It is about to become a little more challenging for companies to pay travel costs for House Members and staff. Starting for trips on or after April 1, 2013, Members and employees of the House must submit pre-approval request forms to the House Ethics Committee at least 30 days prior to the trip. Previously, they could wait until two weeks out to submit this paperwork. This means that trip sponsors will need to start preparing these events sooner than they currently do. In addition, a trip sponsor’s duties will no longer be over even when the event itself is. Sponsors must submit to the House Member or staffer a “Sponsor Post-Travel Disclosure Form” itemizing actual expenses paid on behalf of the traveler within 10 days of the Member or staffer’s return.
These changes are just two of many reflected in new House Ethics Committee travel regulations issued late last year. Among the other new topics covered in these 26 pages of rules (now formatted to look like federal regulations):
- an exception that allows lobbyist board members of sponsoring organizations to plan, organize, request, or arrange trips for House Members and employees if the board member does not lobby for the sponsor or a related entity on issues related to the officially-connected purpose of the trip;
- more detail concerning what counts – and what does not count – as de minimis lobbyist involvement in a trip;
- an affirmation that trip sponsors can be subject to criminal penalties if false information about the trip is submitted to the House Ethics Committee;
- special rules regarding travel offered by private foundations;
- a discussion regarding multi-destination and mixed purpose trips; and
- a list of situations in which first-class airfare can be paid by the trip sponsor.
Simply put, these new rules illustrate two important points for those thinking about paying the travel costs for House Members and staffers: (1) plan ahead and (2) carefully vet each trip, even if the company has previously provided travel for similar events.