The Johns Hopkins University (JHU) and Johns Hopkins Health System (JHHS) are committed to the free and open expression of ideas. The university encourages members of the JHU community — students, faculty, and staff — to be engaged civically and to participate in the electoral process at all levels: local, state, and federal.
Federal law, however, provides that a tax-exempt organizations such as JHU and JHHS may not itself “participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of (or in opposition to) any candidate for public office.” [Section 501(c)(3) of the Internal Revenue Code]. A violation, whether intentional or unintentional, could have serious ramifications for the university.
If you have been invited to testify before a government body, have any questions about engaging in lobbying at the local, state or federal level, or a question about ethics and compliance please reach out to us at firstname.lastname@example.org.
The above documents provide practical guidance to members of the Johns Hopkins community on complying with university and health system policy and IRS requirements. Also included is a list of FAQs and a memo from the American Council on Education on political campaign related activities.
Of course, no set of guidelines can address every potential situation. Questions should be addressed to the Johns Hopkins University General Counsel’s Office (410-516-8128) or the Johns Hopkins Health System General Counsel’s Office (410-614-3323) or Government and Community Affairs (443-287-9900).
The right to lobby, or petition the government to influence public policy, is one of the most treasured in a democracy. It is affirmed by the Declaration of Independence and the Bill of Rights. The following resources are meant to provide practical guidance to Johns Hopkins University and Johns Hopkins Health System faculty, students, and staff on complying with the institution's policies and IRS requirements.
Of course, no set guidelines can address every potential situations. Please contact Government and Community Affairs at 443-287-9900 with any questions or concerns.
Lobbying activities are regulated by the federal government. The rules require the university to report quarterly all lobbying activity and prohibit the use of federal funds, including grant awards, for lobbying activities.
Am I a Lobbyist?
Since 1995, under the federal Lobbying Disclosure Act (2 U.S. Code, Chapter 26), amended by the Honest Leadership and Open Government Act of 2007, most persons who are paid to make direct "lobbying contacts" with members of Congress and officials of the federal executive branch are considered lobbyists. These individuals spend at least 20 percent of their time over a three month period lobbying and are reported on the University’s quarterly report with the Secretary of the Senate and the Clerk of the House of Representatives.
What qualifies as a "lobbying contact"?
Lobbying contact includes any oral or written communication with a covered official* on behalf of the University to influence legislation; an executive order, agency rule or position of the U.S. government; the negotiation, award or administration of a federal contract, grant, loan, permit or license."Lobbying Contact" does not include a request made to an official for a meeting; testimony provided as a member of the public on the record; information provided in writing at the request of an official; or written response to a notice in the Federal Register, Commerce Business Daily or similar publication soliciting comments from the public.
Do I need to fill out a lobbying disclosure?
If you have had any contact with an executive or legislative official on behalf of the University with regard to government policy, action, and legislation, you should complete the questionnaire.
Federal Lobbying Disclosure Questionnaire
In accordance with the requirements of the Lobbying Disclosure Act of 1995 and the Honest Leadership and Open Government Act of 2007, the Federal Affairs office submits a quarterly report of federal lobbying activity. University leadership and certain employees who have lobbied or plan to lobby receive a quarterly reminder email from the Federal Affairs office inviting them to complete an online questionnaire. If you have received such an email, feel free to complete the questionnaire and submit electronically using the link above. If you are unsure whether you need to report lobbying activity or have related questions, contact the Federal Affairs team.
*Covered officials include any Member of Congress and their staff, the President, Vice President, White House staff, federal Department Secretaries, Deputy Secretaries and Assistant Secretaries, Presidential-appointed directors of federal agencies, centers and institutes (for example, the Director of NIH, the Deputy Administrator of NASA, an Assistant Secretary of the Navy, etc).