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Academic Advocacy: Opportunities to Influence Health and Science Policy Under U.S. Lobbying Law

Fernandez Lynch, Holly JD, MBE; Bateman-House, Alison PhD, MPH; Rivera, Suzanne M. PhD, MSW

Author Information
doi: 10.1097/ACM.0000000000003037
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Abstract

Medical school faculty, as well as their colleagues in schools of nursing, public health, social work, and elsewhere around the university, often research issues of critical importance to health and science policy. They have amassed reams of data regarding the Affordable Care Act’s influence on health insurance coverage, cost of care, and health outcomes.1 They understand how exposure to environmental endocrine disruptors influences child development2 and how air pollution affects mortality.3 They have and are collecting substantial evidence regarding how responses to the opioid crisis might help or hurt individuals battling addiction.4,5 Their work on the sequelae of toxic stress and adverse childhood experiences is critically important in the context of government separation of immigrant families.6 Their research can inform which of several proposed approaches to drug pricing is most likely to work,7 uncover the underlying trends in infant8 and maternal mortality,9 and identify the effects of police violence on the mental health of minority communities.10 Academics also can help identify ethical concerns and appropriate responses to emerging technologies, including CRISPR11 and artificial intelligence in health care settings,12 as well as long-standing issues such as patient access to investigational drugs,13 definitions of death,14 and physician aid-in-dying.15 The list goes on. The evidence and expert analyses generated by academic researchers on these and similar questions should play a critical role in developing and informing health and science policy. But to what extent are academics legally permitted to engage directly with government policymakers?

Academics who wish to advocate for policy changes supported by their research outside the typical venues of academic journals, op-eds, and blog posts may consider reaching out to those in a position to effectuate policy change, including federal and state legislators, the president, governors, mayors, executive agencies and committees, the courts, and others. In many cases, however, academics may not be aware that these activities could have legal consequences, both for them individually and for their institutions. At the other extreme, they may be intimidated by ambiguous or restrictive institutional policies. For example, in our experience seeking (unsuccessfully) to discourage Congress from passing a federal Right to Try statute, we organized several open letters directed to relevant congressional leaders and invited experts in bioethics, medicine, and law to sign on.16 However, several academic colleagues privately expressed concern to us about whether and how they could permissibly participate. In addition, academics may be dissuaded from engaging in activities that could be characterized as lobbying because of the negative perception of lobbying as entailing backroom deals and currying personal favor. Some also may be concerned about the potential for such activities to affect their reputation for conducting unbiased, apolitical, independent scholarship. Although there is robust debate about whether academics should engage in advocacy at all, or to what extent and how they should do so,17–23 their decisions about whether to engage in advocacy should be based at the very least on a clear understanding of the relevant legal parameters.

It is our view that if academics stay on the sideline, health and science policy will suffer. As government officials consider pressing issues, such as eligibility for government benefits, climate change, gun violence, immigration, opioid abuse, drug pricing, drug approval standards, conscience-based refusals of medical care, and gene editing, among many others, academics in fields related to health and science policy have much to offer in terms of both empirical evidence and conceptual analysis.

In this article, we provide guidance on the types of academic advocacy activities that are legally permissible and those that are not. In particular, we discuss lobbying disclosure laws, restrictions on the activities of those employed by tax-exempt institutions, and the prohibition of certain uses of public funding (see Table 1). Researchers in nonuniversity settings, such as hospitals and think tanks, also may find this guidance useful, as will academics who engage in advocacy activities in concert with their professional associations. We close with recommendations for universities to support academics in engaging with government policymakers for the public good. Although there are important legal constraints to be aware of, the relevant laws preserve substantial opportunities for academics to directly promote and advocate for evidence-based health and science policy.

Table 1
Table 1:
Scope of U.S. Lobbying Laws and Their Applicability to Academic Advocacy

Lobbying Law

Because lobbying is a term of art with a particular legal meaning, we use it only in reference to specific legal requirements. When discussing the more general types of activities that can raise questions about lobbying restrictions but that may not fit the relevant legal definitions, we use the nonlegal, umbrella term academic advocacy. Academic advocacy can be divided (although not always cleanly) into 2 categories: (1) attempts to influence elections and (2) attempts to influence government policy. While academics are subject to restrictions on their election-related activities, in this article, we focus on those activities that are relevant to policymaking, as this is where academics’ research is likely to be most applicable.

