oversight

2011 Lobbying Disclosure: Observations on Lobbyists' Compliance with Disclosure Requirements

Published by the Government Accountability Office on 2012-03-30.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States Government Accountability Office

GAO          Report to Congressional Committees




March 2012
             2011 LOBBYING
             DISCLOSURE
             Observations on
             Lobbyists’ Compliance
             with Disclosure
             Requirements




GAO-12-492
                                                March 2012

                                                2011 LOBBYING DISCLOSURE
                                                Observations on Lobbyists' Compliance with
                                                Disclosure Requirements
Highlights of GAO-12-492, a report to
congressional committees




Why GAO Did This Study                          What GAO Found
HLOGA requires lobbyists to file                Most lobbyists were able to provide documentation to demonstrate compliance
quarterly lobbying disclosure reports           with disclosure requirements. This finding is similar to GAO’s results from prior
and semiannual reports on certain               reviews. There are no specific requirements for lobbyists to create or maintain
political contributions. HLOGA also             documentation related to disclosure reports they file under the Lobbying
requires that GAO annually                      Disclosure Act of 1995 as amended (LDA). Nonetheless, and similar to last
(1) determine the extent to which               year’s results, for two key elements of the reports (income and expenses), GAO
lobbyists can demonstrate compliance            estimates that lobbyists could provide documentation to support approximately
with disclosure requirements,                   93 percent of the disclosure reports for the third and fourth quarters of 2010 and
(2) identify any challenges to
                                                the first and second quarters of 2011. According to documentation lobbyists
compliance that lobbyists report, and
                                                provided for income and expenses, GAO estimates that the amounts disclosed
(3) describe the resources and
authorities available to the Office and
                                                were properly reported and supported for 63 percent of the quarterly lobbying
the efforts the Office has made to              disclosure (LD-2) reports. For lobbyists and lobbying firms listed on the LD-2
improve its enforcement of the LDA.             report, an estimated 86 percent filed year-end 2010 or midyear 2011 reports of
This is GAO’s fifth report under the            federal political campaign contributions (LD-203) reports as required. For LD-203
mandate. GAO reviewed a stratified              political contributions reports, GAO estimates that a minimum of 4 percent of all
random sample of 100 quarterly LD-2             LD-203 reports omitted one or more reportable political contributions that were
reports filed for the third and fourth          documented in the Federal Election Commission database. Fewer lobbyists—17
quarters of calendar year 2010 and the          this year versus 21 in the prior year—stated that they planned to amend their LD-
first and second quarters of calendar           2 report following GAO’s reviews to make correction on one or more data
year 2011. GAO also reviewed two                elements. As of March 2012, 9 of 17 amended their disclosure reports.
random samples totaling 160 LD-203
reports from year-end 2010 and                  Lobbyists are required to file LD-2 reports for the quarter in which they first
midyear 2011. This methodology                  register. The majority of lobbyists who newly registered with the Secretary of the
allowed GAO to generalize to the                Senate and Clerk of the House of Representatives in the third and fourth quarters
population of 51,792 disclosure reports         of 2010 and first and second quarters of 2011 filed required disclosure reports for
with $5,000 or more in lobbying activity        that period. GAO could identify corresponding reports on file for lobbying activity
and 32,301 reports of federal political         for 88 percent of registrants.
campaign contributions. GAO also met
                                                The majority of lobbyists felt that the terms associated with disclosure reporting
with officials from the Office regarding
efforts to focus resources on lobbyists
                                                were clear and understandable and the requirements were easy to meet.
who fail to comply. GAO provided a              However, a few lobbyists reported challenges in complying with the LDA.
draft of this report to the Attorney            The U.S. Attorney’s Office for the District of Columbia (the Office) stated that it
General for review and comment. The             has resources and authorities to pursue civil or criminal cases for noncompliance
Assistant U.S. Attorney for the District        with LDA requirements. To enhance enforcement efforts and support the 17 staff
of Columbia responded on behalf of              who have been working on compliance issues on a part-time basis, the Office
the Attorney General that the                   hired one contract staff member in September 2010 who works full-time on
Department of Justice had no
                                                lobbying compliance issues. The Office has primarily focused on contacting
comments on the draft of this report.
                                                lobbyists who have potentially violated the LDA by not filing disclosure reports. In
                                                November 2011, the Office settled its first enforcement case since the enactment
                                                of the Honest Leadership and Open Government Act of 2007 (HLOGA), and
                                                reached a $45,000 settlement with a lobbying firm that had been referred to the
                                                Office repeatedly for failure to file disclosure reports. More than half of the 561
                                                lobbyists who were contacted for noncompliance with LD-2 requirements for
                                                calendar years 2009 and 2010 are now compliant. Approximately 1,081 lobbyists
                                                were referred by the Secretary of the Senate for noncompliance with LD-203
View GAO-12-492. For more information,          requirements for calendar year 2009.
contact J. Christopher Mihm at (202) 512-6806
or mihmj@gao.gov.

                                                                                         United States Government Accountability Office
Contents


Letter                                                                                     1
               Background                                                                  4
               Documentation to Support Some LD-2 Report Elements Varied, but
                 Most Newly Registered Lobbyists Met Disclosure Reporting
                 Requirements                                                              7
               While Most Lobbying Firms Reported That the Disclosure
                 Requirements Were Easy or Somewhat Easy to Meet, a Few
                 Lobbyists Reported Challenges in Complying with the Act                 12
               U.S. Attorney’s Office Actions to Enforce the LDA                         15
               Agency Comments                                                           21

Appendix I     Objectives, Scope, and Methodology                                        24



Appendix II    List of Registrants and Clients for Sampled Lobbying Disclosure
               Reports                                                                   30



Appendix III   List of Sampled Lobbying Contribution Reports with Contributions
               and No Contributions Listed                                               33



Appendix IV    GAO Contact and Staff Acknowledgments                                     38



Tables
               Table 1: Reasons Lobbyists in Our Sample Cited for Not Having
                        Documentation for Some Elements of Their LD-2 Reports              9
               Table 2: Feedback from Lobbyists in Our Sample of Reports Who
                        Rated the Lobbying Terms as Either “Not Clear and
                        Understandable” or “Somewhat Clear and
                        Understandable”                                                  15
               Table 3: Number of LD-2 Referrals the U.S. Attorney’s Office
                        Received from the Secretary of the Senate and the Clerk of
                        the House                                                        18
               Table 4: Status of LDA Enforcement Actions for LD-203 Referrals
                        for the 2009 Filing Period (as of February 22, 2012)             20




               Page i                                     GAO-12-492 2011 Lobbying Disclosure
          Table 5: Names of Registrants and Clients Selected in Random
                   Sample of Lobbying Disclosure Reports Filed in the Third
                   and Fourth Quarters of 2010 and the First and Second
                   Quarters of 2011                                                                 30
          Table 6: Lobbyists and Lobbying Firms in Random Sample of
                   Lobbying Contribution Reports with Contributions Listed,
                   Filed Year-end 2010 and Midyear 2011                                             33
          Table 7: Lobbyists and Lobbying Firms in Random Sample of
                   Lobbying Contribution Reports with No Contributions
                   Listed, Filed Year-end 2010 and Midyear 2011                                     35


Figures
          Figure 1: Documentation Lobbyists Provided to Support Selected
                   Elements of LD-2 Reports                                                          8
          Figure 2: Rating of Terms Associated with LD-2 Reporting for
                   Lobbyists in Interviews                                                          14
          Figure 3: U.S. Attorney’s Office Process for Addressing Referrals
                   Received from the Secretary of the Senate and Clerk of
                   the House                                                                        17
          Figure 4: Status of LDA Enforcement Actions for LD-2 Reporting
                   (as of February 22, 2012)                                                        19


          Abbreviations
          Clerk of the House         Clerk of the House of Representatives
          DOJ                        Department of Justice
          FEC                        Federal Election Commission
          HLOGA                      Honest Leadership and Open Government Act of
                                     2007
          LDA                        Lobbying Disclosure Act of 1995
          Office                     U.S. Attorney’s Office for the District of Columbia




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          Page ii                                              GAO-12-492 2011 Lobbying Disclosure
United States Government Accountability Office
Washington, DC 20548




                                   March 30, 2012

                                   Congressional Committees

                                   Questions regarding the influence of special interests in the formation of
                                   government policy have led to a move toward more transparency and
                                   accountability with regard to the lobbying community. The Honest
                                   Leadership and Open Government Act of 2007 (HLOGA) 1 amended the
                                   Lobbying Disclosure Act of 1995 (LDA) 2 to require lobbyists to file
                                   quarterly lobbying disclosure reports and semiannual reports on certain
                                   political contributions. HLOGA also increased civil penalties and added
                                   criminal penalties for failure to comply with LDA requirements. The
                                   mandate requires GAO to audit the extent of lobbyists’ compliance with
                                   the requirements of the LDA by reviewing publicly available lobbying
                                   registrations and a random sampling of reports filed during each calendar
                                   year. 3 Our report shall include any recommendations related to improving
                                   lobbyists’ compliance with the LDA and information on resources and
                                   authorities available to the U.S. Attorney’s Office for the District of
                                   Columbia (the Office) for effective enforcement of the LDA. This is our
                                   fifth mandated review of lobbyists’ disclosure reports filed under the LDA.

                                   Consistent with our mandate, our objectives were to (1) determine the
                                   extent to which lobbyists can demonstrate compliance with the LDA, as
                                   amended, by providing documentation to support information contained in
                                   reports filed under the LDA, (2) identify any challenges that lobbyists
                                   report to compliance and potential improvements, and (3) describe the
                                   resources and authorities available to the Office in its role in enforcing
                                   compliance with the LDA and the efforts the Office has made to improve
                                   its enforcement of the LDA.

