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Montana pilot and Vote Shield monitoring highlight tradeoffs in list maintenance; NVRA procedures slow removals

U.S. Election Assistance Commission · July 9, 2025
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Summary

At the EAC summit, Montana officials described a pilot using credit‑bureau address data plus targeted outreach that reduced undeliverable absentee rates; Vote Shield and panelists warned about matching limits, legal constraints in the National Voter Registration Act, and the need for multiple 'arrows in the quiver.'

Montana described an EAC‑supported pilot that combined commercial address data, targeted mailings and follow‑up to reduce undeliverable absentee mail and encourage voters to update registrations.

Austin James (Montana election director) described the pilot workflow: the state separated active and inactive lists, iteratively applied change‑of‑address and credit‑bureau matches, tailored outreach (postcards and QR codes) by likely move type, and used a secondary address‑validation vendor to reduce bad‑address mailings before absentee ballot mailings. James said the pilot and subsequent mailing rounds cut undeliverable absentee rates roughly in half from 2022 to 2024 in the jurisdictions described, and emphasized designing outreach to encourage voter‑initiated registration updates rather than unilateral office changes.

Quinn Raymond of Vote Shield described weekly, fielded monitoring of voter files — tracking granular, field‑level changes to flag anomalies to election officials. Vote Shield said its review has commonly identified administrative errors, not successful cyber intrusions. Panelists cautioned about the National Voter Registration Act's procedural framework, which requires confirmation notices and multi‑election timing before some removals, limiting how rapidly offices can act even on seemingly high‑quality matches.

Panelists urged using multiple sources — NCOA, DMVs, commercial data, and voter‑initiated confirmations — because each has limits. They also recommended careful public communication to avoid confusing voters when confirmation mailings reach households with multiple names or long‑dormant registrations.

What this changes: pilots that pair commercial data with targeted voter outreach can reduce wasted mail and surface likely moves, but legal and operational safeguards — and clear communication — are necessary to prevent wrongful removals and public confusion.