Lobbying and Other Federal Policies

While the majority of the federal lobbying activity in which VUMC engages is conducted by the Office of Federal Relations in Washington, D.C., VUMC faculty and staff may have cause to communicate with representatives on Capitol Hill and Executive Branch officials on issues of particular concern to them and the institution. This communication could be in person, over the phone, or in writing.

Any direct lobbying by Vanderbilt University Medical Center employees on behalf of the institution or using VUMC resources must be documented and reported. All faculty and staff who directly lobby Members of Congress or their staff on behalf of VUMC and VUMC priorities, and/or use Medical Center resources for lobbying activities, are asked to submit a report to Alex Currie in the Office of Federal Relations in a timely manner. Exchanges with senior Executive Branch officials to advance specific public policy positions should likewise be reported. Reports are required not only for in-person meetings but also any other communications for the purpose of federal lobbying, such as meetings in Nashville, telephone calls, letters and e-mails.

Lobbying contacts made by Medical Center employees in their capacity as private citizens and not using Vanderbilt resources do not need to be reported.

An example of an activity requiring report to OFR: Dr. Jones, a VUMC employee, exchanges email with congressional staff using her vumc.org email and expresses her support for a piece of legislation on behalf of her role as medical director of a clinic at VUMC.

An example of an activity not requiring report to OFR: Dr. Jones, a VUMC employee, participates in advocacy meetings with a specialty society in Washington. She identifies herself as a physician in practice at VUMC, but makes clear she is representing herself and/or her society. No VUMC resources were used for the visit. 

For reportable activities, the following information should be submitted to the Office of Federal Relations within 10 days after the end of each quarter:

the date of all such meetings or communications;
who the meeting or communication was with;
the subject discussed (e.g., “increasing the budget of the National Institutes of Health” or “supporting bill ___” or “opposing Medicare cuts to hospital providers);
the approximate length of time of each meeting, as well as time spent preparing; and
the costs associated with each meeting, including travel costs to Washington (or a pro rata share of those costs when the travel involves other, non-lobbying activities), and a portion of salary and benefits associated with time spent.

The attached form should be used to facilitate this reporting. In addition, faculty and staff are strongly encouraged, if at all possible, to notify VUMC OFR before they engage in federal lobbying activities on behalf of the Medical Center. The OFR is happy to help arrange meetings and provide guidance on the most effective way to communicate a message to a federal official or elected representative.

Vanderbilt conducts its advocacy activities in a transparent and professional manner; in light of ethics rules, it is essential that we carefully and fully report covered advocacy activities by the Medical Center and its employees.

Gifts

Entities employing lobbyists, such as VUMC, are NOT permitted to provide Members of Congress and their staff with gifts, including meals, except in a small number of prescribed exemptions. The term gift includes gifts of services, training, transportation, lodging, and meals, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred. The prohibition includes souvenirs that might be offered at a meeting, conference or special event, such as a t-shirt, hat, or coffee mug. There are certain exceptions for longstanding personal friendships. In addition, the rules generally deem a gift to any family member of a Member of Congress (spouse or child) to be a gift to the Member, subject to all of the ticket, gift, and food restrictions.

Tickets

VUMC cannot provide Members of Congress or their staff with complimentary tickets to sporting events, concerts or other activities for which an admission fee is charged.  All Members and their staff must pay the face value of the ticket.  For locations where there is no face value – such as a suite or box – the Office of Federal Relations should be contacted for guidance. In addition, VUMC is required to charge the Member or staff an additional cost for the value of any food served, unless the food passes the "toothpick exemption."  Again, any requests for tickets from Members of Congress or their staff, or invitations to attend a game or performance, should be directed to the OFR for response.

Meals

VUMC cannot pay for any meal, food or drink with a Member of Congress or their staff that exceeds the gift limit referenced above.  While there are certain prescribed exceptions such as for longstanding personal friendships and for “widely-attended” public events at which passed appetizers can fit on a toothpick (the so-called "toothpick exemption"), the Office of Federal Relations should be consulted in advance of extending an invitation to ensure that the meal is not otherwise prohibited.

Events

VUMC can continue to invite Members of Congress and their staff to certain public events at which food is served, and for which the Member's or staff's presence could be considered directly related to their official duties.  Examples of this would include public lectures, educational events, groundbreakings, dedications, academic conferences, symposia, charity events, etc.  The VUMC Office of Federal Relations should be consulted before such invitations are extended to verify that the event does not fall into a prohibited area.

Political Contributions

501(c)(3) entities are prohibited from making political contributions or engaging in any partisan political activity.

Travel

Finally, there are complex rules concerning sponsorship of travel (transportation and lodging) involving Members of Congress and their staff.  All requests for travel sponsorship involving Members of Congress or their staff should be handled through the VUMC Office of Federal Relations to ensure compliance with these ethics rules.