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While the majority of the lobbying activity in which 91������ engages is conducted by the ��Office of Federal Relations ��in Washington, DC, 91������ 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/virtually, or in writing.

We are not seeking to end this practice – indeed, Members of Congress and their staff are keenly interested in meeting with 91������ 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 91������’s best representatives in meetings with federal policymakers.

However, considering the ethics rules, lobbying activity by any 91������ employee on behalf of the university or using university resources (including time, computers, email addresses, etc.) must be documented and reported.[i] Lobbying activities[ii] generally include a communication with a covered official asking for specific action. Communications can be oral or written and include in-person or virtual meetings, telephone calls, letters, and emails. Covered officials include covered Executive Branch officials,[iii] Members of Congress, or congressional staff; program officers and managers are generally not covered officials. A specific action could include 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. You may reference the university policy on for further information.

[i] Required reporting does not include lobbying activities by students.

[ii] For additional information, please refer to the “lobbying activities” definition found in [] of the Honest Leadership and Open Government Act of 2007 [P.L. 110-81, 2 U.S.C. Sec. 1601 et seq.].

[iii] “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 I through V position, any member of the uniformed services serving at grade O-7 or above, and any Schedule C (political) employees. It does not typically include program managers or officers.

Lobbying activities by university employees in their capacity as private citizens and not using 91������ resources do not need to be reported.

Faculty and staff are asked to report lobbying activities by completing the following Lobbying Disclosure Form and returning it to Alex Shea��in the Division of Government and Community Relations within seven days of the lobbying activity and no later than the following deadlines, so that it can be included in the university’s quarterly lobbying disclosure reports:

• April 10^th – for lobbying activities that take place between January 1 and March 31
• July 10^th – for lobbying activities that take place between April 1 and June 30
• October 10^th – for lobbying activities that take place between July 1 and September 30
• January 10^th – for lobbying activities that take place between October 1 and December 31

The form is intended to capture the following information:

• the date of all such meetings or communications;
• who the meeting or communication was with;
• the subject discussed (e.g., “funding of AI 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, DC (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. Federal Relations staff are happy to help arrange meetings and provide guidance on the most effective way to communicate a message to federal lawmakers or their staff.

91������ conducts its advocacy activities in a very transparent and professional manner; considering 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.

[i] Required reporting does not include lobbying activities by students.
[ii] For additional information, please refer to the “lobbying activities” definition found in [] of the Honest Leadership and Open Government Act of 2007 [P.L. 110-81, 2 U.S.C. Sec. 1601 et seq.].
[iii] “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 I through V position, any member of the uniformed services serving at grade O-7 or above, and any Schedule C (political) employees. It does not typically include program managers or officers.

1. 91������, 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. 91������ 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. 91������ 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 the event is not prohibited and can coordinate the many requests that 91������ makes of our Congressional delegation and other Members of Congress.
4. 91������ 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. 91������ 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.

Thank you for your assistance in ensuring 91������ complies with these rules. Please feel free to distribute this message to your colleagues as needed.

As a , the use of federal grant dollars to engage in or subsidize lobbying remains strictly prohibited. Section 1352 of Title 31 of the United States Code prohibits recipients of federal grants, loans, or cooperative agreements from using federally appropriated funds to pay any person for influencing or attempting to influence any officer or employee of an agency, a Member of Congress, or congressional staff in connection with the awarding, extension, continuation, renewal, amendment, or modification of a federal grant. This prohibition applies to both direct lobbying by the recipient and indirect support through payments to third parties.

Thank you for your assistance in ensuring 91������ complies with these rules. Please feel free to distribute this message to your colleagues as needed.

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

Alex Shea
Director of Business Operations, Division of Government and Community Relations
alex.shea@vanderbilt.edu
202-216-4373