General Guidelines
UW employees can and do engage in federal advocacy and lobbying activities on behalf of the University. Before engaging, please review the below guidelines. We ask UW employees to coordinate advocacy with our office so that we can be clear, consistent, and comply with federal reporting requirements.
UW Administrative Policy Statement 1.3 establishes the role of the Office of Federal Relations in representing UW to the Federal Government, and sets guidelines for employee advocacy.
In general:
- Notify the Office of Federal Relations before any contact with a federal official covered under the Honest Leadership and Open Government Act of 2007, if you speak on behalf of the University or use University resources to make contact (see list of covered officials below). This includes inviting or hosting officials on campus. If you are approached or asked to provide testimony, please let us know so that we can assist you.
- When engaging in professional society contacts with the Federal Government, be careful not to speak on behalf of the University unless coordinated with our office. Do not sign letters on behalf of the University or use UW letterhead for such contacts.
- Using University resources for campaign activities is prohibited under Administrative Policy Statement 47.2.
- Report any lobbying activities by the below deadlines each quarter.
Nothing prevents UW employees from expressing personal views, on personal time, with personal resources.
Reporting Deadlines
Please note these are firm deadlines.
The 2024 deadlines to report federal lobbying activities to the UW Office of Federal Relations are as follows. To receive email reminders regarding the disclosure deadlines, please join the federal lobbying disclosure email list here.
- January 13th, 2024 for 2023 Q4 lobbying activities between October 1 and December 31 (2023)
- April 13th, 2024 for Q1 lobbying activities between January 1 and March 31
- July 13th, 2024 for Q2 lobbying activities between April 1 and June 30
- October 13th, 2024 for Q3 lobbying activities between July 1 and September 30
Lobbying Disclosure
Pursuant to the Honest Leadership and Open Government Act of 2007 [P.L. 110-81, 2 U.S.C. Sec. 1601 et seq.], the UW Office of Federal Relations is required by law to report all federal lobbying contacts and lobbying activities conducted or performed on behalf of the University of Washington to Congress on a quarterly basis. Additionally, UW must report certain contributions such as donations to PACs, events in honor of covered officials, and contributions to presidential library foundations and inaugural committees, on a semi-annual basis.
UW faculty and staff are not generally considered lobbyists. However, many do spend time in Washington, DC directly lobbying or elsewhere engaged in lobbying activities related to efforts on Capitol Hill and with the Administration for specific federal legislation, initiatives, programs, and funding levels.
Officially, only the UW Director and Deputy Director of Federal Relations are considered “lobbyists” to such a percentage of their job on behalf of the University that are required by law to individually file with Congress. They are the only names that will appear on the form filed by the University.
The Office of Federal Relations is required to report the total amount of money the University spends each quarter on federal lobbying efforts, which is why UW staff and faculty are asked to supply information on salary and travel costs. The information provided is kept on file to provide supporting documentation should our records be audited by the Government Accountability Office.
Please use the following criteria to determine what information to report to us (to complete the form correctly). You must report all lobbying activities and lobbying contacts you have had on behalf of UW. It is possible to engage in lobbying activity without having direct contact with a covered official, such as by preparing materials for lobbying or encouraging others to lobby.
Lobbying Activities:
Under [2 U.S.C. Sec. 1602] “lobbying activities” is defined as “lobbying 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”.
Lobbying Contacts:
Under [2 U.S.C. 1602] “lobbying contact” means “any oral or written communication (including an electronic communication) to a covered executive branch official or a covered legislative branch official” regarding:
- the formulation, modification, or adoption of Federal legislation (including legislative proposals);
- the formulation, modification, or adoption of a Federal rule, regulation, Executive order, or any other program, policy, or position of the United States Government;
- the administration or execution of a Federal program or policy (including the negotiation, award, or administration of a Federal contract, grant, loan, permit, or license); or
- the nomination or confirmation of a person for a position subject to confirmation by the Senate.
Covered Officials*:
Under [2 U.S.C. Sec. 1602] covered Legislative and Executive Branch officials include:
- Members of Congress
- Elected officers of either House of Congress
- Employees of a Member of Congress
- Employees of either House of Congress
- Leadership staff of either House of Congress
- Employees of a joint committee of Congress
- Employees of a working group or caucus organized to provide assistance to Congress
- Any other legislative branch employees/officers who occupy a position for at least 60 days for which the pay is 120 percent or more of the lower GS-15 level pay
- The President and Vice President
- Schedule “C” employees (political appointees)
- Officers and Employees of the Executive Office of the President
- Any officer or employee serving in a position in Level I-V of the Executive Schedule
- Any member of the uniformed services whose pay grade is at or above O-7
*Program officers are not usually covered officials. The Plum Book, updated every 4 years, lists many political appointees in the Executive Branch.
Examples of Reportable Activities (for illustrative purposes):
- A faculty member travels to Washington, DC, using UW funds, to meet with congressional staff and advocate for increased funding for a specific program.
- While on duty, a staff member prepares documents for a professor to use during lobbying contacts.
- A dean sends an email to a Member of Congress, using their UW email account, encouraging the Member to vote in favor of certain legislation.
- A department hosts an event on campus honoring a sitting US Senator.
- A faculty member tells an agency head’s senior advisor that changes to an existing program would benefit research at UW.
Reportable Activities do NOT include:
- Speeches or articles available to the public through the mass media;
- Request for a meeting or status information on an issue without any attempt to influence a covered official;
- Testimony given before Congress or submitted to be included in the public record;
- Information provided in response to a request from Congress or subpoena.
There are penalties [2 U.S.C. Sec. 1606]. Individuals who fail to comply are personally subject to both civil (fine up to $200,000) and criminal penalties (up to 5 years imprisonment).
Please reach out to our office with any questions.
Federal lobbying disclosure form