Food and beverages offered to congressional members and staff in a social setting, if paid for by lobbyists or lobbying entities, must conform to the restrictions of the rules, which provide an exception for:
“Food and beverages of nominal value, not as part of a meal.”
This is known as the “reception exception.” The rules in this instance clearly envision that nominal value means more minimalist – and that the phrase “not as part of meal” means no heavy hors d’oeuvres that could be considered a substitute for a meal by hungry interns or low-paid Hill staffers.
As the ethics staff advised one House staffer, “pitcher of margaritas, yes…plate of sliders, no.”
Parties and Receptions — Menus
The House and Senate ethics staff have spent ample time reviewing, editing and discussing catering menus for events hosted or paid for by lobbyists or lobbying entities. Below is a checklist of do’s and don’ts:
- low-cost food that could still be considered a meal item, such as hot dogs, pizza slices, sliders (tiny hamburgers)
- food that requires a fork
- carving stations
- pasta stations
- dining tables
- martini or vodka bars
- passed hors d’oeuvres
- finger foods or food eaten with toothpicks
- beverages, including wine, beer and cocktails (but keep it simple and less expensive)
Invitations and Ethics Approval
The House and Senate Ethics Committee staffs have been gracious about reviewing and approving menus and reception plans in order that hosts and sponsoring organizations can provide comfort to Members and staff that there is no criminal conduct involved in attending a reception Cialis. The ethics staff may require changes in the type of food or beverages to be served prior to granting approval.
A reception is not a widely attended event as that term is defined in the gift rules. A widely attended event requires an educational component or some element that a Member or staffer can claim to fall within his/her official duties. Although attendance at social events is clearly business-related in most instances, the widely attended event exception is not the one that is envisioned by the gift rules to be applied if the occasion is a reception or party to which Members and staffers are invited.
Don’t ask the ethics staff to approve a “widely attended event” that is, in fact, a “social gathering.” Approval will not likely be forthcoming.
An event that is planned within the spirit and letter of the ethics rules regarding the menu of food and beverages to be served can be denoted as such on the invitation by stating:
Cocktails and Reception Fare Only
Cocktails and Light Appetizers
Cocktails and Light Hors d’oeuvres
An indication on the invitation that only appropriate reception food and beverages will be served will demonstrate to an invitee that the host is familiar with the rules and is intent upon following them. That will provide comfort to any guests who are Members and congressional staff and should also help document that the event was in compliance with applicable provisions of the ethics and gift rules.
For more information or to purchase the Lobbying Compliance Handbook click here.