Lobbying registration and disclosure

Federal law requires institutions that employ lobbyists, including institutions of higher education, to register with both houses of Congress and file quarterly disclosure statements describing their lobbying activities.24 The Lobbying Disclosure Act defines lobbyists as individuals who satisfy 3 criteria. First, they must be employed or retained by a client for compensation to engage in lobbying activities on behalf of that client. Second, the services they provide must include more than 1 “lobbying contact” with legislative or executive branch officials covered by the law. And third, their lobbying activities, including efforts to support lobbying contacts, must constitute 20% or more of their time in services for that client in a given quarter.

Although universities often ask faculty to submit lobbying reports to ensure institutional compliance, it is unlikely that an academic would satisfy the first and third criteria listed above.25 Because advocacy work is not typically included in academic standards for promotion or recognition, few academics could or would spend more than 20% of their time engaged in lobbying. Moreover, when academics engage with policymakers about their research, they rarely do so on behalf of their university; the university is not their client, and lobbying is not why they have been employed.25 Thus, so long as academics do not purport to represent their university when communicating with relevant government officials, the activity typically will not trigger federal lobbying disclosure requirements for the university.

State and municipal disclosure laws typically also define lobbying to include only activities on behalf of another entity for compensation, although they can be substantially more restrictive in terms of what counts as a lobbying contact, who must register, and the content of required reporting.26 Importantly, disclosure laws at both the federal and local levels impose no restrictions on lobbying; instead, they are intended exclusively as a transparency mechanism.

Federal tax law

Beyond these lobbying disclosure requirements, U.S. tax laws limit the amount of lobbying that charitable institutions granted tax-exempt status—including most universities and many professional associations—may conduct.25,27 Unlike federal lobbying disclosure laws, lobbying under the U.S. tax code is defined to include only attempts to influence legislation,28,29 either directly or by encouraging others to take action, and therefore does not cover many activities related to the executive branch, such as agency rulemaking. It is important to note that many states rely on federal determinations of tax-exempt status to grant exemptions from certain state tax obligations. Thus, if advocacy activities result in a loss of tax-exempt status at the federal level, there will likely be state-level consequences as well.

Because tax-exempt status applies to institutions, only institutional activities can jeopardize it.25 This raises important questions about when the actions of individuals can be attributed to their institution; these questions are particularly challenging for academics given their tremendous independence to determine the nature of, approach to, and conclusions from their research without interference or control from their university. Accordingly, it is tempting to suggest that an academic’s advocacy activities related to their research should not be attributable to their university for tax law purposes unless the subject and content of the advocacy have been explicitly endorsed by the university or the academic has been officially designated to speak on the university’s behalf, both of which would be relatively unusual circumstances.

Although we find this approach (i.e., a default rule of nonattribution) to be the most compelling, as a legal matter, the question most relevant to assessing attribution is whether the tax-exempt institution’s assets have been used to support the individual’s lobbying activity or preparation for the activity. This covers everything from compensated time to the use of institutional resources, such as reimbursement of expenses or use of letterhead, email accounts, administrative support, and the like. Although the Internal Revenue Service (IRS) sometimes considers the absence of institutional control over the activity when making determinations of attribution,30 there is an insufficient body of prior IRS guidance relevant to this specific question to reliably conclude that academic advocacy activities could avoid institutional attribution on that basis. Thus, when academics use institutional resources to advance their work aiming to influence legislation, it is safest to assume that the IRS will attribute those activities to their institution.

Importantly, employees and nonemployee affiliates of tax-exempt institutions, whether academic or otherwise, do not forfeit the right to engage in advocacy in their personal capacities. But when they engage in activities that would be deemed lobbying if the activities were attributed to their institutions (and when they are not seeking such attribution), they should carry out those activities on their “own” time, avoid using institutional resources, and include specific disclaimers that they are engaging only in their individual capacity.31 It is important to note that individuals may nonetheless provide their professional institutional affiliations solely for identification purposes without potentially problematic attribution. With these safeguards, academics’ advocacy activities will not constitute lobbying on the part of the tax-exempt institutions with which they may be affiliated.

