Thank you for the opportunity to provide comments to the United States Postal Service’s (USPS) proposal to amend the Domestic Mail Manual (DMM) regarding the transmission of mail-in and absentee ballots for federal elections.
The American Association of People with Disabilities (AAPD) is a national, disability-led, cross-disability rights organization that advocates for full civil rights for the over 70 million Americans with disabilities. AAPD’s REV UP campaign (“Register, Educate, Vote, Use your Power”) works to increase civic engagement in the disability community and improve election accessibility. The REV UP campaign includes disability vote coalitions across 22 states that advocate for accessible election policies and polling places, train and support state and local election workers, and provide communities with nonpartisan, accessible voter education and support.
AAPD strongly opposes the proposed changes to the processing of mail ballots. If this Rule is implemented, eligible American citizens will be blocked from participating in our elections and disabled voters will be disproportionately harmed.
Voting is foundational to our democracy, and our democracy works best when every eligible voter can participate. There are an estimated 40.2 million eligible voters with disabilities in the U.S., representing nearly one-sixth of the total eligible voting population. Research from the Election Assistance Commission (EAC) has found that disabled voters are three times more likely to face difficulties casting a ballot than nondisabled voters. The ability to choose which method of voting works best for you is a crucial freedom for all voters and especially those with disabilities. In 2020, over half of disabled voters cast their ballots via mail. States that allow for easier access to vote by mail, such as permanent absentee voter lists and universal mail voting, saw substantial increases in voter turnout among disabled voters.
Many of the barriers that disabled voters face are related to voting in-person, and for many voters with disabilities, voting by mail is the only way they can participate in elections. For example, a wheelchair user in a rural area may not be able to secure accessible transportation to the polls. In 2022, 14.3 percent of people with disabilities aged 18-64 lived in a household without a vehicle , compared to 9.4% of people without disabilities. The 2022 National Household Travel Survey found that 18.6 million people with disabilities ages 5 and older report disabilities that limit their travel, including short errands, and nearly one-third of this population report not leaving the house at all. Crowded polling places may be unsafe and inaccessible to voters who are immunocompromised; additionally, local jurisdictions continue to struggle to implement federal accessibility standards. An audit of 447 polling places across 45 jurisdictions in Michigan during May, August, and November 2025 elections revealed that only 10% of sites met accessibility standards. A voter with an intellectual disability may prefer to vote from home in order to spend more time reading and understanding the ballot. People experiencing long-term hospital stays or living in nursing homes may be unable to leave their beds, making in-person voting highly difficult or impossible. These are realities disabled voters face during every election.
As a result of these barriers, people with disabilities vote by mail at higher rates than people without disabilities. In an analysis of the 2024 election, over 60% of people who report that their disability impacts their daily life (i.e. running errands, self-care, etc.) said that their disability contributed to their decision to vote by mail.
Restrictions to vote by mail will also disproportionately harm older adults, especially as the likelihood of disability increases with age; approximately 2 out of 5 adults over the age of 65 have a disability, compared to 1 in 4 adults age 18-64. Barriers that impact disabled voters, such as lack of access to reliable transportation, also impact older adults, both with and without disabilities. Older adults are less likely to drive and more likely to depend on public transportation or caregivers; many report transportation related barriers keeping them from attending crucial healthcare visits, social activities, and religious services., The 2024 Election Administration and Voting Survey (EAVS) Comprehensive Report reveals that around 30%,or one-third, of Americans voted by mail in the 2024 general election. For voters ages 65 and older, mail ballots accounted for 40% of votes cast.
If USPS were to implement this rule, the timeline for being able to request and receive a ballot by mail would be extended and disrupted by the required data sharing and verification. President Trump’s Executive Order 14399 “Ensuring Citizenship Verification and Integrity in Federal Elections,” proposes a deadline of 60 days before an election to share vote by mail eligibility lists. This would disenfranchise newly eligible voters and voters who have recently moved but are still within state deadlines to update their registration. It would also create barriers for voters with disabilities whose access needs may change unexpectedly. For instance, a voter who typically votes in person may experience a flare in their health, a planned or unplanned hospitalization, a change in their direct care staffing, or loss of accessible transportation.
The acute crisis in the direct care workforce and the shortage of home care attendants and personal care attendants illustrates how easy it is for older people and people with disabilities to experience sudden disruptions in the care they rely on for critical daily support with activites–including voting. Low wages, lack of benefits, and burnout leads to high and often abrupt turnover in the direct care workforce. In 2022, there were less than 5 million direct care workers for over 12 million individuals in need of direct care services.
These examples are only a few reasons why a disabled person might decide to vote by mail on shorter notice than 60 days before an election. Current state processes allow for this flexibility, but the President’s EO 14399 would take it away.
With such a rapid implementation of new lists, platforms, and processes, eligible voters will be disenfranchised due to technical and administrative errors that are no fault of their own. Analysis of voter turnout in 2024 revealed a gap of 7 percentage points between disabled and nondisabled voters, a direct result of difficult and inaccessible voting processes. If the USPS implements the policies within EO 14399, this turnout gap will only increase, denying eligible American citizens–particularly Americans with disabilities and older individuals their ability to exercise their right to vote and to participate in our democracy.
Furthermore, implementing this Rule would violate the Constitution and federal law. The Rule seeks to implement EO 14399, a directive that is itself unconstitutional. Under the Constitution, only states and Congress have the power to mandate election rules, and only Congress can regulate the postal service – not the President.
The duty of the Postal Service is to receive, transmit, and deliver the mail to everyone in the United States . This Rule would allow USPS to violate that important duty by deciding not to deliver ballots to certain voters based on an unconstitutional Executive Order.
Finally, this Rule will place an immense burden on state and local election administrators who are already overworked and underresourced. Implementing entirely new, unvetted data-sharing and list-verification processes during a federal election year would require a massive reallocation of limited resources. This could lead local election offices to take staff away from critical duties like processing new voter registrations, ensuring the accessibility of polling places, securing polling places, updating and testing voting machines, and recruiting and training poll workers.
Similarly, this Rule forces USPS to take on the role of election administration, which it is neither authorized by Congress nor equipped to take on. USPS has no funding, expertise, or ability to engage in election administration, and being forced to do so could divert staff and resources from its primary role of guaranteeing safe and secure communication across the country. This unnecessary policy does nothing to protect the vote; instead, it introduces more room for error and stretches limited resources, impacting systems at both the local and national level. The high likelihood of human and technical error means that eligible American voters–particularly those with disabilities and older adults–will be denied access to the ballot through no fault of their own, with no way to address any issues.
In conclusion, we strongly urge the U.S. Postal Service to defend both the independence of our election systems and their own independence, by refraining from implementing any of the President’s unlawful orders. The strength of our nation lies in the ability of every eligible citizen to vote. Rather than adding administrative hurdles and new obstacles to the voting process, our focus should remain on enhancing election accessibility and removing the existing barriers that currently hinder disabled and multiply marginalized voters from reaching the ballot.
Thank you for your consideration and for the opportunity to provide comments.
Respectfully submitted,
Alexia Kemerling
akemerling@aapd.com
Director of Accessible Democracy
The American Association of People with Disabilities