                                   To fulfill our audit requirement in HLOGA, we took the following steps:

                                   To determine the extent to which lobbyists can demonstrate compliance,
                                   we selected a stratified random sample of 100 quarterly lobbying



                                   1
                                       Pub. L. No. 110-81, 121 Stat. 735 (Sept. 14, 2007).
                                   2
                                       Pub. L. No. 104-65, 109 Stat. 691 (Dec. 19, 1995) (2 U.S.C. §§ 1601-1614).
                                   3
                                       2 U.S.C. § 1614.




                                   Page 1                                                    GAO-12-492 2011 Lobbying Disclosure
disclosure (LD-2) reports with income and expenses of $5,000 or more
filed during the third and fourth quarters of calendar year 2010 and the
first and second quarters of calendar year 2011. 4 We selected the
randomly sampled reports from the publicly downloadable database
maintained by the Clerk of the House of Representatives (Clerk of the
House). Appendix II contains a list of lobbyists (registrants and clients)
who we randomly selected for our review of LD-2 reports. This
methodology allows us to generalize to the population of these LD-2
reports. We then contacted each lobbyist or lobbying firm 5 in our sample
and asked them to provide supporting documentation for key elements of
their LD-2 reports, including the amount of money received for lobbying
activities, the houses of Congress or executive branch agencies lobbied,
lobbying issue areas, and lobbyists reported as having worked on the
issues. We also reviewed whether lobbyists listed on the LD-2 reports
properly disclosed prior covered official positions, and whether the
lobbyists filed the semiannual report of federal political contributions. All
lobbyists in our sample responded to our requests for supporting
documentation.

To determine whether lobbyists’ reported their federal political
contributions as required by the LDA, we analyzed stratified random
samples of year-end 2010 and midyear 2011 semiannual federal political
contributions (LD-203) reports. The samples contain 80 LD-203 reports
that have contributions listed and 80 LD-203 reports that list no
contributions. We selected the randomly sampled reports from the
publicly downloadable contributions database maintained by the Clerk of
the House. See appendix III for a list of lobbyists and lobbying firms
randomly selected for our review of LD-203 reports. We then checked the



4
   LD-2 reports for third quarter 2010 are from the prior review and are included in the
current review to redistribute the LD-2 reports evenly across the calendar year for this and
future lobbying reviews. This will allow us enough time to complete reviews and conduct
the analysis of the data prior to our required reporting date. For the prior report,
GAO-11-452, we drew a sample from the fourth quarter of calendar year 2009 and the
first, second, and third quarters of calendar year 2010. See GAO, 2010 Lobbying
Disclosure: Observations on Lobbyists’ Compliance with Disclosure Requirements,
GAO-11-452 (Washington, D.C.: Apr. 1, 2011).
5
  Although we contacted each lobbyist or lobbying firm in our sample, we did not always
meet with the lobbyists identified as the point of contact or the actual lobbyists, we met
with individuals representing lobbyists or lobbying firms. For the purposes of this review,
we use the term lobbyists to refer to lobbyists, lobbying firms, and individuals representing
the lobbyists that were present during the review.




Page 2                                                GAO-12-492 2011 Lobbying Disclosure
contributions reported in the Federal Election Commission’s (FEC)
database against the contributions identified in our sample to determine
whether all contributions reported in the FEC database were also
reported on the LD-203s, as required. We contacted lobbyists and asked
them to provide documentation to clarify differences we observed. All
lobbyists complied with our request to provide documentation. This
methodology allows us to generalize to the population of LD-203 reports
both with and without contributions.

To determine whether registrants were meeting the requirement to file an
LD-2 report for the quarter in which they registered, we compared new
registrations (commonly referred to as LD-1s) filed in the third and fourth
quarters of 2010 and the first and second quarters of 2011 to the
corresponding LD-2 reports on file with the Clerk of the House.

To identify challenges and potential improvements to compliance, we
used structured interviews to obtain views from lobbyists included in our
sample of reports.

To describe the resources and authorities available to the Office and
efforts the Office has made to improve its enforcement of the LDA, we
interviewed officials from the Office and obtained information on the level
of staffing and resources dedicated to the enforcement of the LDA, and
the practices they have established to enforce the LDA. The Office
provided us with information on the processes used to enforce
compliance with the LDA and reports from the tracking system on the
number and status of referrals.

The mandate does not require GAO to identify lobbyist organizations that
failed to register and report in accordance with LDA requirements. The
mandate also does not require us to determine whether reported lobbying
activity or contributions represented the full extent of lobbying activities
that took place.

We conducted this performance audit from June 2011 to March 2012 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives. For more details on our
methodology, see appendix I.



Page 3                                      GAO-12-492 2011 Lobbying Disclosure
             The LDA, as amended by HLOGA, requires lobbyists to register with the
Background   Secretary of the Senate and the Clerk of the House and file quarterly
             reports disclosing their lobbying activity. Lobbyists are required to file their
             registrations and reports electronically with the Secretary of the Senate
             and the Clerk of the House through a single entry point (as opposed to
             separately with the Secretary of the Senate and the Clerk of the House as
             was done prior to HLOGA). Registrations and reports must be publicly
             available in downloadable, searchable databases from the Secretary of
             the Senate and the Clerk of the House. No specific requirements exist for
             lobbyists to generate or maintain documentation in support of the
             information disclosed in the reports they file. However, guidance issued
             by the Secretary of the Senate and the Clerk of the House recommends
             that lobbyists retain copies of their filings and supporting documentation
             for at least 6 years after they file their reports.

             The LDA requires that the Secretary of the Senate and the Clerk of the
             House provide guidance and assistance on the registration and reporting
             requirements of the LDA and develop common standards, rules, and
             procedures for compliance with the LDA. The Secretary and the Clerk
             review the guidance semiannually. The guidance was last revised and
             published in December 2011. The guidance provides definitions of terms
             in the LDA, elaborates on the registration and reporting requirements,
             includes specific examples of different scenarios, and provides
             explanations of why certain scenarios prompt or do not prompt disclosure
             under the LDA. In meetings with the Secretary of the Senate and Clerk of
             the House, they stated that they consider information we report on
             lobbying disclosure compliance when they periodically update the
             guidance.

             The LDA defines a lobbyist as an individual who is employed or retained
             by a client for compensation, who has made more than one lobbying
             contact (written or oral communication to a covered executive or
             legislative branch official made on behalf of a client), and whose lobbying
             activities 6 represent at least 20 percent of the time that he or she spends
             on behalf of the client during the quarter. 7 Lobbying firms are persons or



             6
              Lobbying activities include not only direct lobbying contacts but also efforts in support of
             such contacts, such as preparation and planning activities, research, and other
             background work that is intended for use in contacts.
             7
                 2 U.S.C. § 1602(10)




             Page 4                                                 GAO-12-492 2011 Lobbying Disclosure
entities that have one or more employees who lobby on behalf of a client
other than that person or entity. 8

Lobbying firms are required to file a registration with the Secretary of the
Senate and the Clerk of the House for each client if the firms receive or
expect to receive over $3,000 in income or $11,500 in incurred expenses
from that client for lobbying activities. 9 Lobbyists are also required to
submit a quarterly report, also known as an LD-2 report, for each
registration filed. The registration and subsequent LD-2 reports contain
the following elements, if applicable:

•     the name of the organization, lobbying firm, or self-employed
      individual that is lobbying on that client’s behalf;
•     a list of individuals who acted as lobbyists on behalf of the client
      during the reporting period;
•     whether any lobbyists served as covered executive branch or
      legislative branch officials “covered officials” in the previous 20
      years; 10
•     the name of and further information about the client, including a
      general description of its business or activities;
•     information on the specific lobbying issue areas and corresponding
      general issue codes used to describe lobbying activities;
•     any foreign entities that have an interest in the client;
•     whether the client is a state or local government;



8
    2 U.S.C. § 1602(9).
9
  Organizations employing in-house lobbyists file only one registration. An organization is
exempt from filing if total expenses in connection with lobbying activities are not expected
to exceed $11,500. Amounts are adjusted for inflation and published in the LDA guidance.
10
   The LDA defines a covered executive branch official as the President, Vice President,
an officer or employee, or any other individual functioning in the capacity of such an officer
or employee of the Executive Office of the President; an officer or employee serving in
levels I through V of the Executive Schedule; members of the uniformed services whose
pay grade is at or above O-7; and any officer or employee serving in a position of a
confidential, policy-determining, policymaking, or policy-advocating character who is
excepted from competitive service as determined by the Office of Personnel Management
(commonly called Schedule C employees). The LDA defines a covered legislative branch
official as a member of Congress, an elected officer of either house of Congress, or any
employee or any other individual functioning in the capacity of an employee of a member,
a committee of either House of Congress, the leadership staff of either House of
Congress, a joint committee of Congress, or a working group or caucus organized to
provide legislative services or other assistance to members. 2 U.S.C. § 1602(3), (4).




