SALEM, OR – DMV has completed its After-Action Report at the Governor’s direction following the voter registration issue it announced two weeks ago. The After-Action Report details new sources for error, identifies additional risks for continued possible errors in the system, and describes adopted and proposed corrective actions.  

An additional 302 records have been sent to Oregon Secretary of State (SoS) for inactivation:  

• 123 records subject to the previously identified clerical error but mistakenly missing from earlier hand review due to a newly identified technical issue.  

• One record caught by DMV’s new quality control issues but after it was sent to SoS.

• 178 records due to the misclassification of citizens of the U.S. territories of American Samoa and Swains Island as citizens of the U.S.  

SoS is reviewing these documents to determine if any of these individuals have a voting history. These records contained evidence of clerical errors regarding citizenship status but that does not necessarily mean they belong to noncitizens. For example, we know that of the 10 individuals identified in an earlier review who had a voting history, at least five were in fact citizens. 

Technical error causes records to go unanalyzed  

DMV committed to an ongoing quality control process after the initial issue was identified, and through that work has identified a technical error that resulted in additional automatic voter registration records that required analysis. DMV staff manually reviewed 3,151 records for any evidence there was an error in the way citizenship was identified; of those, 123 records had evidence of an error. This new technical error was discovered by DMV leadership on Oct. 1 and analysis of the cause and scope of the error began immediately. Upon completion of the analysis, the DMV and the Governor’s Office informed the SoS on Oct. 4. One additional record was found to have the same clerical error unrelated to this technical issue. These records were sent to the SoS to have their voter registration inactivated.  

DMV staff pinpointed evidence of an error in the way citizenship was identified by comparing the digital record with scanned supplemental documents. Whenever the supplemental document denoted a foreign document while the digital record denoted a U.S. document, the record was sent to SoS for inactivation.  

The earlier analysis of DMV records was conducted by DMV staff over two weeks in September. That analysis identified 1,259 records with evidence they were incorrectly classified as providing proof of U.S. citizenship when they did not do so. That made these individuals incorrectly eligible for automatic voter registration.  

These new records do not constitute a new source of error. DMV believes the records in question have errors because of the same clerical issue that affected the 1,259 previous records, but this technological error prevented these records from being included in the earlier analysis. The technical error is an issue found due to rare transactions being written to an alternate file - a "site specific table." 

On Sept. 27, an individual came into a DMV to surrender their out-of-state license and procure a commercial driver's license (CDL). Getting a CDL requires proof of legal presence, so this individual presented immigration documents verified through the SAVE system. This encounter proceeded correctly.  

However, because of the additional manual comparison of records DMV instituted as a corrective action, on August 23, a manager spotted that this individual had presented immigration documents at this DMV interaction, but the individual’s record identified this person as presenting a U.S. passport during a February 2021 interaction. That interaction had marked their account as being that of a U.S. citizen. 

This manager informed DMV leadership on Oct. 1. DMV leadership worked with ODOT, DMV and software vendor FAST Enterprises technical staff to identify the cause and the scope of the error. Their analysis was complete by Oct. 4 at which point the DMV and Governor’s Office informed the SOS.  

An additional 123 errors were found that should have been identified in the earlier manual review. DMV and vendor IT staff determined the failure to identify these records in the earlier data pull was due to a configuration issue, where data entered in a particular order would write those files to a “site specific table.” The query to pull data for manual review did not pull from the “site specific table.” Having validated this technical issue, IT staff then searched the system for other similar records, identifying an additional 6,000 transactions that experienced the same issue, of which 3,151 went in the OMV file and were not subsequently verified by the national systems.  

The review process involved comparing available supplemental documents to identify if there are discrepancies between them and the digital file. This is essentially the same method as the quality control process DMV instituted that caught this record. DMV Administrator Amy Joyce described this process at a legislative hearing on Sept. 25.  

Weakness identified in new quality control measures  

As part of DMV’s new quality control process, a new record with a clerical error, based on a transaction on Sept. 19, was caught. All records are reviewed by a manager for this reason. However, it was caught after the record was sent to the SoS for registration. This voter was not registered to vote before the issue was rectified; however, it showed that the quality control processes put in place need to be enhanced. DMV is adjusting its quality control policies to ensure records are not sent to SoS before the final manual review by a manager takes place.  

Individuals with U.S. passports who are not eligible to vote in all elections  

DMV leadership was made aware through a media inquiry from Willamette Week on Oct. 2 of a potential issue with residents of the U.S. territory of American Samoa and Swains Island. These residents use a U.S. passport but are not eligible to vote in some elections. This is a feature of citizenship law unique to American Samoa and Swains Island, as residents of other U.S. territories are citizens of the U.S. DMV policy has been to identify these individuals as U.S. citizens, making them eligible for automatic voter registration. That policy was incorrect.  

DMV has identified 178 records in which there is evidence a person born in American Samoa presented an identity document that did not prove U.S. citizenship. DMV has no information on whether these individuals are U.S. citizens. The limited information available in the system means this is almost certainly not all of the American Samoans who have received credentials from Oregon DMV.   

DMV has sent these documents to SoS for inactivation. At this time, DMV is working to develop other ways to identify additional possible residents of American Samoa. DMV has updated its policy to ensure these individuals are not identified as U.S. citizens unless they present a document proving U.S. citizenship.  

Existence of new errors requires ongoing analysis  

“Two weeks ago, we believed we had all of the information to project confidence that we understood and had reviewed all records at risk of error,” said DMV Administrator Joyce. “We have since learned this confidence was misplaced based on new information outlined in this announcement and after-action report and for this, we are sorry. DMV will follow the Governor’s directed actions and remains committed to continuous learning, corrective action, transparency and accountability.”  

Some of the corrective actions identified in the After-Action Report are: 

• We’ve made a number of changes to the system user interface to reduce the chance for human error, and more changes are scheduled in the coming weeks. 

• Each day we’re manually checking transactions at each field office for errors and making any needed corrections before sending the records to SoS. 

• We’ve bolstered staff training for new hires and current employees.  

• We’ve implemented a review process change for staff to properly identify source documents from American Samoa and are working toward more sustainable, systemic methods to ensure those records do not go to SoS in the OMV file.  

• We’ll also work with SoS to institute annual reviews of OMV processes to ensure their integrity and will review any changes needed.  

• We’re preparing to hire a Voter Registration Integrity Manager who will be responsible for DMV-wide coordination of efforts to review and improve all aspects of DMV’s role in OMV.  

“Thanks to the swift action of elections officials, I have full confidence that these new errors will not impact the 2024 election,” said Secretary of State LaVonne Griffin-Valade. The SoS produced an FAQ with additional details that can be viewed on the DMV web page. 

The full after-action report identifies in greater detail the process of discovery, the timeline and details on corrective actions.