Guidelines for Communication with Federal and State Public Officials and Political Activity on Campuses

Communication with Federal and State Public Officials

Coordinating our government relations efforts is essential to maintaining professional working relationships with public officials, keeping CSCU messages coherent and effective, and ensuring compliance with all state and federal laws. To that end, communication with any state or federal elected officials or their staff must be coordinated with the CSCU Vice Chancellor for External Affairs, Adam Joseph at adam.joseph@ct.edu.

This two-way communication is essential to maximizing our outreach efforts. For example, a legislator may request a meeting about a program or initiative on campus to learn more about it. Without any coordination, the campus officials may not know that legislator is proposing legislation to defund or expand that program, and the CSCU Senior Director of Government Relations may not know the legislator visited the program when lobbying them on the bill.

Proactive coordination in these instances helps to better manage both the individual campus outreach and the wider system efforts. Additionally, this also helps ensure compliance with all state and federal lobbying disclosure laws.

Such contacts may include but are not limited to: individual or group meetings; testimony before executive or legislative bodies; presentation of written materials or electronic transmissions; invitations to visit campuses; and responses to requests for information.

Political Activity on Campus

As public institutions, CSCU Institutions and foundations receive tax exempt status under either section 115 or 501(c)(3) of the Internal Revenue Code. To maintain this status, the Institutions and affiliated foundations must not participate or intervene in any political campaign and must prevent its resources from being used in any way that may or may appear to support a political candidate.

CSCU Community Members are free to participate in political activities on the national, state, or local level such as running for political office, managing political campaigns, and assuming leadership roles in political organizations, provided that the participation does not prevent full discharge of their obligations to their Institution. However, in any such activities, it must be made clear that the individual is acting as a private citizen and is in no way representing CSCU.

Political events (fundraisers, rallies, candidate announcements, etc.) are permitted on the campus as long as they are sponsored or hosted by registered student organizations and all expenses related to the activity (including fees to cover space rental) are borne by the candidate, political organizations or student organizations. Institution facilities may be rented for political events in accordance with campus policy on facilities use. Such sponsored events may not be “subsidized” or otherwise supported by CSCU or an Institution.

It is important to note that these guidelines apply explicitly to the use of public resources in support of “political campaign activities”. They are not intended to limit discussion among scholars and others regarding political or campaign issues or candidates.

Permissible Activities

1. Voter Education
   
   CSCU Institutions are permitted to conduct voter education activities as long as they are carried out in a non-partisan manner. For example, conducting public forums, get-out-the- vote drives, and the publication of voter education guides that cover a wide range of issues are allowed as long as the activities are not conducted in a biased manner that favors or opposes a single candidate or issue.

2. Candidate Appearances
   
   
   1. Invitations and Events: Institution Sponsored
      
      
      1. Political candidates may be invited to speak at events, including classroom visits and These events are to be educational in nature and offered for that purpose in conjunction with the Institution’s public education mission.
      2. If one candidate is invited to speak at an event, the Institution must provide all legally-qualified candidates or their representatives an opportunity to appear either at the same event or at a comparable event within a reasonable time period. Evidence of invitations and responses must be kept on file. If an invited candidate fails to respond after multiple invitations to the event, such should be noted in the file along with the invitations [An exception may be made for an elected official who is simultaneously a candidate for office, so long as the remarks are limited to official business related to the duties of the elected office.]
      3. The Institution may not co-sponsor a campaign event with an Outside The term “Outside Entity” refers to a candidate, campaign or political organization, not-for profit, and any other outside group.
      4. The introduction of a candidate or the candidate’s representative at an Institution-sponsored event must be neutral and include a brief statement that the Institution or CSCU does not endorse or oppose any candidate or organization in connection with this or any other political campaign or In cases where the individual candidates will appear in a conversational dialogue about issues, each candidate will have the same format of question or topic presentation; same topics in both substance and number; same amount of time for discussion; same moderator for the event; and same physical setting or staging. Appropriate steps must be taken to avoid the appearance of the Institution’s endorsement of or opposition to any candidate.
      5. All expenses related to an event conducted pursuant to this section shall be borne by the sponsoring Institution.
      6. Political fundraising at Institution-sponsored events is strictly prohibited.
         