Page 5                                                 GAO-12-492 2011 Lobbying Disclosure
•   information on which federal agencies and House(s) of Congress the
    lobbyist contacted on behalf of the client during the reporting period;
•   the amount of income related to lobbying activities received from the
    client (or expenses for organizations with in-house lobbyists) during
    the quarter rounded to the nearest $10,000; and
•   a list of constituent organizations that contribute more than $5,000 for
    lobbying in a quarter and actively participate in planning, supervising,
    or controlling lobbying activities, if the client is a coalition or
    association.
The LDA, as amended, also requires lobbyists to report certain
contributions semiannually in the LD-203 report. These reports must be
filed 30 days after the end of a semiannual period by each lobbying firm
registered to lobby and by each individual listed as a lobbyist on a firm’s
lobbying reports. The lobbyists or lobbying firms must

•   list the name of each federal candidate or officeholder, leadership
    political action committee, or political party committee to which they
    made contributions equal to or exceeding $200 in the aggregate
    during the semiannual period;
•   report contributions made to presidential library foundations and
    presidential inaugural committees;
•   report funds contributed to pay the cost of an event to honor or
    recognize a covered official, funds paid to an entity named for or
    controlled by a covered official, and contributions to a person or entity
    in recognition of an official or to pay the costs of a meeting or other
    event held by or in the name of a covered official; and
•   certify that they have read and are familiar with the gift and travel
    rules of the Senate and House and that they have not provided,
    requested, or directed a gift or travel to a member, officer, or
    employee of Congress that would violate those rules.
The Secretary of the Senate and the Clerk of the House, along with the
Office are responsible for ensuring compliance with the LDA. The
Secretary of the Senate and the Clerk of the House notify lobbyists or
lobbying firms in writing that they are not complying with reporting
requirements in the LDA, and subsequently refer those lobbyists who fail
to provide an appropriate response to the Office. The Office researches
these referrals and sends additional noncompliance notices to the
lobbyists, requesting that the lobbyists file reports or correct reported
information. If the Office does not receive a response after 60 days, it
decides whether to pursue a civil or criminal case against each
noncompliant lobbyist. A civil case could lead to penalties up to $200,000,
while a criminal case—usually pursued if a lobbyist’s noncompliance is



Page 6                                       GAO-12-492 2011 Lobbying Disclosure
                          found to be knowing and corrupt—could lead to a maximum of 5 years in
                          prison.



Documentation to
Support Some LD-2
Report Elements
Varied, but Most
Newly Registered
Lobbyists Met
Disclosure Reporting
Requirements
Most Lobbyists Provided   As in our prior reviews, most lobbyists reporting $5,000 or more in income
Documentation for LD-2    or expenses were able to provide documentation to varying degrees for
Reports, but              the reporting elements in their disclosure reports. 11 Lobbyists for an
                          estimated 93 percent of LD-2 reports were able to provide documentation
Documentation for Some
                          to support the income and expenses reported for the third and fourth
Report Elements Did Not   quarters of 2010 and the first and second quarters of 2011. 12 Last year,
Match Their Disclosure    we reported that lobbyists for an estimated 97 percent of LD-2 reports
Reports                   were able to provide documentation for income and expenses for the
                          quarters under review. 13 The most common forms of documentation
                          provided included invoices for income and payroll records for expenses.
                          According to the documentation lobbyists provided for income and


                          11
                            See GAO-11-452, and GAO, 2009 Lobbying Disclosure: Observations on Lobbyists’
                          Compliance with Disclosure Requirements, GAO-10-499 (Washington, D.C.: Apr. 1,
                          2010); 2008 Lobbying Disclosure: Observations on Lobbyists’ Compliance with Disclosure
                          Requirements, GAO-09-487 (Washington, D.C.: Apr. 1, 2009); and Lobbying Disclosure:
                          Observations on Lobbyists’ Compliance with New Disclosure Requirements,
                          GAO-08-1099 (Washington, D.C.: Sept. 30, 2008).
                          12
                             Our sample is only one of a large number of samples that we might have drawn.
                          Because each sample could have provided different estimates, we express our confidence
                          in the precision of our estimate as a 95 percent confidence interval. This interval would
                          contain the actual population value for 95 percent of the samples we could have drawn.
                          Unless otherwise stated, all percentage estimates have a maximum 95 percent
                          confidence interval of within 10.0 percentage points or less of the estimate.
                          13
                               GAO-11-452.




                          Page 7                                              GAO-12-492 2011 Lobbying Disclosure
expenses, we estimate that the amount disclosed was properly rounded
to the nearest $10,000 and supported for 63 percent (59 of 93) of the LD-
2 reports; differed by at least $10,000 from the reported amount in 16
percent (15 of 93) of LD-2 reports; and had rounding errors in 21 percent
(19 of 93) of LD-2 reports. 14

Figure 1 illustrates the extent to which lobbyists were able to provide
documentation to support selected elements on the LD-2 reports.

Figure 1: Documentation Lobbyists Provided to Support Selected Elements of LD-2
Reports




14
   Lobbyists are expected to provide a good faith estimate on the LD-2 report of income
and expenses reported rounded to the nearest $10,000. Our estimate of the number of
reports with rounding errors includes reports that disclosed the exact amount of income
from or expenditures on lobbying activities, but failed to round to the nearest $10,000 as
required.




Page 8                                                GAO-12-492 2011 Lobbying Disclosure
a
 Percentage estimates in the figure have a 95 percent confidence interval of plus or minus 10
percentage points or less of the estimates.
b
 Lobbyists having some documentation to support issue codes and the names of individuals acting as
lobbyists refers to the lobbyists being able to provide documentation for only some of the total number
of issue codes or lobbyists reported.


Of the 100 LD-2 reports in our sample, 47 disclosed lobbying activities at
executive branch agencies, with lobbyists for 19 of these reports
providing documentation to support lobbying activities at all agencies
listed.

Table 1 lists the common reasons why lobbyists we interviewed said they
did not have documentation for some of the elements of their LD-2
reports.

Table 1: Reasons Lobbyists in Our Sample Cited for Not Having Documentation for
Some Elements of Their LD-2 Reports

    LD-2 report element                      Reasons for not having documentation
    Lobbied the Houses of Congress           Several lobbyists told us they did not keep
                                             documentation of their lobbying contacts with the
                                             House and the Senate. Additionally several
                                             lobbyists told us they overreported contact with the
                                             House and Senate staff and that the contact did
                                             not occur during the quarter under review.
    Lobbied executive branch agencies        Several lobbyists told us they did not keep
                                             documentation of their contacts with executive
                                             branch agencies. Several lobbyists told us they
                                             overreported their contact with the agencies and
                                             that lobbying activity with the agencies listed did
                                             not occur during the quarter under review.
    Individuals acting as lobbyists          As in last year’s report, several lobbyists told us
                                             they listed all lobbyists on the LD-2 reports even if
                                             they did not lobby on behalf of the client during the
                                             quarter under review. Several lobbyists stated that
                                             they might have lobbied on behalf of the client in a
                                             previous quarter but not the quarter under review.
    Covered positions                        Several lobbyists told us it was oversight that they
                                             did not disclose the covered positions and that
                                             they planned to amend their LD-2 reports.
                                             Confusion still exists among some lobbyists as to
                                             whether congressional interns were considered
                                             covered positions and therefore need to be
                                                        a
                                             disclosed.
Source: GAO.
a
 In our last report, officials from the Offices of the Secretary of the Senate and Clerk of the House
confirmed that internships are considered covered official positions and therefore should be
disclosed.




Page 9                                                       GAO-12-492 2011 Lobbying Disclosure
Most Lobbyists Properly       The LDA requires a lobbyist to disclose previously held covered positions
Disclosed Covered             when first registering as a lobbyist for a new client, either on the LD-1 or
Positions as Required         on the LD-2 quarterly filing when added as a new lobbyist. Based on our
                              analysis, we estimate that a minimum of 11 percent of all LD-2 reports did
                              not properly disclose one or more previously held covered positions. 15
                              This finding is consistent with last year’s report. 16 Lobbyists for an
                              estimated 86 percent of LD-2 reports filed year-end 2010 or midyear 2011
                              LD-203 contribution reports for all of the lobbyists and lobbying firms
                              listed on the report as required. 17 All individual lobbyists and lobbying
                              firms reporting specific lobbying activity are required to file LD-203 reports
                              semiannually, even if they have no contributions to report, because they
                              must certify compliance with the gift and travel rules.


Fewer Lobbying Firms          Compared to our last review, fewer lobbying firms indicated that they plan
Indicated That They           to amend their LD-2 reports as a result of our review. This year, lobbying
Planned to Amend Their        firms for 17 of the LD-2 reports in our sample indicated that they planned
                              to amend their LD-2 reports as a result of our review. Last year, 21
LD-2 Reports as a Result of   lobbying firms indicated they planned to amend their LD-2 reports. As of
GAO’s Review                  March 2012, 9 lobbying firms have amended their LD-2 reports
                              (compared to 12 lobbying firms last year).

                              Specific reasons for filing amendments included the following:

                              •     Decreasing reported income from $60,000 to $30,000
                              •     Increasing the reported income from $20,000 to $30,000
                              •     Changing the client’s name on the LD-2 report
                              •     Adding additional information about the specific issues lobbied
                              •     Adding contact with the House
                              •     Removing reported contact with the Senate
                              •     Adding a federal agency
                              •     Adding covered positions
                              •     Adding a lobbyist




                              15
                                   For information on our methodology, see app. I.
                              16
                                   GAO-11-452.
                              17
                                 As part of our LD-2 report review, we checked the Clerk of the House’s database to
                              ensure that each lobbyist and organization listed on the LD-2 report filed an LD-203 report
                              during the most recent reporting period.




                              Page 10                                                GAO-12-492 2011 Lobbying Disclosure
                              In addition, lobbying firms filed amendments for 3 (compared to 8 reports
                              last year) 18 of the LD-2 reports in our sample after being notified that their
                              LD-2 reports were selected as part of our random sample but prior to our
                              review.


Some LD-203 Contribution      We estimate that overall, a minimum of 4 percent of reports failed to
Reports Omitted Political     disclose one or more contributions. 19 As part of our review, we compared
Contributions Listed in the   contributions listed on lobbyists’ and lobbying firms’ LD-203 reports
                              against those political contributions reported in the FEC database to
FEC Database
                              identify whether political contributions were omitted on LD-2 reports in our
                              sample. The sample of LD-203 reports we reviewed contained 80 reports
                              with political contributions and 80 reports without political contributions. Of
                              the 80 LD-203 reports sampled with contributions reported, 12 reports
                              omitted one or more contributions. Of the 80 LD-203 reports sampled with
                              no contributions reported, 2 reports failed to disclose contributions listed
                              in the FEC database.


