0105.026.00 VOTER REGISTRATION REQUIREMENTS

The National Voter Registration Act of 1993 (NVRA) requires that individuals be given the opportunity to register to vote (or change their voter registration) in elections for federal office when applying for or receiving public assistance or services. This opportunity must also be extended to those individuals coming to Family Support Division offices not seeking public assistance but requesting voter registration services only.

House Bill 1411, passed in 1994, placed into Section 115.162 of the Revised Statutes of Missouri the public assistance voter registration provisions in Section 7 of the National Voter Registration Act of 1993 (Public Law 103-31, 103d Congress).

As a result of the Act, each public assistance office is required to:

• distribute voter registration forms;
• provide assistance completing the voter registration forms; and
• accept completed voter registration forms and forward completed voter registration forms within 5 business days to the appropriate election authority.

0105.026.02 NVRA Coordinators

The Family Support Division is required to identify an individual as the statewide NVRA Coordinator.  This individual is responsible for:

• coordinating and overseeing FSD Income Maintenance and local office compliance with the requirements of Section 7 of the NVRA procedures,
• maintaining a list of local FSD Income Maintenance NVRA Coordinators,
• answering agency questions on NVRA procedures,
• tracking compliance data and corrective action plans as needed,
• monitoring that FSD Income Maintenance as a whole has at least 200,000 of the combined Missouri Voter Registration Application/declination forms at all times and each FSD Income Maintenance office has an adequate supply of the Missouri Voter Registration Application/declination forms at all times, and
• serving as a liaison with the Secretary of State and local election authorities regarding FSD Income Maintenance NVRA compliance.

Each local office must identify an individual who is at the level of a Family Support Eligibility Supervisor or above to be the local NVRA Coordinator.  The local NVRA Coordinator is responsible for:

• administering the voter registration procedures for the office,
• ensuring the completion of any required recordkeeping and reporting,
• acting as that local office’s liaison with the statewide NVRA Coordinator regarding NVRA issues, and with the appropriate local election authority,
• ensuring all staff receive training on NVRA procedures,
• monitoring the office's supply of combined Missouri Voter Registration Application/declination forms and ordering forms as needed to maintain a two month supply. If an immediate need for additional forms is identified, order by e-mailing the FSD NVRA Coordinator,
• monitoring compliance with the policy on retention of completed declination forms (Missouri Voter Registration Application forms marked No, No already registered, or declined to declare),
• monitoring compliance with the policy on copying and retention of copies of completed voter registration applications,
• monitoring the timely submission of completed voter registration applications to election officials,
• ensuring that signs advising individuals of their right to register to vote at that site are displayed in prominent locations in the office
• gathering data and conducting analysis on NVRA compliance and enforcement of NVRA policy in the local office, and
• reporting any discrepancies in compliance to the statewide NVRA Coordinator.

If discrepancies are identified the local NVRA Coordinator will work with management staff to determine the source of the deficiency and develop an appropriate corrective action plan.  The local NVRA Coordinator and the statewide NVRA Coordinator will monitor the implementation of the corrective action plan.

0105.026.05 Distribution Of Voter Registration Forms

The Family Support Division is required by law to offer the opportunity to register to vote.  FSD staff members are required to offer the same degree of assistance to individuals in completing the voter registration application forms as offered to individuals in completing other agency forms, unless the individual refuses such assistance (refer to 0105.026.10 FORM COMPLETION ASSISTANCE).

• application for any IM program, including Child Care and Food Stamp recertifications;
• Food Stamp mid-certification reviews, Temporary Assistance reviews, MO HealthNet reviews; and
• a change of address report.

NOTE: Offer to send voter registration forms with the applicant or recipient for other individuals listed in the household who may want to register to vote but are not physically present in the office.

Voter registration services must also be made available for non-applicants who come into the office and request voter registration services.

Refer to Section 0105.026.05.15 for special procedures for out-of-state residents.

Do not deny anyone the right to complete and submit a voter registration application form. Election officials will determine if eligibility requirements are met.

Homeless individuals who come into the office are to be given the same opportunity to register to vote as those who have a permanent residential address.  Not having a fixed, permanent residence does not disqualify an individual from the voting process.  The individual can list the general area in which s/he stays, the address for a shelter at which s/he stays, a relative’s address where s/he stays, etc. as their address on the form. The individual should not list the FSD office address for the “address where you live” on this form. Send the voter registration application forms for homeless individuals to the local election authority following normal processes for the FSD office.

