An Important Note to those Associated with Voices for National Service
As we work to be convincing voices for national service and volunteering, we must be mindful of how critically important it is to keep all political and advocacy activities completely separate from federal grant activities. Furthermore, service has always had bipartisan support. That’s why we must be vigilant in maintaining our focus on educating and informing our representatives about our work and impact in a non-partisan and respectful manner, at all times.
If your organization receives federal funds, you are allowed to participate in Voices for National Service events and activities. But it is absolutely critical that organizations who receive federal funds keep any political and advocacy activities completely disassociated with their federal grant activities.
The Corporation for National and Community Service rules are clear on this issue, as are the general rules that apply to all grantees of the federal government (OMB Circular A-122 - http://www.whitehouse.gov/omb/circulars/a122/a122.html).
We must be scrupulous in conforming with these rules, and we hope you will review the letter below from Corporation Counsel Wilsie Minor that explains the restrictions on legislative lobbying and partisan politics, and responds to some frequently asked questions.
Again, thank you so much for your passion for national service. We look forward to working together.
This memorandum is for those overseeing, operating, and serving in, national and community service programs supported by the Corporation. It covers the rules concerning legislative lobbying and partisan politics.
You should keep in mind the following rule: Grantee staff and program participants may not (1) attempt to influence legislation or (2) participate in, or endorse, political events or activities, if they are doing so while charging time to a Corporation-supported program, accumulating service or training hours towards an education award, or otherwise performing activities supported by the Corporation.
Individuals may exercise their First Amendment rights, including participating in the political process, on their own initiative, on their own time, and using non-Corporation funds and resources. But in doing so, it is very important to avoid even a perception that national and community service staff or participants are engaging in political activities in those capacities. For example, if your organization engages in lobbying activities you must be careful to document that such activities are outside the scope of your Corporation-funded program. Separate accounting for costs is crucial on this particular point. As another example, wearing AmeriCorps gear while participating in a political event may result in an allegation that the AmeriCorps program is supporting political activities, even if that is not the case. If your organization signs a public petition advocating some legislative action, you should be sure it identifies itself by its organizational name rather than as an AmeriCorps program. It is paramount that AmeriCorps and all of our national and community service programs proceed with utmost care to avoid perceptions that Federal resources are being mis-directed to political activities.
I am attaching answers to frequently-asked questions on this topic. If you need additional guidance, please contact your program officer at the Corporation.
What if I provide a factual, technical presentation to a legislator who is visiting our program and at the end the legislator makes an unexpected announcement that he or she has decided to co-sponsor legislation to support national service?
May a local program supervisor visit elected officials in Washington, D.C.?
As a program director, I periodically travel to Washington, D.C. to educate our elected officials about our program's achievements. What happens if the Corporation determines that the costs of my visits are not reasonable and necessary expenses of the program?
An elected official who is running for re-election wants to have a campaign publicity event at our service site. Is this type of site visit permitted?
While I am in Washington, D.C. attending a program director's conference, am I prohibited from visiting my elected officials during a break in the conference?
I work for a national non-profit organization that receives a grant to operate an AmeriCorps program. My position is partially funded under the AmeriCorps grant and partially funded by non-federal sources. Can I lobby on issues related to AmeriCorps when I am not on AmeriCorps time?
I am the executive director of a State Commission. Our Cost Principles say nothing about legislative lobbying being an unallowable cost. What are the rules for States?
If a particular activity is not specifically disallowed under the applicable OMB Cost Principles or grant terms, does that mean it is allowed?
Doesn't the Domestic Volunteer Service Act give programs specific statutory authority to lobby concerning appropriations or authorization legislation?
May a Corporation-funded program sponsor or endorse an event, such as a debate between candidates, which itself is not partisan, but which likely will include advocacy for or against political parties, platforms, candidates, proposed legislation or elected officials?
Does that mean an organization receiving Corporation funds may not take part in the political process?
I am a Commissioner on a State Service Commission. My position is uncompensated or not paid by CNCS grant funds. May I lobby for federal support of national service, including CNCS, on my own time?
May staff whose salary is fully or partially paid from AmeriCorps or matching funds participate in advocacy or public policy efforts, including promotion of events?
May staff whose salary is not paid from AmeriCorps or matching funds, but whose work supports the AmeriCorps program on either a full or part time basis, participate in advocacy or public policy efforts?
How should a staff member record the time spent in attending an advocacy event or other related activity during the normal work day?
May an organization that receives AmeriCorps funds use any of its organizational resources, such as phone, email, organizational contact lists, list-serves or meeting space, to participate in such efforts? Are there restrictions that apply for resources belonging to organizations which only host AmeriCorps members?
May staff or AmeriCorps members identify themselves as AmeriCorps members or staff of an AmeriCorps-funded organization, by means of service gear, logos, letters, on line media (Facebook, Twitter, blogs), when participating in advocacy efforts or expressing an opinion about same? Is there specific disclaimer language that should be used?
How are efforts to educate and inform elected officials about the value of AmeriCorps programs different and distinct from political advocacy?
Do any of these restrictions apply to AmeriCorps alumni, and if so, under what circumstances?