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Re: lobbying certification Charlie Hathaway 30 Nov 2009 16:37 EST

To my mind there are 2 important words in the original question:

"some":     "spends SOME time organizing..."

"for":    "No federal appropriated funds have been paid...to any person
FOR influencing or attempting to influence an officer..."

I'm guessing that this person does not spend much time "lobbying" (broadly
defined) and is probably not paid to lobby.

So???

CH

>    That person cannot be paid 100% from federal funds.  The percentage
> that they spend doing lobbying must be paid from general university
> funds and cannot become a part of the overhead.  In addition, the
> overhead associated is also unallowable as are their benefits.  It's a
> taboo cost that will cause a lot of questions.   Because universities
> do not account for actual hours worked, calculating the percentage will
> be difficult to prove.  They will make you prove the hours.  This is
> why universities will hire someone specifically to do lobbying for them
> and identify a specific office for that activity - so there can be no
> questions.   Good luck.  You may need it.
> Greg Schmidt
>
> GKS Consulting, LLC
> 703-346-5696
>
>
>
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>
> Nov 30, 2009 12:57:52 PM, xxxxxx@hrinet.org wrote:
>   We have a person on our campus who is paid 100% with federal funds.  If
> that  person spends some time organizing local support for his center
> and visits congressional aids to garner support for his center (with the
> ultimate goal of getting a federal contract) I believe we can no longer
> make the lobbying certification that states:
>
>  No federal appropriated funds have been paid or will be paid, by or on
> behalf of the undersigned, to 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 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.
>
>  However, another interpretation of this certification on our campus is
> that this only applies if we HIRE a person to perform lobbying
> services--but does not apply to a center director who is doing these
> activities "on his own time."
>  All comments will be welcome.
>
>
>
>
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