Signature Verification

This page assesses the signature verification process as weak barrier to preventing election fraud.

In our assessment, we believe MC employees are doing what is expected of them to confirm the signatures on an early ballot match the signature on the voter's registration record. The MC employees are not deviating from organizational norms. That said, the governance practices hindering the employees from effectively detecting fraud.

Some background information is necessary to understand why MC employees cannot adequately detect fraud.

Background

Arizona Law for Elections

Title 16 of the Arizona Revised Statutes governs elections, voter qualifications, political parties, campaign finance, and related electoral procedures in Arizona. This statute states what must be done. The statute does not contain enough detail to explain how it is done.

For those that familiar with corporate operations, statutes would be equivalent to policy statements and procedures would explain how policies are fulfilled.

Arizona State Procedures for Elections

Arizona's Secretary of State (SOS) is responsible for ensuring elections are implemented fairly and consistent statewide, which gets complicated because elections are implemented at the county level. Arizona SOS creates the Arizona Election Procedures Manual (EPM) to explain how each county is required to fulfill their duties to implement election services.

Did you Forget Maricopa County Procedures for Elections?

No. The blank space underneath the title was made to emphasis a point. There aren't any Maricopa County Procedures posted on the MC Elections Department website.

The Arizona SOS created and publicly posted the Arizona Elections Manual to explain how Arizona Counties are required to implement election services at the county level. Apparently, MC Elections department does not believe procedures are necessary to implement state procedures at the voting centers OR, even worse, MC Elections department has Election Procedures for the voting centers but does not want to reveal the content of those procedures to the public.

The "OR" statement with regard to the reason for the lack of publicly post MC Election Procedures presents a governance dilemma. The effectiveness of internal controls for election-related activities is compromised if there are no procedures for the voting centers. Conversely, ethical questions arise if the MC Elections Department management does not want the procedures to be shared with its citizens if the Voting Center election procedures actually exist. The AZ SOS is publicly sharing their election procedures. If the County has procedures for their voting centers, why do they believe this information should be treated as confidential?

Nondisclosure of the MC Election procedures inhibit the public's ability to hold the county accountable to their own standards. Citizens can't compare anomalous events observed in the MC Voting Centers to a MC elections procedure if none is available to the public.

Potential Governance Gaps:

• Principle 1 - Demonstrate Commitment to Integrity and Ethical Values
  • Attribute(s): 1.04,
• Principle 2 - Exercise Oversight Responsibility
  • Attribute(s): 2.09
• Principle 3 - Establish Structure, Responsibility, and Authority
  • Attribute(s): 3.09, 3.10, 3.11, 3,12

>>>>>>>FINISH REVIEWING for applicable attributes<<<<<<

Conceptual Importance of Signature Verification

This section will describe how signature verification is used to prevent fraud.

First some clarifying notes are necessary to understand the importance of signature verification.

1. The term "early ballot" used herein and is considered synonymous with the term "mail-in ballot" for the purpose of this assessment. We wanted to be consistent with the AZ EPM use of the term early ballot.
2. Signature verification is only applied to early ballots.
3. Signature verification is performed by a person, not a machine.
4. Signatures on the early ballot envelope are compared to the signature on the voter's registration record as a means of authentication.
5. Voter registration signatures may be collected by ink on paper (wet signature) or digitally with a stylus on a computer screen.
6. There is no traceability from the ballot back to the person once the ballot has been removed from the envelope.
7. The ballot is removed from the envelope after the signature on the envelope has been verified.

Early ballot fraud occurs when an ineligible ballot passes through the signature verification process step without being detected by the signature verifier. Signature verifiers do not induce fraud; they allow fraudulent ballots to be counted. Signature verifiers do not reject early ballots with signature mismatches. Ballots with mismatched signatures are separated and not counted until the signature mismatch is addressed. Some of these separated early ballots may ultimately be counted if their authenticity is subsequently confirmed alternative methods.

The following diagram may help understand how fraud occurs. Some fraudulent early ballots are expected to be mailed in with the intent of being tabulated. In other words, signature verification would not be needed if everyone was honest. Therefore, the signature verification is the only step to detect fraudulent ballots. Interestingly, a valid vote has a second opportunity to be correctly tabulated if it is incorrectly identified as suspect. However, there is no second chance to detect a fraudulent ballot if missed by the Signature Verifier. The fraudulent vote cannot be retrieved by any method once it gets past the Signature Verifier; a fraudulent vote will therefore be counted as a valid vote.

This signature verification process is inherently weak, given that a single person is being relied upon to screen out potentially fraudulent ballots. Consider these factors when judging the robustness this process step.

• Chances of not detecting a fraudulent ballot increase with the number of fraudulent ballots mailed in to be tabulated.
• The competency of person performing the verification.
• Conditions at home or at work that may increase the likelihood of verification errors.

Potential Governance Gaps:

• Principle 5 - Enforce Accountability
  • Attribute(s): 5.01Note: can't assess performance because the of the single-person vulnerability, Never will no if they are doing a good or bad job.
• Principle 6 - Define Objectives and Risk Tolerances
  • Attrubute(s): 6.02 (can't measure SV performance 6.04 6.07 6.08
• Principle 8 - Assess Fraud, Improper Payment, and Information
  • Attribute(s):

Signature Verifier Training Investigation

A criminal investigation was initiated by the Arizona Attorney General (AG) in response to seven issues identified by the Arizona Senate 2020 General Election Forensic Audit for Maricopa County Elections on September 24, 2021. One of the issues to be investigated was titled "Maricopa County Elections Department - Signature Verification Process." The Arizona Attorney General’s (AG) Office issued a report, which is titled 2020 General Election Investigation. The investigation of the Signature Verification Training resulted in the following: Finding - No improper Election Procedures were discovered during the Signature Verification Training.

