified assessors in the execution of
accreditation activities and provides for each assessor's
qualifications to be documented. Further, it has defined generic
training that applies to all of its accreditation assessors. For
example, the NVLAP Assessor Training Syllabus includes training on ISO/
IEC 17011 and 17025, as well as training on the NVLAP general handbook.
In addition, the VSTL accreditation program manager stated that new
assessors receive training on the 2002 VSS and 2005 VVSG and that
periodic training seminars are provided to assessors on changes to
either the general handbook or the 2005 VVSG.
In addition, the program manager told us that candidate assessors must
submit some form of documentation (e.g., a resume), and that this
documentation is used to evaluate, rank, and select candidates that are
best qualified. The NIST VSTL assessors that we interviewed confirmed
that they were required to submit such documentation at NIST's request.
However, NIST's defined approach does not cite the explicit
capabilities and qualifications that an assessor must meet or the
associated documentation needed to demonstrate these capabilities and
qualifications. According to the program manager, this is because the
field of potential assessors in the voting system arena is small and
specialized and because they focused on defining other aspects of the
program that were higher priorities. Further, NIST has not defined and
documented the specific training requirements needed to be a VSTL lead
assessor or a technical assessor for the VSTL program. According to the
program manager, this is because these assessors receive all the
training they need by working on the job with more experienced
assessors. Not specifying criteria governing assessor qualifications
and training is of concern because differences in assessors'
capabilities could cause inconsistencies in how assessments are
performed.
NIST's Approach Does Not Fully Specify Criteria for Evaluating and
Documenting VSTL Capabilities:
NIST recognizes the importance of specifying explicit criteria against
which all candidate laboratories will be assessed and fully documenting
the assessments that are performed. Specifically, the general handbook
provides the criteria and requirements that will be used to evaluate
basic laboratory capabilities. It also states that technical
requirements specific to a given field of accreditation are published
in program-specific handbooks. To that end, NIST published a
supplemental program-specific handbook in December 2005 that provided
the voting-specific requirements to be used to evaluate VSTLs,
additional guidance, and related interpretive information.[Footnote 23]
NIST's 2005 supplemental handbook does not contain sufficient criteria
against which to evaluate VSTLs. It identifies specific requirements
that laboratories are to demonstrate relative to the 2002 VSS but not
the 2005 VVSG. For example, the handbook states that laboratories are
expected to develop, validate, and document test methods that meet the
2002 VSS. However, it does not refer to the 2005 VVSG. In addition, the
program-specific checklist that accompanies this version of the
handbook does not identify all the 2005 VVSG standards against which
laboratories are evaluated. Specifically, this checklist makes
reference to the VVSG in relation to just a few checklist requirements.
According to the NIST program manager, the 2005 handbook did not refer
to the 2005 VVSG requirements because only the 2002 VSS requirements
were mandatory at the time it was published. He further stated that,
despite the fact that the 2005 VVSG requirements were not included in
that handbook, NIST assessors were expected to use them when performing
the first laboratory assessments. Representatives for two laboratories
stated that because these requirements were not documented or
identified in the NIST handbooks, they did not learn that they would be
required to demonstrate 2005 VVSG-based capabilities until the NIST on-
site assessment teams arrived.
In December 2007, NIST released draft revisions of the voting program-
specific handbook and checklist, stating that labs are expected to meet
both 2002 VSS and 2005 VVSG. In addition, the 2007 draft handbook
clearly specifies that laboratories must demonstrate how developed test
methods and planned tests trace back to and satisfy both the 2002 VSS
and the 2005 VVSG. Taken together, the new handbook and checklist
should better identify the requirements and criteria used to evaluate a
laboratory and document the results. According to NIST, the new
handbook and checklist have recently been finalized, and both are now
in use.[Footnote 24]
Available Documentation Does Not Show That NIST Has Consistently
Followed All Aspects of Its Defined Accreditation Approach:
NIST has found that reliable and accurate documentation provides
assurance that laboratory accreditation activities have been
effectively fulfilled.[Footnote 25] However, in its efforts to date in
accrediting four VSTLs, documentation of the assessments does not show
that NIST has fully followed its defined accreditation approach. While
we could not determine whether this is due to incomplete documentation
of the steps performed and the decisions made during an assessment or
due to steps not being performed as defined, this absence of verifiable
evidence raises questions about the consistency of the assessments and
the resultant accreditations. Without adequately documenting each
assessment, including all steps performed and the basis for any steps
not performed, such questions may continue to be raised.
To NIST's credit, available documentation shows that it consistently
followed some aspects of its defined approach in accrediting the four
laboratories. For example, we verified that NIST received an
application from each of the laboratories as required, and our review
of completed checklists and summary reports shows that preassessment
reviews and on-site assessments were performed for each laboratory, as
was required. According to a lead assessor, this review usually focused
on the laboratories' quality assurance manuals. Moreover, the completed
checklists identified whether the requirement was met or not for each
listed requirement, and included comments, in some cases, as to how a
laboratory addressed a requirement. Also as required, NIST received
laboratory responses describing how unmet requirements were addressed
within specified time frames, used the responses in making
accreditation decisions, and notified EAC of its decisions via letters
of recommendation. Furthermore, NIST has recently begun reaccreditation
reviews at two laboratories, as required.
However, documentation does not show that NIST has consistently
followed other aspects of its defined approach. Our analysis of the
checklists that are to be used to both guide and document a given
assessment, including identifying unmet requirements and capturing
assessor comments and observations, shows some differences. For
example:
* One type of checklist (the supplemental handbook checklist) was
prepared for only two of the four laboratory assessments. According to
the program manager, this is because even though a draft revision of
this checklist was actually used to assess the other two laboratories,
the assessment results were recorded on a different checklist (the
general handbook checklist). While this is indicated on one of the two
checklists, it is not indicated on the other.
* On the checklist used for one laboratory, an assessor marked several
sections as "TA" with no explanation as to what this means. Also, the
checklist used for another laboratory did not identify whether most of
the requirements were met or not met. Further, the checklist for a
third laboratory had one section marked as "not applicable" but
included no explanation as to why that section did not apply, while the
checklist for a different laboratory marked the same section as "not
applicable" but included a reason for doing so.
Notwithstanding these differences, the program manager told us that
each laboratory was assessed using the same requirements and all
assessments to date were performed in a consistent manner. On the basis
of available documentation, however, we could not verify that this is
the case. As a result, it is not clear that NIST has consistently
followed its defined approach.
Available documentation also does not show that NIST followed other
aspects of its approach. For example:
* The program handbook states that each laboratory is to identify the
requested scope of accreditation in its application package. However,
our analysis of the four application packages shows that two
laboratories did not specify a requested scope of accreditation.
According to the program manager, the scope of accreditation for all
laboratories was the 2002 VSS and 2005 VVSG because, even though the
latter standards were not yet in effect at the time, they were
anticipated to be in effect in the near future.[Footnote 26] However,
NIST did not have documentation that notified the laboratories of this
scope of accreditation or that indicated whether this scope was
established by EAC, NIST, or the laboratories.