Most Newly Registered         Of the 3,802 new registrations we identified from fiscal year 2011, we
Lobbyists Filed Disclosure    were able to match 3,357 reports filed in the first quarter in which they
Reports as Required           were registered. This is a match rate of 88 percent of registrations, which
                              is consistent with our prior reviews. 20 To determine whether new
                              registrants were meeting the requirement to file, we matched newly filed
                              registrations in the third and fourth quarters of 2010 and the first and
                              second quarters of 2011 from the House Lobbyist Disclosure Database to
                              their corresponding quarterly disclosure reports using an electronic
                              matching algorithm that allows for misspelling and other minor
                              inconsistencies between the registrations and reports.




                              18
                                   GAO-11-452.
                              19
                                 We did not estimate the percentage of other non-FEC political contributions that were
                              omitted (such as honoraria or gifts to presidential libraries) because they tend to constitute
                              a small minority of all listed contributions and cannot be verified against an external data
                              source.
                              20
                                   GAO-11-452 and GAO-10-499.




                              Page 11                                                GAO-12-492 2011 Lobbying Disclosure
While Most Lobbying
Firms Reported That
the Disclosure
Requirements Were
Easy or Somewhat
Easy to Meet, a Few
Lobbyists Reported
Challenges in
Complying with the
Act
Disclosure Requirements   As part of our review, 90 different lobbying firms were included in our
Were Easy or Somewhat     sample. 21 Of the 90 lobbying firms, 86 reported that the disclosure
Easy to Meet for Most     requirements were “easy” or “somewhat easy” to meet. 22 Of the 86
Lobbying Firms            lobbying firms in our sample of LD-2 reports that said the requirements
                          were “easy” or “somewhat easy” to meet, 61 lobbyists indicated that the
                          requirements were “easy” and 25 indicated that the requirements were
                          “somewhat easy” to meet. Compared to last year, fewer lobbyists told us
                          that they found the quarterly reporting requirement difficult to meet. This
                          year, 5 lobbyists we interviewed (compared to 10 lobbyists last year) 23
                          said that it was difficult to file reports quarterly or difficult to meet the 20
                          day filing deadline. The deadline for filing disclosure reports is 20 days




                          21
                             The number of lobbying firms total 90 and is less than our sample of 100 reports
                          because some lobbying firms had more than one LD-2 report included in our sample for
                          lobbyists that we interviewed on the same day. In these cases, we interviewed each
                          lobbyist once to ask about lobbying disclosure requirements and the clarity of lobbying
                          terms.
                          22
                            Although the quantitative results from lobbyists in our sample of LD-2 reports are
                          generalizable to all LD-2 reports, the qualitative results are not generalizable because our
                          sample was designed to develop population estimates of the accuracy of information on
                          LD-2 reports and was not designed to estimate the opinions of lobbyists.
                          23
                               GAO-11-452.




                          Page 12                                               GAO-12-492 2011 Lobbying Disclosure
                          after each reporting period, or the first business day after the 20th day if
                          the 20th day is not a business day. 24

A Few Lobbyists Cited     While most lobbyists we interviewed told us they thought that the terms
Challenges in Complying   associated with LD-2 reporting requirements were clear, a few lobbyists
with the Act              highlighted areas of confusion in applying some aspects of LDA reporting
                          requirements. This is consistent with our prior report. We asked the
                          lobbyists we interviewed to rate various terms associated with LD-2
                          reporting as being “clear and understandable,” “somewhat clear and
                          understandable,” or, “not clear and understandable.” Figure 2 shows the
                          terms associated with LD-2 reporting that the lobbyists were asked to rate
                          and how they responded to each term. Table 2 summarizes the feedback
                          we obtained from the lobbying firms in our sample of reports that rated
                          the lobbying terms as either “not clear and understandable” or “somewhat
                          clear and understandable.”




                          24
                             Prior to the enactment of HLOGA, the deadline for filing disclosure reports was 45 days
                          after the end of each reporting period.




                          Page 13                                              GAO-12-492 2011 Lobbying Disclosure
Figure 2: Rating of Terms Associated with LD-2 Reporting for Lobbyists in
Interviews




Page 14                                         GAO-12-492 2011 Lobbying Disclosure
                            Table 2: Feedback from Lobbyists in Our Sample of Reports Who Rated the
                            Lobbying Terms as Either “Not Clear and Understandable” or “Somewhat Clear and
                            Understandable”

                                                        Feedback about LD-2 terminology and challenges to
                                Associated terms        reporting
                                Lobbying definitions    Some lobbyists stated that lobbying definitions were unclear and
                                                        that it was difficult to determine which activities met the definition
                                                        of lobbying activity. A few lobbyists said that it was difficult to
                                                        understand the definition of lobbying activities or determine
                                                        whether 20 percent of their time over the three-month period was
                                                        spent on lobbying activities.
                                Lobbying activities     Some lobbyists still expressed concern about differentiating
                                                        between lobbying activities versus nonlobbying activities. For
                                                        example, some lobbyists said they were not sure when research
                                                        and support activities become lobbying activities and therefore
                                                                                 a
                                                        needed to be disclosed.
                                Issue codes             Some lobbyists said additional clarity would be helpful to
                                                        determine the most appropriate issue codes to use. For
                                                        example, lobbyists mentioned confusion with using an
                                                        appropriation code versus the specific issue area code.
                                Covered positions       Some lobbyists continued to express concern about knowing
                                                        when a federal official they met with held a covered position.
                                                        Some lobbyists said they might overreport their meetings
                                                        because they are unclear whether the person they met with held
                                                        a covered position.
                                Terminating lobbyists   Few lobbyists expressed concerns about when to terminate a
                                                        lobbyist who was no longer lobbying on behalf of the client.
                            Source: GAO.
                            a
                             The LDA guidance provides examples of lobbying activities, which includes preparation or planning
                            activities and research and background work that is expected to be used in contacting and
                            coordinating the lobbying activities of others.



U.S. Attorney’s Office
Actions to Enforce
the LDA
The Office’s Authorities,   The Office stated that it has sufficient resources and authority to enforce
Processes, and Resources    compliance with LDA requirements, including imposing civil or criminal
to Enforce LDA              penalties for noncompliance. In a prior report, we recommended that the
                            Office develop a structured approach for the tracking and recording of
Compliance                  enforcement activities for lobbyists whom the Secretary of the Senate and
                            the Clerk of the House identify as failing to comply with LDA




                            Page 15                                                   GAO-12-492 2011 Lobbying Disclosure
requirements. 25 As a result, the Office developed a system that allowed it
to track when referrals are received, record reasons for referrals, record
actions taken to resolve them, and assess the results of actions taken.
The system has allowed the Office to take actions to achieve compliance
with the LDA. The Office uses the summary reports to track progress and
quickly identify lobbyists that continuously fail to comply. In addition, the
Office hired one contract staff member in September 2010 to work on
lobbying compliance issues on a full-time basis. This has enhanced the
Office’s ability to pursue enforcement actions by centralizing the process
of checking and resolving referrals. The Office has 17 staff to assist with
lobbying compliance issues on a part-time basis.

To enforce LDA compliance, the Office has primarily focused on sending
letters to lobbyists who have potentially violated the LDA by not filing
disclosure reports as required. The letters request that lobbyists comply
with the law by promptly filing the appropriate disclosure documents. Not
all referred lobbyists receive noncompliance letters because some of the
lobbyists have terminated their registrations, or lobbyists may have
complied by filing the report before the Office sent noncompliance letters.
In addition to sending letters, the contractor sends e-mails and calls
lobbyists to inform them of their need to comply with the LDA
requirements. Figure 3 describes the process and time frames of the
Office’s enforcement efforts.




25
     GAO-08-1099.




Page 16                                      GAO-12-492 2011 Lobbying Disclosure
Figure 3: U.S. Attorney’s Office Process for Addressing Referrals Received from the Secretary of the Senate and Clerk of the
House




                                         Page 17                                          GAO-12-492 2011 Lobbying Disclosure
                        Typically, lobbyists resolve their noncompliance issues by filing the
                        reports or terminating their registration. Resolving referrals can take
                        anywhere from a few days to years depending on the circumstances.
                        Office officials said that they could not set strict time frames or deadlines
                        for closing out pending cases because of these varying circumstances. In
                        addition, they stated that setting strict deadlines might encourage
                        noncompliance if a lobbyist believes that a referral will close out on a
                        certain date if he or she never responds. Although the Office is concerned
                        with all noncompliance, it places a greater emphasis on pursuing
                        lobbyists and registrants who continue to lobby and avoid filing required
                        disclosure reports. A similar approach to the LD-2 enforcement process is
                        being developed for tracking and reporting noncompliance with LD-203
                        reporting.


Update on Enforcement   Since the enactment of HLOGA, both the Secretary of the Senate and the
for the 2009 and 2010   Clerk of the House have made quarterly referrals for noncompliance with
Reporting Periods       the LD-2 requirements. Table 3 shows the number of referrals the Office
                        received from both the Secretary and the Clerk for noncompliance with
                        reports filed for the 2009 and 2010 reporting periods and the actions
                        taken by the Office.

