Moira Kavanagh-Pratt
General Counsel · Society of Rural Hospital Administrators
Lobbying Disclosure Compliance
What counts as a reportable lobbying contact for a 501(c)(6), and how the proposed grassroots-disclosure rule would change the answer.
On-demand · Virtual
- 1.5 CAE hrs
Members $0 · Non-members $125
Moira Kavanagh-Pratt, general counsel at the Society of Rural Hospital Administrators, teaches the course NANA built to answer the question its own government relations team gets most: what actually counts as lobbying. The stakes are rising. A proposed rule under review at the Lobbying Disclosure Modernization docket would count grassroots "call to action" emails as reportable lobbying contacts, a change that would pull most membership associations' routine member communications into disclosure territory for the first time.
Modules
Current disclosure rules
The Lobbying Disclosure Act's definitions of lobbying contact and lobbying activities, applied to the communications an association staffer sends in a typical week: emails to committee staff, coalition letters, and member alerts.
The proposed grassroots standard
A close read of the proposed rule's "call to action" language, which would treat a member email urging a legislative position as a lobbying contact if it names a bill or a vote. Moira Kavanagh-Pratt walks through the rule's text against three sample emails.
Recordkeeping that holds up
Building a lobbying-activity log now, before the rule takes effect, so the association isn't reconstructing records under a compliance deadline. Covers time tracking, expense allocation, and what triggers Form LD-2 filing.
Briefing the board
How to explain lobbying-disclosure exposure to a board of directors without alarming them, including a one-page summary format the course provides as a template.
Who it's for
General counsel, government relations staff, and executive directors at 501(c)(6) associations that run any advocacy program, from occasional coalition letters to a standing government-relations team. Pairs with the Lobbying Disclosure Compliance Brief.
What you’ll learn
Classify a communication as a lobbying contact under current federal rules
Distinguish direct lobbying from grassroots lobbying for recordkeeping purposes
Apply the proposed rule's "call to action" standard to a sample member email
Set up a quarterly lobbying-activity log that would survive an audit
Brief a board on the association's current lobbying-disclosure exposure
Instructor
Register for Lobbying Disclosure Compliance
What counts as a reportable lobbying contact for a 501(c)(6), and how the proposed grassroots-disclosure rule would change the answer.