* The program handbook states that after receiving a laboratory's
application package, NIST will acknowledge its receipt in writing and
will inform the laboratory of the next steps in the accreditation
process. However, NIST did not have documentation demonstrating that
this was done. According to the program manager, this was handled via
telephone conversations. However, representatives for several
laboratories noted that these calls did not clearly establish
expectations, adding that some expectations were not communicated until
the NIST team assessors arrived to conduct the on-site assessment.
The program manager stated that these deviations from the defined
approach are attributable to the relative newness of the program, but
despite these discrepancies, each laboratory was assessed consistently.
However, we could not verify this, and thus it is not clear that NIST
has consistently followed its defined approach. According to this
official, future versions of the program handbook would address these
limitations. However, documented plans for doing so have not been
developed.
EAC's Recently Drafted Accreditation Approach and Its Earlier Performed
Laboratory Accreditations Lack Key Effectiveness Factors and Features:
EAC has recently defined its voting system laboratory accreditation
approach in a draft program manual. However, this draft manual omits
important content. While addressing relevant HAVA requirements, the
draft manual does not adequately define key accreditation factors that
NIST has identified, and a key accreditation feature that we have
previously reported as being integral to an effective accreditation
program. Moreover, not all factors and features that the draft manual
does include have been defined to a level that would ensure thorough,
consistent, and verifiable implementation. Because this manual was not
available for EAC to use on the four laboratory accreditations that it
has completed, the accreditations were performed using a largely
undocumented series of steps. As a result, the thoroughness and
consistency of these accreditations is not clear. According to EAC
officials, these gaps are due to the agency's limited resources being
focused on other issues, and will be addressed as its accreditation
program evolves. However, they said that they do not yet have
documented plans to accomplish this. Until EAC fully defines a
repeatable VSTL accreditation approach, it will be challenged in its
ability to treat all laboratories consistently and produce verifiable
results.
EAC Has Defined a Draft Accreditation Approach that Meets HAVA
Requirements:
In February 2008, EAC issued a draft version of a VSTL accreditation
program manual[Footnote 27] for public comment. According to HAVA,
EAC's accreditation program is to meet certain requirements.
Specifically, it is to provide for voting system hardware and software
testing, certification, decertification, and recertification by
accredited laboratories. Additionally, it is to base laboratory
accreditation decisions, including decisions to revoke an
accreditation, on a vote of the commissioners, and it is to provide for
a published explanation of any commission decision to accredit any
laboratory that was not first recommended for accreditation by NIST.
To EAC's credit, its draft accreditation program manual addresses each
of these requirements. First, the manual defines the role that the
laboratories are to play relative to voting system testing,
certification, recertification and decertification, and it incorporates
by reference an EAC companion voting system certification
manual[Footnote 28] that defines requirements and process steps for
voting system testing and certification-related activities.
With respect to the remaining three HAVA requirements, the draft EAC
accreditation manual also requires (1) that the commissioners vote on
the accreditation of laboratories recommended by NIST for
accreditation, (2) that EAC publish an explanation for the
accreditation of any laboratory not recommended by NIST for
accreditation, and (3) that the commissioners vote on the proposed
revocation of a laboratory's accreditation.
According to EAC officials, its draft approach incorporates HAVA
requirements because the commission is focused on meeting its legal
obligations in all aspects of its operations, including VSTL
accreditation. In doing so, EAC has addressed one important aspect of
having an effective accreditation program.
EAC Draft Approach Does Not Adequately Define Key Accreditation-Related
Steps and Decision Criteria:
Beyond addressing relevant HAVA requirements, EAC's draft accreditation
manual defines an accreditation process, including program phases,
requirements, and certain evaluation criteria. However, it does not do
so in a manner that fully satisfies factors that NIST has reported can
affect the effectiveness of accreditation programs.[Footnote 29]
Moreover, it does not adequately address a set of features that our
research shows are common to federal accreditation programs[Footnote
30] and that can influence a program's effectiveness. According to EAC
officials, these factors and features are not fully addressed in the
draft program manual because its accreditation program is still in its
early stages of development and is still evolving. Until they are fully
addressed, EAC's accreditation program's effectiveness will be limited.
Key NIST Accreditation Factors Not Fully Addressed:
According to NIST, having confidence in and ensuring appropriate use of
an accredited testing laboratory requires that accreditation
stakeholders have an adequate understanding of the accreditation
process, scope, and related criteria. NIST further reports that
confidence in the accreditation process can be traced to a number of
factors that will influence the thoroughness and competence of
accreditation programs, and thus these factors can be viewed as
essential accreditation program characteristics. They include having:
* published procedures governing how the accreditation program is to be
executed, such as procedures for granting, maintaining, modifying,
suspending, and withdrawing accreditation;
* specific instructions, steps, and criteria for those who conduct an
accreditation assessment (assessors) to follow, such as a test
methodology that is acceptable to the accreditation program;
* knowledgeable and experienced assessors to execute the instructions
and steps and apply the related criteria; and:
* complete records on the data collected, results found, and reports
prepared relative to each assessment performed.
EAC's draft accreditation program manual addresses one of these factors
but it does not fully address the other three. (See table 2.) For
example, while the manual requires that EAC maintain records, it only
addresses the retention of records associated with the testing of
voting systems and not those associated with the accreditation of
laboratories. EAC officials told us that testing records are meant to
include accreditation records, although they added that this is not
explicit in the manual and needs to be clarified. Further, the manual
is silent on the steps to be followed and criteria to be applied in
reviewing a laboratory's application and the qualifications required
for accreditation reviewers. By not fully addressing these factors, EAC
increases the risk that its accreditation reviews will not be performed
consistently and comprehensively.
Table 2: Summary of Extent to Which EAC Draft Approach Addresses NIST-
Identified Accreditation Factors:
Accreditation program factor: Published accreditation program
procedures; Addressed by EAC?: Yes.
Accreditation program factor: Specific accreditation instructions;
Addressed by EAC?: No.
Accreditation program factor: Established accreditation personnel
qualifications; Addressed by EAC?: No.
Accreditation program factor: Adequate maintenance of records;
Addressed by EAC?: Partially.
Source: GAO analysis of EAC data.
[End of table]
All but One Key GAO-Reported Accreditation Program Feature Has Been
Addressed:
As we have previously reported,[Footnote 31] the nature and focus of
federal programs for accrediting laboratories vary, but nevertheless
include certain common features. In particular, these programs require
laboratories to provide certain information to the accrediting body,
and they provide for evaluation of this information by the accrediting
body in making an accreditation determination. As we reported, the
required information is to include, among other things, the
laboratory's (1) organizational information, (2) records and record-
keeping policy, (3) test methods and procedures, (4) conflict of
interest policy, and (5) financial stability.
