480.1 Policy 480 Voter Registration – Nat’l Voter Registration Act April 2, 2021 POLICY Local WIC programs will provide potential voters with the opportunity to register to vote, will assist those who request help in completing the form, will send completed registration forms to local election offices, and will report registration to the Secretary of State’s office. PURPOSE To comply with the National Voter Registration Act (NVRA) and increase the number of Americans registered to vote. RELEVANT REGULATIONS PL 103-31—National Voter Registration Act of 1993 7 CFR §246.8 ¶(c)—Non-English materials OAR 165-005-0055 Designating NVRA Voter Registration Agencies OAR 165-005-0060 Collection of Registration Cards OAR 165-005-0065 Compiling and Reporting Registrations OAR 165-005-0070 Agency Registration Procedures OAR 165-005-0130—Residence address disclosure exemption ORS 247.208—Voter registration agencies; designation; prohibited activities; required services ORS 247.965—Disclosure of residence address or signature of electors ORS 247.967—Conditions where disclosure of elector’s residence address required, procedure OREGON WIC PPM REFERENCES  426—Record Retention Period  452—Civil Rights DEFINITIONS NVRA: National Voter Registration Act SED: State Elections Division Agency Voter Registration form: The special voter registration form (form SEL-503) produced by the State Elections Division (SED) for use by public assistance and other agencies when implementing NVRA. Voter or potential voter: Program applicants, participants, parents or caregivers who are offered the opportunity to register to vote or update their voter registration address.

Voter Registration – Nat’l Voter Registration Act, Continued 480.2 Voter registration: The part of the Agency Voter Registration form which is sent to local elections offices. Declination: The document signed by the applicant that indicates the desire to register or declines the invitation to register. WIC uses the special declination that is included on the Participant Signature form. The declination is retained for two years by local programs Reporting form: Form SEL-504—The electronic form used by local programs to report the number of voter registrations collected to the Elections Division. See ¶10.0 of this policy. BACKGROUND NVRA requires all agencies that provide public assistance to give potential voters the opportunity to register to vote. WIC is designated as one of these agencies. The WIC program has worked closely with the SED to make this process as simple as possible. To assist local efforts, the elections division has provided the “National Voter Registration Act Manual for Covered Agencies.” The guide is available at http://sos.oregon.gov/elections/Documents/nvra-manual.pdf Since multiple agencies are required to offer voter registration, certain people may have been offered voter registration on multiple occasions. This does not change WIC’s requirement to offer registration. Other agencies designated by NVRA as voter registration sites include: • Addictions and Mental Health Division (AMH) • Children, Adults and Families (CAF) • Senior and People with Disabilities (SPD) • Oregon Department of Transportation (ODOT-DMV) • Oregon Commission for the Blind (OCB) • Oregon Disabilities Commission (ODC)

• Division of Medical Assistance Programs (DMAP) • Office of Vocational Rehabilitation Services (OVRS) PROCEDURE Core NVRA requirements 1.0 Compliance with the NVRA entails local agencies performing six core requirements: • Offering voter registration and providing assistance with registration to all potential voters coming to WIC for certification, recertification, or address changes • Reviewing submitted registration forms for completeness • Dating voter registration forms with the date received • Retaining declinations for 24 months • Submitting registration forms to local elections officials within 5 days of receipt When and how to offer registration 2.0 Offer voter registration to applicants, participants, guardians, or caretakers at certification, each re-certification, and when an address change occurs.

Offer voter registration whenever a potential voter changes their address in person or by phone.

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Offer voter registration by asking, “If you are not registered to vote where you live now, would you like to register here today?” Use form SEL-503

If the participant chooses to register when physically in the WIC office, WIC programs must use English form SEL-503 or Spanish form SEL-503(a), “Agency Voter Registration Form” from SED. This voter registration form is slightly different than the standard registration form seen in post offices and banks. 2.3.1. The voter registration form is available online in English and Spanish at: http://sos.oregon.gov/elections/Pages/electionforms.aspx 2.3.2. The voter registration form in English or Spanish is the only form accepted by elections officials. Local programs shall not adapt or alter the form. Photocopies of the registration form are not allowed. Who can register? 3.0 Local WIC programs shall offer potential voters who meet the requirements to vote in Oregon the opportunity to complete a voter registration form or update their registration address.

