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Public Agency Lobbying Regulations & Disclosure

As a state public agency, the UW is permitted to lobby state government using public funds but must adhere to strict lobbying reporting requirements to ensure the complete disclosure of how public dollars are being utilized. Certain advocacy activities are also limited or prohibited for the UW with the use of public resources (e.g. grassroots lobbying).

All UW employees are allowed to engage in lobbying activities on behalf of the University but must report their activities and related expenditures in accordance with the Washington Public Disclosure Act (RCW 42.17A; WAC 390). State lobbying activities and expenditures must be reported to the Office of State Relations. If you are looking for federal lobbying guidance, visit the UW’s Office of Federal Relations.

Before engaging in advocacy on behalf of the UW, please review the below guidelines. It’s important to note that UW employees are required to coordinate state lobbying activities with the UW Office of State Relations to help safeguard compliance with the law. UW Administrative Policy Statement 1.3 establishes the role of the Office of State Relations in representing the UW to the state government and sets guidelines for employee advocacy. We will go into more detail below, but in general:

  • Notify the UW Office of State Relations before interacting with state officials and before representing the University to state government. This includes inviting or hosting elected officials or government agencies on campus.
  • If you are asked by a state official to provide testimony, professional expertise, or educate them about the work of the University, notify the Office of State Relations in advance for assistance and to ensure state lobbying laws are followed.
  • When engaging in personal or professional society contacts with state government, make clear that the contact is not made on behalf of the University. Additionally, do not sign letters or other communication materials on behalf of the University or use UW letterhead for such contacts.
  • Using University resources for campaign or grassroots activities, including promoting or opposing a ballot proposition or initiative, is prohibited under Administrative Policy Statement 47.2 and by the Washington State Public Disclosure Act.
  • Report state lobbying activities and expenditures to the Office of State Relations by the below deadlines each quarter.

Nothing prevents UW employees from expressing personal views, on personal time, with personal resources.

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What is Lobbying?

The Public Disclosure Commission (PDC) defines lobbying as “attempting to influence the passage or defeat of any legislation by the Washington State Legislature, or the adoption or rejection of any rule, standard, rate, or other legislative enactment of any state agency under the state Administrative Procedure Act, RCW 34.05.”

The most common form of lobbying is in-person meetings with elected officials or legislative or gubernatorial staff to influence action or inaction on policy, including budget proposals. While phone calls are exempt from public agency lobbying reporting, video calls and virtual meetings should be reported. Lobbying also includes testifying at legislative or agency committees and hearings.

Limits on public agency lobbying: The UW’s lobbying authority is generally limited to communicating with state government on official agency business and advocating only the official positions of interest of the agency. State agencies are prohibited from:

  • Engaging in grassroots or other indirect forms of lobbying or advocacy.
  • Spending public funds directly or indirectly for campaign contributions.
  • Spending public funds directly or indirectly for gifts, which include meals, beverages, leisure travel, theater or sporting event tickets, artwork, flowers, etc. However, state agencies may use non-public monies to entertain state elected officials and staff if certain criteria is met.
  • Using public resources, including facilities, to support or oppose a ballot measure such as an initiative or referendum to the people.

Disclosure Requirements

The UW is required by law to report all state lobbying activity conducted on behalf of the University and related expenses to the state via the Public Disclosure Commission on a quarterly basis. The UW Office of State Relations is designated to compile and submit the University’s quarterly lobbying report, but UW employees are individually responsible for submitting their lobbying activities and expenses to the Office of State Relations.

The report must disclose:

  • The dates of lobbying, the names and titles of all employees engaging in activity, the amount of time spent lobbying, the issues lobbied, and all associated costs including wages, travel expenses, and entertainment expenses. See the definition of lobbying above.
  • Itemization of non-public fund expenditures spent in conjunction with lobbying (i.e., meals, beverages, travel, etc.).
    Expenditures on publications printed for the purpose of lobbying.
  • Expenditures on consultants or contractors employed by the agency to support lobbying activities.

Activities not required to be reported:

  • Budget requests to the Washington State Office of Financial Management (OFM) or requests by OFM to the legislature on behalf of the UW.
  • Recommendations or reports to the legislature in response to a legislative request or funding proviso expressly requesting or directing a specific study, recommendation, or report on a particular subject.
  • Official reports, including recommendations, submitted annually or biennially as required by law.
    Requests, recommendations, or other communications between or within state or local agencies.
  • Telephone conversations or preparation of written correspondence.
  • Monitoring legislative or agency meetings and hearings. However, testifying is considered lobbying.
  • Preparation or adoption of policy positions within an agency or group of agencies.
  • Attempts to influence federal or local legislation. Please note that federal lobbying activities must be reported to the UW Office of Federal Relations.

Lobbying Reporting Deadlines

Please note these are firm deadlines.

The 2022 deadlines to report state lobbying activities to the UW Office of State Relations are:

  • April 13 for Q1 (Jan. 1–Mar. 31)
  • July 15 for Q2 (Apr. 1–June 30)
  • October 14 for Q3 (July 1–Sept. 30)
  • January 13, 2022 for Q4 (Oct. 1–Dec. 31)

Download the state lobbying disclosure form here.

To receive an email reminder regarding reporting deadlines, please contact staterel@uw.edu and ask to join the state lobbying disclosure email list.

Penalties for Failure to Report

Failure to file complete, accurate, and timely state disclosure reports may result in enforcement and a monetary penalty. A state agency director who knowingly fails to file a report when required shall be subject to a personal civil penalty of $100 dollars per statement. A state agency official, officer, or employee who is responsible for, or knowingly directs or spends public funds in violation of RCW 42.17A.635(2) (3) may be personally subject to penalties equal to the amount of public funds spent.

Additional Resources

More information about public agency lobbying can be found by visiting the Public Disclosure Commission’s public agency lobbying guide.

For questions about state advocacy, please contact the UW Office of State Relations at staterel@uw.edu.