Federal Lobbying Restrictions

Policy Letter 18-01

Publication Date: October 5, 2017

October 5, 2017

This Policy Letter reminds ORR grantees of the restrictions on the use of federal funding for lobbying activities.  Generally stated, ORR grantees may not use federal funding to influence official actions (such as legislation or regulation) at the federal, state, or local level.  

ORR grantees complete a Certification Regarding Lobbying as part of the grant application process.  This form requires grantees to certify that federal funds will not be used to influence or attempt to influence an officer or employee of any federal agency or Congressional member/staff in connection with actions related to the making of a grant (or awarding of a contract) or extending or renewing it. A grantee must complete and submit Standard Form-LLL, “Disclosure Form to Report Lobbying,” in accordance with its instructions if federal funds are used for such activity.  Grantees must also include this certification language in the award documents for subawards at all levels (including subcontracts, subgrants, and contracts under grants, loans, and cooperative agreements), and subrecipients must also certify and disclose lobbying activities.  A grantee that fails to file the required certification may be subject to a civil penalty.1  For more information, please see the Certification Regarding Lobbying.

In addition to the restrictions outlined in the Certification Regarding Lobbying, the Appropriations Acts prohibit ORR grantees from using federal funds for activities designed to influence the actions of Congress, any state government, or state or local legislature.2

If you have questions about the information in this Policy Letter, please contact Jennifer Schmalz at (202) 260-5186 or Jennifer.Schmalz@acf.hhs.gov.

E. Scott Lloyd


1. See 31 USCA 1352(c)(1).
2. See The Consolidated Appropriations Act, 2017. Pub. L. 115-31.

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