When an authorized representative makes an application for benefits, offer voter registration services to the authorized representative.  Do not ask the authorized representative to complete and sign the Missouri Voter Registration Application for the applicant.  If the authorized representative chooses, s/he may take a Missouri Voter Registration Application to the applicant/household.

FAMIS sends the Missouri Voter Registration Application (VR-100) when any of the following forms is sent:

• Temporary Assistance Eligibility Review Form (FA-202),
• MO HealthNet Eligibility Review Information Form (FA-402),
• Child Care Reapplication/Review Form (FA-502),
• Notice of Expiration of Food Stamp Benefits (FA-520), and
• Food Stamp Mid-Certification Review Report Form (FA-545).

Only one VR-100 generates to an Eligibility Unit (EU) on a specific day. If multiple notices are generated on the same day, and one of those notices is an FA-520, the VR-100 will be mailed with the FA-520. If no FA-520 is produced for a particular date and any or all of the other forms are produced (FA-202, FA-402, FA-502, or FA-545), the VR-100 is mailed with only one of these forms.

If a participant or applicant brings the VR-100 with them to the office accept and process the form. Do not offer the individual another Missouri Voter Registration Application on that visit.  If a participant mails in the VR-100 along with his or her application for benefits or review form and then later comes into the office to complete an in-person interview, make another application for benefits, report a change of address, or request voter registration services only, he or she must be presented with another Missouri Voter Registration Application at the time of the office visit.

0105.026.05.02 Reception Log

The receptionist/s in each local office must keep a log of all persons who come into the office for one of the following reasons:

• apply for benefits;
• complete reviews;
• report changes of address; and
• register to vote only.

  NOTE: If the individual is in the office to register to vote only, the receptionist will give the individual a Missouri Voter Registration Application form and offer to assist him/her with completing the form.  Refer to Section 0105.026.05.15 for special procedures for out-of-state residents.

  If an individual is in the office to drop off information regarding an address change or pick up an application for benefits, review form, or address change form the receptionist will provide a Missouri Voter Registration Application form with the appropriate FSD forms.

Do not enter on the Reception Log the names of individuals:

• who are not present in the office and request application for benefits forms or review forms be sent to them by mail.
• who are not present in the office and whose applications for benefits and reviews are received in the mail, even if the Missouri Voter Registration Application or VR-100 is returned with the application or review.  (The individuals’ names from mailed voter registration applications are not included on the Reception Log; however the names of individuals returning a completed voter registration or declination form are listed on the Voter Registration Log.)

Reception Logs currently in the office files and all Reception Logs that will be received or created prior to June 25, 2013 must be retained until June 26, 2015. Reception Logs received or created on or after June 26, 2013, shall be retained for 24 months after they were received or created. Reception logs may be destroyed thereafter following departmental policy for destruction of records containing sensitive or confidential information.

0105.026.05.03 Voter Registration Log

FSD offices are required to keep a log of all voter registration application forms and declination forms that are received. A declination is when the individual marks “No” and signs or does not sign the back of the Missouri Voter Registration Application, or declines to declare.

The log must include columns to record the date, the individual’s name, the individual’s date of birth, and to indicate the individual’s response of Yes; No; No, Already Registered; or Declined to Declare to the question from the form “If you are not registered to vote where you live now, would you like to apply to register to vote here today?”.

Log as Yes:

• If the individual marks the box “yes”, completes the form, and signs the form or does not sign the form.
• If the individual does not mark the “yes” box but completes the application portion of the form, and signs the form or does not sign the form.

Log as No:

• If the individual marks the box “no”, and signs the form or does not sign the form.
• If the individual marks the box “yes” but then takes the form with her/him to complete later ( the ES will complete a separate form checking “no” in these instances)
• If the individual marks the box “yes”, does not complete the form, and indicates that s/he is ineligible to register to vote.

Log as No already Registered:

• If the individual marks the box No, already registered at current address and signs the form or does not sign the form.

Log as Declined to Declare:

• If the individual declines to mark any box on the Missouri Voter Registration Application form.

