Federal Lobbying Disclosure
The Office of Government Relations (OGR) serves as the primary point of contact between the University of Georgia and local, state, and federal government offices and legislative bodies. OGR is responsible for ensuring that the University complies with state and federal disclosure requirements set forth in the Federal Lobbying Disclosure Act of 1995 and the Georgia Ethics in Government Act, and that the institutional priorities and views of the University are clearly and effectively communicated to elected officials.
Procedure for Interacting with Elected Officials
For these reasons, when interacting with elected officials or staff on behalf of the University all UGA employees should notify the Office of Government Relations. Interacting with elected officials or staff includes, but is not limited to, meeting with elected officials or staff to discuss funding for University research; meeting with officials or staff while attending association conferences; and inviting officials or staff to campus.
University of Georgia Federal Lobbying Guidelines
The Lobbying Disclosure Act, as amended, (2 U.S.C. § 1601 et. seq., referred to hereinafter as the “LDA”) requires the Secretary of the Senate and the Clerk of the House of Representatives to provide guidance and assistance on the registration and reporting of lobbying activities by organizations and individuals who make contacts with Members of Congress and staff and certain federal executive branch officials.
The LDA was amended by the Honest Leadership and Open Government Act (HLOGA) (Public Law 110-81) and new congressional ethics rules were adopted related to gifts, travel, entertainment, and events to honor members of Congress and staff.
As a result of HLOGA, the University of Georgia has established a procedure for internal tracking and reporting of lobbying contacts. As part of this effort, the University of Georgia must also collect and report relevant costs related to lobbying activities to the nearest $10,000. This is premised on a good faith effort but would include such costs as:
- Travel and other expenses.
- Payment to outside lobbying firms.
- An appropriate percentage of dues paid to organizations that lobby on behalf of UGA and other higher education institutions.
In order to ensure compliance with the law, there are three issues to be addressed:
- Whether you have engaged in any lobbying contacts on behalf of UGA;
- Whether there were any lobbying activity costs associated with such contacts; and
- The amount of time spent lobbying (Section V below).
All of these must be reported to the University so it may accurately estimate its activities and contacts in its quarterly report. To properly capture the qualified lobbying activities of University of Georgia employees, refer to the instructions and relevant form on this site.
Who qualifies as a Lobbyist:
- More than one “lobbying contact” with covered officials.
- “Lobbying activities” constitute 20% or more of the services performed by that individual on behalf of his/her employer or client during any quarter.
- The organization has “lobbying expenses” of $13,000 per quarter in the case of an employed “lobbyist” (or $3,000 per quarter if an outside lobbying firm).
Who must register?
- Organizations including universities are not themselves “lobbyists” but must register under the LDA and list any employees who meet the definition of a “lobbyist”.
- If a higher education institution hires an outside person or entity that meets the definition of a “lobbyist” – then that person or entity must register under the LDA and list the higher education institution organization as its “client”.
- Form LD-1 registration must be filed within 45 days after meeting the threshold for registration listed above.
Lobbying Contact Definition
What is a federal “lobbying contact”?
Oral (phone calls or face-to-face meetings), written (letters), or electronic communications (emails) to a covered Legislative or Executive Branch Official regarding:
- Formulation, modification, or adoption of Federal legislation.
- The administration or execution of a Federal program or policy.
- Formulation, modification, or adoption of a Federal 10 rule, regulation, executive order, policy or position of the United States Government.
- The nomination or confirmation of a person subject to confirmation by the Senate.
What is NOT a “lobbying contact”?
- A speech, article, publication or other material that is distributed and made available to the public through a medium of mass communication.
- A request for a meeting, a request for the status of an action, or other similar administrative request.
- Testimony given before Congress or submitted for inclusion in the public record.
- Information provided in writing in response to an oral or written request, or in response to a request for public comments in the 11 Federal Register.
- Required by subpoena or civil investigative demand.
- Written comment filed in the course of a public proceeding.
- Made by the media if the purpose is gathering and disseminating news and information to the public.
Examples of “lobbying contacts”:
Covered Legislative Branch Official
- Members of Congress.
- An elected officer of either chamber of Congress (House or Senate).
- Employees of a member, committee, leadership staff, joint committee, working group or caucus.
Covered Executive Branch Official
- The President.
- The Vice President.
- Any officer or employee in the Executive Office of the President.
- Any Executive Schedule level I – V officer or L-13 employee.
- Any member of the armed services at or above pay grade 0-7 & above.
- “Schedule C”, any officer or employee in a confidential policy advocating position and/or political appointees.
III. Lobbying Activities
- Lobbying activities are contacts AND efforts in support of such contacts, including preparation and planning activities, research and other background work that is intended, at the time it is performed, for use in contacts and coordination with the lobbying activities of others.
- If you or someone in your unit believes they have engaged in any lobbying activity, REPORTING THIS INFORMATION TO THE UNIVERSITY IS A REQUIREMENT. After completing the report, you may be contacted by the Office of Federal Relations to assess whether the information is a reportable lobbying activity. Your cooperation in this important endeavor is greatly appreciated.
IV. Consulting and Association Membership Fees
- If a unit of the University of Georgia is part of an association that partakes in lobbying activities, on behalf of its members, and the University pays fees to that association, the unit needs to report the percentage of fees that the association used towards lobbying activities. This may require the unit to ask the association what percentage of dues were used for lobbying activities. Examples of UGA units include, but are not limited to, the UGA Graduate School, the University of Georgia School of Veterinary Medicine, and UGA Marine Extension and Georgia Sea Grant. Examples of associations include, but are not limited to, Council of Graduate Schools (CGS), Association of American Veterinary Medical Colleges (AAVMC), Sea Grant Association, and Association of Public and Land-grant Universities (APLU).
- If an individual or unit of the University of Georgia uses University funds to pay for a consultant that engages in lobbying activities on behalf of the University, they need to report the fees paid to that consultant.
University of Georgia Lobbying Resources
Lobbying Report Form
The University of Georgia Office of Government Relations is available to answer any questions you may have. Please contact the Assistant Director of Federal Relations, Samantha Cadet by email at firstname.lastname@example.org or phone 202.957.8705.
|Reporting Schedule*||Due Date:|
|First Quarter: January 1 – March 31||April 20|
|Second Quarter: April 1 – June 30||July 20|
|Third Quarter: July 1 – September 30||October 20|
|Fourth Quarter: October 1 – December 31||January 20|
|Contribution Reports*||Due Date:|
|Mid year: January 1 – June 30||July 30|
|Year end: July 1 – December 31||January 30|
*If the deadline falls on a weekend or holiday, the report is due the following business day.