SD5 - Statewide Change of Address Portal and Address Database Feasibility Study (Chapter 553, 2017 Acts of Assembly)
Chapter 553 of the 2017 Acts of Assembly required the Secretary of Transportation to “convene a task force to study the feasibility of establishing a statewide one-stop online portal for address changes for the purposes of developing a statewide address database.” The Department of Motor Vehicles (DMV) led the task force on behalf of the Secretary. A full list of task force members is included in Appendix B.
The task force considered a number of different technological solutions to implement a change of address portal and database, including use of the Department of Motor Vehicles’ (DMV) existing change of address process, use of a partial or full master data management model, and use of a dedicated website for submitting address change information. Each approach has both benefits and drawbacks. For each of these approaches, the task force believes that governance of a portal and database would be best approached by designating one or two agencies to have control of the operation instead of by using a governing committee.
The task force also looked at potential costs for implementation of a change of address portal and database. The task force had difficulty determining the costs because of the preliminary nature of the proposals and their inherent uncertainties. While a precise proposal cannot be given at this time, preliminary cost estimates based on the information available to the task force for the six agencies which submitted cost estimates to the task force could be between approximately $1.04 million and $3.8 million, with ongoing annual maintenance costs ranging from approximately $790,000 to $2.47 million, depending on the solution option selected. Costs are likely to be higher once cost estimates for other agencies are included. The task force recommends that, if a portal and database are pursued, the General Assembly should provide funding for its construction and maintenance.
The task force examined the benefits and drawbacks of implementing a change of address portal and database. The benefits to the citizen are the increased efficiency that a change of address portal would provide, potentially allowing the citizen to make one notification to the portal to update several state agencies. State agencies could benefit from potentially having more accurate addresses, as well as the possibility that an address database could diminish fraudulent activity related to addresses.
Nonetheless, there are several drawbacks to the proposal. Data sharing is legally restricted in many instances, and the task force found numerous instances where existing state and federal laws and regulations would require amendment before a change of address portal could be implemented. In fact, because many of the statutes specifically affect only one agency, the task force is unable to provide a comprehensive list of all of the legal requirements that must be satisfied before implementing a statewide portal, as such a list would require a survey of all 112 state agencies. The task force also noted that securing amendment to federal laws and regulations could be difficult. Finally, the task force was concerned that application of the Virginia Freedom of Information Act to the portal could lead to the release of sensitive information which would not normally be released, suggesting that a portal and database would require a blanket exemption from the mandatory disclosure provisions of the Act.
The proposal also suffers from a number of practical problems. As the proposal is to build a database with the addresses of a good proportion of the citizens of the Commonwealth, such a database would be a tempting target for criminals and would require extensive security. Additionally, many agencies have business rules which would severely limit the usefulness of a portal and database to them. For example, many agencies require verification prior to accepting a change of address, while others allow customers to maintain multiple addresses and would need a way to verify the type of address submitted. There is also a question of whether customer consent should be required in order to share addresses with different agencies; while obtaining such consent is more transparent than sharing addresses without consent, and would help to satisfy certain legal requirements, it could prove detrimental to attempts to use the portal for antifraud purposes.
While the creation of a change of address portal and database would have benefits for citizens and state agencies, the benefits it would create do not outweigh the drawbacks if the portal and database are designed as a standalone program. The task force, therefore, cannot recommend that the General Assembly authorize a portal and database as a standalone project. Nonetheless, the task force believes that it may be possible to overcome some of these drawbacks by integrating a change of address portal and database into a project providing additional services beyond just the portal and database. Likewise, it believes that it would be prudent to proceed at first with a pilot of a smaller subset of agencies. The task force is aware that the Health and Human Resources (HHR) secretariat is currently considering an initiative to share medical records among agencies in that secretariat. Integrating a change of address portal and database into that initiative could be one way to move forward with the project if the General Assembly desires to do so.
Findings and Recommendations
1. The General Assembly Should Not Authorize a Statewide, One-Stop Online Change of Address Portal and Statewide Address Database as a Standalone Project at This Time.
The task force recognizes that the creation of a statewide, one-stop online change of address portal and statewide address database is technically feasible and could have benefits for both citizens and agencies. Nonetheless, the task force believes that these benefits are likely to be minimal —many state agencies are transitioning to communicating via e-mail where feasible, and the laws, regulations, and business rules which restrict the ways in which the portal and database can be used will limit its usefulness to agencies and citizens. Ultimately, the task force believes that creation of a standalone change of address portal and statewide address database would require tremendous Commonwealth resources, the expenditure of which cannot currently be justified by the limited benefit that will be returned to agencies and citizens. The task force recommends that the General Assembly should not authorize a statewide, one-stop online change of address portal and statewide address database at this time.
2. If the General Assembly Wishes to Proceed with Studying the Concept, it should do so in a Manner Which Allows it to Consider the Benefits of a Change of Address Portal and Database in the Context of Larger Projects.
Although the benefits of this project do not outweigh its drawbacks, the task force recognizes the benefits that data-sharing could provide in a general sense. State agencies have frequently undertaken such initiatives in the past on a smaller scale. For example, DMV and the Department of Elections (ELECT) have worked together to share change of address data electronically, allowing these agencies to comply with the National Voter Registration Act while reducing the amount of paper printed and mailed and increasing citizen convenience. The Commonwealth has also had some limited experience with multi-agency efforts, such as the Virginia Longitudinal Data Survey, an agreement between eight health, social service, and education agencies to provide data from those agencies to researchers.
Although the benefits of the portal are real, realization of these benefits will likely require that the project be integrated into a project which delivers other services besides the change of address portal and database. One potential solution would be to integrate any further change of address study into the HHR secretariat’s data sharing initiative for medical records, which often include addresses. This would allow the solution to be tested within a larger study while allowing for a pilot of the change of address functionality within a smaller subset of agencies. The task force recommends that, if the General Assembly wishes to proceed with a change of address study, it does so either in the context of the HHR initiative or within the context of another initiative of a similar size and scope as the HHR initiative.