Do not log No or Declined to Declare on the Voter Registration Log if the VR-100 is not returned with an application for benefits or review form that the individual submitted by mail or fax.

Do not log No or Declined to Declare on the Voter Registration Log if an individual is in the office to see another agency and declines to complete a voter registration application.

Do not make an entry on the Voter Registration Log when the FSD is not required to provide voter registration services--the individual is not applying for assistance, is not completing a review or recertification for assistance, is not reporting a change of address, or requesting voter registration services.

Do not make an entry on the Voter Registration Log if a blank Missouri Voter Registration Application or VR-100 is received in the mail.

Include on the Voter Registration log the name of the individual returning a Missouri Voter Registration Application or VR-100 in the appropriate Yes or No column if there is a box checked on the form.

Voter Registration Logs currently in the office files and all Voter Registration Logs that will be received or created prior to June 25, 2013 must be retained until June 26, 2015. Voter Registration Logs received or created on or after June 26, 2013, shall be retained for 24 months after they were received or created. Voter Registration Logs may be destroyed thereafter following departmental policy for destruction of records containing sensitive or confidential information.

0105.026.05.05 Interview Procedure

An eligibility specialist (ES) must present an applicant or participant with an original Missouri Voter Registration Application form at the time of the in-person interview. Blue or black ink must be used to fill out the form.

NOTE: FSD offices can print voter registration forms on paper at the county office, and may use these forms to offer voter registration service to individuals at the county office, rather than using the cardstock forms from the Secretary of State provided that these forms are printed on one sheet of paper with the registration application on one side and the declination on the other.

Have the individual mark a response to the question on the form that asks: “If you are not registered to vote where you live now, would you like to apply to register to vote here today?”

The eligibility specialist will take the following actions before giving the voter registration application to the person designated to log all voter registration applications:

• If the individual declines to mark any box, the ES will record on the declination form the individual's name, date of birth, the fact that s/he declined voter registration services, the date, and the ES will sign the form.  (Log as a Declined to Declare on the Voter Registration Log.)
• If the individual marks the box "no" or "no, already registered" and signs the form, the ES will record the date and the individual's date of birth on the form.  If the signature is not legible, record the individual’s name on the form also. (Log as a No on the Voter Registration Log.) 
• If the individual marks the box "no" or "no, already registered" and does not sign the form, the ES will record the date, the individual's name, and date of birth on the form.  (Log as a No on the Voter Registration Log.)
• If the individual marks "yes" but does not actually complete the voter registration application form in the office because s/he chose to take the voter registration application home to complete, the ES will complete a separate voter registration application checking “no”.  The ES will record on the separate voter registration application the individual's name, date of birth, the fact s/he declined to complete the voter registration application in the office and instead took it home to complete, the date, and the ES's signature. ES's will encourage individuals to fill out the form at the office. (Log as a No on the Voter Registration Log.  When the other voter registration application form is received, log in the appropriate column.)
• If the individual marks "yes" but does not fully complete the voter registration application form in the office either because s/he is under age or is not a United States citizen, the ES will record on the form the individual's name, date of birth, the fact s/he indicated s/he is ineligible to register, the date, and the worker's signature. (These incomplete voter registration applications will be logged on the voter registration log as a No.)
• If the individual marks the box "yes" and completes the form, the ES will follow appropriate local office procedures to submit the voter registration application form to the appropriate election authority.  (Log as a Yes on the Voter Registration Log.)

If the voter registration application has a box checked, but is unsigned, do not log as Declined to Declare.  Log the voter registration application as it normally would be logged if the individual had signed the form.

Voter registration services must be offered even if the individual has previously declined to register to vote or they are already registered to vote.

NOTE: DO NOT detach the top portion of the Missouri Voter Registration Application form. The entire form must be forwarded to the election official upon completion. Refer to Section 0105.026.20 for transmission of completed forms.

Date stamp the completed Missouri Voter Registration Application above the “Code 02” line on the form. The date stamp determines when a person becomes eligible to vote. If a date stamp is unavailable, write the date by hand.

IMPORTANT: There must be nothing on the Missouri Voter Registration Application form to indicate it came from Family Support Division, other than the Code 02

0105.026.05.10 Procedure for Completed Forms

When the ES or receptionist has finished conducting business with the individual, the ES or receptionist will give the voter registration form to the staff in the local county office designated to handle the completed forms.

