USPS OIG: Our objective was to evaluate the Postal Service’s readiness for timely processing of Election and Political Mail for the 2020 general elections.
Election Mail is any mailpiece that an authorized election official creates for voters participating in the election process and includes ballots and voter registration materials. Political Mail is any mailpiece created by a registered political candidate, a campaign committee, or a committee of a political party for political campaign purposes.
Election and Political Mail can be sent as either First-Class Mail, which takes 2 to 5 days to be delivered, or Marketing Mail, which takes 3 to 10 days to be delivered, depending on the preference of the customer. However, ballots returned by voters are required to be sent as First-Class Mail. While Marketing Mail has longer processing and delivery timeframes, it costs less than First‑Class Mail.
The Postal Service plays a vital role in the American democratic process and this role continues to grow as the volume of Election and Political Mail increases. In addition to the next general election, which will be held November 3, 2020, there will be federal elections for all 435 seats in the U.S. House of Representatives and 35 of the 100 seats in the U.S. Senate. There will also be 13 state and territorial elections for governor and numerous other state and local elections. Due to the COVID-19 pandemic, there is an expected increase in the number of Americans who will choose to vote by mail and avoid in-person voting.
Our prior audits related to the Postal Service’s processing of Election and Political mail include: Processing Readiness for Election and Political Mail for the 2018 Midterm Elections (Report Number NO-AR-18-007; June 5, 2018), Service Performance of Election and Political Mail During the 2018 Midterm and Special Elections (Report Number 19XG010NO000-R20; November 4, 2019), and Timeliness of Ballot Mail in the Milwaukee Processing and Distribution Center Service Area (Report Number 20-235-R20; July 7, 2020).
In the prior audits, we found the Postal Service needed to improve communication between headquarters, mail processing facilities, and election officials; train staff on Election and Political Mail processes; keep internal Election and Political Mail websites up-to-date; and appropriately align resources to process peak Election and Political Mail volume.
This audit was conducted during special and primary elections held in May and June 2020 and included reviewing operations at Processing and Distribution Centers (P&DC) that were processing mail for a special or primary election in each of the seven Postal Service areas. The facilities reviewed were Santa Clarita, Portland, Indianapolis, Baltimore, Charleston, Brooklyn, and Oklahoma City P&DCs.
We did not evaluate recent operational changes made by the Postal Service or the significant increases in delayed mail at delivery units experienced this summer. In response to a congressional request received on August 7, 2020, we have an ongoing project which will evaluate these operational changes and their impact on mail service. On August 18, 2020, the Postmaster General announced he was suspending initiatives regarding Postal Service operational changes until after the general election is concluded.
While the Postal Service has made progress in preparing for the 2020 general election, there are concerns surrounding integrating stakeholder processes with Postal Service processes to help ensure the timely delivery of Election and Political Mail. These potential concerns include:
- Ballots mailed without barcode mail tracking technology;
- Ballot mailpiece designs that result in improper processing;
- Election and Political Mail likely to be mailed too close to the election, resulting in insufficient time for the Postal Service to process and deliver the mailpieces;
- Postmark requirements for ballots; and
- Voter addresses that are out of date.
Resolving these issues will require higher level partnerships and cooperation between the Postal Service and various state officials, including secretaries of state and state election boards. Timely delivery of Election and Political Mail is necessary to ensure the integrity of the U.S. election process.
Stakeholder-Related Election Mail Issues
The Postal Service has frequently communicated to state election officials the importance of ballot mailpiece tracking and design, the required timeframes for processing and delivering mail, and the importance of updating voter addresses. They have designated area and district Political and Election Mail coordinators to conduct outreach to state and local election officials and published a toolkit for election officials to facilitate voting by mail. Further, the Postal Service has altered their normal processes to accommodate for the timely processing of Election and Political Mail, such as requiring postmarks on all ballots, prioritizing the pickup, processing, and delivery of Election and Political Mail, and diverting resources as necessary. However, as mentioned in the Timeliness of Ballot Mail in the Milwaukee P&DC Service Area audit, issues surrounding these items continue to occur.
- The Postal Service, mailers, and election boards are not able to track ballot envelopes that do not have barcodes. According to Postal Service management, some election boards have chosen to continue using excess stock of ballot envelopes without barcodes and some lack the funding for integrating the use of barcodes in their mailing process. Based on data analyzed from the 2018 general election season, about 31.1 million ballots were cast by mail, but only 4.1 million (13 percent) Election Mail mailpieces used mail tracking technology.
- Some election boards continue using ballot envelope designs which can cause mail processing machines to return ballots to voters. This can occur when the ballot envelope contains more than two addresses, as well as when addresses are located on both sides of the envelope.
- Mailers, election boards, and voters are likely to mail Election and Political Mail too close to an election. This could result in insufficient time for the Postal Service to process and deliver the mailpieces within prescribed delivery standards, and still meet state deadlines for receiving ballots from voters. The Postal Service suggests election offices send ballots as First-Class Mail, and while First-Class Mail only takes 2 to 5 days to be delivered, the Postal Service recommends election offices send ballots to voters at least 15 days prior to an election. This is to ensure time for the ballot to reach the voter and for the voter to complete and return the ballot. However, 48 states and the District of Columbia have absentee ballot request deadlines less than 15 days in advance of an election. According to Postal Service management, during the primary election season, election boards mailed over 1 million ballots to voters within 7 days of an election. This put these ballots at high risk by not allowing sufficient time for delivery to voters and their subsequent delivery back to the election boards.
