This Guidance Document is intended to promote transparency and further compliance with University Policy GE003 State and Federal Government Relations Activities by providing helpful guidance, instruction and/or non-exhaustive lists or illustrative examples to help guide the reader. This Guidance Document has no force or effect on any University Policy or Related Procedure and readers should contact appropriate subject matter experts, including their supervisor, for further guidance. This Guidance Document was created pursuant to University Policy GE0001.  

 Examples of activities covered by this policy include:

• A University faculty member travels to Washington, D.C., to meet with congressional staff to discuss the importance of funding for her research field. This constitutes a lobbying contact subject to this policy. Faculty should make clear that their comments are as an individual and not representative of the University. Questions regarding the proper use of University resources should be directed to Government Relations & Advocacy. (governmentrelations@tennessee.edu)

• A University faculty member calls the Assistant Secretary of a federal agency from the faculty member’s office in Tennessee to advocate on behalf of a proposal for funding that the University submitted to the agency. This constitutes a lobbying contact subject to this policy.

• While in Washington, D.C., for a professional association meeting, a University faculty member contacts a member of Congress regarding federal funding for University sponsored cancer research. The contact with the member of Congress constitutes a lobbying contact subject to this policy.

• A University faculty member is in a leadership position in the Faculty Senate.  At a campus event, the faculty member engages in a discussion with a member of Congress about a federal law issue impacting employee benefits on the campus that is the subject of current discussions and debate in the Faculty Senate.  During the course of the conversation with the member of Congress, the faculty member discloses her Faculty Senate leadership position, indicates that the Faculty Senate is grappling with the issue, and expresses the concerns of Faculty Senate members about the issue that have been voiced in recent meetings of the Faculty Senate and its committees.  The University does not consider the faculty member’s conversation with the member of Congress to be a lobbying contact subject to this policy because the faculty member is speaking on behalf of the Faculty Senate, not the University. Nevertheless, the faculty member should make it clear to the member of Congress that he/she is speaking on behalf of the Faculty Senate, not the University.

• A group of University officials involved in widget research decide to honor two members of Congress with “Widget Research Legislative Leaders of 2015” plaques. The University officials are aware that the senator has checked with the Senate Select Committee on Ethics regarding his or her ability to accept the award and attend the coffee, and the representative has checked with the House Committee on Standards of Official Conduct. The University officials pay a caterer $500 and a hotel $200 to partially fund the event. The university officials would report that they paid $500 to the caterer and $200 to the hotel on the next quarterly disclosure report for the purpose of an event to honor or recognize the members of Congress with the plaques.

• The University buys a table at a dinner event sponsored by a 501(c) organization to honor a member of Congress, but the University is not considered a sponsor of the event under House and Senate gift rules. The University President pays the $150 individual ticket cost to attend the dinner, but is not considered a sponsor of the event under House and Senate gift rules. The purchase of a table or ticket to another entity’s event, in and of itself, is not sufficient to be considered paying the “cost of an event.” Supplemental facts might require reporting the cost of the event. For example, if (1) the University or the President undertake activities such that either becomes a sponsor of the event for House and/or Senate gift rule purposes; or (2) the University or the President purchases enough tickets/tables so that it would appear that they are paying the costs of the event and/or would not appear to be just ticket or table-buyers, then the University and the President would need to report the costs incurred by either (as the case may be) for the event, noting the member of Congress who was the honoree.

• In May 2015, in conjunction with its commencement event, the University conferred an honorary degree upon Senator “P.” The University must report all payments relating to the commencement event (chair rental, lunch for honorees, etc.) on its semiannual report of honorary contributions, listing “various vendors” as the payee, and Senator “P” as the honoree.

• A University employee schedules an appointment with a state legislator to advocate for funding or a policy issue on behalf of the system, campus, or unit. This constitutes lobbying contact subject to this policy.

• A University dean sends a letter to state officials opposing legislation under consideration using University letterhead. This constitutes lobbying activity subject to this policy.

• A media outlet contacts a faculty member to request comments on proposed legislation. Response to such an inquiry does not constitute lobbying contact subject to this policy, however, faculty are encouraged to clarify that their comments are as an individual, and not representative of the University. 

• A University employee is applying for or performing work on a governmental grant or contract requiring contact with certain government officials to facilitate the work. This does not constitute lobbying under this policy, however, if such communications extend to government officials not directly involved in the grant or contract process and include an effort to advocate then such communications should be coordinated with Government Relations and Advocacy.