To its credit, EAC's draft accreditation manual provides for
laboratories to submit information relative to each of these features
that are common to federal accreditation programs. For example, it
provides for laboratories to submit organizational information, such as
location(s), ownership, and organizational chart; a written policy for
maintaining accreditation-related records for 5 years; conflict of
interest policies and procedures; test-related polices and procedures,
as well as system-specific test plans; and financial information needed
to demonstrate stability. Moreover, for four of the five features, the
manual identifies the specific types of information needed for
accreditation and how the information is to be evaluated, including the
criteria that are to be used in evaluating it. However, for the
financial stability feature, the manual does not describe what specific
documents are required from the laboratory to satisfy this requirement,
nor does the manual indicate how information provided by a laboratory
will be evaluated.
Table 3: Summary of Extent to Which EAC Satisfies Features Common to
Federal Accreditation Programs:
Accreditation program feature: Organizational information;
EAC requires information?: Yes;
EAC specifies information scope and level of detail?: Yes;
EAC specifies how information is to be evaluated and criteria to be
used?: Yes.
Accreditation program feature: Records and record-keeping;
EAC requires information?: Yes;
EAC specifies information scope and level of detail?: Yes;
EAC specifies how information is to be evaluated and criteria to be
used?: Yes.
Accreditation program feature: Test methods and procedures;
EAC requires information?: Yes;
EAC specifies information scope and level of detail?: Yes;
EAC specifies how information is to be evaluated and criteria to be
used?: Yes.
Accreditation program feature: Conflict of interest policy;
EAC requires information?: Yes;
EAC specifies information scope and level of detail?: Yes;
EAC specifies how information is to be evaluated and criteria to be
used?: Yes.
Accreditation program feature: Assurance of financial stability;
EAC requires information?: Yes;
EAC specifies information scope and level of detail?: No;
EAC specifies how information is to be evaluated and criteria to be
used?: No.
Source: GAO analysis of EAC data.
[End of table]
At the time of our review, EAC's Director of Voting System Testing and
Certification[Footnote 32] told us that the draft accreditation manual
was to be submitted for approval and that this draft did not address
all of the limitations cited above.[Footnote 33] For example, it would
not contain the information needed and the evaluation approach and
criteria to be used in making determinations about financial stability
because this decision is to be based on what the director referred to
as a "reasonableness" test that involves EAC evaluation of the
information relative to that provided by other laboratories. Further,
while EAC officials said that they plan to evolve their approach to
VSTL accreditation and to address these gaps, EAC does not have
documented plans for accomplishing this. Without clearly defining
information to be used and how it is to be used, EAC increases the risk
that financial stability determinations will not be consistently and
thoroughly made.
Available Documentation Does Not Demonstrate EAC's Basis for
Accrediting Laboratories to Date:
As of May 2008, EAC has accredited four laboratories,[Footnote 34] but
the documentation associated with each of these accreditations is not
sufficient to recreate a meaningful understanding of how each
evaluation was performed and how decisions were made, and thus, the
bases for each accreditation were not clear. Specifically, each of the
accreditations occurred before EAC had defined its approach for
conducting them. Because of this, EAC performed each one using a
broadly defined process outlined in a letter to each laboratory and an
associated checklist that only indicated whether certain documents were
received. Our analysis of these letters showed that the correspondence
sent to each laboratory was all the same, identifying three basic
review steps to be performed and citing a list of documents that the
laboratories were to provide as part of their applications.[Footnote
35] However, the letters did not describe in any manner how EAC would
review the submitted material, including the criteria to be used.
According to EAC officials, the review steps were not documented.
Instead, they were derived by a single reviewer using (1) the
applications and accompanying documents submitted by the laboratories,
(2) familiarity with the materials used by the state election directors-
sponsored accreditation program, and (3) the judgment of each reviewer.
Further, while the reviews were supported by a checklist that covered
each of the items that was to be included in the laboratory
applications and provided space for the reviewer(s) to make notes
relative to each of these items, the checklists did not include any
guidance or methodology, including criteria, for evaluating the
submitted items. Rather, the EAC accreditation program director told us
that he was the reviewer on all the accreditations and he applied his
own, but undocumented, tests for reasonableness in deciding on the
submissions' adequacy and acceptability.
Our analysis of the checklists for each laboratory accreditation showed
that while the same checklist was used for each laboratory, the
checklists did not provide a basis for evaluating and documenting the
basis for the sufficiency of those documents. In some cases, additional
communications occurred between the reviewer and the laboratory to
obtain additional documents. However, no documentation was available to
demonstrate what standards or other criteria the laboratories were held
to or how their submissions were otherwise reviewed. For example, each
of the checklists indicated that each laboratory provided "a copy of
the laboratory's conflict of interest policy." However, they did not
specify, for example, whether the policy adequately addressed
particular requirements. Nevertheless, for three of the four accredited
laboratories, documentation shows that EAC sought clarification on or
modification to the policies provided, thus suggesting that some form
of review was performed against more detailed requirements. Similarly,
while the checklists indicate that the laboratories disclosed their
respective coverage limits for general liability insurance policies,
and in one case EAC communicated to the laboratory that the limits
appeared to be low, no documentation specifies the expected coverage
limits. According to the EAC Director of Voting System Testing and
Certification, this determination was made after comparing limits among
the laboratories and was not based on any predetermined threshold.
Further, while the checklists indicate that each laboratory provided
audited financial statements, there is no documentation indicating how
these statements were reviewed.
According to the EAC program director, the lack of documentation
demonstrating the basis for EAC's laboratory accreditations is due to
the need at the time to move quickly in accrediting the laboratories
and the fact that use of the same individual to review the
accreditation evaluation negated the need for greater documentation.
Without such documentation, however, we could not fully establish how
the accreditations were performed, including whether there was an
adequate basis for the:
accreditation decisions reached and whether they were performed
consistently.
Conclusions:
The effectiveness of our nation's overall election system depends on
many interrelated and interdependent variables, including the security
and reliability of voting systems. Both NIST and EAC play critical
roles in ensuring that the laboratories that test these two variables
have the capability, experience, and competence necessary to test a
voting system against the relevant standards. NIST has recently
established an accreditation program that largely accomplishes this,
and while EAC is not as far along, it has a foundation upon which it
can build.
However, important elements are still missing from both programs.
Specifically, the current NIST approach does not define requirements
for assessor qualifications and training or ensure that assessments are
fully documented. Additionally, EAC has not developed program
management practices that are fully consistent with what NIST has found
to be hallmarks of an effective accreditation program, nor has the
agency adequately specified how evaluations are to be performed and
documented. As a result, opportunities exist for NIST and EAC to
further define and implement their respective programs in ways that
promote greater consistency, repeatability, and transparency--and thus
improve the results achieved. It is also important for NIST and EAC to
follow through on their stated intentions to evolve their respective
programs, building on what they have already accomplished through the
development and execution of well-defined plans of action. If they do
not, both will be challenged in their ability to consistently provide
the American people with adequate assurance that accredited
laboratories are qualified to test the voting systems that will
eventually be used in U.S. elections.
Recommendations for Executive Action:
To help NIST in evolving its VSTL accreditation program, we recommend
that the Director of NIST ensure that the accreditation program manager
develops and executes plans that specify tasks, milestones, resources,
and performance measures that provide for the following two actions:
* Establish and implement transparent requirements for the technical
qualifications and training of accreditation assessors.
