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Laws Prohibit the Use of HHS Grant Funds for Lobbying, but Limited Methods Exist To Identify Noncompliance


This evaluation responded to a congressional request for OIG to review grantees' use of Department of Health and Human Services (HHS) funds and awarding agencies' implementation and oversight regarding the prohibitions on the use of grant funds for lobbying activities.


This evaluation included 13 grantmaking agencies (awarding agencies) within HHS. We collected and reviewed departmental and awarding agency directives in place for fiscal years (FYs) 2011 and 2012. We conducted structured telephone interviews with each agency's Chief Grants Management Officer and/or his or her designated staff. We asked about awarding agencies' notifications to grantees of the prohibitions on the use of grant funds for lobbying. We also asked about awarding agencies' mechanisms for identifying grantees that may have violated lobbying prohibitions and the mechanisms in place for reviewing allegations of lobbying. We conducted surveys with a sample of grantees from five awarding agencies regarding their awareness of the lobbying prohibitions.


All awarding agencies reported using Federal and departmental sources of guidance regarding the prohibitions on the use of grant funds for lobbying. Through grant applications, notices of award, and/or training, all awarding agencies informed grantees of the prohibitions. For all sampled grant awards, grantees reported being aware of the lobbying prohibitions. However, limited methods exist to identify noncompliance. HHS awarding agencies found two instances of noncompliance in FYs 2011 and 2012



We recommend that ASFR facilitate Departmentwide information sharing among awarding agencies about methods to identify the use of grant funds for prohibited lobbying activities. We also recommend that ASFR centralize on its Web site the guidance pertaining to the prohibitions on the use of grant funds for lobbying. ASFR concurred with our recommendations.