                        Table 3: Number of LD-2 Referrals the U.S. Attorney’s Office Received from the
                        Secretary of the Senate and the Clerk of the House

                                                                                                  Number of                 Number of
                                                                                             noncompliance      noncompliance phone
                            Reporting period                        Number of                 letters sent by    calls made or e-mails
                                                                               a                            b
                            (calendar year)                 referrals received                    the Office         sent by the Office
                            2009                                                       457               320                         0
                            2010                                                       446               193                        48
                        Source: U.S. Attorney’s Office for the District of Columbia.
                        a
                         As of January 25, 2012.
                        b
                         As of February 22, 2012.


                        As of January 25, 2012, the Office has received 118 referrals from the
                        Clerk of the House for the first and second quarter for the 2011 LD-2
                        reporting period, but has not yet received any referrals from the Secretary
                        of the Senate for the 2011 reporting period.

                        As shown in figure 4, about 56 percent (312 of 561) of the lobbyists who
                        received letters, phone calls, or e-mails from the Office for noncompliance
                        for 2009 and 2010 LD-2 referrals have either filed reports or have



                        Page 18                                                                    GAO-12-492 2011 Lobbying Disclosure
                                         terminated their registrations and are now considered compliant.
                                         Additionally, about 43 percent (243 of 561) are pending action because
                                         the Office did not receive a response from the lobbyist and plans to
                                         conduct additional research to determine if it can locate the lobbyist. The
                                         remaining 1 percent of (6 of 561) referrals did not require action because
                                         the lobbyist or client was no longer in business or the lobbyist was
                                         deceased. In addition, lobbyists were found to be compliant when the
                                         Office received the referral. This may occur when lobbyists have
                                         responded to the contact letters from the Secretary of the Senate and
                                         Clerk of the House after the Office has received the referrals.

Figure 4: Status of LDA Enforcement Actions for LD-2 Reporting (as of February 22, 2012)




                                         a
                                          Letters sent includes those sent to referred registrants who may have been referred for
                                         noncompliance with more than one client.


                                         The Office has also received referrals from the Secretary of the Senate
                                         and the Clerk of the House for noncompliance with LD-203 reports. The
                                         Office sends noncompliance letters to the registered organizations and
                                         includes the names of the lobbyists who did not comply with the
                                         requirement to report federal campaign and political contributions and
                                         certify that they understand the gift rules. For noncompliance in the 2009
                                         filing period, as of January 25, 2012, the Office has received LD-203
                                         referrals from the Secretary of the Senate for 1,081 lobbyists. As of



                                         Page 19                                                    GAO-12-492 2011 Lobbying Disclosure
                      March 23, 2012, the Office received LD-203 referrals from the Secretary
                      of the Senate for noncompliance in the 2010 filing period and from the
                      Clerk of the House for the 2009 and 2010 filing periods; however, the
                      Office is still processing the referrals. As of February 22, 2012, the Office
                      has mailed 68 noncompliance letters to the registered organizations. 26
                      The registered organizations may receive a noncompliance letter listing
                      the name of more than one lobbyist. As a result, the number of letters
                      sent will not match the number of referrals now compliant, pending, and
                      with no action taken. However, 7 percent of (73 of 1,081) referrals did not
                      require action because the lobbyist was no longer in business, deceased,
                      or found to be compliant when the Office received the referral. This may
                      occur when lobbyists have responded to the contact letters from the
                      Secretary of the Senate and Clerk of the House after the Office has
                      received the referrals. Table 4 shows the status of enforcement actions
                      for LD-203 reporting after noncompliance letters were sent to registrant
                      organizations for 2009.

                      Table 4: Status of LDA Enforcement Actions for LD-203 Referrals for the 2009 Filing
                      Period (as of February 22, 2012)

                       Actions taken for LD-203 referrals for the 2009 filing                        Number of LD-203
                       period                                                                                referrals
                       Number of referrals now compliant                                                            97
                       Number of referrals pending action                                                          530
                       Number of referrals with no action taken by the Office                                       73
                      Source: U.S. Attorney’s Office for the District of Columbia.




Status of Pending     According to officials from the Office, many of the LD-2 pending cases
Enforcement Actions   represent lobbyists who are no longer lobbying or have never filed a
                      disclosure report. Officials from the Office stated that they have been
                      working more closely with the Senate and the House to remove these
                      referrals before they are forwarded to the Office.

                      The Office has mailed noncompliance letters to the registered
                      organizations and included the names of the lobbyists who did not comply



                      26
                         The Office is in the process of updating the noncompliance letter it sends to referred
                      organizations. Officials said that they plan to send the new letters to the remaining
                      referred organizations starting in the fall of 2012.




                      Page 20                                                        GAO-12-492 2011 Lobbying Disclosure
                         with the LD-203 requirement. However, Office officials said that there
                         have been complaints within the lobbying community regarding
                         responsibility for responding to letters of noncompliance with LD-203
                         requirements. They also said that many lobbyists who were not in
                         compliance no longer lobby for the organizations affiliated with the
                         referrals, even though these organizations may be listed on their original
                         lobbyist registration. Organizations are not responsible for an individual
                         lobbyist’s failure to comply with the LD-203 disclosure requirement, nor
                         are they required to provide contact information for the noncompliant
                         lobbyist. Because of these limitations, officials told us that the Office has
                         very little leverage to bring individual lobbyists into compliance. Officials
                         stated that many of the LD-203 pending cases remain open in an attempt
                         to locate the individual lobbyists, and as a result, these referrals may take
                         years to resolve.


Enforcement Settlement   Since the enactment of the LDA in 1995, but before the 2008
Actions                  implementation of HLOGA, the Office had settled with three lobbyists who
                         failed to file and collected civil penalties totaling about $47,000. In
                         November 2011, the Office settled its first enforcement case since the
                         enactment of HLOGA in 2007 and reached a $45,000 settlement with a
                         lobbying firm that had been referred to the Office repeatedly for failure to
                         file disclosure reports. HLOGA increased the penalties for offenses
                         committed after January 1, 2008. As stated earlier, a civil case could lead
                         to penalties up to $200,000, while a criminal case—usually pursued if
                         lobbyists’ noncompliance is found to be knowing and corrupt—could lead
                         to a maximum of 5 years in prison.

                         We previously reported that the Office planned to identify additional cases
                         of repeat LDA noncompliance for civil enforcement review in the spring
                         and summer of 2011. The Office conducted research and used the
                         system it developed to identify and track lobbyists and firms that have a
                         history of chronic noncompliance. As a result, the Office has developed a
                         “top 10 list” of noncompliant lobbyists whom it may potentially pursue for
                         enforcement actions using five civil enforcement attorneys who have
                         been assigned to review the cases.


                         We provided a draft of this report to the Attorney General for review and
Agency Comments          comment. We met with the Assistant U.S. Attorney for the District of
                         Columbia, who on behalf of the Attorney General responded that
                         Department of Justice had no comments of the draft of this report.



                         Page 21                                      GAO-12-492 2011 Lobbying Disclosure
We are sending copies of this report to the Attorney General, Secretary of
the Senate, Clerk of the House of Representatives, and interested
congressional committees and members. In addition, this report is
available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact
me at (202) 512-6806 or mihmj@gao.gov. Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made major contributions to this report
are listed in appendix IV.




J. Christopher Mihm
Managing Director, Strategic Issues




Page 22                                    GAO-12-492 2011 Lobbying Disclosure
List of Committees

The Honorable Joseph I. Lieberman
Chairman
The Honorable Susan M. Collins
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Patrick J. Leahy
Chairman
The Honorable Charles E. Grassley
Ranking Member
Committee on the Judiciary
United States Senate

The Honorable Charles E. Schumer
Chairman
The Honorable Lamar Alexander
Ranking Member
Committee on Rules and Administration
United States Senate

The Honorable Daniel E. Lungren
Chairman
The Honorable Robert A. Brady
Ranking Member
Committee on House Administration
House of Representatives

The Honorable Lamar S. Smith
Chairman
The Honorable John Conyers, Jr.
Ranking Member
Committee on the Judiciary
House of Representatives

The Honorable Darrell E. Issa
Chairman
The Honorable Elijah E. Cummings
Ranking Member
Committee on Oversight and Government Reform
House of Representatives


Page 23                                 GAO-12-492 2011 Lobbying Disclosure
Appendix I: Objectives, Scope, and
              Appendix I: Objectives, Scope, and
              Methodology



Methodology

              Consistent with the audit mandates in the Honest Leadership and Open
              Government Act (HLOGA), our objectives were to

              •   determine the extent to which lobbyists are able to demonstrate
                  compliance with the Lobbying Disclosure Act of 1995 as amended
                  (LDA) by providing documentation to support information contained on
                  registrations and reports filed under the LDA;
              •   identify any challenges to compliance and potential improvements;
                  and
              •   describe the resources and authorities available to the U.S. Attorney’s
                  Office for the District of Columbia (the Office) and the efforts the
                  Office has made to improve enforcement of the LDA, including
                  identifying trends in past lobbying disclosure compliance.
              To respond to our mandate, we used information in the lobbying
              disclosure database maintained by the Clerk of the House of
              Representatives (Clerk of the House). To assess whether these
              disclosure data were sufficiently reliable for the purposes of this report,
              we reviewed relevant documentation and spoke to officials responsible for
              maintaining the data. Although registrations and reports are filed through
              a single web portal, each chamber subsequently receives copies of the
              data and follows different data cleaning, processing, and editing
              procedures before storing the data in either individual files (in the House)
              or databases (in the Senate). Currently, there is no means of reconciling
              discrepancies between the two databases caused by the differences in
              data processing. For example, Senate staff have told us during previous
              reviews that they set aside a greater proportion of registration and report
              submissions than the House for manual review before entering the
              information into the database, and as a result, the Senate database would
              be slightly less current than the House database on any given day
              pending review and clearance. House staff also told us during previous
              reviews that they rely heavily on automated processing, and that while
              they manually review reports that do not perfectly match in formation file
              for a given registrant or client, they will approve and upload such reports
              as originally filed by each lobbyist even if the reports contain errors or
              discrepancies (such as a variant on how a name is spelled).
              Nevertheless, we do not have reasons to believe that the content of the
              Senate and House systems would vary substantially. For this review, we
              determined that House disclosure data were sufficiently reliable for
              identifying a sample of quarterly disclosure (LD-2) reports and for
              assessing whether newly filed registrants also filed required reports. We
              used the House database for sampling LD-2 reports from the third and
              fourth quarters of calendar year 2010 and the first and second quarters of



              Page 24                                     GAO-12-492 2011 Lobbying Disclosure
Appendix I: Objectives, Scope, and
Methodology




calendar year 2011, as well as for sampling year-end 2010 and midyear
2011 political contributions (LD-203) reports, and finally for matching
quarterly registrations with filed reports. We did not evaluate the Offices
of the Secretary of the Senate or the Clerk of the House, both of which
have key roles in the lobbying disclosure process, although we consulted
with officials from each office, and they provided us with general
background information at our request and detailed information on data
processing procedures.

