Applies to: (examples; Faculty,Staff, Students, etc)
Faculty , Staff , Students
Faculty , Staff , Students
This policy outlines the scope of permissible and impermissible conduct applicable to the College as a tax-exempt organization under the Internal Revenue Code and recipient of federal research funding.
Applies to all faculty, staff, and students.
Lobbying Activities: Attempting to influence legislation or actions by a governmental law making body with respect to acts, bills, resolutions, proposed regulations, confirmation of appointees, or similar activity by the public in the form of referendum, ballot initiative, constitutional amendment, or other procedures. Lobbying activities covered under the Internal Revenue Code do not include actions by executive, judicial or administrative bodies; however, NIH grantees are restricted on use of appropriated funds for lobbying, advocacy, or attempts to influence deliberations or actions by federal, state, or local legislative or executive branches.
Political Campaign Activities: Contributions, public statements, or other direct or indirect support in favor or in opposition to a candidate for public office.
Section 503 of the Internal Revenue Code prohibit the St. Louis College of Pharmacy as a tax-exempt organization from directly or indirectly participating in political campaigns or supporting candidates for public office. Additionally, a substantial part of the College’s overall activities may not involve lobbying to influence legislation. Federal law prohibits use of appropriated funds by NIH grantees, either directly or indirectly, for advocacy, lobbying, and related activities.
The College may engage in or sponsor activities that promote non-partisan voter education and participation in the electoral process. It may also provide equal opportunities for political candidates to access College facilities in a non-partisan manner. The College must sponsor and approve all lobbying activities to ensure effective monitoring. Lobbying does not include educational activities on public policy issues.
Any student or student organization or group seeking to engage in or sponsor non-partisan political campaign or lobbying activities must submit a written request for approval to the Vice President of Student Affairs. Departments or employees must obtain approval from the Director, Human Resources.
The Vice President of Student Affairs and Director of Human Resources will consult with the President and General Counsel to obtain authorization to approve the proposed activity and establish appropriate parameters to ensure compliance. Failure to obtain approvals or violation of established rules and regulations or conditions of approvals may result in disciplinary action. The College reserves the right to approve or deny a request for any reason that it deems to be in the best interest of the institution.
II. Guidelines
The following activities may be allowed while observing the following guidelines: the activities are conducted in a non-partisan or neutral manner or setting; equal opportunities are extended to all legally-qualified candidates; no campaigning, fundraising or endorsement occurs; questions or data is presented in a non-biased or partisan manner; and any personal appearances are coordinated as speeches, questions and answers to create an academic setting as opposed to a campaign rally or event.
B. Public policy education activities
C. Institutional Resources
D. Prohibited Activities
E. NIH Lobbying Guidance
In addition to compliance with the lobbying restrictions imposed under the Internal Revenue Code, the NIH has provided the following guidelines for NIH grantees.
F. Byrd Amendment
Additionally, the Byrd Amendment makes it unlawful for the College to engage in advocacy with members of federal government agencies and Congress to perpetuate or increase federal funding.
Position/Office/Department |
Responsibility |
General Counsel |
Socializing policy and providing legal advice |
Vice President, Student Affairs |
Review and approve student activities; enforce policy |
Director, Human Resources |
Review and approve employee activities; enforce policy |
Tax-Exempt Organizations: https://www.acenet.edu/Documents/Political-campaign-activities-issue-brief-2018.pdf.
National Institute of Health Grantees: https://grants.nih.gov/policy/lobbying_guidance.htm.
Byrd Amendment regulations: 40 CFR Part 34
Name |
Contact Information |
Kenneth Fleischmann |
Kenneth.Fleischmann@stlcop.edu, ext. 8104 |
Heather French |
|
Dan Bauer |
Dan.Bauer@stlcop.edu, ext. 8308 |