Federal lobbying reporting
A page within Research & Sponsored Programs
At UWL, lobbying has the potential to:
- Facilitate positive interactions and communications;
- Build relationships with new lawmakers; and
- Provide a voice of representation for UWL as part of UW System.
While lobbying can have a positive impact, transparency in the process is needed. Failure to comply with federal lobbying reporting requirements has a negative impact on UWL’s government relations program and may result in:
- Increased scrutiny of lobbying activities;
- Suspension of privileges; or
- Serious civil and criminal penalties, including fines and prison time.
In order to comply with federal lobbying reporting regulations, UW campuses are required to provide quarterly reports to the UW System Office of Federal Relations regarding lobbying activities and contributions. In turn, UW System files federal lobbying and federal contributions reports on behalf of the Board of Regents. UW System requires that UW campuses’ Chancellors, Vice Chancellors (including Assistants and Associates), Deans (including Associates), Division Heads, and Legislative Liaisons file lobbying activity reports each quarter. The reporting process is conducted via a Qualtrics survey distributed by the Office of Research & Sponsored Programs. Please direct questions related to lobbying and/or the reporting process to grants@uwlax.edu or 785-8007.
The following questions and answers are intended to assist the UWL campus community in reporting lobbying activities.
What is lobbying?
Lobbying is any “legal” attempt to influence government policy or action; and refers to communications with covered officials regarding formulation, modification, or adoption of legislation, orders, rules and regulations, or other policy positions, or regarding the administration or execution of a program or policy.
Communications include oral, written, or electronic contacts.
Covered officials generally are executive branch, administrative, and legislative officials. At UWL, this includes the Chancellor, Vice Chancellors (including Assistants and Associates), Deans (including Associates), Division Heads, and Legislative Liaisons.
Am I authorized or permitted to lobby on behalf of UWL?
It is important for the campus to have coordinated, transparent lobbying efforts. To that end, prior to engaging in lobbying activities on behalf the university, faculty/staff should coordinate efforts with their respective dean/division director. This will ensure consistency with the university's mission and transparency for federal reporting.
What activities are considered to be exempt from reporting standards?
- Responding to requests for factual information;
- Providing information to a federal official in response to a subpoena or investigation, or in response to a notice in a federal ledger;
- Routine discussions with program officers;
- Contacts with government officials made by faculty/staff on their own behalf without the use of university resources; or
- Mass communications.
My department, school, or college recently held an event that a member of Congress attended. Do we need to report the costs of that event?
It depends. Under the law, events “honoring” members of Congress need to be reported. This includes costs associated with travel for staff, hall rental, catering, plaque or award creation, or any other direct costs.
The rules used to define what events do and do not qualify can be hard to apply properly and will need to be evaluated on a case-by-case basis in consultation with the Director of Research & Sponsored Programs.
Can the university contribute funds to a federal candidate or officeholder, leadership PAC, or political committee?
No. By law, UWL should have no such expenditures.
Do I have permission to contact a Member of Congress/Executive Agency regarding a personal matter or on behalf of a professional association without requiring reporting?
You may do so if you are using your own resources, or the resources of the association, to contact a federal official in your capacity as a private citizen (without indicating the representation of the university). Communications made on behalf of an individual concerning his or her own benefits, employment, and other personal matters involving only that individual are not considered lobbying contacts. When doing so, you should make it clear that you are acting on behalf of your association or yourself and not for UWL. You may not do so if university resources are used. However, de minimis usage is allowed.
If I contact a Member of Congress/Executive Agency to request a letter of support for a federal grant, does this need to be reported as a federal lobbying activity?
Yes. Under the Lobbying Disclosure Act, asking for support regarding the award of a grant is a reportable activity, and no exception to the reporting requirement applies.
What is considered a “university resource?”
University resources include, but are not limited to, letterhead and IT resources (email, telecommunications, internet access, and other information technology services).
How do I calculate and report the cost of any lobbying activity?
Calculating and reporting the cost of lobbying activity is on a good-faith estimate basis. Total expenses incurred for lobbying activities include:
- Travel and office expenses;
- Hospitality;
- Meals;
- Events; and
- Employment time.
In regards to employee costs, first formulate a good-faith percentage of total time spent during the quarter on lobbying, and then multiply this percentage by the applicable salary earned by the employee for that quarter.
- Example: $[Salary for the quarter] x Percentage = $[Amount Reported]
May federal funds or federal grant money be used for lobbying purposes?
No. Federal funds and federally funded resources may not be used for any lobbying purposes, including state, county, or city.