To assess the extent to which lobbyists could provide evidence of their
compliance with reporting requirements, we examined a stratified random
sample of 100 LD-2 reports from the third and fourth quarters of 2010 and
the first and second quarters of 2011. The third quarter 2010 LD-2 reports
were from our prior review and were included in the current review to
redistribute the LD-2 reports evenly across the calendar year for future
lobbying reviews. 1 We excluded reports with no lobbying activity or with
income less than $5,000 from our sampling frame. 2 The third quarter
2010 sample was drawn from 13,489 activity reports and we drew our
remaining sample from 38,303 activity reports filed for the fourth quarter
of 2010 and first and second quarters of 2011 available in the public
House database, as of our final download date for each quarter. This
allowed us to generalize to a population of 51,792 activity reports. Our
sample is based on a stratified random selection, and it is only one of a
large number of samples that we may have drawn. Because each sample
could have provided different estimates, we express our confidence in the
precision of our particular sample’s results as a 95 percent confidence
interval. This interval would contain the actual population value for 95
percent of the samples that we could have drawn. All percentage
estimates in this report have 95 percent confidence intervals of within plus
or minus 10.0 percentage points or less of the estimate itself, unless
otherwise noted. When estimating compliance with certain of the
elements we examined, we base our estimate on a one-sided 95 percent
confidence interval to generate a conservative estimate of either the




1
 For the prior review, we drew a stratified random sample of LD-2 reports from the fourth
quarter of 2009 and the first, second, and third quarters of 2010.
2
  LD-2 activity reports with “no lobbying issue activity” and reports with less than $5,000 in
reported income or expenses are filtered out because they do not contain verifiable
information on income, expenses, or activity.




Page 25                                                GAO-12-492 2011 Lobbying Disclosure
Appendix I: Objectives, Scope, and
Methodology




minimum or the maximum percentage of reports in the population
exhibiting the characteristic.

We contacted all the lobbyists and lobbying firms in our sample and
asked them to provide support for key elements in their reports, including

•   the amount of income reported for lobbying activities,
•   the amount of expenses reported on lobbying activities,
•   the names of those lobbyists listed in the report,
•   the Houses of Congress and federal agencies that they lobbied, and
•   the issue codes listed to describe their lobbying activity.
Prior to each interview, we conducted an open source search to identify
lobbyists on each report who may have held a covered official position.
We reviewed the lobbyists’ previous work histories by searching lobbying
firms’ websites, LinkedIn, Leadership Directories, Who’s Who in American
Politics, Legistorm, and U.S. newspapers through Nexis. Prior to 2008,
lobbyists were only required to disclose covered official positions held
within 2 years of registering as a lobbyist for the client. HLOGA amended
that time frame to require disclosure of positions held 20 years before the
date the lobbyists first lobbied on behalf of the client. Lobbyist are
required to disclose previously held covered official positions either on the
client registration (LD-1) or on the first LD-2 report when the lobbyist is
added as “new.” Consequently, those who held covered official positions
may have disclosed the information on the LD-1 or a LD-2 report filed
prior to the report we examined as part of our random sample. Therefore,
where we found evidence that a lobbyist previously held a covered official
position, we conducted an additional review of the publicly available
Secretary of the Senate or Clerk of the House database to determine
whether the lobbyist properly disclosed the covered official position.
Finally, if a lobbyist appeared to hold a covered position that was not
disclosed, we asked for an explanation at the interview with the lobbying
firm to ensure that our research was accurate. Despite our rigorous
search, it is possible that we failed to identify all previously held covered
official positions for all lobbyists listed. Thus, our estimate of the
proportion of reports with lobbyists who failed to properly disclose
covered official positions is a lower-bound estimate of the minimum
proportion of reports that failed to report such positions.

In addition to examining the content of the LD-2 reports, we confirmed
whether year-end 2010 or midyear 2011 LD-203 reports had been filed
for each firm and lobbyist listed on the LD-2 reports in our random
sample. Although this review represents a random selection of lobbyists



Page 26                                      GAO-12-492 2011 Lobbying Disclosure
Appendix I: Objectives, Scope, and
Methodology




and firms, it is not a direct probability sample of firms filing LD-2 reports or
lobbyists listed on LD-2 reports. As such, we did not estimate the
likelihood that LD-203 reports were appropriately filed for the population
of firms or lobbyists listed on LD-2 reports.

To determine if the LDA’s requirement for registrants to file a report in the
quarter of registration was met for the third and fourth quarters of 2010
and the first and second quarters of 2011, we used data filed with the
Clerk of the House to match newly filed registrations with corresponding
disclosure reports. Using direct matching and text and pattern matching
procedures, we were able to identify matching disclosure reports for
3,357, or 88 percent, of the 3,802 newly filed registrations. We began by
standardizing client and registrant names in both the report and
registration files (including removing punctuation and standardizing words
and abbreviations, such as “company” and “CO”). We then matched
reports and registrations using the House identification number (which is
linked to a unique registrant-client pair), as well as the names of the
registrant and client. For reports we could not match by identification
number and standardized name, we also attempted to match reports and
registrations by client and registrant name, allowing for variations in the
names to accommodate minor misspellings or typos. For these cases, we
used professional judgment to determine whether cases with typos were
sufficiently similar to consider as matches. We could not readily identify
matches in the report database for the remaining registrations using
electronic means.

To assess the accuracy of the LD-203 reports, we analyzed stratified
random samples of LD-203 reports from the 32,301 total LD-203 reports.
The first sample contains 80 reports of the 10,646 reports with political
contributions and the second contains 80 reports of the 21,655 reports
listing no contributions. Each sample contains 40 reports from the year-
end 2010 filing period and 40 reports from the midyear 2011 filing period.
The samples allow us to generalize estimates in this report to either the
population of LD-203 reports with contributions or the reports without
contributions to within a 95 percent confidence interval of plus or minus
8.2 percentage points or less, and to within 4.2 percentage points of
estimate when analyzing both samples together. We analyzed the
contents of the LD-203 reports and compared them to contribution data
found in the publicly available Federal Elections Commission’s (FEC)
political contribution database. For our fiscal year 2009 report, we
interviewed staff at the FEC responsible for administering the database
and determined that the data reliability is suitable for the purpose of



Page 27                                       GAO-12-492 2011 Lobbying Disclosure
Appendix I: Objectives, Scope, and
Methodology




confirming whether a FEC-reportable disclosure listed in the FEC
database had been reported on an LD-203 report.

We compared the FEC-reportable contributions reporting on the LD-203
reports with information in the FEC database. The verification process
required text and pattern matching procedures, and we used professional
judgment when assessing whether an individual listed is the same
individual filing an LD-203. For contributions reported in the FEC
database and not on the LD-203 report, we asked the lobbyists or
organizations to provide an explanation of why the contribution was not
listed on the LD-203 report or to provide documentation of those
contributions. As with covered positions on LD-2 disclosure reports, we
cannot be certain that our review identified all cases of FEC-reportable
contributions that were inappropriately omitted from a lobbyist’s LD-203
report. We did not estimate the percentage of other non-FEC political
contributions that were omitted (such as honoraria or gifts to presidential
libraries).

To identify challenges to compliance, we used structured interviews and
obtained views from lobbyists included in our sample of LD-2 reports on
any challenges to compliance. In addition, we asked lobbyists to rate
various terms associated with disclosure requirements.

To describe the resources and authorities available to the Office, we
interviewed officials from the Office and obtained information on the level
of staffing and resources dedicated to the enforcement of the LDA. The
Office provided us with information on the processes used to enforce
compliance with the LDA, and reports from the tracking system on their
number and status of referrals.

To describe the efforts the Office has made to improve its enforcement of
the LDA, we interviewed officials from the Office and obtained information
on the processes used by the Office in following up on referrals from the
Secretary of the Senate and the Clerk of the House. The Office provided
us with reports from the tracking system on the number and status of the
referred cases.

The mandate does not include identifying lobbyists who failed to register
and report in accordance with LDA requirements, or whether for those
lobbyists who did register and report all lobbying activity or contributions
were disclosed.




Page 28                                      GAO-12-492 2011 Lobbying Disclosure
Appendix I: Objectives, Scope, and
Methodology




We conducted this performance audit from June 2011 through March
2012 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.




Page 29                                    GAO-12-492 2011 Lobbying Disclosure
Appendix II: List of Registrants and Clients
                                            Appendix II: List of Registrants and Clients for
                                            Sampled Lobbying Disclosure Reports



for Sampled Lobbying Disclosure Reports

                                            The random sample of lobbying disclosure reports we selected was
                                            based on unique combinations of registrant lobbyists and client names
                                            (see table 5).