This staff person will log all voter registration applications/declinations received on the Voter Registration Log by recording the date, individual's name, date of birth, and whether the individual marked yes; no; no, already registered; or declined to declare (Refer to 0105.026.05.03 Voter Registration Log).

If the individual marked "yes" and completed the application for voter registration, the staff person will make a copy of the voter registration application.  Completed voter registration applications returned to the office after the office visit will also be copied and logged prior to submission to the local election authority.

Keep all declination forms and copies of all completed voter registration application forms or VR-100 forms in a central county/office file organized by month received.

NOTE: Do not file the voter registration application or declination form in the applicant or participant's case file.

Create subfolders in the central county/office file for copies of any corrective action letters and copies of the Missouri Voter Registration Application form that are mailed to individuals organized by month sent. See 0105.026.15 Corrective Action Required When There Is No Record That An Applicant/EU Was Offered The Opportunity To Register To Vote.  All declination forms and copies of all completed voter registration application forms or VR-100 forms currently in the office files and all declination forms and copies of all completed voter registration application forms or VR-100 forms that will be received or created prior to June 25, 2013 must be retained until June 26, 2015. Declination forms, voter registration forms or VR-100 forms received or created on or after June 26, 2013, shall be retained for 24 months after they were created or received. Declination forms, voter registration forms or VR-100 forms may be destroyed thereafter following departmental policy for destruction of records containing sensitive or confidential information.

Refer to 0105.026.20 Transmission of Completed Forms for more information.

0105.026.05.11 Reconciliation of the Reception Log and Voter Registration Log

At least weekly, local office staff must reconcile the Reception Log with the Voter Registration Log to ensure that the number of voter registration application/declination forms is equal to (or greater than) the total number of applications for benefits, reviews, changes of address, or individuals who wished only to register to vote.  This information must be reported to the local NVRA Coordinator.

NOTE:  The number of voter registration application/declination forms may be larger than the number of applications if voter registration application forms are received in the mail or if multiple members of a household complete voter registration applications while in the office.

0105.026.05.12 Recording the Data from the Logs Into Survey Monkey

Local office staff, designated by the local NVRA Coordinator, must enter information into the Survey Monkey from the voter registration logs and the data collected on the number of persons in each office:

• to apply for benefits,
• complete a review,
• report a change of address,
• the number of letters sent to take corrective action when it is found an individual was not offered the opportunity to register to vote, and
• those who chose only to register to vote.

The reporting periods are as follows:

• for the 1st – 15th of each month, the data must be entered into Survey Monkey by the 22nd of the month; and
• for the 16th – last day of the month, the data must be entered into Survey Monkey by the 7th of the next month.

Clay County, Jackson County, Jefferson County, St. Louis County, and St. Louis City will report their information by office and not county.

Survey Monkey will compile the information into a statewide report that will be submitted to the statewide NVRA Coordinator for review and monitoring.  The statewide NVRA Coordinator will monitor the compliance of all offices with voter registration policy.  The statewide NVRA Coordinator will contact any local office whose reported numbers indicate there may be a deficiency and will work with the local NVRA Coordinator to develop a corrective action plan, if warranted.

0105.026.05.15 Out of State Residents

Individuals from another state who are planning to return to that state must also be offered voter registration assistance (refer to Section 0105.026.10). National Mail Voter Registration forms are to be downloaded as needed from the United States Election Assistance Commission web site at http://www.eac.gov/voter_resources/register_to_vote.aspx. Mail completed registrations to the mailing address indicated on the form for the individual's state of residence.

0105.026.10 Form Completion Assistance

Offer the same degree of assistance to individuals in completing a voter registration application form as offered to individuals in completing agency forms, unless the individual refuses such assistance.

Eligibility specialists providing assistance in completing Voter Registration application forms are prohibited from:

• seeking to influence an individual's party preference or party registration;
• displaying any political preference or party allegiance;
• making any statement or taking any action whose purpose or effect is to discourage the individual from registering to vote; or
• making any statement or taking any action whose purpose or effect is to lead the individual to believe that a decision whether or not to register has any bearing on the availability of services or benefits.

