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Lobbying Disclosure

Congressional Lobbying Disclosure Requirements and Gift, Meal, and Travel Restrictions

With the start of the 116th Congress, we want to remind you of the current regulations regarding federal lobbying disclosure reports as well as congressional restrictions on gifts, meals, and travel. As an institution that employs registered lobbyists to advance and safeguard its considerable interests in the nation’s capital, Vanderbilt University is required to file quarterly disclosure reports with the House and Senate detailing lobbying activity[1] and associated expenses. We are also subject to sweeping rules severely restricting gifts and meals for covered Executive Branch officials,[2] Members of Congress, and congressional staff.  There are substantial civil and criminal penalties for violations of these ethics rules and failing to file lobbying reports in a timely and accurate manner. These restrictions apply to all Vanderbilt University employees, faculty, and staff and we ask for your continued cooperation with the following internal guidelines, which are designed to reduce the possibility of inadvertently violating the rules. These guidelines are based on analysis prepared by the American Council on Education.

We would appreciate your assistance in distributing this memorandum and the accompanying form to faculty and staff as appropriate.

Lobbying Disclosure

While the majority of the lobbying activity in which Vanderbilt University engages is conducted by the  Office of Federal Relations in Washington, D.C., Vanderbilt has historically encouraged faculty and staff to communicate with our representatives on Capitol Hill and in Executive Branch agencies on issues of particular concern to them and the university – sometimes individually, but often through their professional organizations. This communication could be in person, over the phone, or in writing.

We are not seeking to end this practice – indeed, Members of Congress and their staff are keenly interested in meeting with Vanderbilt experts on a range of issues, from financial aid to research priorities. Furthermore, our Federal Relations staff relies on our campus experts to illustrate and explain our federal priorities. Our faculty and administrators have tremendous credibility and are consistently Vanderbilt’s best representatives in meetings with federal policymakers.

However, in light of the ethics rules, any direct lobbying by any Vanderbilt University employee on behalf of the university or using university resources must be documented and reported. [3] Our peer institutions face the same requirements and have similar procedures to help ensure compliance. We need your assistance with this.  All faculty and staff who directly lobby covered Executive Branch officials, Members of Congress, or their staff, on behalf of the university and university priorities and/or use university resources are asked to submit a report to Walton Hall ( walton.hall@vanderbilt.edu ) in the Division of Public Affairs. Reports are required not only for in-person meetings with covered Executive Branch officials, Members of Congress or their staff but also any other communications for the purpose of federal lobbying, such as meetings in Nashville, telephone calls, letters and e-mails.

Lobbying contacts made by university employees in their capacity as private citizens and not using Vanderbilt resources do not need to be reported.

 The following form should be submitted within 10 days after the end of each quarter and needs to record:

  • the date of all such meetings or communications;
  • who the meeting or communication was with;
  • the subject discussed (e.g., “funding of Alpha Project research” or “amending the immigration bill to promote access by foreign students” or “increasing the budget of the National Endowment for the Humanities”);
  • the approximate length of time of each meeting; and
  • the costs associated with each meeting, including travel costs to Washington, D.C. (or a pro rata share of those costs when the travel involves other, non-lobbying activities), if appropriate, and a portion of salary and benefits.

In addition, university faculty and staff are encouraged to notify the Office of Federal Relations before, if possible, they engage in federal lobbying activities on behalf of the university. We are happy to help arrange meetings and provide guidance on the most effective way to communicate a message to federal lawmakers or their staff.

Vanderbilt University conducts its advocacy activities in a very transparent and professional manner; in light of the ethics rules, it is essential that we carefully and fully report all such activities by the university and its employees to the House and Senate.

Congressional Rules Related to Gifts, Meals, and Travel

  1. Vanderbilt University, and individuals employed by the university and acting on our behalf, cannot provide gifts to Members of Congress and their staff with a value in excess of $10.  This eliminates virtually any souvenir that might be offered at a meeting, conference, or special event, such as a t-shirt, hat, or coffee mug. Please check with the Office of Federal Relations if you have any questions.
  2. Vanderbilt University cannot pay for any meal, food, or drink with a Member of Congress or their staff. While there are certain prescribed exceptions please check with the Office of Federal Relations in advance of extending an invitation so we can ensure that the meal is not otherwise prohibited.
  3. Vanderbilt University can invite Members of Congress and their staff to certain public events at which food is served, and for which the Member's or staff's presence could be considered directly related to their official duties. Please alert the Office of Federal Relations before such invitations are extended so we can verify that the event does not fall into a prohibited area and so that we can coordinate the many requests that Vanderbilt makes of our Congressional delegation and other Members of Congress.
  4. Vanderbilt University cannot provide Members of Congress or their staff with complimentary tickets to sporting events, concerts, or other activities for which an admission fee is charged.  All Members and their staff must pay the face value of the ticket. We ask that any requests for tickets from Members of Congress or their staff, or invitations to attend a game or performance, be directed to the Office of Federal Relations for response.
  5. Finally, there are complex rules concerning sponsorship of travel (transportation and lodging) involving Members of Congress and their staff.  Vanderbilt University typically does not sponsor congressional travel, but it is an area of great sensitivity with significant advance warning necessary for paperwork and approval. All requests for travel sponsorship involving Members of Congress or their staff should be handled through the Office of Federal Relations to ensure compliance with these ethics rules.

I realize these rules sound onerous and overly proscriptive. They are, however, the law, and we have to make a good faith effort to abide by them.  Please feel free to distribute this message to your colleagues as needed.

Questions? Please contact:

Christina West
Assistant Vice Chancellor for Federal Relations
christina.west@vanderbilt.edu
202-216-4370

Walton Hall
Executive Assistant, Division of Public Affairs
walton.hall@vanderbilt.edu
615-322-4447

 


[1] “Direct lobbying” means any direct contact with covered Executive Branch officials, Members of Congress, or their staffs in which an individual is asking for federal funding, requesting specific legislative action or attempting to influence the position of a federal official on an issue pending before Congress or the Executive Branch.

[2] “Covered Executive Branch official” includes: the President, the Vice President, Officers and employees of the Executive Office of the President, any official serving in an Executive Level 1 through V position, any member of the uniformed services serving at grade 0-7 or above, and any Schedule C (political) employees. It does not typically include program managers or officers.

[3] This does not include lobbying activity by students.