Contact with Federal and State Government Officials

Scope

This Policy applies to the following Indiana University Community Members (“IU Community Members”):
A. Any employee of the University, including administrators, faculty, staff, temporary, and student employees;
B. All students and student organizations;
C. All University units;
D. Any individual using Indiana University resources or facilities or receiving funds administered by Indiana University; and
E. Volunteers and other representatives when speaking or acting on behalf of Indiana University.

[Definition based on the Principles of Ethical Conduct]

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Policy Statement

All IU Community Members are expected at all times to distinguish between when they speak or act in their personal capacity (including when they speak or act on behalf of professional societies and other organizations) and when they speak or act on behalf of the University’s interests.

Any personal contact with federal or state government officials or governmental agencies should be done in the name of the individual or the professional society. Indiana University letterhead and electronic resources (email) must not be used. If using the individual’s University title as an identifier, special care must be taken to make it clear in the text of the communication that the contact is being made in the individual’s personal capacity and that the individual is not speaking on behalf of the University.

Communication with Federal and State Public Officials
Prior to contacting or communicating with any state or federal official or agency, a department or unit must coordinate with the Office of the Vice President for Government Relations, which is charged with the responsibility of providing leadership for Indiana University’s governmental relations activities. Coordination with the Office of the Vice President for Government Relations is essential to maintaining professional working relationships with public officials, keeping IU messages coherent and effective, and ensuring compliance with all state and federal laws.

Such contacts may include, but are not limited to: individual or group meetings; testimony before executive or legislative bodies; presentation of written materials or electronic transmissions; invitations to visit campuses; and responses to requests for information.

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Reason for Policy

Indiana University has established certain policies, guidelines, and procedures pertaining to contacts being made on behalf of the University with federal and state government officials and agencies. These policies, guidelines, and procedures are designed to ensure compliance with legal requirements; to enhance the effectiveness of governmental contacts; and to facilitate coordination and communication within the university.

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Procedures

Contacts with Federal Officials
Indiana University is listed as a lobbying registrant with the U.S. House of Representatives and the U.S. Senate. As a lobbying registrant, under federal law the university must report each quarter on its federal lobbying activities, such as contacts with certain federal elected and appointed officials.

In order to ensure compliance with federal law and regulations, any proposed outreach to covered federal officials, including all Members of Congress and all congressional staff, on behalf of a University interest, must be coordinated with the IU Office of Federal Relations before the contact is made. Because IU’s quarterly lobbying report must disclose any and all contacts with covered federal officials, including the reason for the contact, it is important to discuss the matter with the Office of Federal Relations before any outreach takes place.

Further, only IU personnel approved in accordance with this policy are authorized to lobby on behalf of or represent Indiana University’s interests with the above federal officials. The responsibility for authorizing such persons rests with the Vice President for Government Relations.

This policy is not intended to limit the personal rights of IU Community Members to contact federal officials for their personal beliefs and issues, nor is it directed toward those contacts made on behalf of their professional societies as long as that representation is not in the name of Indiana University.

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Sanctions

Violations of university policies, including the failure to avoid a prohibited activity or obtain required approvals, will be addressed in accordance with applicable University policies and procedures.

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History

This policy was established in 2016 to combine existing guidelines from the IU Office of Government Relations as well as ACA-36 Contacts with Federal and State Government Officials and Agencies for Academic Appointees. ACA-36 was retired in 2016 having been superseded by this policy.

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