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Contractor Lobbying Statute - 1994

Jan. 17, 1995

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Contractor Lobbying Statute - 1994

Audit Report No. 223
January 17, 1995


As required by 31 U.S.C. 1352, we evaluated Commission compliance with the lobbying disclosure requirements found there (see Background). Our review included discussions with contracting staff in the Office of Administrative and Personnel Management (OAPM), and analysis of eleven fiscal year 1994 contracts subject to the requirements.

The audit was conducted during December 1994, in accordance with generally accepted government auditing standards.


In 31 U.S.C. 1352 (Public Law 101-121), Congress imposed restrictions on lobbying by those receiving Federal funds. Section 1352 generally prohibits recipients of Federal contracts, grants, and loans from using appropriated funds to lobby the executive or legislative branches of the Federal government in connection with a specific contract, grant, or loan. The statute requires recipients of Federal funds to disclose any lobbying, and to certify that appropriated funds were not used to lobby. Agencies are required to submit to the Congress a semi-annual compilation of disclosure reports they receive.

Contracts, grants, loans, and cooperative agreements exceeding $100,000 are covered by the Act, which became effective on December 23, 1989. Civil penalties for non-compliance range from $10,000 to $100,000. Inspectors General are required to evaluate their agencies' compliance with the requirements.

Audit Results

We found that OAPM incorporated the appropriate Federal Acquisition Regulation clause in the eleven contracts we reviewed. OAPM also submitted the required semi-annual reports on lobbying activities to the Congress during fiscal year 1994. OAPM concurs with our findings. 

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