* Ensure that each laboratory accreditation review is fully and
consistently documented in accordance with NIST program requirements.
To help EAC in evolving its VSTL accreditation program, we recommend
that the Chair of the EAC ensure that the EAC Executive Director
develops and executes plans that specify tasks, milestones, resources,
and performance measures that provide for the following action:
* Establish and implement practices for the VSTL accreditation program
consistent with accreditation program management guidance published by
NIST and GAO, including:
- documentation of specific accreditation steps and criteria to guide
assessors in conducting each laboratory review;
- transparent requirements for the qualifications of accreditation
reviewers;
- requirements for the adequate maintenance of records related to the
VSTL accreditation program; and:
- requirements for determining laboratory financial stability.
Agency Comments and Our Evaluation:
Both NIST and EAC provided written comments on a draft of this report,
signed by the Deputy Director of NIST and the Executive Director of
EAC, respectively. These comments are described below along with our
response to them.
In its comments, NIST stated that it appreciates our careful review of
its VSTL program and generally concurs with our conclusions that its
program must continue to evolve and improve. However, NIST also
provided comments to clarify the current status of the program relative
to three of our findings.
* With respect to our finding that NIST's defined approach for
accrediting VSTLs does not cite explicit qualifications for the persons
who conduct the technical assessments, the institute stated that it
does explicitly cite assessor qualifications for its overall national
laboratory accreditation program, adding that this approach to
specifying assessor qualifications has a proven record of success. It
also stated that the overall program's management manual requires all
assessors to meet defined criteria in such areas as laboratory
experience, assessment skills, and technical knowledge, and that
candidate assessors must submit information addressing each of these
areas as well as factors addressing technical competence in a given
laboratory's focus area (e.g., voting systems). Further, it stated that
candidate assessors' qualification ratings and rankings are captured in
work sheets.
In response, we do not disagree with any of these statements. However,
our finding is that NIST's defined approach for VSTL accreditation does
not specify requirements for persons who assess those laboratories that
specifically test voting systems. In this regard, NIST's own written
comments confirm this, stating that specific requirements for assessors
are not separately documented for each of its national laboratory
accreditation programs, such as the VSTL program. Therefore, we have
not modified this finding or the related recommendation.
* Regarding our finding that NIST's defined approach for accrediting
VSTLs has not always cited the current voting system standards, the
institute affirmed this in its comments by stating that the VSTL
program handbook that it provided to us only cites the 2002 system
standards, as these were the only standards in place when the handbook
was published. However, NIST also noted that when the 2005 system
guidelines were adopted in December 2005, it began the process of
updating the handbook and associated assessment checklist, and that the
handbook update was recently finalized for publication and is now being
used.
In response, we stand by our finding that NIST's defined approach has
not always cited the current voting system standards, which NIST
acknowledges in its comments. However, we also recognize that NIST has
recently addressed this inconsistency by finalizing its new handbook
and the associated assessment checklist. In light of NIST's recent
actions, we have updated the report to acknowledge the finalization of
the handbook and checklist, and removed the associated recommendation
that was contained in our draft report for NIST to ensure that its
defined approach addresses all required voting system standards.
* Regarding our finding that available documentation from completed
accreditations does not show that NIST has consistently followed all
aspects of its defined approach, the institute stated that, among other
things, all required documents for its VSTL accreditation program are
currently in use and reflect the recent update to its handbook and
checklist, and that all these documents are securely maintained.
In response, we do not question these statements; however, they are not
pertinent to our finding. Specifically, our finding is that the four
completed accreditations that we reviewed were not consistently
documented. As we state in our report, we reviewed the documentation
associated with the accreditation assessments for these four
laboratories, and we found that all four were not documented in a
similar manner, even though they were based on the same version of the
program handbook. For example, neither the laboratory notifications of
the scope of the assessment nor the next steps in the accreditation
process were consistently documented. Therefore, we have not modified
our finding, but have slightly modified our recommendation to make it
clear that its intent is to ensure that all phases of the accreditation
review are fully and consistently documented.
In its comments, EAC described our review and report as being helpful
to the commission as it works to fully develop and implement its VSTL
program. It also stated that it agrees with the report's conclusions
that additional written internal procedures, standards, and
documentation are needed to ensure more consistent and repeatable
implementation of the program. The commission added that it generally
accepts our recommendations and will work hard to implement them. To
assist it in doing so, it sought clarification about two of our
recommendations, as discussed below.
* EAC stated that the recommendation in our draft report for the
commission to develop specific accreditation steps and criteria was
broadly worded, and thus the recommendation's intent was not clear. EAC
also stated that it interpreted the recommendation to mean that it
should define internal instructions to guide assessors in performing an
accreditation, and that the recommendation was not intended to have any
impact on its published requirements and procedures governing, for
example, granting, suspending, or withdrawing an accreditation. We
agree with EAC's interpretation, as it is in line with the intent of
our recommendation. To avoid the potential for any future
misunderstanding, we have modified the wording of the recommendation to
clarify its intent.
* EAC stated that the recommendation in our draft report for the
commission to develop transparent technical requirements for the
qualifications of its assessors may be confusing because, as we state
in our report, only NIST performs a technical accreditation review, as
EAC's review is administrative, non-technical in nature. To avoid the
potential for any confusion, we have modified the wording of the
recommendation to eliminate any reference to technical qualification
requirements.
We are sending copies of this report to the Ranking Member of the House
Committee on House Administration, the Chairman and Ranking Member of
the Senate Committee on Rules and Administration, the Chairmen and
Ranking Members of the Subcommittees on Financial Services and General
Government, Senate and House Committees on Appropriations, and the
Chairman and Ranking Member of the House Committee on Oversight and
Government Reform. We are also sending copies to the Chair and
Executive Director of EAC, the Secretary of Commerce, the Deputy
Director of NIST, and other interested parties. We will also make
copies available to others on request. In addition, this report will be
available at no charge on the GAO Website at [hyperlink,
http://www.gao.gov].
Should you or your staffs have any questions on matters discussed in
this report, please contact me at (202) 512-3439 or at hiter@gao.gov.
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 IV.
Sincerely yours,
Randolph C. Hite:
Director, Information Technology Architecture and System Issues:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
Our objectives were to determine whether the National Institute of
Standards and Technology (NIST) and the Election Assistance Commission
(EAC) have defined effective voting system testing laboratory (VSTL)
accreditation approaches, and whether each is following its defined
approach.
To determine whether NIST has defined an effective accreditation
approach, we reviewed documentation from its VSTL accreditation
program, such as handbooks and program manuals for the National
Voluntary Laboratory Accreditation Program (NVLAP), of which the VSTL
accreditation program is a part. In doing so, we compared these
documents with applicable statute, guidance, and best practices,
primarily the Help America Vote Act of 2002 (HAVA), internationally
recognized standards from the International Organization for
Standardization (ISO), and federal accreditation program management
guidance published by NIST. We compared program documentation with
HAVA's NIST-specific accreditation requirements to determine the extent
to which the agency was fulfilling its HAVA responsibilities. We also
reviewed program documentation against ISO/IEC 17011,[Footnote 36]
which establishes general requirements for accreditation bodies, and
ISO/IEC 17025,[Footnote 37] which establishes the general requirements
for assessing the competence of laboratories, to determine the extent
to which NIST's accreditation program was based on internationally
recognized standards. We also compared the documentation against NIST
publication NISTIR 6014,[Footnote 38] which contains sections that
provide guidance for laboratory accreditation programs, to determine
whether the VSTL accreditation program had defined other elements of
effective accreditation programs. We also interviewed the voting
accreditation program manager to determine how these documents were
used to guide the program.
