Federal funds cannot be used for legislative lobbying, but some exceptions apply.

Source: OMB Circular A-122

Q: Who is subject to restrictions on use of federal funds for lobbying?

A: Nonprofit that get federal funds through categorical grants, contracts or cooperative agreements, whether directly or through an intermediary. The rules are found in OMB Circular A-122. Hospitals, universities, state and local government agencies, public nonprofits like the Legal Services Corporation and large nonprofits are governed by separate but similar rules.

Q: What activity cannot be paid for with federal funds?

A: “Disallowed” costs that cannot be reimbursed include:

• Attempts to influence legislation by direct contact with legislators
• Grassroots appeals using "publicity or propaganda"
• Urging the public to participate in rallies, marches, telephone or letter writing campaigns aimed at legislation
• Legislative liaison work, including attending hearings, tracking and analyzing bills
• Gathering and publicizing information about legislation in "support or knowing preparation" for lobbying
• Research and nonpartisan analysis made in knowing preparation for lobbying
• Referendum campaigns
• “Electioneering,” including helping candidates, parties or PACs
• Lobbying for awarding or renewal of a grant, contact or cooperative agreement

Q: What are the exceptions to these prohibitions?

A: Exceptions allow lobbying in the following circumstances:

• Influencing state legislation that would directly reduce the cost of carrying out the grant
• Influencing state legislation that would cause “material impairment” of the group’s ability or authority to carry out the grant
• Advocating changes in administrative regulations of federal agencies
• Providing information and assistance to legislators or their staff at their request if:
  1. the request is specific
  2. the request is directed to the group or the general public
  3. you respond only to the requestor
  4. presentations can be in writing or oral, but must be mostly informational
  5. presentation related directly to performance of the grant
  6. the information must be readily obtainable
• Any activity that is specifically authorized by law