Table 5: Names of Registrants and Clients Selected in Random Sample of Lobbying Disclosure Reports Filed in the Third and
Fourth Quarters of 2010 and the First and Second Quarters of 2011

Registrant name                                                          Client
Aguirre                                                                  The Geo Group Inc.
AJW, Inc.                                                                Noresco
Akin Gump Strauss Hauer & Feld                                           Kohlberg Kravis Roberts & Company
Alcade & Fay                                                             Marin County, California
American Continental Group                                               Liberty Lane Partners
American Gas Association                                                 American Gas Association
American Network of Community Options & Resources                        American Network of Community Options & Resources
Baker Donelson Bearman Caldwell & Berkowitz                              Helen Keller National Center
Barbour Griffith & Rogers, LLC d/b/a BGR Government Affairs              The American Chamber of Commerce in the People’s
                                                                         Republic of China (AmCham-China)
Barnes & Thornburg LLP                                                   Town of Fishers
Behar & Kalman, LLP                                                      National Association of Long Term Hospitals
Bockorny Group, Inc.                                                     Elanco Animal Health
Brownstein Hyatt Farber Schreck, LLP                                     Z-MEDICA
Brownstein Hyatt Farber Schreck, LLP                                     Westwood College
Capitol Federal Strategies, LLC                                          GE Inspection Technologies
Capstone National Partners                                               Museum of Science and Industry
Cassidy & Associates, Inc. (formerly known as Cassidy & Associates)      Vion Corporation
Cavarocchi Ruscio Dennis Associates, L.L.C.                              Coalition for Health Services Research
CG Technologies, Inc.                                                    Dynetics, Inc.
Competition Advocates, LLC                                               Daikin Industries Limited
Concerned Women for America Legislative Action Committee                 Concerned Women for America Legislative Action Committee
Cystic Fibrosis Foundation                                               Cystic Fibrosis Foundation
David Turch & Associates                                                 City of Palmdale,
D.C. Legislative and Regulatory Services, Inc.                           British Petroleum, America
DeBrunner & Associates, Inc.                                             Monongahela Valley Hospital
Defense Strategic Advantage, LLC                                         Sabreliner Corporation
Delta Strategy Group                                                     Chesapeake Energy Corporation
Delta Strategy Group (formerly Parsons Strategies)                       D.E. Shaw & Co., L.P.
Energy Future Holdings (formerly TXU Electric Delivery)                  Energy Future Holdings (formerly TXU Electric Delivery)
Ernst & Young LLP (Washington Council Ernst & Young)                     Covidien




                                            Page 30                                                  GAO-12-492 2011 Lobbying Disclosure
                                          Appendix II: List of Registrants and Clients for
                                          Sampled Lobbying Disclosure Reports




Registrant name                                                        Client
Etherton and Associates, Inc.                                          Lockheed Martin Corporation
Federal Policy Group (Clark & Wamberg LLC)                             Cigar Association of America
Ferguson Group                                                         Cary-NC, Town of
Firstenergy Corp                                                       Firstenergy Corp
Fisher Consulting                                                      Ball State University
Food Marketing Institute                                               Food Marketing Institute
Gephardt Group Government Affairs                                      Rational Entertainment Enterprises (on behalf of PokerStars)
Holland & Knight LLP                                                   League of California Cities
Innovative Federal Strategies, LLC                                     Advatech Pacific, Inc.
JEH Government Services, Inc.                                          Appleton Paper
KAR Associates, LLC                                                    Emergency Nurses Assn.
Law Offices of Kevin G. Curtin                                         Grocery Manufacturers/Food Products Association
Legislative Strategies, Inc.                                           Kinder Morgan CO2 Company LP
LeMunyon Group, LLC                                                    Brazos River Authority
Liebman & Associates, Inc.                                             Lineage Power
Marlowe & Company                                                      City of Havelock
Mattoon & Associates, LLC                                              Rolls-Royce North America, Inc.
Mayer Brown LLP                                                        U.S. Chamber of Commerce
McAllister & Quinn LLC                                                 Childhelp
mCapitol Management                                                    Emergent Biosolutions
McGuireWoods Consulting                                                Dominion Resources, Inc.
McGuireWoods Consulting                                                Federal Home Loan Bank of Atlanta
ML Strategies, LLC                                                     APCO Worldwide (Dow Corning)
Murray, Montgomery & O’Donnell                                         City of Phoenix
National Association of Credit Unions                                  National Association of Credit Unions
National Association of Letter Carriers                                National Association of Letter Carriers
National Corn Growers Association                                      National Corn Growers Association
National Fair Housing Alliance                                         National Fair Housing Alliance
National Fisheries Institute                                           National Fisheries Institute
National Venture Capital Association                                   National Venture Capital Association
Navigators Global LLC (formerly DC Navigators, LLC)                    Pala Band of Mission Indians
NCR Corporation                                                        NCR Corporation
Nelson, Mullins, Riley & Scarborough                                   Maricopa County
New York Life Insurance Company                                        New York Life Insurance Company
North Shore Consultants                                                JASON Project
Ogilvy Government Relations                                            Ogilvy Public Relations on behalf of California High-Speed
                                                                       Rail




                                          Page 31                                                 GAO-12-492 2011 Lobbying Disclosure
                                         Appendix II: List of Registrants and Clients for
                                         Sampled Lobbying Disclosure Reports




Registrant name                                                                   Client
Oglethorpe Power Corporation                                                      Oglethorpe Power Corporation
Olsson Frank Weeda Terman Bode Matz PC                                            National Meat Association
O’Neill and Associates                                                            Massachusetts Port Authority
Petrizzo Strategic Group, Inc.                                                    Allen Institute for Brain Science
Podesta Group, Inc.                                                               University of South Carolina
Public Strategies Washington                                                      Anheuser-Busch Cos.
Quinn Gillespie & Associates                                                      Satcon Technology Corporation
Quinn Gillespie & Associates                                                      Cayman Finance
Ricchetti Incorporated                                                            Novartis
Rose, Peter J.                                                                    Lockheed Martin Group
Russ Reid Company                                                                 Valparaiso University
Save Darfur Coalition                                                             Save Darfur Coalition
Sears Holdings Corporation                                                        Sears Holdings Corporation
Smith Dawson & Andrews                                                            City of Fontana
SRG & Associates                                                                  Warren Corp.
Strafegies International, Ltd.                                                    American Sesame Growers Association
Strategic Marketing Innovations                                                   University of Maine
Strategic Marketing Innovations                                                   Ingersoll Machine Tools
The Accord Group                                                                  Southern Company
The Glover Park Group LLC                                                         Ernst & Young LLP
The Glover Park Group LLC                                                         Amerilink Telecom Corporation
The Livingston Group, L.L.C.                                                      New Orleans Business Council
The McManus Group                                                                 Genentech
The Nickles Group, LLC                                                            Novartis Corporation
Troutman Sanders Public Affairs Group, LLC                                        City of Sacramento
Urban Swirski & Associates, LLC                                                   National Association of Water Companies
Van Scoyoc Associates                                                             The Rotary Foundation of Rotary International
Van Scoyoc Associates                                                             City of Pismo Beach,
Van Scoyoc Associates                                                             Martin County, Florida
White & Case LLP                                                                  Employee-Owned S Corporations of America
Whitmer & Worrall, LLC                                                            Community College of Allegheny County
Williams & Jensen, PLLC                                                           City of New Haven, Connecticut
Williams & Jensen, PLLC                                                           U.S. Israel Science and Technology Foundation
Williams and Jensen, PLLC                                                         County of Maui, Hawaii
                                         Source: Lobbying disclosure database of the Clerk of the House of Representatives for the third and fourth quarters of calendar year
                                         2010 and the first and second quarters of calendar year 2011.




                                         Page 32                                                                        GAO-12-492 2011 Lobbying Disclosure
Appendix III: List of Sampled Lobbying
              Appendix III: List of Sampled Lobbying
              Contribution Reports with Contributions and
              No Contributions Listed


Contribution Reports with Contributions and
No Contributions Listed
              See table 6 for a list of lobbyists and lobbying firms from our random
              sample of lobbying contribution reports with contributions. See table 7 for
              a list of lobbyists and lobbying firms from our random sample of lobbying
              contribution reports without contributions.

