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Government Interaction Recommendations

The following is not intended as legal advice and does not represent every potential interaction and scenario but is intended to provide guidance for interactions with elected officials and their staff.

Example of Interaction Should I contact the Northwestern Government Relations Office? Is University Lobbying Reporting Required?
In my personal time, I sign a petition or letter in support of a cause or write or call a Congressional office asking them to vote for or against legislation. Please note – you are not to use any University resources (computer, email, etc.) if you choose to engage in personal advocacy. No No
As a private citizen, I have voluntarily given a financial contributions to a political candidate or organization. No No
I send a one-page information sheet detailing my research to a government official Yes No
I am participating in a lobbying or advocacy day with my scientific society that includes meeting with government officials. Yes Yes
I call a program officer at a federal agency to discuss the status of a grant or ask questions regarding an award. No No
I want to invite an elected official to campus. Yes Depends – all such inquiries should be run by NUGR
When communicating with a federal office on an issue approved by the university I use university resources, such as letterhead. Yes Yes
I provide a legislative office a non-partisan study or research analysis that does not advocate for a specific government law or action. Yes No
I meet with a government official and ask for additional funding to the federal budget for a program or agency. Yes Yes
A government agency releases a request for information (RFI) and I respond on behalf of Northwestern University. Yes Yes
I have been invited to testify before a legislative or administrative panel. Yes Depends – if the testimony will represent a university position, it is lobbying. If speaking as an individual expert, it is not lobbying.

Illinois law defines lobbying as a communication with a covered governmental official to influence any government action. The law also defines lobbying as a solicitation for others to communicate with government officials.

Covered government officials include Statewide-Elected officers and their executive staff, members of the Illinois General Assembly, members of Boards, Commissions, Authoritys, or Task-Forces, Mayors, Aldermen, Commissioners, and Trustees. This includes entities like the Metropolitan Water Reclamation District, the Chicago Park District, Chicago Public Schools, and the Chicago Transit Authority, which due to their status as organizations founded under State charter are governed by State lobbying rules.

Individuals speaking in their own capacity or providing professional expertise and not using University resources to communicate or solicit others to communicate with covered officials are not required to register as lobbyists. However, individuals must make clear that the views expressed are their own and not those of the University. Individuals are highly encouraged to contact Government Relations for guidance on whether an activity amounts to lobbying under Illinois law.

Illinois’s lobbying law is unique, as it governs groups that receive funding from the University.  Departments or groups who expend University resources, including funds, equipment, or University email addresses for lobbying must report this activity to Government Relations.

Example of Interaction Should I contact the Northwestern Government Relations Office? Is University Lobbying Reporting Required?
A government official solicits my professional opinion about legislation. Yes No
I want to apply for a state, county, or municipal grant (outside of Chicago). No No
I want to ask about the status of a state, county, or municipal grant (outside of Chicago). No No
I want the state to extend my current grant that is due to expire soon. Yes Yes
I want to approach a legislator to file a bill about my own personal policy idea. Yes – you may contact NUGR to discuss personal ideas and to ensure lobbying reporting is not required No
A government official asks me to attend a legislative hearing/press conference to support/oppose legislation. Yes Depends – If you fail to clarify your views as your own rather than those of the university, this could be lobbying.
An association asks me to add my signature to a letter of support/opposition for a policy. Yes Depends - If the association uses Northwestern branding or indicates or suggests that Northwestern supports/opposes the legislation, this is lobbying.
I want to join/represent Northwestern on a state, county, or municipal (outside of Chicago) task force, board, or commission. Yes Depends – If you seek university assistance to recommend your application, this is lobbying.
I would like a letter of support from the State for my grant application. Yes Yes
My department/university-funded organization plans to write a letter of support/opposition on state legislation or policy. Yes Yes
My department/university-funded organization wants to ask people to contact a government official (outside of Chicago) to support/oppose a policy or action. Yes Yes

The City of Chicago has recently required non-profit organizations to register as lobbying entities if they have total expenses and net assets greater than $5M, and if an individual lobbying on behalf of that entity spends more than 20 hours per quarter lobbying or more than $1,250 on lobbying expenses (percentage of salary, travel, expenses).

Importantly, lobbying rules in the City of Chicago apply only to City Departments, City Council, and the Mayor's Office.

Individuals engaging in the democratic process are not subject to registration if they are using their own voice, and speaking only for themselves, or serving as a volunteer. Additionally, the categories below DO NOT CONSTITUTE LOBBYING IN THE CITY OF CHICAGO.

  • Participation on a task force, commission, or advisory committee working on an issue of interest to the City;
  • Funding a City position or program at the request of or in coordination with a City agency;
  • Undertaking non-partisan analysis study or research, providing technical advice or assistance, or discussing broad social, economic, or similar problems and related solutions; or,
  • Making a "self-defense" or a "grassroots lobbying" communication.

Many faculty and staff interact with Chicago departments and may advise non-profit organizations engaged in advocacy activities. It is important to contact the Office of Government Relations if you have questions about your work with the City to determine if your interactions trigger a lobbying activity that must be reported. Persons found to be in violation of the Chicago lobbying rules are held individually responsible and are subject to a fine of $1,000 per day by the Chicago Board of Ethics.

Example of Interaction Should I contact Northwestern Government Relations Office? Is this a University lobbying contact?
I meet with a City of Chicago Department to pitch them about why my research lab should receive a City grant. Yes Yes
A representative from a City of Chicago Department reaches out to solicit advice or expertise on a particular topic. Yes No
A representative from a City of Chicago Department asks Professor Jones to serve on an advisory board and/or provide testimony before a City Council Committee. Yes No
Professor Jones and Staff Smith meet with a City of Chicago Department to discuss their work in a local Chicago community. Yes Depends – if faculty or staff are just meeting to discuss or share information about an ongoing partnership, it is not lobbying. If the faculty or staff ask for specific City support, e.g., funding to expand the project, this is considered lobbying.
Staff Smith meets with Chicago's Department of Planning to review new construction plans and discuss permits needed for construction. Yes Depends – inquiring about the status of a permit or requesting a meeting with Department Personnel does not constitute lobbying. If you plan to discuss a zoning matter, this could constitute lobbying.
Professor Jones partners with a local non-profit to provide pro-bono advice and consultation as they oppose City of Chicago efforts to open a manufacturing plant in Ward X. Yes Yes – this could trigger the lobbying requirement if Professor Jones spends more than 20 hours during the quarter working with the non-profit to specifically strategize and oppose City efforts, or spends more than $1,250 in lobbying expenses during the quarter to support the professor's work, even though the support is pro-bono