Federal Grant Funds Used For Association Dues

A recent Presidential Memorandum, as well as a Department of Education “Dear Colleague” letter, reminds organizations that receive federal grants, that federal funds can’t be used to pay for membership dues if the association engages in lobbying activity. Please note this is a reminder to current federal law, not a new precedent.

However, to clarify, Associations West understands that an association, or their members, that receive federal grants can in fact be members of an association that engages in lobbying – they just can’t use the federal funds to pay for the membership. As such, it is advised that the organization keep records indicating the dues were paid from funds other than the federal grant.

Please use guidance from this article in ASAE's Associations Now magazine, from the law firm of Pillsbury Winthrop Shaw Pittman LLP.

Here is an excerpt from the article: “In short, the recent White House Presidential Memorandum and the Department of Education “Dear Colleague” letter are both useful reminders that recipients of federal grants may not use grant funds for lobbying; but they should not be read as discouraging in any way grant recipients from maintaining memberships in associations.