OMB has issued interim guidance covering communications with registered lobbyists about Recovery Act funds.
A memo, "Ensuring Responsible Spending of Recovery Act Funds, requires specific protocols for oral communications between agency officials and federally registered lobbyists.
To help employees comply with the memo, departments and agencies, with the assistance of OMB, are required to distribute guidance to their employees.
MemoM-09-16 includes sample guidance that agencies may use as a template for communicating requirements to employees.
According to the guidance, for example, if a city official contacts an agency representative about a specific project such as light rail project, the agency official may not meet with that city official if a federally registered lobbyist is to participate in the discussion.
OMB said the internal agency guidance should include internal agency points of contact and should be distributed to agency staff as soon as possible, with a copy to OMB’s general counsel.
The sample interim guidance outlines the actions employees are required to take whenever they receive or participate in oral communications with any outside persons or entities regarding Recovery Act funds.
