University of Southern California

USC Policy

Administrative and Business Practices

Date issued: July 30, 2013

Lobbying and Gifts to Government Officials

Lobbying

Because governmental decisions have the potential to significantly impact the university, USC frequently participates in the governmental process at the federal, state, and local level. A number of laws impose registration and reporting requirements on individuals who engage in certain types of communication with public officials. In addition, when such communications are made on behalf of the university, the university may be required to register and report. These laws are generally referred to as lobbying laws.

    To ensure that the university and its employees fully comply with all applicable laws relating to lobbying:

  1. Any staff member who communicates with a federal, state, or local public official (elected, appointed, or staff) on behalf of the university must complete and submit a form to the Office of Government Relations at the end of each month in which such communication occurs.
        a. Communication includes in-person meetings, telephone calls, emails, letters, or any other means of communication.
  2. Any staff member who does research or prepares materials that will be used by another person when communicating with a federal, state, or local public official (elected, appointed, or staff) on behalf of the university must complete and submit a form to the Office of Government Relations at the end of each month in which such activity occurs.
  3. No outside lobbyist or lobbying firm may be engaged by any school or department without the prior approval of the Vice President for Government Relations.

Contact the Office of Government Relations at (213) 740-5371 to obtain forms for reporting lobbying activity. Employees will be asked to identify the nature of their communications or other activity, the amount of time spent, and whether any reimbursable expenses were incurred.

Gifts

The university occasionally provides items of value, such as meals or tickets to events, to federal, state, and local public officials. Depending on the official and the nature of the gift, these gifts are subject to certain limits and reporting requirements. For example, many California officials are permitted to receive modest gifts up to a certain amount, while gifts to members of Congress and their staff are generally prohibited. Because the limits apply to the university as a whole, it is critical that the university maintain a central database of these gifts.

To ensure that the university and its employees fully comply with all applicable laws relating to gifts, no expenses may be incurred to provide anything of value to a federal, state, or local public official (elected, appointed, or staff) without prior approval of the Office of Government Relations. For example, all administrators, faculty, and staff must alert the Vice President for Government Relations prior to honoring a public official and must receive pre-approval for an awards dinner or plaque.

Responsible Office

Office of Government Relations

(213) 740-5371

Issued by

Todd R. Dickey, Senior Vice President, Administration
University of Southern California