A man, arms crossed, looks into the camera. In the background is a capital building.

The Hatch Act typically applies to federal employees, and may apply to state and local elected officials. It forbids intimidation or bribery of voters and restricts political campaign activities by federal employees. It does not apply to Title VII funded grantees such as the centers and SILCs.

When you are a 723 state (where the state provides more funding than the federal grants), you will want to ask your DSE if that is the case in their view. That is who provides oversite in 723 states.  

There are other prohibitions regarding partisan political activity in the IRS code because of your 501(c)3 status, which is required for all centers and optional for SILCs. Here is an article regarding those prohibitions: https://www.irs.gov/pub/irs-tege/eotopici02.pdf

Related to lobbying, specifically, we do provide guidance as those prohibitions do apply to centers. 45 CFR 93 says in §93.100:

Conditions on use of funds.

(a) No appropriated funds may be expended by the recipient of a Federal contract, grant, loan, or cooperative agreement to pay any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with any of the following covered Federal actions: the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement.

And this definition may help:

(o) Recipient includes all contractors, subcontractors at any tier, and subgrantees at any tier of the recipient of funds received in connection with a Federal contract, grant, loan, or cooperative agreement. The term excludes an Indian tribe, tribal organization, or any other Indian organization with respect to expenditures specifically permitted by other Federal law.

A proper statement for your policies might be this from the certification regarding lobbying:

No Federal appropriated funds can be paid or will be paid, by or on behalf of (name of center), to any person for influencing or attempting to influence an officer or employee of an agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement. As an employee or board member of (name of center) you cannot lobby on behalf of the center without the approval of the Executive Director. If you participate in lobbying, all related costs such as travel, lodging, or meals and indirect costs cannot be paid with federal funds.

You might add that the Center cannot and will not support a specific candidate for office, and cannot act in a partisan manner related to elections. Political materials supporting a candidate cannot be displayed on Center property.

Does the Hatch Act apply to CILs or SILCs?

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