Disclosure of Lobbying Activities
Section: Sponsored Program Administration
Pursuant to Section 1352, Title 31, U.S. Code, the University of Houston-Victoria prohibits faculty, research, and administrative staff from using federal funds to campaign to obtain, extend, or modify a federal award.
This policy prevents the recipient of a federal contract, grant, loan, or cooperative agreement from paying any person to influence or attempt to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress. The policy also involves the continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement. Furthermore, charging travel expenses or drawing a salary from a federal agreement while trying to attempt or influence the awarding of federal funds is defined as lobbying and is prohibited for faculty, researchers, and administrative staff or hiring a paid lobbyist.
Certain legislative liaison activities are allowed when conducted prior to the solicitation of a federal grant, contract, cooperative agreement, or an extension, continuation, renewal, amendment, or modification.
- Discussing with an agency the features and benefits of the university's goods or services, the terms or conditions of sale, and service capabilities, including personalized demonstrations,
- Technical conversations and other activities relating to the use of university products or services by an agency or their use or adaptation for that use.
The regulation identifies certain persons as "regular employees" of an institution and allows them more freedom to discuss research activities with agencies than provided to non-employee "lobbyists." However, a "regular" employee is an individual who has been employed 130 days by the institution in the previous 12 months; faculty and researchers new to the institution must keep in mind this "130-day rule" and be very careful about talking to agencies about specific research projects until they have been at the University of Houston-Victoria for 130 days.
Recipients of federal awards are required to inform the awarding agency when they use non-federal cash for lobbying. The principal investigator is required to submit a Standard Form-LLL Disclosure Form to Report Lobbying activities to the Director of Research and Sponsored Programs for reporting to the federal government.
The Disclosure of Lobbying Activities will also be provided if there has been lobbying for the specific project proposal using non-federal means. A semi-annual compilation of the Disclosure reports will be provided by the Director of Research and Sponsored Programs to the Secretary of the Senate and the Clerk of the House of Representatives.
When submitting a proposal, the Director of Research and Sponsored Programs must certify on behalf of the University that it will adhere to the aforementioned rules if the proposed award exceeds $100,000.
The University may be subject to fines of $10,000 to $100,000 for each breach of the aforementioned rules, as well as other applicable remedies determined by the Federal government. Loss of the specific award is one of these consequences, as is the institution's suspension or debarment from receiving future federal funds.
Review and Responsibility
By authority of the Provost and Vice President for Academic Affairs, the Office of Research and Sponsored Programs shall be responsible for reviewing this policy every four years and updating the policy as federal regulations are modified.
31 U.S.C. 1352 – Limitation on use of appropriated funds to influence certain Federal contracting and financial transactions.
Disclosure Form to Report Lobbying
Robert K. Glenn, Ph.D.
Next review date: December 2027 (5 years)
Origination: Provost and Vice President for Academic Affairs