              Table 6: Lobbyists and Lobbying Firms in Random Sample of Lobbying
              Contribution Reports with Contributions Listed, Filed Year-end 2010 and Midyear
              2011

              Lobbyist or lobbying firm                                     Reporting period
              Air Conditioning Contractors of America                       Midyear 2011
              Alan Slomowitz                                                Year-end 2010
              American Resort Development Assn.                             Midyear 2011
              Association of Home Appliance Manufacturers                   Year-end 2010
              Baker Donelson Bearman Caldwell & Berkowitz                   Year-end 2010
              Business Software Alliance                                    Year-end 2010
              Carl Chidlow                                                  Year-end 2010
              Cecil Swamidoss                                               Year-end 2010
              Citigroup Management Corp.                                    Midyear 2011
              Clothilde Hewlett                                             Midyear 2011
              David Horne                                                   Year-end 2010
              David Polster                                                 Midyear 2011
              eBay Inc.                                                     Midyear 2011
              Edward Baxter                                                 Year-end 2010
              Elizabeth Sharp                                               Year-end 2010
              Eric Stewart                                                  Year-end 2010
              Erin Martinko                                                 Midyear 2011
              Frederick Dombo                                               Midyear 2011
              George Mannina                                                Midyear 2011
              Grayson Winterling                                            Year-end 2010
              Gregory Baise                                                 Year-end 2010
              Holcim (US) Inc.                                              Year-end 2010
              James Gelfand                                                 Year-end 2010
              James Hooley                                                  Midyear 2011
              James Rock                                                    Midyear 2011
              Jeanne Campbell                                               Midyear 2011
              John Blount                                                   Midyear 2011
              John Runyan                                                   Midyear 2011
              John Troy                                                     Midyear 2011




              Page 33                                         GAO-12-492 2011 Lobbying Disclosure
Appendix III: List of Sampled Lobbying
Contribution Reports with Contributions and
No Contributions Listed




Lobbyist or lobbying firm                                    Reporting period
Jose Fuentes                                                 Year-end 2010
Josh Bourne                                                  Year-end 2010
Kaiser Foundation Health Plan Inc.                           Year-end 2010
Keith Amason                                                 Year-end 2010
Kerry McKenney                                               Year-end 2010
Lawrence Pratt                                               Midyear 2011
Leann Fox                                                    Year-end 2010
Leslie Belcher                                               Year-end 2010
Lisa Potetz                                                  Year-end 2010
M. Skiles                                                    Year-end 2010
Mark Disler                                                  Year-end 2010
Mark Malone                                                  Year-end 2010
Melinda Dutton                                               Year-end 2010
Melinda Maxfield                                             Midyear 2011
Michael Johnson                                              Year-end 2010
Michael Mawby                                                Midyear 2011
Michael Werner                                               Year-end 2010
Michelle Vogel                                               Year-end 2010
Mr. Jackson DeWitt                                           Year-end 2010
Mr. Robert Zimmer                                            Midyear 2011
Mrs. Helen Delich Bentley                                    Midyear 2011
National Air Traffic Controllers Association                 Year-end 2010
National Association for Uniformed Services                  Midyear 2011
National Association of Realtors                             Midyear 2011
National Music Publishers’ Association                       Year-end 2010
Newmont Mining Corporation                                   Midyear 2011
Pablo Chavez                                                 Year-end 2010
Patrick Carroll                                              Year-end 2010
Peter Loughlin                                               Midyear 2011
Peter Newbould                                               Midyear 2011
Public Service Enterprise Group                              Midyear 2011
Richard Efford                                               Midyear 2011
Robert Hurt                                                  Year-end 2010
Sandra Swirski                                               Midyear 2011
Scott Keefer                                                 Year-end 2010
Scott Scanland                                               Midyear 2011
Sodexo Inc.                                                  Year-end 2010




Page 34                                        GAO-12-492 2011 Lobbying Disclosure
Appendix III: List of Sampled Lobbying
Contribution Reports with Contributions and
No Contributions Listed




 Lobbyist or lobbying firm                                                                          Reporting period
 Steven Fisher                                                                                      Midyear 2011
 Steven McKnight                                                                                    Midyear 2011
 Susan Ingargiola                                                                                   Year-end 2010
 Ted Monoson                                                                                        Midyear 2011
 Terry Allen                                                                                        Year-end 2010
 Tesoro Companies                                                                                   Midyear 2011
 Thane Young                                                                                        Midyear 2011
 The GoodYear Tire & Rubber Company                                                                 Midyear 2011
 Thomas Keating                                                                                     Midyear 2011
 Universal Music Group                                                                              Midyear 2011
 Vicki Iseman                                                                                       Midyear 2011
 Vincent Versage                                                                                    Midyear 2011
 William Ris                                                                                        Midyear 2011
 Yahoo! Inc.                                                                                        Year-end 2010
Source: Lobbying contributions database of the Clerk of the House of Representatives, Year-end reports for calendar year 2010 and
midyear reports for calendar year 2011.




Table 7: Lobbyists and Lobbying Firms in Random Sample of Lobbying
Contribution Reports with No Contributions Listed, Filed Year-end 2010 and
Midyear 2011

 Lobbyist or lobbying firm                                                                            Reporting period
 Abby Bownas                                                                                          Year-end 2010
 Alan Ross                                                                                            Year-end 2010
 Alexis Latifi                                                                                        Midyear 2011
 Alliance for Excellent Education                                                                     Midyear 2011
 American Business Conference                                                                         Midyear 2011
 America’s Blood Centers                                                                              Year-end 2010
 Amy Edwards                                                                                          Year-end 2010
 Amy Rosenthal                                                                                        Midyear 2011
 Anne Duffy                                                                                           Midyear 2011
 BAFT-IFSA (formerly known as Bankers’ Association for Finance & Year-end 2010
 Trade)
 Brendan Flanagan                                                                                     Year-end 2010
 Brigen Winters                                                                                       Year-end 2010
 Camille Donald                                                                                       Midyear 2011
 Capitol Counsel LLC                                                                                  Midyear 2011




Page 35                                                                      GAO-12-492 2011 Lobbying Disclosure
Appendix III: List of Sampled Lobbying
Contribution Reports with Contributions and
No Contributions Listed




Lobbyist or lobbying firm                                         Reporting period
Charlene Macdonald                                                Year-end 2010
Christopher Kearney                                               Year-end 2010
Christopher Ross                                                  Midyear 2011
Connect                                                           Year-end 2010
Corporate Voices for Working Families                             Midyear 2011
Craig Updyke                                                      Year-end 2010
Daniel Smith                                                      Year-end 2010
Darah Franklin                                                    Midyear 2011
Darren Lasorte                                                    Year-end 2010
Deirdre Stach                                                     Year-end 2010
Dirk Vande Beek                                                   Midyear 2011
Don Miller                                                        Year-end 2010
Edward Edens                                                      Year-end 2010
Edward Olivares                                                   Midyear 2011
Emmer Consulting, P.C.                                            Midyear 2011
Fernando Gomez                                                    Midyear 2011
Florida State University                                          Midyear 2011
Frank Ryan                                                        Year-end 2010
Fred Searle                                                       Midyear 2011
Geos Institute (formerly National Center for Conservation Sc)     Midyear 2011
Good Will Industries International Inc.                           Year-end 2010
Harold Johnson                                                    Midyear 2011
Heidi Salow                                                       Midyear 2011
International Union of Operating Engineers                        Midyear 2011
Jake Jacoby                                                       Year-end 2010
James Kuhn                                                        Year-end 2010
Jeffry P. Mahoney                                                 Midyear 2011
Jerome Nagy                                                       Year-end 2010
John Sabo                                                         Year-end 2010
Jonathan Bergner                                                  Midyear 2011
Joyce Knott                                                       Midyear 2011
Kenneth Nahigian                                                  Year-end 2010
Kevin Dempsey                                                     Year-end 2010
Kirsten Zewers                                                    Midyear 2011
Law Offices of James L. Kane, Jr.                                 Midyear 2011
Madison Government Affairs                                        Year-end 2010
Martin Regalia                                                    Year-end 2010




Page 36                                            GAO-12-492 2011 Lobbying Disclosure
Appendix III: List of Sampled Lobbying
Contribution Reports with Contributions and
No Contributions Listed




 Lobbyist or lobbying firm                                                                            Reporting period
 Morgan Brown                                                                                         Year-end 2010
 Nancy Kohler                                                                                         Midyear 2011
 Natasha Bui                                                                                          Year-end 2010
 National Action Council for Minorities in Engineering, Inc.                                          Midyear 2011
 National Alliance on Mental Illness                                                                  Midyear 2011
 Nora Super                                                                                           Midyear 2011
 Patricia Chavez                                                                                      Year-end 2010
 Porter Delaney                                                                                       Midyear 2011
 Priscilla Chatman                                                                                    Year-end 2010
 Profit Sharing/401(K) Council of America                                                             Midyear 2011
 Rachel Hedge                                                                                         Midyear 2011
 Rebecca Kelly                                                                                        Midyear 2011
 Redfern Resources                                                                                    Year-end 2010
 Ryan Quinn                                                                                           Midyear 2011
 Safety Net Hospitals for Pharmaceutical Access                                                       Midyear 2011
 Scott North                                                                                          Year-end 2010
 Scott Thompson                                                                                       Midyear 2011
 Sean Heather                                                                                         Year-end 2010
 Stephan Bell                                                                                         Year-end 2010
 Steve Gotthiem                                                                                       Year-end 2010
 Steven Brownlee                                                                                      Midyear 2011
 Terry Francl                                                                                         Year-end 2010
 The Collette Group LLC                                                                               Midyear 2011
 Traditional Values Coalition                                                                         Midyear 2011
 Washington University in St. Louis                                                                   Year-end 2010
 Wayne LaPierre                                                                                       Year-end 2010
 William Cloherty                                                                                     Midyear 2011
 William Weber                                                                                        Year-end 2010
 Yvonne Roberts                                                                                       Year-end 2010
Source: Lobbying contributions database of the Clerk of the House of Representatives, Year-end reports for calendar year 2010 and
midyear reports for calendar year 2011.




Page 37                                                                      GAO-12-492 2011 Lobbying Disclosure
Appendix IV: GAO Contact and Staff
                  Appendix IV: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  J. Christopher Mihm, (202) 512-6806 or mihmj@gao.gov
GAO Contact
                  In addition to the contact named above, Robert Cramer, Associate
Staff             General Counsel; Bill Reinsberg, Assistant Director; Shirley Jones,
Acknowledgments   Assistant General Counsel; Crystal Bernard; Amy Bowser; Colleen
                  Candrl; Jill Lacey; Natalie Maddox; Donna Miller; Anna Maria Ortiz;
                  Melanie Papasian; and Katrina Taylor made key contributions to this
                  report.

                  Assisting with lobbyist file reviews were Vida Awumey, Alexandra
                  Edwards, Emily Gruenwald, Lois Hanshaw, Jeff McDermott, Stacey Ann
                  Spence, Megan Taylor and Daniel Webb.




(450912)
                  Page 38                                   GAO-12-492 2011 Lobbying Disclosure
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