A person may register to vote if they are at least 16 years of age, even though they will not receive a ballot until an election occurs on or after their 18th birthday.

A person who is known not to be a U.S. citizen does not need to be offered the opportunity to register. Do not assume a person is not a citizen because they cannot speak English. See ¶16.4 for more information

A person must be an Oregon resident to register to vote. A person visiting Oregon or in Oregon temporarily is not considered a resident. Refer the potential voter to local elections offices if clarification is necessary.

Local programs shall not require proof of identity, proof of date of birth or proof of citizenship to offer voter registration.

It is not the responsibility of the WIC staff to ensure that all adults accompanying the applicant to the WIC office are offered registration.

Potential voters can also register online or download registration forms at http://www.oregonvotes.gov/ Documenting the offer 4.0 At certification and recertification, the potential voter’s response to the offer of voter registration must be documented on the declination portion of either the “Participant Signature Form” (form 57-629), form SEL-503, or SEL-503d.

Local programs may not develop their own declination form and may not copy the state provided declination onto their own forms.

Photocopies of approved declinations may be used if necessary.

Use the translated “Participant Signature Form” for potential voters who read Spanish, Russian, Vietnamese, Chinese, Somali, Arabic, Burmese, Karen, Nepali, Chuukese and Ukrainian. These forms are available on the WIC website.

Voter Registration – Nat’l Voter Registration Act, Continued 480.4 Completing the registration form 5.0 After the staff person offers voter registration, they must ask the potential voter to complete the declination portion of the form. They will document their answer to the question on the declination, “If you are not registered to vote where you live now, would you like to register here today?” If “Yes”

If the answer is “Yes,” have the voter sign and date the declination form, and then the voter may: 5.1.1. Complete the voter registration form (in private) and give it to the local WIC staff person; or request help in completing the form from the local WIC staff; or 5.1.2. Take the form home to complete and mail to the elections’ office themselves. If they choose this option, retain the declination and make sure they know the address of the local elections office. These are located on the back of the registration card. If “No”

If the answer is “No,” have them sign and date the declination form. 5.2.1. If they do not complete the declination, offer the voter registration form. 5.2.2. If the potential voter refuses to sign or complete the declination, the staff person should offer the voter registration form,” indicate the refusal on the declination and initial the form. 5.2.3. If the potential voter informs you they are already registered to vote where they live, consider that a “No” response since they don’t need to register at this time.

If the potential voter is not sure what registering to vote means, staff may explain that “Registering to vote allows US citizens over the age of 18 to vote in government elections.” Providing assistance

WIC staff must provide the same amount of assistance to a potential voter completing the voter registration form as they would to someone completing the WIC forms. See ⧫452-Civil Rights 5.4.1. If a potential voter is unable to read, a staff person must read the form to them. 5.4.2. If a potential voter is sight impaired, a staff person must read the form to them and assist them in completing the form. 5.4.3. If a potential voter reads a language other than English, provide an interpreter or translated instructions to assist the voter in completing the form. 5.4.4. If a potential voter is disabled and unable to sign the form, have them use their signature stamps or make their mark, write “their mark” and initial the notation.

Voter Registration – Nat’l Voter Registration Act, Continued 480.5 SEL-540: Signature Stamp Attestation 5.4.4.1. Local agency staff must then complete form SEL-540, “Signature Stamp Attestation” and submit it along with the voter registration form. These forms are available to download at http://sos.oregon.gov/elections/Pages/electionforms.aspx SEL-550: Public record exemption form

If a potential voter feels uncomfortable registering to vote because it makes their address a public record, they may complete form SEL-550, “Application to Exempt Residence Address from Disclosure as a Public Record.” Completing this form and submitting it with the registration form allows an individual to apply to have their residence address exempted from disclosure as a public record. This may be of interest to potential voters with concerns related to domestic violence. The potential voter must attach some evidence, such as a police report, court order, affidavit or medical record, in order to justify the request to have their residence and/or telephone number kept confidential. The County Clerk may contact the potential voter and request additional documentation. The individual must reapply for this exemption each time they update their voter registration. These forms are available to download at http://sos.oregon.gov/elections/Pages/electionforms.aspx

After providing any necessary assistance, if the potential voter does not complete the declination form, assume the potential voter chooses not to register at that time. No further request to complete the declination is required. 5.6.1. Staff should indicate refusal and initial the form.

