Authority of the Legal Services Corporation To Expend Appropriated Funds for Lobbying Activities

A Representative requested an opinion on whether a firm could use appropriated funds for publicity or propaganda purposes designed to induce members of the public to contact elected representatives for the purpose of supporting or defeating legislation pending in Congress or any state legislature. Specifically, the requester referred to a memorandum issued by the firm setting forth its interpretation of its legal authority to engage in legislative representation activities. GAO believes that applicable law prohibits using appropriated funds for such purposes. The memorandum, in essence, takes this position also. However, the memorandum does not fully explain the restrictions on such activities, nor does it give the controls necessary to ensure proper enforcement of the restrictions. To help ensure full compliance with all statutory restrictions in this area, GAO recommends that the firm clarify its policy guidance on lobbying activities and fully explain the statutory restrictions on those activities. In addition, the firm should include appropriate restrictions in grant instruments and contracts with providers of legal assistance to ensure that grantees and contractors have actual knowledge of these restrictions.