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Federal Lobbying Disclosure Policy

Title: Federal Lobbying Disclosure Policy
Responsible Unit: Government Relations
Effective: March 1, 2022
Review Date: February 2027
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1. Purpose and Scope

1.1. Purpose. The purpose of this Policy is to ensure West Virginia University’s compliance with the Lobbying Disclosure Act of 1995 (“LDA”) and the House Leadership and Open Government Act of 2007.

1.2. Scope. This policy applies to all West Virginia University faculty, staff, and student employees.

2. Definitions

2.1. “Covered Executive Branch Officials” include the following:

2.2. “Covered Legislative Branch Officials” include the following:

2.3. “Lobbying Contact” means a written, oral, or electronic communication made to a Covered Official on behalf of WVU related to the following:

2.4. Exceptions or Exempted Communications – “Lobbying Contact” does not include the following:

2.5. “Lobbying Activity” means Lobbying Contacts and efforts in support of such contacts on behalf of WVU including preparation and planning activities, research, and other background work that is intended, at the time performed, for use in contacts, or with regard to the Lobbying Contacts of another.

3. Policy

3.1. WVU’s Government Relations Office represents the University’s interest to the federal government and seeks to influence its actions when the University’s interest may be affected. This includes invitations to campus, requests for appointments with legislative or senior executive branch officials regarding legislation, rules, or policies made on behalf of the University. To maximize the effectiveness of all Congressional contacts, it is critical that messages related to University business be coordinated through the Government Relations Office. Communications on behalf of WVU to the Congressional Offices shall be through the Government Relations Office.

3.2. Reporting Expenditures – WVU must provide a “good faith estimate” of the total amount of its lobbying expenses during each quarterly period. The amount WVU must report includes the following:

3.3. All WVU employees that engage in Lobbying Activities or Lobbying Contact with a Covered Executive or Legislative Branch Official must complete the WVU Federal Lobbying Activities Report each quarter and submit that form to the Director of Federal Relations. The form is available on the University’s Government Relations website. The completed forms must be submitted to the Director of Federal Relations no later than the 15th day of each month following the end of the quarterly reporting period:

3.4. When engaging in Lobbying Activities on behalf of professional organizations or for personal interests, WVU employees must comply with WVU BOG Governance Rule 1.4 – Ethics, Conflicts of Interest, and Outside Consulting Arrangements, and shall not use University-provided email accounts when engaging in such activities.

4. Administration of Policy

4.1. The responsibility for application of this policy and the development of procedures rests with the Office of Government Relations in consultation with the General Counsel’s Office.

4.2. For additional information regarding the application of this policy or the reporting of expenditures, please contact the Director of Federal Relations in the Government Relations Office.

5. Authority

5.1. W. Va. Code § 18B-1-6; 2 U.S.C.S § 1602, et seq.; WVU Board of Governors Governance Rule 1.1.