Letter Regarding Voter Registration

AACRAO letter to The Honorable George Miller Regarding Voter Registration

The Honorable George Miller
United States House of Representatives
2205 Rayburn House Office Building
Washington, D.C. 20515

Dear Representative Miller,

I write on behalf of the American Association of Collegiate Registrars and Admissions Officers to provide you with our membership’s views on the important topic of voter registration on college campuses. I would also like to take this opportunity to respectfully propose changes to the Higher Education Act that would, in our opinion, improve collegiate voter registration efforts.

AACRAO is a nonprofit professional association of more than 2,300 institutions of higher education and more that 9,000 campus enrollment services officials including those responsible for registration, records keeping and admissions. Nearly half of our members are campus registration and academic records professionals with frontline responsibility for compliance with the HEA’s voter registration mandate.

You already are aware of the survey conducted by Harvard University’s Institute of Politics and The Chronicle of Higher Education on political engagement and voter registration on college campuses. The survey, whose voter registration questions were significantly based on a March 2004 survey conducted by AACRAO in cooperation with the New Voters Project, has made headlines with its finding that some 33 percent of its respondents were not in compliance with the HEA’s voter registration requirement. While any finding of failure to comply is—and should be—grounds for concern, we believe that the IOP/Chronicle survey paints an inaccurate and misleading picture of what is actually being done on college campuses and that its sensational findings of non-compliance are suspect:

The study is statistically invalid because of basic methodological flaws. First, by its own description, the study relies on a sample of 249 self-selected respondents to a questionnaire sent to an original list of 815 target institutions. The fundamental error of relying on a “sample of a sample” invalidates any inferences to be drawn on the basis of this study about the more than 6,400 institutions that are subject to the HEA’s voter registration mandate. Second, even with regard to the target universe of 815 institutions, 249 respondents do not constitute a large enough sample so as to be statistically reliable. The findings become all the more suspect as the study provides finding by type and control.

The Executive Summary makes the allegation that 33 percent of institutions are out of compliance with federal law, but we cannot identify the data elements on the survey instrument on the basis of which this claim could be made.

If anything, the data made available on the IOP Web site indicate overwhelming instances of positive efforts on college campuses, including an 86 percent affirmative response rate to whether colleges surveyed provide students with opportunities to register to vote. Our survey, based on a sample size more than twice the size of the IOP/Chronicle survey, finds that better than 99 percent of institutions are making various efforts to promote voter registration.

In addition, we believe that the IOP/Chronicle study fails to make a distinction between non-compliance with the HEA’s bureaucratic mandate and actual voter registration drives that virtually all institutions actively promote. That such a distinction exists is unfortunate, particularly because, too often, compliance with the HEA’s mandate consists of a meaningless exchange of letters within certain statutorily prescribed timelines between campus administrators and state election officials. These statutorily-mandated communications require campuses to request adequate numbers of forms for distribution to students. But, because no corresponding federal mandate is imposed on the states to actually provide the forms to institutions, the federal requirement is often met by a fruitless exchange of letters. The AACRAO survey found that at least 18 percent of institutions have been unable to obtain a sufficient number of forms to comply with the federal mandate beyond making the forms available because their state’s election body has never provided them.

Our membership shares the high-minded goal of enabling eligible students to exercise their right to vote, and stands ready to help in any way that it can. Specifically, we believe the HEA’s language can be significantly improved by enabling institutions to actively distribute Internet links to printable voter registration forms for the campus community. This approach, which enjoys the support of student groups as well as institutions, is the most likely method to accomplish our common goal of promoting access to the ballot box.

We sincerely appreciate your leadership and thank you for your unwavering support of equal opportunity and access to higher education. If you would like further information regarding campus compliance with the federal voter registration mandate, please feel free to contact me.

Kind regards,

Jerome H. Sullivan
Executive Director