Over the next few weeks we are going to address the costs that are NOT allowed with federal money, or that are allowed in some cases and not others. The first topic we should discuss is lobbying.
  •  First, a CIL or SILC is allowed to lobby for specific legislation — you just can’t do it with federal money. Any staff time spent lobbying is tracked, and the staff time and both direct and indirect expenses have to be paid for with non-federal, discretionary funds. This would include any legislative contact when you request a specific action on a specific piece of legislation.
  • Second, lobbying also includes grass roots lobbying — anything you do to get the individuals in the disability community to vote in a certain way. It is also considered lobbying if you go to anyone in the chain of authority over services, from federal legislators to the staff of the offices funding you, in an attempt to sway them concerning your funding.
  • I’m sure you can see where a CIL may at times want to take their advocacy further, and when they lobby, they need to keep accurate records of the costs and make sure they can show that the lobbying costs were not paid for with federal money. Most centers set aside donations and other discretionary money so that they can lobby when needed. Our role as advocates may take us into lobbying territory, and clear records of the costs will serve you well.
  • Finally, lobbying does not include other contact with legislators to inform them of the status and purpose of your organization, or even to provide testimony related to legislation, right up to the point that you might want to suggest how they vote. At that point you’ve crossed back into lobbying territory.
  • To keep your 501(c)(3) status with the IRS, you cannot spend a significant amount of money on lobbying, and you cannot give money to or have signs in your offices (or any other support from your organization) for any specific candidate or party. You can hold a voter education workshop as long as you don’t suggest how people vote. You can hold a candidate forum, for consumers/voters to ask questions as long as you invite ALL the candidates for that seat. They don’t all have to show up, but you have to invite them all.
These are the items related to how federal money can or must not be spent. More is found at the HHS website. Much of the information is from the Code of Federal Regulations, at 45 CFR Part 93.
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Allowable costs for federal grants — about lobbying

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