Gifts and Honorariums
Gift and Honorariums for Covered Federal Officials
What expenditures need to be reported and how?
The University and its lobbyist (the Director of Federal Relations) are required to file a semi- annual report disclosing payments made by the University to honor or recognize covered federal officials, and/or funds paid to designated entities at their suggestion. The reports also include certifications regarding compliance with the House and Senate gift and travel rules. Although employees, besides for the Director of Federal Relations, are not required to file individual reports, all covered expenditures on behalf of the University must be included in its report; and all covered activities must, therefore, be reported to the Director of Federal Relations.
The law requires the disclosure of expenses paid: for an event to honor or recognize a covered federal official; to an entity that is named for or in recognition of a covered federal official; to an entity established, financed, maintained, controlled or designated by a covered federal official; for a meeting, retreat, conference, or other similar event held by, or in the name of, one or more covered federal official(s); and to a Presidential library foundation or Presidential inaugural committee.
Reporting is generally required only when a federal official is being “honored or recognized” by the University in a special way. The mere fact that a covered official attends or speaks at an event sponsored by the University does not trigger the reporting requirement. However, interpretation of the reporting requirements can be complicated, and questions about whether an activity or expenditure is covered should be referred to the Director of Federal
What gifts can the University give federal officials and their staff?
The rules prohibit members of Congress and their staffers from accepting a gift unless it falls within one of the narrow exceptions enumerated in the Rules. One of those exceptions is for gifts funded by state and local governments, including public institutions like the University. However, this exception does not apply to private entities, including private colleges and universities, even when they act jointly with a public institution; and additional restrictions may be imposed by other federal and State laws. Therefore, any gifts (including tickets and travel) for federal officials should be coordinated, in advance, through the Director of Federal Relations. The law also requires the University to certify that it is familiar with the House and Senate Rules relating to gifts and travel and that it has not provided, requested or directed a gift (including travel) with knowledge that the gift may not be accepted under the Rules.