In some instances, however, the use of university resources beyond simply stating a professional title will be important to the success of academic advocacy. Moreover, firewalls between personal and professional activities can sometimes be difficult to establish. Use of letterhead or an institutional email address, for example, can help academics get their foot in the door with legislators and serve as a signal of credibility. Without university funding, academics may lack alternative mechanisms to support their advocacy activities. They also may wish to incorporate advocacy as an important part of their academic professional contribution, rather than as a purely personal endeavor. Tax law offers 2 types of flexibility relevant to these circumstances.

First, when academics’ efforts to influence legislation may be attributed to their university, the university must report those efforts to the IRS as lobbying, but the activities themselves are not barred under federal tax law. Instead, tax-exempt institutions are permitted to engage in some lobbying, just not too much. When it comes to specifying the limit under which lobbying activities must remain to maintain an institution’s tax-exempt status, the standard test is whether an institution’s lobbying activities constitute a “substantial part” of its overall activities based on a number of subjective factors, including time commitment, expenditures, visibility, frequency, and content.32 Institutions may instead elect to use an alternative test based exclusively on their expenditures in support of lobbying activities, which are capped based on the institution’s total annual budget and cannot exceed $1 million in a given year.31 This relatively low cap can provide an important safe harbor for some professional associations given that their total operating budgets are relatively small, but it means that most universities are better off using the “substantial part” test, despite its lack of a clear threshold or definitions. Although lobbying by academics about their research would almost certainly not cause the university to exceed the substantial part limitation when taken in isolation, those activities must be considered against the backdrop of the other lobbying activities that the university engages in, typically through its office of government affairs. Thus, universities must determine how to balance the lobbying priorities of individual academics and those of the institution.

The second type of flexibility for tax-exempt institutions stems from the fact that tax laws establish a number of exceptions to what would otherwise count as lobbying.31,32 For example, nonpartisan analysis, study, or research that provides a full and fair exposition of the facts sufficient to allow the formation of an independent opinion on an issue (such as most peer-reviewed articles, white papers, and reports) may be provided by tax-exempt institutions directly to government bodies, officials, or employees (as well as to members of the general public), even if such work takes a position on specific legislation (i.e., already introduced) or a specific legislative proposal (i.e., not yet introduced). However, to take advantage of this exception, tax-exempt institutions may not directly encourage action by members of the general public with respect to legislation, such as providing contact information for a legislator. This activity also may not be directed only toward persons interested in one side of an issue, such as legislators of a single political party; instead, it must be broadly disseminated. Academics sharing a rigorous and comprehensive empirical or conceptual analysis of a given legislative proposal with all members of a relevant congressional committee or with both majority and minority party leaders are good examples of activities that likely would fall under this exception.

Another type of permissible activity applies to technical advice or assistance provided to a government body in response to a written request on behalf of that body. This exception does not apply to requests made by individual legislators or their staff members, however. Responses by academics to this type of individual solicitation regarding specific legislative proposals may count as lobbying by their tax-exempt universities, depending on the resources used to fill the request. Moreover, if an academic independently reached out to an individual legislator to express their unsolicited perspective on a specific legislative proposal, that action may be considered lobbying, unless the academic reaches out to a range of individual legislators in a way that could satisfy the nonpartisan analysis exemption described above. However, if the communication, whether solicited or unsolicited, has to do with broad social and economic issues rather than specific legislation, it will not be deemed an attempt to influence legislation and therefore will not be considered lobbying under the IRS definitions. Ultimately, academics have the widest latitude to engage legislators on the subject matter of their research when that engagement is not aimed at the merits of specific legislative proposals. Nonetheless, certain exceptions do allow for advocacy regarding specific legislation.

When a relevant exception like those described above applies, academic advocacy can permissibly be supported by university resources without triggering federal tax law consequences for the institution. Other types of activities require more caution and coordination, however.