- Postmarking provides an official date stamp for ballots; however, ballot postmarking policies vary by state. Although 29 states do not currently require postmarks on absentee ballots, the states that do require them have different timeframes for when ballots must be postmarked or received to be counted. In anticipation of an increase in voting by mail during the November 2020 general election, some states have recently updated their postmark requirements.
- States have different requirements and timeframes for updating their voter registries. Some states only update voter address information every two years and run the risk of using outdated addresses for their registered residents who have moved. This can cause absentee ballots intended for voters to be returned to election officials as undeliverable.
When mailers, states, and election boards do not follow recommended best practices to prepare, process, and track Election and Political Mail sent to voters, there is an increased risk the mail may not be delivered timely.
Readiness for Timely Processing
Since our prior audits, the Postal Service has improved internal communication between headquarters and mail processing facilities, and developed online Election and Political Mail training. However, the amount of identifiable Election and Political Mail delivered on-time nationwide was 94.5 percent from April 2020 through June 2020, a decrease of 1.7 percentage points compared to the same time period in 2018.
The seven P&DCs we reviewed that were processing Election and Political Mail for special or primary elections did not always comply with Election and Political Mail readiness procedures. Specifically:
- While all seven facilities performed some level of certification that they were clear of Election and Political Mail in their facility at the end of the day, five of the facilities did not fully comply during the two weeks leading up to the election. Specifically, facilities either did not complete, properly complete, or timely complete the daily certification. Further, even though the Oklahoma and Baltimore P&DCs certified they were clear of Election and Political Mail daily, we identified approximately 200 ballots at the Oklahoma City P&DC and 68,000 Political Mail mailpieces at the Baltimore P&DC that had not been processed.
- Six of the seven facilities did not always complete daily self-audits of Election and Political Mail readiness. The self-audit verifies readiness to receive and process Election and Political Mail and includes items such as verifying daily all-clear checks, evaluating the setup of a staging area, and logging the arrival of Election and Political Mail.
- None of the seven facilities used the Postal Service’s Operational Clean Sweep Search Checklist. This checklist provides a list of specific areas to check when searching for Election and Political Mail within the mail processing facility.
- Six of the seven facilities used their own variation of the Election and Political Mail logs, which were missing key information such as mail class and the date/time it was cleared from the operation. The logs help track Election and Political Mail as it moves through the Postal Service’s network.
These issues occurred due to a lack of management oversight and unclear guidance regarding who is responsible for completing all-clear certifications, checklists, and logs; who ensures issues are resolved; and how often these items should be completed and maintained. Not completing and using these tools could result in processing delays and lower service performance. An analysis of data determined the total number of identifiable Election and Political Mail mailpieces not delivered on time from April 2020 through June 2020 for the seven P&DCs was about 1.6 million (8 percent) of 20.2 million mailpieces.
In addition, we noted that while postmarks are not required on all mailings and are intended to be a revenue protection mechanism to prevent the reuse of postage, the Postal Service has directed personnel to postmark all ballots to assist state election boards. However, we found that ballots are not always being postmarked as required and it is a challenge for the Postal Service to ensure full compliance. Some ballots did not receive a postmark due to: (1) envelopes sticking together when processed on a machine; (2) manual mail processing; or (3) personnel unaware that all return ballots, even those in prepaid reply envelopes, need to receive a postmark. Without a postmark on return ballots mailed by voters, a ballot could be rejected and a vote not counted. The Postal Service reissued guidance on July 29, 2020 and held a webinar reiterating to employees that all ballots sent by voters must have a postmark. The Postal Service is also currently evaluating the proper postmarking procedures for situations where a ballot is received at a delivery unit with no postmark, but there is evidence that it was processed by the Postal Service on or before election day. Therefore, we are not making a recommendation regarding this issue.
We identified several best practices employed at various locations to improve readiness for processing Election and Political Mail. These practices include:
- Political and Election Mail coordinators obtaining an estimate of Election and Political Mail volume and drop off dates in advance from mailers which helped inform facilities of potential staffing requirements.
- Facilities obtaining sample ballot envelopes to test in mail processing machines.
- Facilities using work floor monitors to display important Election and Political Mail information, such as upcoming election dates and deadlines.
- States, such as Colorado, paying independent contractors to track ballots and provide alerts during each step of the voting process – from ballot printing to acceptance by election officials.
- Election officials creating colored absentee ballot return envelopes to make identifying return ballots easier for the Postal Service, election offices, and voters.
We recommended management:
- Leverage established partnerships with state and local election officials to work toward creating a separate, simplified mail product exclusively for Election Mail that would support uniform mail processing, including mandatory mailpiece tracking and proper mailpiece design. Until this new product is developed, continue to prioritize the processing of Election Mail consistent with past practices.
- Ensure mail processing facilities perform an accurate daily certification that they are clear of Election and Political Mail using the Operational Clean Sweep Search Checklist.
- Clearly define roles, responsibilities, and oversight to ensure that the Political and Election Mail Audit Checklist is completed; and define timeframes for completion during election season.
- Ensure mail processing facilities use and maintain the standardized Election and Political Mail log for each operation.
- Implement best practices identified during our audit and continue educating election officials on identified best practices to increase nationwide Election and Political Mail readiness.