Interaction with Government Officials

Personal Capacity vs. NYU Representative

Obligation to Identify Personal Capacity and Refrain from Using NYU Resources

NYU does not discourage members of the University Community from engaging in Political Campaign Activity or Lobbying Activity on their own time in a personal capacity, or on behalf of groups or organizations to which they belong.

However, when activities are undertaken in a personal capacity, it is the responsibility of the University Community member involved to state expressly that the activity is conducted in a personal capacity and not in his or her capacity as a representative of NYU.

Subject to limited exceptions for permissible certain student activities, NYU resources of any kind (e.g., NYU letterhead, email, secretarial support, printers, office supplies, meeting rooms) may never be used in connection with any Political Campaign Activity; and NYU resources may be used in connection with Lobbying Activity undertaken in a personal capacity only when approved by NYU Government Affairs or the NYU Langone Medical Center Office of Government Affairs, as appropriate (collectively, “OGA”).

Activities Undertaken as NYU Representative

Prohibited Activity: Political Campaign Activities

In their capacity as representatives of NYU, members of the University Community are strictly prohibited from:

• Endorsing or opposing candidates for public office (e.g., presidential, congressional, state, city);
• Contributing institutional funds to political campaigns, parties, or PACs;
• Using institutional resources to host or conduct a partisan political event;
• Conducting or hosting political fundraising; and
• Publishing materials that support a particular candidacy or party.

There are limited exceptions to these rules for certain activities conducted as part of NYU’s educational mission (e.g., student editorials on political matters appearing in student newspapers, or events hosted by student groups). Any questions concerning the scope of the prohibited activity in this policy should be referred to OGA. Contact individuals are provided in the section of this policy entitled “Procedures for Implementation.”

Activity Requiring Advance Approval: Contacts with Government Officials

Members of the University Community must contact the OGA prior to any interactions with Government Officials if they:

• Would like to invite a Government Official or a candidate, or are approached by a Government Official or candidate about visiting campus;
• Would like to make a gift to a Government Official, including the purchase of a meal;
• Are contacted by a Government Official requesting the use of space on campus;
• Are seeking to participate at a public hearing or similar event in which Government Officials are soliciting public comment on a policy matter;
  
• Are considering directly contacting a Government Official with respect to legislation or executive actions or decisions on government policies, programs or regulations; or with respect to government funding, including contracts and grants (note faculty exceptions below);
• Are considering indirectly contacting a Government Official, through avenues such as the media or other “grassroots lobbying”, in attempt to influence actions or decisions regarding legislation or executive actions or decisions on government policies, programs or regulations; or with respect to government funding, including contracts and grants (note faculty exceptions below).

The OGA will review the proposed interaction, which may be reportable on city, state, or federal levels, and will provide guidance on the interaction.

Permitted Activity: Policy Expertise/Testimony and Contacts With Grant-Making Agencies

Faculty and non-faculty researchers applying for research grants as well as NYU staff in the Office of Sponsored Progrmas who are assistng them are encouraged to:

• Accept invitations from the government to provide policy expertise and testimony in faculty member's or non-faculty researcher's field of expertise to Government Officials and staff (but note that OGA must be contacted in advance if the invitation was initiated by an individual or party other than the government); and
• Contact program and grant/program officers to discuss prospective or ongoing governmental funding projects that have been, or will be, awarded through a competitive review process. (Note that faculty and non-faculty researchers as well as NYU staff in the Office of Sponosored Programs who are assisting should review the applicable grant request for proposal for any restrictions it may contain on who can be contacted.)

Faculty and non-faculty researchers as well as NYU staff in the Office of Sponsored Programs who are assisting them do not need to contact the OGA prior to engaging in such interactions.

Disclosure of Status as NY State Official

If you meet the definition of a NY State Official, please contact OGA.  NYU has reporting obligations relating to NY State Officials that are employed by NYU and will need to review whether your status is captured by its reporting requirements.

Procedures for Implementation

Members of the University Community should seek guidance on how these rules apply to a particular situation by contacting NYU Government Affairs or the NYU Langone Medical Center Office of Government Affairs, as appropriate:

• For all schools, except the School of Medicine and NYU Hospital, individuals should contact the Assistant Vice President for Government Affairs (202-654-8329).
• For the School of Medicine and NYU Hospital, individuals should contact the Vice President, Government Affairs (212-404-4077).

The OGA will seek advice from the Office of General Counsel where questions of law arise.

Related Policies

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