Advocacy and Lobbying Procedure

I. Purpose & Relevant Policies

This procedure applies to all employees at The College of St. Scholastica. It is set forth to guide employees through the process for pursuing advocacy related to a grant, project, or program, ensuring all activities align with College policy, applicable regulations, and the Staff and Faculty Handbooks.

As stated in the Code of Conduct under “Lobbying” in both handbooks:

“The College encourages every employee to take an active interest in government processes. Any participation in a political process, however, is to be undertaken as an individual – not as a representative of the College. An employee undertaking any advocacy activities on behalf of the College must be authorized by the College President or the Vice President for College Advancement.”

For reference, see:

• Faculty Handbook – Code of Conduct: Lobbying

• Staff Handbook – Code of Conduct: Lobbying

Any lobbying efforts are explicitly unallowable for federal or state-funded College employees, as stated as an unallowable cost in the Federal Grant Allowability of Costs policy. Other non-federal or state-funded employees at the College may only engage in lobbying or advocacy on behalf of the institution through the process outlined below and with appropriate authorization.

II. Definitions

Advocacy: Efforts to share information and increase awareness of issues impacting the College or community.  Examples include providing factual, non-partisan information about a program or issue to educate the public or policymakers, or inviting a legislator to see a program in action 

• Individual Capacity: Employees may engage in advocacy as private citizens, using their own time and resources, provided they do not represent the College or imply institutional endorsement.

• Institutional Capacity: Advocacy conducted as part of one’s College role must be factual, nonpartisan, and authorized in advance through this procedure. For federally or state-funded employees, advocacy is allowable only when it directly relates to the approved objectives of the funded program and does not constitute lobbying.

Lobbying: Any attempt to influence legislation, appropriations, regulations, or official decisions by elected or appointed officials. Examples include asking a legislator to support or oppose specific legislation, requesting federal funds for a project, or organizing the lobbying efforts of others.

• Individual Capacity: Employees may participate in lobbying as private citizens on their own time and without using College resources, provided they do not identify themselves as representatives of the College.

• Institutional Capacity:

• Employees supported by federal or state grants may not engage in any lobbying activities, directly or indirectly, on College time or using College resources, including grant funds, even if the intent is to support their program or project.

• Other employees may support authorized institutional lobbying efforts (for example, preparing factual materials or coordinating approved communications) only through this formal process.

III. Procedure

No College resources, including paid work time, email, or institutional systems, may be used for advocacy or lobbying in an institutional capacity without prior authorization, as outlined in the steps below to ensure regulatory compliance and institutional alignment.

1.Concept Consultation with FGR

Before preparing any communication, event, or outreach that could be considered advocacy or lobbying:

• Contact the Assistant Director of Grant Compliance and Administration (ADGCA) in Foundation & Government Resources (FGR) at alee4@css.edu or via Zoom.

• Provide a brief description of what you’d like to do, including:

  • The purpose of the communication or engagement (e.g., sharing data, raising awareness, responding to an inquiry)

  • The intended audience (e.g., public, policymakers, media, partner agencies)

  • The anticipated outcome or goal

• FGR will review the concept and advise on allowable next steps.

  • If the request originates from a federally or state-funded employee, FGR will confirm that the activity does not constitute lobbying and falls within allowable advocacy parameters.

  • If the request is from a non-federally funded employee, FGR will determine whether it should proceed as advocacy or requires elevation for lobbying authorization.

Only after FGR confirms that the concept is allowable should you proceed to develop a draft.

2. Draft Development

Once FGR has determined that the activity is allowable:

• Draft your proposed communication (email, letter, talking points, post, etc.).

• Keep it factual, nonpartisan, and aligned with the purpose approved by FGR.

• FGR can assist with drafting or refining content to maintain compliance.

3. FGR Review and Escalation

FGR will review the draft and determine if it requires elevation to other stakeholders, such as:

• Alumni Engagement - if communication is being targeted to alums or specific alumni groups

• Director of Media Relations & Communications – for media or public-facing messaging

• VP for College Advancement – if communication involves elected officials

• Senior Vice President and Provost – for advocacy related to academic programs, curriculum, faculty, or student engagement and success, or matters needing legal review

• President’s Office – for high-profile or institutional advocacy matters, or matters needing legal review

 4. Final Approval and Coordination

After all necessary reviews are completed:

• FGR will facilitate final authorization.

• No communication may be sent or shared publicly until approval is obtained.

5. Dissemination and Recordkeeping

• Disseminate only the approved message.

• FGR will retain the final version and decision record in the Advocacy Request Log.