To determine whether NIST has followed its defined approach, we
examined artifacts from the accreditation assessments of five VSTLs,
including one laboratory accredited by NVLAP, but not yet recommended
to EAC. This material included completed assessment checklists derived
from the accreditation program handbooks, additional documents
supporting the assessments, and laboratory accreditation applications
and supporting documentation. We compared artifacts from these
assessments to program guidance to determine the extent to which the
defined process was followed. In addition, we interviewed officials
from NIST and NIST contract assessors and officials from EAC and the
four EAC-accredited VSTLs to understand how the NIST process was
implemented and how it related to the process managed by EAC.
To determine whether EAC has defined an effective accreditation
approach, we reviewed documentation from its VSTL accreditation
program, such as the draft Voting System Test Laboratory Accreditation
Program Manual.[Footnote 39] In doing so, we compared this document
with applicable statute and best practices, primarily HAVA and federal
accreditation program management guidance published by NIST. We
compared the draft program manual with HAVA's EAC-specific
accreditation requirements to determine the extent to which the agency
was fulfilling its HAVA responsibilities. We also compared the
documentation against the accreditation guidance in NISTIR 6014 to
determine whether the accreditation program had defined other elements
of effective accreditation programs. We also interviewed the EAC voting
program director and executive director to determine how these
documents were used to guide the program and to understand EAC's
defined accreditation approach prior to the development of the draft
manual.
To determine whether EAC has followed its defined approach, we compared
artifacts from the accreditation reviews of four VSTLs. We did not
review a fifth laboratory, which had been accredited by NVLAP, but not
yet recommended to EAC. The materials reviewed included checklists
completed by EAC in the absence of an approved program manual. In doing
so, we compared the review artifacts to accreditation program
requirements, as communicated to the laboratories, to determine the
extent to which the agency followed its process, as verbally described
to us. We did not compare accreditation submissions or EAC review
artifacts with the draft accreditation manual because agency officials
stated that the draft manual had not been used in the review of any
laboratory. In addition, we interviewed officials from NIST, EAC, and
the four EAC-accredited VSTLs[Footnote 40] to understand how the EAC
process was implemented and how it related to the process managed by
NIST.
To assess data reliability, we reviewed program documentation to
substantiate data provided in interviews with knowledgeable agency
officials. We have also made appropriate attribution indicating the
data's sources.
We conducted this performance audit at EAC and NIST offices in
Washington, D.C., and Gaithersburg, Maryland, respectively, from
September 2007 to September 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: Comments from the National Institute of Standards and
Technology:
United States Department Of Commerce:
National Institute of Standards and Technology:
Gaithersburg, Maryland 20899-0001:
Office Of The Director:
Memorandum For:
Randolph C. Hite:
Director, Information Technology Architecture and System Issues:
Government Accountability Office:
From:
Signed by:
James M. Turner, Ph.D.:
Deputy Director:
Subject: Comments on Government Accountability Office (GAO) Draft
Report Entitled "Elections: Federal Programs for Accrediting
Laboratories that Test Voting Systems Need to Be Better Defined and
Implemented" (GAO-08-770):
This is in response to your draft report dated March 2008, entitled
"Elections: Federal Programs for Accrediting Laboratories that Test
Voting Systems Need to Be Better Defined and Implemented." Thank you
for the opportunity to review and comment on this draft.
I appreciate the GAO team's careful review of the NIST/NVLAP program to
accredit voting system testing laboratories under the EAC program. I am
pleased that the GAO review found that the NIST voting system
accreditation program reflects HAVA requirements, incorporates relevant
international accreditation standards and meets International
Organization for Standardization (ISO) accreditation body requirements,
and laboratory accreditation review requirements.
The draft report also states, however, that the NIST program is missing
details needed for consistent and verifiable implementation. While NIST
generally concurs with the GAO findings that the Voting System Testing
Laboratory (VSTL) program must continue to evolve and be enhanced over
time, we think it is important to clarify the current state of the
program, particularly the state of the documentation associated with
the program's consistent and verifiable implementation. In the
attachment to this memorandum, we respond to the three areas of
specific concern identified in the draft report regarding NIST's role
in the voting system accreditation process provided for under HAVA.
I am confident that the accreditation program implemented by NVLAP
currently fully meets the requirements of HAVA and will lead to
increased confidence in the electronic voting process. NIST remains
committed to improving the operation of the program as we move forward.
We are looking forward to receiving your final report. Please contact
Steve Willett on (301) 975-8707 should you have any questions regarding
this response.
Attachment:
Below is the NIST response to the three areas of specific concern
identified in the draft report regarding NIST's role in the voting
system accreditation process provided for under HAVA.
(1) First, the draft findings state that NIST has not specified
requirements for assessor qualifications and training. Specifically,
"NIST's defined approach does not, for example, cite explicit
qualifications for the persons who conduct accreditation technical
assessments, as called for in federal accreditation program guidance."
Response – The NVLAP program does cite explicit qualifications for
technical assessors, as required under the provisions of ISO/IEC
17011:2004, the international standard that establishes general
requirements for accreditation bodies. This standard is incorporated in
the NVLAP Management System Manual. Section 6.3.2.1 of the manual,
which addresses assessor selection criteria, states, "NVLAP uses the
services of assessors and technical experts who meet defined criteria
in the areas of laboratory experience, communication, assessment
skills, technical knowledge, quality management, professional
activities, and education and training." Candidate assessors must
submit biographies and supporting information that address each of the
above criteria, in each case specifically addressing factors that
demonstrate technical competence relevant to a specific NVLAP
laboratory accreditation program or programs, e.g., voting system
testing.
To evaluate a potential assessor, NVLAP relies on the assessor
biography, interviews, and recommendations to prepare an assessor
summary sheet that documents the basis for selection. Rating work
sheets are used to rank the assessor's knowledge and ability in the
areas of: education, lab experience, communication skills, assessment
experience, lab management experience, and professional association
affiliations. While specific requirements for assessors are not
separately documented for each NVLAP program, the procedure currently
in use has a proven record of success within NVLAP and other
accreditation bodies. NVLAP also monitors its assessors and solicits
written comments from customer laboratories covering many issues,
including assessor technical competence. Initial qualification,
monitoring and laboratory feedback information is documented and
maintained in the assessor files in a secured file room.
The GAO report also states that, "NIST officials said that they rely on
individuals who have prior experience in reviewing such laboratories."
