University Lobbying Policy
Policy Number: 01.0002
Introduction
Universities routinely engage with elected representatives to convey and promote the values, priorities, and best interests of the institution, our students, faculty, and staff, and higher education broadly. Some forms of engagement and advocacy are defined by law as lobbying. Lobbying is an appropriate and permissible activity so long as the engagement in lobbying activity is in compliance with all applicable laws and regulations. These laws require the university to register and report its lobbying activities.
Purpose
The University Lobbying Policy is in place to ensure that all lobbying activity on behalf of The New School is in compliance with applicable City, State, and Federal laws, regulations, and requirements.
Scope
All New School employees (including faculty, staff, and university officers) and all members of the Board of Trustees are governed by this policy when acting in their capacity as representatives of the university and engaged in the activities defined within this policy. This policy is not intended to limit or discourage members of the university community from engaging with their elected representatives as private citizens or on behalf of groups or organizations to which they belong.
Definitions
Employee: Any staff member (full-time, part-time, temporary) or faculty member (full-time and part-time) of The New School.
Lobbying: Lobbying is an attempt to influence government decision-making. The exact definitions of lobbying vary from the federal, state, and local levels of government. See the following for additional information.
Trustee: Any member of The New School’s Board of Trustees.
Responsibilities
The Senior Director of Government and External Affairs and designated representatives in the Office of the President and the Office of the General Counsel have a responsibility to fairly consider, offer guidance, and support appropriate lobbying activity in the best interests of the university.
Any university Employee or Trustee who wishes to engage in lobbying activity on behalf of the university has a responsibility to consult with the Senior Director of Government and External Affairs before engaging in such activities and to cooperate with the guidance given.
Every university Employee or Trustee who engages in lobbying activity on behalf of the university must comply with applicable City, State, and Federal laws, regulations, and requirements.
Policy
As a matter of regular university business, the designated lobbyists for the university will be the President and Senior Director of Government and External Affairs.
From time to time, it may be deemed appropriate for additional university Employees or Trustees to engage in lobbying activity as representatives of the university. Such lobbying might be for the purpose of advancing a particular initiative, program, policy, or activity where the faculty or staff member has authority and expertise within the university.
Determinations about lobbying authorization and oversight of the related registration, training, and reporting will be guided by the Senior Director of Government and External Affairs in consultation with designated representatives in the Office of the President and Office of the General Counsel.
No Employee or Trustee may engage in lobbying activity on behalf of the university without authorization, registration, and training as described in this Policy.
Procedure
Any university Employee or Trustee who has an interest or role in activities that might be construed as lobbying will engage in discussion with the Senior Director of Government and External Affairs before engaging in such activities.
The Senior Director of Government and External Affairs will work with the university Employee or Trustee to understand their goals, strategy, and the nature of the activity they wish to engage in and will confer with colleagues in the Office of the President and Office of the General Counsel to determine an appropriate approach to both support the goals and ensure compliance with lobbying laws and guidelines. In some cases, the course of action will be for the university Employee or Trustee to be registered as a lobbyist on behalf of the university.
If a determination is made to register a university Employee or Trustee as a lobbyist on behalf of the university, the Senior Director of Government and External Affairs will advise and assist the university Employee with the processes for registration, train
Enforcement
City, State, and Federal lobbying laws and regulations outline penalties that relevant agencies can impose on individuals and institutions found to be out of compliance. See the following summaries of the lobbying laws for specific penalties.
Policy Administration
Responsible University Official: SVP for Administration and Chief of Staff
Responsible Office: Office of the President
Contact Information: Contact the Senior Director of Government and External Affairs at shahr@newschool.edu
Policy History
Effective Date: May 8, 2024
Last Reviewed Date: June 21 ,2024
Next Review Date: May 8, 2029
Revision History:
- 6/21/24: Policy scope expanded to include the Board of Trustees