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OGC COMMUNICATIONS REGARDING
LOBBYING
July
18, 2005
(Updated 8/9/05)
TO: NAVREF Members
FROM: Barbara West
In a letter to NAVREF dated June 29, the
VA Office of General Counsel takes issue with NAVREF lobbying activities
and NPC involvement in such efforts. The letter and NAVREF’s response
are linked above.
It is our understanding that last Friday
ORD sent an email to VA personnel with a memo entitled “NAVREF
Initiative Criticizing the President’s Budget.” See http://navref.org/library/OGC_Lobbying_Correspondence.htm
While somewhat similar to the June 29 letter to NAVREF, this memo takes
particular issue with NAVREF’s efforts to improve on the FY 2006
budget request for VA research, how NAVREF attempts to engage VA
personnel in such efforts and how NPCs support them.
As stated in NAVREF’s response to OGC,
NAVREF sought and abided by both OGC and congressional staff guidance on
engaging VA personnel in lobbying efforts and the role of NPCs. It now
seems that such OGC guidance may have been incomplete. We are reviewing our
current practices and will make any necessary changes to ensure that we
do not put VA employees or the NPCs at risk. We have also offered to let
OGC review our lobbying materials and make recommendations as well as to
collaborate on updated practical guidance on acceptable lobbying
activities for individuals who wish to partake in their personal
capacities.
NAVREF lobbying alerts are disseminated
far and wide, but it was never our expectation that every recipient
would respond nor that everyone should. NAVREF has relied on VA
personnel’s own judgment to decide whether their participation is
appropriate and we are confident that they are cognizant of the
constraints on their ability to lobby in their official capacities.
NAVREF made every effort to assure our materials were appropriate and
would in no way be misleading to our member nonprofits or to any
individual.
In its formal response to OGC, NAVREF
chose not to address the points made about NAVREF dues and the statement
that dues detract from funds available for VA research or education.
However, for our membership we wish to note that last year NAVREF dues
collectively represented less than two tenths of one percent (.17% or
.0017) of NPC revenues and it is generally agreed that NPCs receive a
high return on the cost of their NAVREF membership.
The vast majority of NAVREF expenditures
relate to its educational programs, policy matters, and both developing
and promulgating best practices in NPC management. During its last
completed fiscal year, NAVREF spent only $16,000 in staff time and
allocated administrative support functions on lobbying activities. This
is less than 5% of its total budget and far less than the IRS allows
501(c)(3) organizations to spend. NAVREF’s non-dues revenues are
sufficient to cover its lobbying cost.
NAVREF had no advance warning of the OGC
determinations. Thank you for your patience and support for NAVREF as we
work through the implications.
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