All NVLAP programs rely on experts that have prior experience; this is
viewed as an asset. Assessors are selected for their technical
expertise and trained in assessment techniques and NIST Handbook 150
(NVLAP's version of ISO/IEC 17025). This is accomplished by NVLAP
through workshops, on the job training, and/or one-on-one training. The
NVLAP technical assessor supporting the voting system testing
laboratory program has both extensive prior experience in voting system
testing and evaluating technical competence through the National
Association of State Election Directors (NASED) assessment program and
current experience as an EAC evaluator. This is documented in his
assessor file. The voting system lead assessor has over 10 years of
experience as a NVLAP lead management system assessor and as a
technical assessor in the area of electromagnetic compatibility and
telecommunications. He has attended courses offered periodically by
NVLAP to its assessors and has been qualified as a NVLAP assessor with
the appropriate certificate. This is documented in his assessor file.
(2) Second, the draft findings state that the current NIST approach
does not fully specify criteria for evaluating and documenting VSTL
capabilities. Specifically, "Even though the EAC requires that
laboratory accreditation be based on demonstrated capabilities to test
against the latest voting system standards, NIST's defined approach has
not always cited these current standards." The draft report cites
instances where the technical (program specific) checklists were not
always consistent for the on-site assessments and notes that some
laboratories stated they did not know what was expected of them. This
finding refers to the development and implementation of the program
specific handbook and checklist.
Response - When the NVLAP voting system accreditation program was first
made available to interested laboratories in June 2005, the 2002 VVS
was the only approved standard in existence. Therefore, NVLAP's initial
program specific handbook took only this standard into account. The EAC
formally adopted the 2005 VVSG in December 2005, with an effective date
of December 2007. NVLAP informed the candidate VSTLs in early 2006 that
their scope of accreditation would include both the 2002 VVS and 2005
VVSG. The process was begun at that time to revise the initial program
specific handbook to reflect both standards.
Candidate VSTLs were clearly told by NIST that the accreditation would
be to both the 2002 VVS and 2005 VVSG. The labs were informed that in
order to be accredited as Voting System Testing Laboratories by NVLAP
they would have to be accredited to the core set of test methods
contained in both standards. This was communicated to the labs during
the pre- assessments, in e-mail and phone communications, and at the on-
site assessment visit. In addition the candidate VSTLs should have
known this since the same information was available on the EAC website.
NVLAP conducted no-cost pre-assessments of each candidate VSTL,
beginning in February 2006. In parallel, a program specific checklist
was being developed to encompass both standards. During these pre-
assessments (lasting an average of two days), the laboratory's
technical and quality systems were reviewed, personnel interviewed and
issues discussed. The program specific handbook was updated and
approved at the NVLAP level in December 2007. It was denoted as being
in draft form at that time because it had not been through a NIST
internal editorial review process needed for hardcopy publication. This
editorial process has been completed and the handbook has been
finalized for publication. Final versions of the program specific
handbook and checklist are now in use. Each VSTL has been assessed to
both the 2002 VVS and 2005 VVSG.
NVLAP's general requirements are found in NIST Handbook 150. Program
specific handbooks and checklists are provided by NVLAP as a tool for
identifying and documenting assessment findings and nonconformities
relative to the test methods being assessed. They incorporate the same
numbering system and section headings as Handbook 150. The difference
between the general and program specific handbooks is that the program
specific handbook (Handbook 150-22 in the case of the voting program)
provides additional guidance for coverage of specific test methods
without repeating the general criterion in Handbook 150. In the case of
the voting system testing program, the specific test methods are found
in 2002 VVS and 2005 VVSG. There are roughly one thousand test methods
in the 2005 VVSG alone. The goal of Handbook 150-22 is not to reiterate
every requirement in the technical standards, since these are already
stated in the standards themselves, but to provide a framework so the
laboratory will know where elements of the standard will be considered
and recorded in our documentation. NVLAP's function is not to educate
the laboratories in the standard but to document their competency in
applying voting system standards to equipment under test.
(3) The third finding was that available documentation does not show
that NIST has consistently followed all aspects of its defined
accreditation approach. Specifically, the GAO report recommends that
the NIST/NVLAP program manager needs to provide actions for, "Ensuring
that each laboratory accreditation review is fully documented."
Response: All required documents for the voting system testing program
are currently in use and include the most recent, up-to-date Handbook
150-22 with its checklist. The documentation used for accreditation
review by NVLAP includes: the lab application, laboratory management
system manual, on-site report, lab responses to nonconformities, and
documentation to support the laboratory's response. The on-site report
consists of the general operations checklist, program specific
checklist, signature sheet, narrative summary, and assessment summary.
All these documents remain on file in a secure NVLAP file room.
Every NVLAP program documents the evaluation using the NVLAP On-site
Assessment Review form. Additionally, as part of the on-site assessment
report, the assessor completes a narrative summary addressing the
overall findings of each section of the standard as well as the
assessment checklists for both the NVLAP general and program specific
handbooks. The assessment process requires that the assessor leave
copies of the assessment report with the lab on the last day of the on-
site assessment.
Unlike NVLAP's other programs, where strict confidentiality is
observed, the voting program must exhibit a level of transparency in
order to remain open to the public. To accomplish this, the on-site
report, lab responses, and evaluation form are made available on the
NIST voting website. Proprietary information in the nonconformity
response documentation is not posted.
Over the past several years NIST has worked to provide the American
public with a comprehensive accreditation program capable of assessing
the competency of voting system testing laboratories to current
standards while also maintaining a process which will allow the program
to accommodate the development of new standards. NIST recognizes the
need for an unbiased assessment of its process and commends the GAO for
providing this service. The NVLAP voting system testing laboratory
program has gone through a maturation process since 2004. NIST is
confident that the accreditation program implemented by NVLAP currently
fully meets the requirements of HAVA and will lead to increased
confidence in the electronic voting process. We remain committed to
improving the operation of the program as we move forward. In
particular, as recommended by the GAO, we will continue to enhance the
transparency of NVLAP requirements for the technical qualifications and
training of assessors, ensure that all required voting system standards
are addressed, and ensure that each laboratory accreditation review is
fully documented.
[End of section]
Appendix III: Comments from the Election Assistance Commission:
U.S. Election Assistance Commission:
Office Of The Executive Director:
1225 New York Avenue, NW, Suite 1100:
Washington, DC. 20005:
Mr. Randolph C. Hite, Director:
Information Technology Architecture and Systems:
United States Government Accountability Office:
Re: Draft Report GAO 08-770, Elections: Federal Programs for
Accrediting Laboratories that Test Voting Systems Need to Be Better
Defined and Implemented:
Thank you for the opportunity to provide comments on GAO Report 08-770
regarding Federal voting system test laboratory accreditation programs.
The U.S. Election Assistance Commission (EAC) appreciates the time and
effort put forth by GAO during the preparation of this document and the
willingness of GAO staff to discuss pertinent issues at length with the
EAC, NIST and other key stakeholders in the voting system testing
community. The EAC has found both the review process and report helpful
as it works to fully develop and implement its new Laboratory
Accreditation Program.
