Contacts with Federal and State Government Officials and Agencies
Chapter 3095
This policy governs employees contacting federal or state government officials within the course and scope of their employment with Kansas State University. It does not prohibit employees from participating in federal and state government as individuals. This policy does, however, require employees to ensure that their contacts with federal or state officials are clearly as individuals only, and are not part of their University role.
.010 The Office of Governmental Relations and the employee notification requirement
The Office of Governmental Relations is charged with leading and coordinating the University's governmental relations activities, as directed by the University President. To ensure proper coordination of governmental contacts, all University employees and agents must notify the Director of Governmental Relations ("the Director") about their intent to make contact with a federal or state governmental official regarding the formulation, modification, or adoption of a law, regulation, rule, program policy, or an administration action or policy. The Director may approve the contact, may require the employee to modify the message or form of the contact, or may require that the contact not be made.
Employees who have any questions about whether a contact needs to be reported should contact the Office of Governmental Relations.
.020 Individual contacts or contacts on behalf of professional societies or associations
In the interest of the fullest participation in public affairs, employees are free to express opinions speaking or writing as an individual in their personal capacity and not as a representative of the institution in signed advertisements, pamphlets and related material in support of or opposition to parties and causes. There shall be the commensurate responsibility of making plain that each person so doing is acting for himself or herself and not on behalf of Kansas State University. This responsibility includes avoiding the use of university letterhead and stationery and other official university designations.
Many professional societies and associations representing academic fields and higher education hold annual federal legislative conferences in Washington D.C. to support policy positions and budgets of those entities. Contacts with federal or state officials on behalf of these entities – if not specifically for the benefit of Kansas State University – do not need to be reported to the Director of Governmental Relations, although employees testifying before the Kansas Legislature or before Congress on behalf of outside entities shall notify the Director of Governmental Relations prior to such testimony.
The Office of Governmental Relations appreciates being informed about contacts with federal and state officials, particularly legislative contacts, even when those contacts have not been made because of an employee's University role.
.030 Guidance regarding different types of government contacts
Contacts with government officials and agencies may take many forms, including but not limited to individual or group meetings, testimony before executive or legislative bodies, presentation of written materials or electronic transmissions, invitations to visit campuses, and responses to requests for information from governmental officials.
- Individual or group meetings with executive and legislative elected officials and staff: If such meetings are for the purpose of representing the interests of Kansas State University, including specific funding requests or grant proposals, they must be coordinated with and approved by the Office of Governmental Relations.
- Appearances before executive and legislative bodies including committees, study groups, commissions: If such appearances are for the purpose of representing the interests of Kansas State University, the Office of Governmental Relations must be notified and must grant approval for such representation. The Kansas Board of Regents must also be notified if a faculty or staff member testifies before a legislative body, legislative meeting, or commission.
- Written Materials or Electronic Transmissions: It is useful for officials to receive official University publications and periodicals, but it is important to coordinate such distributions to avoid duplication of effort and other problems that may result from overloading officials with such material. Therefore, the distribution of materials to officials should be coordinated with the Office of Governmental Relations.
- Invitations to visit campuses: The University welcomes visits by elected officials and staff, whether they visit as private citizens or in their capacities as government officials. Invitations to elected officials to visit any campus of the University in their official capacity are to be approved in advance by the President or CEO of the campus, and also by the Office of Governmental Relations.
- Responses to requests for information, reports, and data from elected officials and staff: When requests for information, reports and data related to the University have been made to the campuses or to individual faculty and staff members of the University community, responses to such requests are to be coordinated through the Office of Governmental Relations.
.040 Compliance with Federal Lobbying Requirements
Kansas State University is registered as a lobbying organization is compliance with the federal Lobbying Disclosure Act of 1995. This act was amended by the Honest Leadership and Open Government Act HLOGA (Public Law 110-81). This law implemented congressional ethics rules related to gifts, travel, and events to honor members of Congress and staff. Kansas State University is required to report on federal lobbying activities and contacts with certain federal elected and appointed persons, including all members of Congress, all congressional staff, all federal Schedule C employees (positions involved in making and approving policy recommendations), and military personnel pay grade 0-7 or higher.
To comply with federal law and regulations, Kansas State University has a required procedure for quarterly reporting for any employees who may have contact with the above-mentioned categories of federal elected officials, appointed staff and employees, and military members.
Coordination with the Director of Governmental Relations is essential for the University to maintain professional working relationships with public officials, project coherent and effective messages and ensure compliance with federal laws. The Office of Governmental Relations is responsible for the preparation and submission of the required federal reports associated with federal lobbying activities.
Contracting with an outside lobbying firm or lobbyist is prohibited, unless approved by the Director of Governmental Relations.
