In-person contacts by agency lobbyists or liaisons with legislators to influence action or inaction on legislation is understood fairly universally to be reportable lobbying. However, some agencies may not be aware that reportable lobbying also includes efforts to inform, sway, convince or otherwise influence the action or inaction of legislative staff members. Staff evaluations and recommendations play a significant role in the legislative process. In-person contacts with legislative staff constitute lobbying. Gift, travel and entertainment expenditures for legislators and staffers alike, whether using public or non-public dollars, are reportable.
Requests, recommendations or other communications between or within state agencies, whether in-person or by phone or letter, is not considered lobbying. Therefore, state agencies may attempt to influence each other's actions without reporting the expenditures incurred. State agencies may also "lobby" local and federal agencies without reporting this activity under state law.
Similarly, local agencies may "lobby" their local counterparts and federal agencies without incurring any state reporting requirements. However, if a local agency employee has an in-person contact with a state agency representative in order to attempt to influence that state agency's adoption, repeal or amendment of a rule, rate, standard or other legislative enactment of the agency, the expenditures made in connection with that contact are reportable by the local agency.
Were a local agency to request a state agency to interpret or apply existing laws or rules to a particular situation in a manner preferred by the local agency, reportable lobbying would not occur. Attempting to influence the interpretation or application of an existing state rule or policy is not lobbying; attempting to change a state agency's rule, rate or standard is.