GAO recognized that EAC has successfully "published procedures
governing how the accreditation program is to be executed" (pgs 31-32)
and that its program includes requirements for all five recognized
accreditation program features (pgs 33-34). The EAC agrees with the
report's conclusion that while EAC's accreditation program has
effectively laid out its program requirements, additional written
internal procedures, standards and documentation are needed to ensure a
more consistent and repeatable review process. The EAC is currently
developing written, internal procedures to better implement and
document its Laboratory Accreditation Manual. As the EAC implements the
various aspects of its accreditation program, it will incorporate the
recommendations provided in the GAO report.
The report provides four recommendations for the EAC to better conform
to accreditation program management guidance published by NIST and GAO.
Generally, the EAC accepts the recommendations provided with little
comment. However, in one instance the phrasing of a recommendation is
questioned in light of the report's findings. Additionally, the EAC
expresses concern that certain technical responsibilities under the
purview of NIST are placed upon the EAC. The following are EAC's
comments in response to each recommendation.
1. Documentation of specific accreditation steps and criteria. This
recommendation is stated broadly and, as a result, is unclear in light
of the content of the report. Despite its broad language, the EAC does
not read this recommendation as impacting the program's laboratory
accreditation requirements, as the report has found that the EAC has
properly "published procedures governing how the accreditation program
is to be executed, such as procedures for granting, maintaining,
modifying, suspending, and withdrawing accreditation." (pg 31 – 32).
Rather, based upon the discussion on page 31-32 of the report, the EAC
reads this recommendation as advising that EAC develop additional
"instructions, steps, and criteria for those who conduct an
accreditation assessment."
Based upon this reading, the EAC concurs with GAO's recommendation to
develop a more formalized internal process for reviewing accreditation
applications. The EAC has a checklist in place to guide the process;
however we will review the document with an eye toward improving it by
developing additional internal procedures and criteria for reviewing
applications.
2. Transparent technical requirements for the qualifications of
accreditation reviewers. EAC is concerned that this recommendation may
confuse readers of this report regarding the distinct roles of EAC and
NIST in the laboratory accreditation process. According to HAVA, NIST
is responsible for the technical review of voting system test
laboratories; the EAC performs a "nontechnical" review of laboratories
after the technical review by NIST is completed. As the GAO report
notes, "NIST is to focus on assessing laboratory technical
qualifications, while the EAC is to use those assessment results and
recommendations, and augment them with its own review of related
laboratory capabilities, to reach an accreditation decision." (pg 13).
EAC's review is administrative, and it is initiated only after
receiving a laboratory accreditation recommendation from NIST.
After it has received technical recommendation from NIST, the EAC
conducts an administrative review of the applicant laboratory. This
includes collecting: (1) laboratory information required by Section
3.4.1. of EAC Draft Voting System Test Laboratory Program Manual
(Accreditation Manual); (2) a signed agreement affirming that the
laboratory will meet all elements of the EAC Accreditation Program
(Chapter 2 of the Accreditation Manual); and (3) a Certification of
Laboratory Conditions and Practices (Attachment A of the Accreditation
Manual) documenting that the laboratory has certain conditions and
required policies in place (specifically: a conflict of interest
policy, a personnel policy, a recordkeeping policy and evidence of
sufficient resources and financial stability). Thus, the EAC's
nontechnical review is limited to (1) determining whether required
information and the signed agreement and certification are, in fact,
provided and (2) determining whether the certifications of the
laboratory (concerning its conflict of interest policy, personnel
policy, recordkeeping policy and resources and financial stability) are
acceptable by comparing the policies provided with the EAC program
requirements.
EAC's staff has the appropriate credentials for nontechnical reviews of
laboratory applicants in accordance with the accreditation process
contained in HAVA. These qualifications include a detailed
understanding of EAC's Accreditation Program and its requirements. The
EAC will place this qualification and any others deemed necessary in
the internal procedures it is creating (as noted above).
3. Requirements for the adequate maintenance of records related to the
VSTL accreditation program. This recommendation is similar to 1 and 2,
above. EAC agrees that more formalized review procedures would benefit
its accreditation program. Documentation is a key element of such
action. The adoption of EAC's Accreditation Manual (anticipated date of
approval, July, 2008) will go a long way to assist with improving the
laboratory accreditation process. The manual prescribes an application
package which includes a certification form, an agreement document and
specific information. As noted above, EAC is already using an
application checklist which it plans to amend consistent with GAO
recommendations. Moreover, the Commission will ensure that its internal
procedures require formal documentation of each EAC action and basis
for it. The EAC is making documentation a priority throughout its
Laboratory Accreditation Program.
The EAC has made it a priority to provide the public with program
information, including correspondence and many other program-related
materials. This information is readily available at [hyperlink,
http://www.eac.gov], and stakeholders including State and local
election officials, voting system manufacturers, test laboratories and
the voting public are notified frequently about program updates. The
EAC also provides links to program material generated by NIST's
technical reviews of the laboratories.
4. Requirements for determining laboratory financial stability. The GAO
Report specifies five program features (or areas of required
information) that an accreditation program should include. As the GAO
report notes, EAC's Accreditation Program Manual contains requirements
for each of these features, including: organizational information,
records and record keeping, test methods and procedures, conflict of
interest policy and assurance of financial stability. However, for the
last requirement, GAO has recommended that the EAC provide additional
criteria for review and obtain additional laboratory information.
EAC's Draft Accreditation Manual provides a concise requirement for
laboratory financial stability. "As a condition of accreditation, all
VSTLs shall allocate sufficient resources to enable the laboratory to
properly use and maintain its test equipment, personnel, and facility
and to satisfactorily perform all required laboratory functions. The
laboratory shall maintain insurance policies sufficient to indemnify,
itself against financial liabilities or penalties that may result from
its operations." (Accreditation Manual §2.14). The EAC agrees that this
requirement should look more like its other four program features and
provide more specific criteria. The EAC will amend its draft manual to
reflect GAO's recommendations before the document's final publication
in July. In addition, the EAC will require additional information with
respect to the issue of financial stability. Presently the draft manual
requires the submission of insurance, workman's compensation, staffing,
facilities, and financial reporting information. (Accreditation Manual
§3.4.1).
The EAC recognizes that the Federal government's first voting system
test laboratory accreditation program must have a solid foundation. The
EAC continues to evaluate its progress and identify issues of concern
to ensure that this new program is robust and thorough. For instance,
the EAC recently asked NIST (Attachment; EAC letter to NIST Standards
Services Division Chief Mary Saunders, March 13, 2008. Also available
at [hyperlink, http://www.eac.gov] under the Voting Systems Center.) to
address and report back to the EAC on some areas of concern noted by
the EAC in its review of VSTL work products. We also requested NIST to
review the laboratories' management process for assigning appropriate
levels of staff, the qualifications of laboratory employees and how
federal testing assignments are prioritized. Further, we requested a
review of the laboratories' test methods and the validation process
used to ensure that "NIST remains confident of each VSTL's ability to
test voting systems."
The EAC will continue to work with NIST to ensure that the laboratory
accreditation process is monitored very closely, and after NIST produce
this additional information, we will provide it to GAO, Congress, and
the public.