Restrictions from funders

The least flexible limitations on academic advocacy come from prohibitions against using government (and sometimes other) funding for lobbying activities.25 As the U.S. Department of Health and Human Services explains, “[i]n general, recipients of federal funds are not allowed to use said federal funding to lobby federal, state, or local officials or their staff to receive additional funding or influence legislation.”33 Critically, this is not simply a matter of reporting or limiting activities but rather an outright bar. There are, however, exceptions to the definition of lobbying that substantially overlap with those definitions used for the purposes of federal tax law.34

Because academics and their institutions typically receive funding from many sources, funder restrictions on lobbying activities often can be overcome by using other available monies for such work.25 However, this approach may be more challenging for academics employed by public universities due to laws and policies restricting the use of public funds for lobbying and/or the lobbying activities of public employees.35 Clear guidance from public universities on these issues is essential and ideally should be no more restrictive than the law requires. Nonetheless, even when academics at such institutions are fully funded by public monies, these laws would not restrict advocacy activities performed in their purely personal capacities (i.e., without using university resources). As private institutions also receive state and local funds, the restrictions associated with those funds will be an important consideration for their affiliates as well.

Advocacy Through Professional Associations

So far, we have focused on academics advocating in their capacity as university affiliates, but they also may advocate in the context of their professional associations. For example, each year the American Medical Association (AMA) hosts a National Advocacy Conference in Washington, DC, replete with an overview of the AMA’s priority issues from association leadership and advocacy staff, updates from federal agencies and elected officials, insight from political analysts, and training on “key messages you should be delivering while visiting your members of Congress.”36 The AMA also hosts a Medical Student Advocacy and Region Conference to educate students on “how to be a successful advocate,” including the opportunity to meet with their elected representatives.37 Associations also may encourage their members to advocate for certain policy positions. For example, the American Public Health Association has a range of position statements on its website about which it specifically encourages members to contact policymakers and, in some cases, offers draft text.38 In addition, professional associations may invite their members to participate in various taskforces or working groups that are charged with examining policy issues, sometimes based on members’ own research, making recommendations regarding the association’s official position, and engaging in related advocacy activities.

These activities range from broad encouragement of members to act as individual advocates and training on how to be most effective in a political setting to advancing specific positions and shaping those positions through leadership roles. Simple encouragement and training in advocacy raise no legal concerns as they do not constitute lobbying under any definition. The same is true for internal association work to determine what positions the association should take on various issues. To the extent that members engage in outward advocacy to advance their association’s positions, if they are also affiliated with a university, then the issues described in the preceding section become relevant. Association-based advocacy by academics using university resources can affect a university’s tax-exempt status unless that advocacy falls into a relevant exception. In addition, the same funding restrictions apply regardless of whether academics are engaging in lobbying alone or in concert with a professional association.

Academics engaged in association-based advocacy should consider whether they must register as lobbyists under lobbying disclosure laws. However, they often will not meet the relevant criteria, including being “retained” to lobby on behalf of the association as a “client” for compensation, in contrast to the professional lobbyists that some associations keep on staff. Unlike the issues that arise when academics lobby in ways that may conflict or interfere with the positions of their university or cause their institution to exceed acceptable lobbying levels, when association members engage in lobbying in accordance with the directives issued by their association, those activities presumably align with the association’s planned lobbying strategy, within the confines of their tax-exempt status.

Ultimately, our concern in this article is not whether professional associations are compliant with lobbying laws but instead what restrictions academics should be aware of if they engage in lobbying via these associations. The restrictions are typically the same as if academics were engaging in their own advocacy—consider lobbying disclosure requirements, restrictions on the use of university resources relevant to tax-exempt status, and restrictions on the use of certain funding.