         
   2. Invitations and Events: Student Organization Sponsored
      
      
      1. “Student organization” refers to any CSCU student group that is recognized in accordance with any Institution specific policies or practices.
      2. A student organization may conduct a single-candidate or single-party event pursuant to this section; however, if any funding used to pay for the event originated from the CSCU or an Institution, the student organization must invite all legally-qualified candidates to participate in the event.
      3. A student organization may hold a meeting or event that is closed to the general public and limited to student organization members in which case the student organization sponsored event will be subject to the normal fees assessed to a student organization for facility rental and usage fees, if applicable.
      4. If the event is open to the general public, the student organization’s advisor or designee must be present at the event for the duration of the event, and the student organization must include a brief statement when introducing the candidate or the candidate’s representative that the Institution does not endorse or oppose any candidate or organization in connection with this or any other political campaign or The student organization sponsored event will be subject to the normal fees assessed to a student organization for facility rental and usage fees for public gatherings, if applicable.
      5. Appropriate steps must be taken by student organizations to avoid the appearance of the University’s endorsement of or opposition to any candidate.
         
         
   3. Invitations and Events: Sponsored by Outside Entities
      
      
      1. Outside Entities may rent space on Institution Property to host political events, which may be either limited audience or general public events.
      2. An event sponsored by an Outside Entity shall be subject to normal charges assessed to Outside Entities renting space with no discounts, preferential scheduling or other gratuities, or free or reduced rates for related services (such as security, sound systems, parking, broadcasting or web services, etc.).
      3. No exceptions to facility rental practices shall be made for a candidate or political party. Candidates or parties may rent only those Institution facilities that are regularly available for rent.
      4. If facilities are rented to one candidate or political party, the same or similar facilities must be made available for rent to all others on equal terms and conditions, subject to any limitations on availability of particular facilities, due to the scheduling of other events, at the time a candidate or party makes a request.
      5. Outside Entities that conduct events pursuant to this section shall take appropriate steps to avoid the appearance of the Institution’s endorsement of or opposition to any candidate.

Prohibited Activities

1. Endorsements
   Institutions must not expressly or impliedly endorse any candidate for public office. In this regard, it is extremely important that Community Members refrain from using State provided email or other communication tools for personal discussion of or advocacy on behalf of a candidate.
2. Political fundraising
   Political fundraising utilizing Institution Property or through the use of the Institution’s technology resources, including but not limited to Institution email accounts, is prohibited. Individual University email accounts, campus mail, and University social media accounts may not be used by Community Members to urge financial support of a particular candidate or to invite others to political fundraisers, whether hosted/sponsored by the candidate or by others in support of the candidate.
3. Distribution of campaign materials
   Community Members may not use Institution email, campus mail, and Institution social media accounts to forward or otherwise distribute messages, invitations, solicitations, or campaign literature from or on behalf of a candidate or political party.
4. Student organizations shall not use any funding that originated from Institution funding on behalf of a candidate for public office or in a political campaign.

Definitions

Community Members: Any employee of the CSCU, including administrators, faculty, staff, temporary, and student employees; all CSCU Institutions; any individual using Institution or CSCU resources or facilities or receiving funds administered by the State; and volunteers and other representatives when speaking or acting on behalf of CSCU or any of its composite institutions.

Institution Resources: Include but are not limited to the Institution’s name, logo, or other identifying mark; the Institution’s funds, facilities, office supplies, photo equipment, letterhead, telephones, fax machines, and computers; and the Institution’s information technology resources such as email, websites, and on-line discussion boards. Institution resources does not include student activity funds.

Institution Property: Buildings, grounds, and land that are owned by the CT Board of Regents for Higher Education or controlled by the Connecticut State Colleges and Universities via leases or other formal contractual arrangements to house ongoing CSCU operations.

Outside Entity(ies): Candidates, campaign or political organizations, not-for profits, and all other outside groups.

Student Organization: A student group that is recognized in accordance with any CSCU Institution specific policies or practices.

University Sponsor: An Institution campus, school, department, or unit.