If an individual believes that someone has interfered with his/her voter registration rights, s/he may file a complaint with the Secretary of State.

NOTE: If staff has reason to believe the individual does not meet eligibility requirements to register to vote, do not deny the right to complete a voter registration application form.  The completed form must be submitted to the appropriate election official. The election official will determine if eligibility requirements are met.

0105.026.15 Corrective Action Required When There Is No Record That An Applicant/EU Was Offered The Opportunity To Register To Vote

If it is found that there is not a record of an individual being given the opportunity to register to vote, county staff, under the direction of the local NVRA Coordinator, must immediately send the Voter Registration Letter and a Voter Registration application to the individual, offering him/her the opportunity to register to vote.  The Voter Registration Letter must be completed in its entirety using local letterhead.

Keep a copy of the letter and form in a subfolder designated for these letters in the central county/office file.

County management and the local NVRA Coordinator must monitor that the corrective action is taken on cases when there is no record of the applicant/EU being given the opportunity to register to vote.

0105.026.20 Transmission Of Completed Forms

Completed Missouri Voter Registration Application forms must be sent to the appropriate County Clerk’s office or election authority within five business days after receipt. DO NOT detach the top portion of the Missouri Voter Registration Application form. The entire form must be forwarded to the election official upon completion.

County Clerk's office information may be accessed through the Secretary of State's web site at http://www.sos.mo.gov/elections/countyclerks.asp.

Completed National Mail Voter Registration forms must be sent, within five business days, to the mailing address indicated on the form for the individual's state of residence (refer to Section 0105.026.05.15).

NOTE: While individuals registering to vote may choose to transmit the forms themselves, it is important to note that Family Support Division is held accountable for effective procedures in conjunction with Voter Registration Services, including timely transmittal.

Copy all voter registration applications prior to submission to the County Clerk's office or nearest election authority within the county. Refer to Section 0105.026.05.10 Procedure for Completed Forms for information on retaining and logging voter registration applications.

0105.026.25 Adequate Supply of Voter Registration Forms

County offices must have Missouri Voter Registration Application/declination forms available at all times. FSD offices must through normal ordering procedures re-order Missouri Voter Registration Application forms as needed to maintain an amount that is projected to be adequate for two months of voter registration services. It is the responsibility of the local NVRA Coordinator to monitor the number of forms the county has in stock.

If for any reason, a county office runs out of Missouri Voter Registration Application forms provided through the Secretary of State's office and the warehouse cannot immediately send of Missouri Voter Registration Application forms, contact the state FSD NVRA coordinator immediately for assistance.

FSD offices can print Missouri Voter Registration Application forms on paper at the county office, and may use these forms to offer voter registration service to individuals, rather than the cardstock forms provided by the Secretary of State if these forms are printed on one sheet of paper with the Missouri Voter Registration Application on one side of the page and the declination on the other.

To access the Missouri Voter Registration Application:

• from the FSD Intranet page, click the pink Voter Registration link in the top right section of the page;
• on the top left section of the Voter Registration (VR) Information page, click the Voter Registration Application link.

The Missouri Voter Registration Application is also available in Volume 2 of the IM Forms Manual on the Intranet.  To access:

• from the FSD Intranet page, click either Food Stamps, MO HealthNet, or Temporary Assistance on the left side of the page;
• click Forms on the left side of the page;
• click Forms Manual;
• click Volume 2; and
• scroll down to the end of the list and click Voter Registration Application pdf.

Follow normal NVRA procedures established in the local offices after the applicant either completes the voter registration application, or declines to register to vote.

0105.026.30 Voter Registration Training Requirement

A mandatory NVRA computer-based training has been developed and is available in the Employee Learning Center (ELC).

New staff, including those newly assigned to work in a position that include NVRA-related responsibilities, must complete NVRA training no later than one month after their start date with that position.

Each FSD Income Maintenance employee shall receive training on NVRA procedures every two years. Current staff who have positions that include NVRA-related responsibilities will receive a biennial email reminder from the ELC that it is time to complete the training again. Managers are responsible for ensuring their staff have taken this training.

If there are staff with both Children's Division and Income Maintenance duties that include NVRA related responsibilities, managers in those offices will need to assign this training to those individuals in the ELC.

All training and other NVRA support information for employee use is available on the FSD intranet site.