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ACE Memo Gives Guidance for Inviting Federal Officials to Commencement

April 28, 2014

Graduation caps

 

​ACE has updated and released a memo to help colleges and universities better understand how to comply with federal ethics and reporting requirements when inviting government officials to speak at commencement, particularly if they are presented with an honorary degree.

The Honest Leadership and Open Government Act (HLOGA) passed in 2007, which amended parts of the Lobbying Disclosure Act of 1995, strengthened the public disclosure requirements concerning lobbying activity and funding and placed more restrictions on gifts for members of Congress and their staff.

There are no restrictions on who may be invited to speak at commencements or other campus events. However, HLOGA does necessitate the disclosure and reimbursement of travel and entertainment expenses associated with participation in commencement, depending on the type of institution, whether the institution is a registrant under the Lobbying Disclosure Act and whether the invitee is a member of Congress, congressional staff member or a senior executive branch official.

The ACE memo outlines these r​​​​​ules, which can be extremely complicated. Institutions with further questions should seek specific legal advice in advance.

 

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