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B-202787 1 (1981-05-01)

handle is hein.gao/gaobadjjc0001 and id is 1 raw text is: 










FILE: B-20

MATTER C


DIGEST:


THE COMPTROLLER OENERAL
OF THE UNITED STATES
ASH I N G TON. 0. C. 2054 8


DATE: MAY 1, 1981


2787


JF: &leged grass roots lobbying by a CSA recipie


1. A letter written by a Community Services
    Administration (CSA) recipient to members of the
    public requesting they contact their congressional
    delegation and urge support for CSA constitutes
    grass roots lobbying and if paid for with Federal
    funds is a violation of applicable appropriation
    restrictions.

 2. Community Services Administration (CSA) promulgated
    an Interpretative Ruling and Waiver of Special Con-
    ditions in the Federal Register which exempted its
    recipients from the lobbying restrictions on CSA
    appropriations in Section 407 of the Departments of
    Labor, Health and Human Services, and Education,
    and Related Agencies Appropriation Act. We recom-
    mended that CSA rescind the ruling and waiver and
    nrnm1mcl-a- a new r1linn mAirn ii- olqr t-1-


                section 407 is applicable to its recipients.

     The Honorable Vin Weber, House of Representatives, has provided C
us with a copy of a letter prepared by Region 6E, Community Action -
Staff, Community Action Agency, Willmar, Minnesota, a Federal fund       i
recipient of the Community Services Administration (CSA). Mr. Weber AQCtID'
states that this recipient made a mass mailing of the letter to
members of the public in Minnesota. The letter indicates that the
Reagan Administration is attempting to eliminate the CSA which would
result in the crippling or death of program recipients, such as the
originator of the letter, all across the nation. Readers are re-
quested to write to their Congressmen and urge support for CSA in
order to prevent its abolition.

     If Federal funds were used in the preparation or carrying out
of the mass mailing, it constituted an illegal expenditure for what
amounts to grass roots lobbying by the recipient. We define
grass roots lobbying as an indirect attempt to influence pending
legislation by urging members of the public to contact legislators
to express support of, or opposition to the legislation or to request
them to vote in a particular manner. 56 Comp. Gen. 889 (1977).
59 Comp. Gen. 115 (1979).


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