The investigators used facts to provide proof that training was performed in accordance with Arizona State requirements. However, these facts also suggested poor governance.

Quantity of Training

The Level 1 Signature Verifier is the one person that allows a fraudulent ballot to be counted if they do not detect a mismatched signature; the Level 1 Signature Verifier gets two hours of training.

If flagged by a Level 1 Signature Verifier, the suspect early ballot is then directed to the Level II Signature Verifiers, where alternative methods to authenticate the ballot may be applied. Eight hours of training are provided to Level II Signature Verifies and they are not a "single-person-vulnerability." Level II Signature Verifiers may involve other staff for assistance, but a Level 1 is performing their task independently.

Potential Governance Gaps:

• Principle 4 - Demonstrate Commitment to Competence
  • Attribute(s): 4.02

Pace of Training

The two hours of Level 1 training consisted of 41 slides, which results in a average pace of less than three minutes per slide. Potential Governance Gaps:

• Principle 4 - Demonstrate Commitment to Competence
  • Attribute(s): 4.02

Proficiency Objective

A training model called Blooms Taxonomy is used during the design and development of training so the student can perform the new task to the desired level of proficiency. In this case, the student would need to have become proficient in Signature Verifier knowledge and comprehension before acquiring proficiency with application, which seems to be the appropriate competency level for a Signature Verifier.

Potential Governance Gaps:

• Principle 4 - Demonstrate Commitment to Competence
  • Attribute(s): 4.02

Verifying the Student's Completion of Training

The inspector interviewed an Elections Department to determine if all the Level 1 Signature Verifiers had completed the training. Apparently, there were no training documents created or retained to provide objective evidence of training attendance.

Potential Governance Gaps:

• Principle 3 - Establish Structure, Responsibility, and Authority
  • Attribute(s): 3.09, (no documentation) Principle 4 - Demonstrate Commitment to Competence
  • Attribute(s): 4.02

Verification the Competency of the Student

No evidence was provided in the inspector's report to suggest Signature Verification competency was verified. The were apparently no test scores for each student. Test scores would have been a more objective method of confirming student attendance than an interview with a manager (see above). A final examination is not noted as a training topic the investigator included in the report. Potential Governance Gaps:

• Principle 4 - Demonstrate Commitment to Competence
  • Attribute(s): 4.02

Verification of Student Competency in the Work Setting

The inspector stated the Level 1 Signature Verifiers are expected to complete, on average, one verification every seven seconds. If seven seconds if the average rate, some verifications need to be completed in less than seven seconds. A valid competency training examination would have needed to replicate this astounding pace for an extended period time given that the pace would be expected for an eight-hour shift, maybe longer based on information the inspector included in his report. Potential Governance Gaps:

• Principle 4 - Demonstrate Commitment to Competence
  • Attribute(s): 4.02

Wait! Did I read this wrong or what?

The inspector makes the statement, "This new training was provided in June 2020 prior to the General Election."

Later, the inspector makes the statement, "According to the Maricopa Elections Department, an additional group of 40 temporary employees were hired from October 30th 2020 to November 6th 2020 to assist with Signature Verification and ballot curing.

Apparently, the 40 new hires did not receive any training since they were hired after the training was provided. If true, there were more untrained Level 1 Signature Verifiers than trained Level 1's given that 33 employees completed the training in June.

This assessment is focused on County governance, so the question is why did the County feel that it was acceptable to hire 40 temporary workers and not provide them with training?

Why were more temporary employees used to perform a critical single-person vulnerability task as Level 1 Signature Verifiers? Potential Governance Gaps:

• Principle 4 - Demonstrate Commitment to Competence
  • Attribute(s): 4.02, 4.04, 4.05
• Principle 5 - Enforce Accountability
  • Attribute(s): 5.03 (no oversight)
• Principle 7 - Identify, Analyze, and Respond to Risks
  • Attribute(s): 7.05 (doc no training decision)

Possible Personal Performance Deficiencies Unrelated to Training

Level 1 Signature Verifiers may mis fraudulent signatures for issues unrelated to training, which include the following:

• Quick pace - one signature verification per seven seconds is a quick pace (per investigation)
• Duration of task - Signature Verifiers were expected to work eight-hour shifts sometimes longer
• Fatigue - Doing a repetitive task at a quick pace for an extended duration
• Clarity of the Voter Registration Signature - The signature may be a pen on paper (wet signature) or digital signature acquired from the Arizona Motor Vehicle Department's voter registration process
• High rates of flagging signature mismatches may be culturally discouraged since suborinate Level 1 Signature Verifiers would be making more work for the Level II Signature Verifiers, which appears to be their leadership
• Low rates of flagging signature mismatches may be culturally and personally rewarding since little consetration is needed if the personal standard is low and the Level II Signature Verifiers are unlikely to complain about getting fewer suspect early ballots.
• Workload is increased with emphasis on the convenience of early voting and voter registration errors that generator more ballots than valid voters.

Potential Governance Gaps:

Principle 6 - Define Objectives and Risk Tolerances

• Attrubute: 6.02 (can't measure SV performance 6.04 6.07 6.08