Keeping stakeholders and the general public informed about program
activities, milestones and challenges continues to be a top priority. A
May 2, 2008 memo (attached and available at [hyperlink,
http://www.eac.gov] under Voting System Center), to election officials
from Program Director Brian Hancock indicated that challenges remain in
the certification process, such as the length of time it takes
accredited laboratories to evaluate voting systems. Some participants
in the certification program are experiencing challenges meeting the
requirements of a more robust and thorough testing process, as
evidenced by the submission of nine test plans from a single testing
engagement. All draft and final test plans as well as test reports are
available at [hyperlink, http://www.eac.gov] under the Voting System
Center.
The EAC thanks GAO for its work in assisting the Commission in its
efforts to improve and develop the Voting System Laboratory
Accreditation Program. The EAC is committed to continuous improvement
in all of it programs and will work hard to implement the
recommendations made in this report. The EAC is committed to making its
accreditation process part of a world class testing and certification
program.
Sincerely,
Signed by:
Thomas R. Wilkey:
Executive Director:
[End of section]
Appendix IV: GAO Contact and Staff Acknowledgments:
GAO Contact:
Randolph C. Hite, (202) 512-3439 or hiter@gao.gov:
Staff Acknowledgments:
Paula Moore, Assistant Director; Justin Booth; Timothy Case; Neil
Doherty; Timothy Eagle; Nancy Glover; Dave Hinchman; Rebecca LaPaze;
Freda Paintsil; Nik Rapelje; and Jeffrey Woodward made key
contributions to this report.
[End of section]
Footnotes:
[1] See, for example, GAO, Elections: Perspectives on Activities and
Challenges Across the Nation, GAO-02-3 (Washington, D.C.: Oct. 15,
2001); Elections: Status and Use of Federal Voting Equipment Standards,
GAO-02-52 (Washington, D.C.: Oct. 15, 2001); Elections: A Framework for
Evaluating Reform Proposals, GAO-02-90 (Washington, D.C.: Oct. 15,
2001); 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.: Sept. 21, 2005); and
Elections: All Levels of Government Are Needed to Address Electronic
Voting System Challenges, GAO-07-576T (Washington, D.C.: Mar. 7, 2007).
[2] GAO-02-52.
[3] 42 U.S.C. § 15371.
[4] In August 2008, after EAC provided comments on, and we had
finalized, this report, the commission announced that it had approved
its draft accreditation program manual. As a result, we did not review
the approved manual.
[5] GAO-02-3.
[6] GAO-02-3.
[7] GAO, Elections: Electronic Voting Offers Opportunities and Presents
Challenges, GAO-04-975T (Washington, D.C.: July 20, 2004).
[8] GAO-05-956.
[9] Help America Vote Act, Pub. L. No. 107-252 (Oct. 29. 2002).
[10] Federal Election Commission, Performance and Test Standards for
Punchcard, Marksense, and Direct Recording Electronic Voting Systems
(January 1990).
[11] GAO-05-956.
[12] The VVSG did not take effect until December 2007.
[13] We have ongoing work to review EAC's certification program for the
House Committee on House Administration.
[14] GAO-02-90.
[15] The state elections directors' accreditation program was
discontinued in July 2006.
[16] A suspension provides the laboratory an opportunity to address the
identified issues.
[17] NIST, NIST Handbook 150: National Voluntary Laboratory
Accreditation Program Procedures and General Requirements
(Gaithersburg, Md.: February 2006).
[18] NIST, NIST Handbook 150-22: National Voluntary Laboratory
Accreditation Program: Voting System Testing (Gaithersburg, Md.:
December 2005).
[19] ISO, ISO/IEC 17011: Conformity Assessment: General Requirements
for Accreditation Bodies Accrediting Conformity Assessment Bodies
(Geneva, Switzerland: Feb. 15, 2005).
[20] ISO, ISO/IEC 17025: General Requirements for the Competence of
Testing and Calibration Laboratories (Geneva, Switzerland: May 15,
2005).
[21] NIST, National Voluntary Laboratory Accreditation Program:
Management System Manual, Revision 2 (Gaithersburg, Md.: Mar. 25,
2008).
[22] NIST, The ABC's of the U.S. Conformity Assessment System, NISTIR
6014 (Gaithersburg, Md.: April 1997).
[23] NIST, NIST Handbook 150-22.
[24] NIST, Handbook 150-22 2008 Edition: National Voluntary Laboratory
Accreditation Program: Voting System Testing (Gaithersburg, Md.: May
2008); NIST Handbook 150-22 Checklist: Voting System Testing Program
(Rev. 2008-06-25).
[25] NIST, National Voluntary Laboratory Accreditation Program:
Management System Manual, Revision 2.
[26] As mentioned earlier, these guidelines became effective in
December 2007.
[27] EAC, Voting System Test Laboratory Accreditation Program Manual
(draft, Washington, D.C., February 2008).
[28] EAC, Testing and Certification Program Manual (Washington, D.C.:
January 2007).
[29] NIST, The ABC's of the U.S. Conformity Assessment System, NISTIR
6014.
[30] GAO, Laboratory Accreditation: Requirements Vary Throughout the
Federal Government, GAO/RCED-89-102 (Washington, D.C.: Mar. 28, 1989).
[31] GAO/RCED-89-102.
[32] The EAC Director of Voting System Testing and Certification also
manages EAC's VSTL accreditation program.
[33] On August 4, 2008, EAC reported that it approved an initial
version of its program manual. However, we did not evaluate this
initial version to determine the extent to which it addresses
limitations that we found in the draft manual because it was approved
after EAC provided comments on a draft of, and we had finalized, this
report.
[34] According to the NIST program manager, a fifth laboratory has been
accredited by NVLAP but not yet recommended to EAC.
[35] The steps were to: 1) provide information, such as the
laboratory's conflict of interest policy, evidence of insurance
coverage limits, and audited financial statements; 2) provide a signed,
standardized letter of agreement to abide by the EAC program terms; and
3) provide a signed certification of laboratory practices and
conditions, such as having policies in place with respect to personnel
practices, record-keeping requirements, and financial stability.
[36] ISO, ISO/IEC 17011: Conformity Assessment: General Requirements
for Accreditation Bodies Accrediting Conformity Assessment Bodies
(Geneva, Switzerland: Feb. 15, 2005).
[37] ISO, ISO/IEC 17025: General Requirements for the Competence of
Testing and Calibration Laboratories (Geneva, Switzerland: May 15,
2005).
[38] NIST, The ABC's of the U.S. Conformity Assessment System, NISTIR
6014 (Gaithersburg, Md.: April 1997).
[39] EAC, Voting System Test Laboratory Accreditation Program Manual
(draft, Washington, D.C.: February 2008). EAC approved the program
manual for publication in July 2008; however this was accomplished too
late for GAO to review the manual's contents for this report.
[40] In June 2008, NIST granted NVLAP accreditation to a fifth
laboratory, CIBER Inc., and recommended it for EAC accreditation. As of
August 2008, that accreditation had yet to be granted.
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