Offering registration must be documented in the WIC data system..

Regardless of the potential voter’s response, when the declination is completed, follow the procedure in ¶8.0. Change of address 6.0 When changing addresses in the WIC office, offer voter registration to the potential voter and document their response on either form SEL-503 or form SEL-503d.

If the potential voter’s response is “yes”, have them complete the declination on form SEL-503. Retain the completed declination portion and give the registration portion to the voter to complete.

If the potential voter’s response to the offer of voter registration is “no”, have them complete the declination only form SEL-503d. 7.0 Offer voter registration to potential voters who call the WIC office to change their address by asking “If you are not registered to vote where you live now, would you like to register? If they say yes, offer to either mail the voter registration form or email them the Voter registration website link.

If the voter requests a form to be mailed, complete the declination on form SEL-503. 7.1.1. Check yes, fill in the voter’s name in the signature space, and date.

Voter Registration – Nat’l Voter Registration Act, Continued 480.6 7.1.2. Note the voter registration form is being mailed and initial the declination. 7.1.3. Mail the registration portion of the form to the voter.

If the voter requests information to be emailed, complete the declination on form SEL-503d. 7.2.1. Check yes, fill in the voter’s name in the signature space, and date. 7.2.2. Note the voter registration website is being emailed and initial the declination. 7.2.3. Email the voter registration website to the voter. 7.2.4. Participants who were registered to vote at their previous address or have an Oregon Driver’s License or ID may be directed to the online registration site http://oregonvotes.gov/. They can select the My Vote link to update their address or select the Register link to register if they have an Oregon Drivers’ License or DMV issued ID.

Documentation of refusal of the offer for voter registration over the phone is not required. Processing completed registrations 8.0 If the potential voter chooses to complete the voter registration at the program site, the local WIC staff will:

Review the registration form to make sure it is complete and legible. 8.1.1. Check that the required sections are complete. Required sections include eligibility questions, name, address, date of birth, proof of identity, party affiliation, signature and date. 8.1.2. Staff do not need to check for accuracy, correctness, or view the proof of identity provided. 8.1.3. If the form is not complete, inform the voter and let them decide if they want to make any changes.

Tear the declination from the registration form.

Date stamp the registration form with the current date. If a stamp is unavailable, hand write the date. The date goes to the right of the bar code.

Retain the declination according to ¶11.0.

Follow the procedure for reporting and mailing the registration forms to the correct agency. Follow the guidelines in ¶9.0. Submitting completed forms 9.0 Mail completed registration cards to local county elections offices within five calendar days of receiving the completed forms.

Assign a staff person to process the forms weekly. Mailing forms every Friday will ensure that the five-day requirement is met.

Count the registration forms before mailing them out.

Mail the registration cards to the local elections office. You are encouraged to use special envelopes (SEL-505). If these are not available, you must use

Voter Registration – Nat’l Voter Registration Act, Continued 480.7 blank envelopes for mailing the registrations. This ensures the anonymity of the potential voter by removing the agency information from the registration process. 9.3.1 If using blank envelopes, print #3 on the flap of the envelope to indicate agency type. 9.3.2 SEL-505 envelopes are for agency use only and should not be given to potential voters.

Local elections office addresses are printed on the back of the registration forms.

All registration forms may be sent to one local elections office. They will sort and forward registration forms from other counties.

Use the U.S. Postal Service unless you have made arrangements with the local elections office to do differently. Local elections officials are to treat all agency registrations the same as other voter registrations. Reporting form instructions 10.0 Local programs must report the number of registrations submitted to the Secretary of State Elections Division at least monthly. Agencies must submit a monthly report no later than the 15th of the following month. Reports must be submitted via the online form at http://sos.oregon.gov/elections/Pages/voter-registration-reporting.aspx. In addition to the number of registration forms submitted that month, you will need to provide your local program name, agency ID from SED, clinic address and main telephone number for identification. 10.1.1 Agency ID numbers from SED are not related to your WIC agency numbers. Contact the SED at 503-986-1518 for your agency ID number. Consider submitting the report at the same time as the registration forms are sent to the local elections office. Local program staff must submit a report to the Secretary of State’s office monthly to report “0” registrations if no registrations have been collected during a calendar month. Retention of declinations 11.0 The local WIC Program is responsible for retaining declinations forms SEL-503, or SEL-503d for 2 years. If the declination is on the “Participant Signature Form” (form 57-629), retention rules for that form apply. When using form SEL-503, separate the declination from the registration form. When using the “Participant Signature Form” (form 57-629), refer to ⧫426— Record Retention for instructions on retention. Declinations may be kept in an aggregate file. The declinations on file may be audited by federal or state elections staff or program monitoring personnel to determine whether programs are complying with NVRA. Local programs are not required to track of the number of declinations on file.