Translating Lobbying Law Into Institutional Policy to Support Academic Advocacy

Despite some legal constraints, academics have substantial leeway to engage in advocacy related to their research (see Table 2). When acting in their personal capacity without the use of outside resources, academics may freely engage with policymakers in any branch of government to provide their expertise and advocate for desired outcomes. Importantly, even when advocating in their personal capacity, academics are permitted to provide their university or organizational titles and affiliations for the purpose of identification, but they should be clear that they are speaking for themselves and not on behalf of their institutions. Particularly when academics are acting as private citizens, their lobbying activities are also entitled to constitutional protections under the First Amendment’s guarantees of free speech and the right to petition for redress of grievances.39

Table 2
Table 2:
Selected Examples of Academic Advocacy and Legal Analysisa

These constitutional protections are somewhat more constrained when the government imposes restrictions on lobbying as a condition of receiving certain benefits, such as tax-exempt status or public funding (and constitutional protections are not applicable to the restrictions imposed by private institutions). Nonetheless, when acting in their professional capacity, based on the use of university or organizational resources, academics are free—as a legal matter—to engage in certain advocacy activities directed to the executive and judicial branches, such as making public comments on rulemaking actions or participating in amicus briefs. They also may advocate to influence legislation, within certain limits and exceptions that are particularly relevant to academic work, and may engage in communications regarding broad social, economic, and other problems apart from specific legislative proposals. In all cases, academics must take care not to use restricted funds for lobbying.

Many university policies fail to appropriately highlight these permissible advocacy activities, instead focusing primarily on what academics may not do. Although compliance with relevant legal restrictions is a priority and it is appropriate for universities to seek internal reports from academics and other affiliates regarding their policy-related contacts with government stakeholders to ensure compliance and inform university strategies for engaging policymakers, universities should affirmatively support academic advocacy whenever possible. At a minimum, universities should create user-friendly, clear, comprehensive, and accessible institutional policies that equally address opportunities for advocacy and the potential constraints applicable to such activities. These policies should be only as restrictive as necessary to ensure legal compliance. As an additional step, universities could provide training and resources to facilitate effective academic engagement with policymakers. Finally, they could consider mechanisms to address barriers to academic advocacy related to existing standards for promotion and recognition that do not include such activities.17

Far from conflicting with the university’s mission to promote free inquiry and the pursuit of truth, academic advocacy is within the scope of the university’s responsibility to the public. Just as university “tech transfer” offices are expected (and, in the context of federal research funding, legally required) to move new ideas quickly into the marketplace where they can advance the public good,40 efforts to translate academic research into rigorous health and science policy should be encouraged. This is especially true for schools of medicine, nursing, public health, social work, and the like, given their commitment to promoting individual and population health and well-being. Academics must ensure that their work adheres to relevant discipline-specific standards of excellence and is not biased, but these expectations apply regardless of whether the final step in the research cycle is academic advocacy.

Importantly, both academics and their institutions should recognize that evidence-based advocacy based on academics’ research may be most successful when combined with university lobbying efforts. This practice can help avoid both confusion among policymakers about relevant priorities and interinstitutional competition for limited attention and resources. Academics may therefore wish to start their advocacy efforts at their home institutions, encouraging university leadership to lobby for certain positions when appropriate. However, time constraints in the face of rapid policy developments can render such coordination difficult.

Of course, the positions of individual academics may not necessarily align with those of their institution. In these circumstances, institutional policy should prioritize academic freedom so long as it can be accomplished in compliance with the legal requirements described above. Professional associations and other organizations engaging academics in advocacy activities also should generate their own clear and facilitative policies, as many already do.41

Conclusions

There has always been a need for evidence-based health and science policy, but in the current climate of “alternative facts” and political discord, it is more important than ever to make sure that policymakers have access to rigorous data about the likely impact of potential approaches to addressing pressing issues and that health and science policy interventions are rigorously evaluated to determine whether they are having their intended effect without unintended consequences. Academic researchers, particularly in the health professions, have a critical role to play in this environment. They can help advance evidence-based health and science policy, and lobbying laws afford numerous avenues for them to do so. It is our hope that academics make use of this freedom in service of advancing the public good.

Acknowledgments:

The authors wish to thank Eric Gorovitz, Joshua Greenberg, Bill Andresen, Steven Joffe, Kayte Spector-Bagdady, and Heather Pierce for helpful comments and discussions on these topics.

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