Voter Registration – Nat’l Voter Registration Act, Continued 480.8 Declinations on forms SEL-503 or SEL-503d may be aggregated and stored separately since they have a shorter retention period than the “Participant Signature Form”. Required notification of address change 12.0 Local WIC programs are required to notify SED officials and the state WIC office of change of address or telephone number of the main WIC clinic, or change of coordinator within 10 days. Questions about registration forms 13.0 If you are unsure about the validity or accurateness of the information on a particular completed registration form, send it to the local elections office and let them make the decision about the validity of the registration. Notice of registration will go directly from the election’s office to the voter. Refer questions about registration and the voting process to the local election’s office. Ordering supplies 14.0 Order registration form SEL-503 Agency Voter Registration Forms and SEL-505 Voter Registration Envelopes through Shopify https://oregon-wic.myshopify.com/. All NVRA forms except for the SEL-505 Voter Registration Envelopes can also be downloaded electronically from http://sos.oregon.gov/elections/Pages/electionforms.aspx • SEL-504 Reporting Forms (postcard) • SEL-540 Signature Stamp Attestation • SEL-550 Application to Exempt Residence Address from Disclosure as a Public Record Local WIC program responsibilities 15.0 Local WIC programs are responsible for developing a procedure outlining clinic- specific methods of implementing NVRA. This procedure will include at a minimum: • How staff will be trained to offer voter registration; • the filing method for declinations; • how registrations will be distributed; and • who is responsible for reporting information to elections officials. Staff guidelines 16.0 Every effort should be made by local WIC staff to make sure potential voters are comfortable with the registration process. Listed below are some ideas and information that may help. The declination states that the amount of assistance (or WIC eligibility) will not be affected by answering “No” on the declination form. The information on the declination is confidential, as is the site of registration. 16.2.1. Voter registration information can be used to identify potential jurors for jury duty, but jury duty is also drawn from driver’s license data.

Voter Registration – Nat’l Voter Registration Act, Continued 480.9 Never assume that a potential voter is not eligible to vote. If you are unsure, offer the registration form. Civil rights There is a concern about civil rights violations when the issue of citizenship arises. Once again, do not assume a person is or is not a citizen. Do not ask them if they are a citizen. When in doubt, offer the registration form, even if the person does not speak English. If the potential voter requires clarification of the form, simply read the declination or provide a translation of the form. The registration form includes the information on the requirements to register to vote (Oregon residency, age 16 or older, and U.S. citizenship). Notify local community groups that serve undocumented immigrants about the requirements to offer voter registration. Explain that WIC does not have a citizenship requirement and that eligibility for WIC is not connected to eligibility to vote. Encourage these groups to refer women and children who meet WIC eligibility requirements. WIC staff shall not influence a potential voter’s decision to register or choice of political preference. Refer to the Implementation Guide online for more information 16.6.1. WIC staff shall not display or wear anything which could be construed as having political connotations, such as political preference or party allegiance. 16.6.2. WIC staff should be aware of non-verbal cues, such as body language and attitude, when offering registration forms. Staff concern over the extra time it takes to process the registration forms should not be communicated in any way to potential voters. 16.6.3. WIC staff should be mindful of verbal cues, such as tone of voice and wording choices, when offering registration forms. Refer all complaints or inquiries not answered in this policy to local elections officials or the SED at: Secretary of State Elections Division 255 Capitol St. NE Suite 501 Salem, Oregon 97310-0722 Phone: 503-986-1518

If you need this in large print or an alternate format, please call 971-673-0040. This institution is an equal opportunity provider.

Voter Registration – Nat’l Voter Registration Act, Continued 480.10

POLICY HISTORY Date * Major Revision, Minor revision 4/2/2021 Minor revision

The date located at the top of the policy is the implementation date unless an “effective date” is noted on the policy. Policies will become compliance findings 6 months from the implementation date.