| Approved by: | The President | |
| History: | Issued -- September 15, 2000 | |
| Revised -- October 5, 2022 | ||
| Last Reviewed -- October 5, 2022 | ||
| Related Policies: | Co-Curricular Scheduling Policy; Presentations Policy; Posting Policy; Personal Social Media Policy; Social Media Policy | |
| Additional References: | ACE Memo on Political Campaign Related Activities of and at Colleges and Universities; Frequently Asked Questions; Student Organization Resource Center | |
|
Policy Owner: Contact Person: |
Office of the President, tel. (202) 319-5100 Office of General Counsel, tel. (202) 319-5142 |
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I. Policy Statement
The University is committed to the free and open discussion of ideas and opinions both as part of its academic mission and through the political process. However, as a non-profit, private institution of higher education whose activities are regulated in part by Section 501(c)(3) of the Internal Revenue Code, the University itself is prohibited from directly or indirectly participating in any political campaign on behalf of or against any candidate for elective public office. Accordingly, no University school, department or unit, and no member of the University community speaking for the University may advocate for or against a Candidate for elective office or use University resources to do so. Violation of this prohibition can jeopardize the University's tax-exempt status.
This policy provides general guidance for faculty, staff, and students so that they may engage in the political process in an individual manner that does not jeopardize the University's tax-exempt status. This policy also provides guidelines for permissible appearances of Candidates on campus.
Whether any particular activity constitutes impermissible participation or intervention in a political campaign is fact-specific and depends on full consideration of all surrounding circumstances. If you are considering taking an action that relates to a political campaign, candidate, or issue and are unsure whether it is appropriate, please review the Frequently Asked Questions and contact the Office of General Counsel tel. 202-319-5142, CUA-OGC@CUA.EDU) in advance so appropriate guidance can be provided.
II. Definitions
A. Campaign means an organized effort to influence individuals and/or groups to elect a particular Candidate or Candidates to public office.
B. Candidate means an individual who has announced themselves as campaigning for an elective public office, whether at the federal, state or local level.
C. Political Activities mean actions that endorse or oppose a Candidate, a political party, or a political action committee (PAC); taking a position on an issue for the purpose of assisting or opposing a Candidate or political party in a Campaign; or otherwise supporting a Candidate, political party, or PAC in a Campaign.
D. Candidate Surrogate or Advocate means another politician, celebrity, or person of influence, campaigning on a Candidate’s behalf.
E. University Resources for the purposes of this policy means: University funds and purchasing mechanisms, including the Procurement Card; University offices, conference rooms, and other spaces and facilities; University copiers, fax machines, computers, and other electronic equipment; University computer networks, websites, social media accounts, email accounts, listservs, trademarks or intellectual property, and mailing lists; University telephones, and voicemail and mail systems; and University letterhead, stationery, and other supplies.
F. Work Hours mean the regularly scheduled hours of work assigned to an employee as determined by their supervisor or designee and in accordance with Catholic University policies, employment contracts, and/or applicable collective bargaining agreements.
III. Political Activity Guidelines
A. Faculty and staff (including student employees) may not engage in Political Activities during work hours.
B. Faculty, staff, and students are free to express their individual and collective political views, provided they understand and make clear that they are not speaking for or in the name of The Catholic University of America.
C. University Resources may not be used for Political Activities, either by University units or by outside organizations. Use of University buildings and facilities is permissible for the limited purposes set forth in Section A below, and subject to the University's Co-Curricular Scheduling Policy.
D. The University's name, seal, and insignia, or those of a University school, department, or unit may not be used on any documents to endorse or oppose any candidate for elective public office. This prohibition applies to any University entities supported in whole or part by University funds, such as registered student organizations.
A. Candidate Appearances On Campus
Appearance of a Candidate or their Surrogate or Advocate on campus must be for an educational or informational discussion, forum or talk to the University community, or for a political debate. Such appearances must be approved by the President or a delegated representative authorized to approve candidate appearances, and in the case of a student group or organization, by the Office of Campus Activities.
The following restrictions will apply to approved events:
There may be no fundraising (seeking of financial support) of any kind by political candidates, elected officials, political campaigns, political parties, or other political organizations in association with a University event, or on campus at any time. This prohibition also applies to fundraising by student organizations recognized by the University.
In accordance with IRS regulations that prohibit the endorsement or the appearance of an endorsement of a political candidate by a tax-exempt organization, traditional political rallies are prohibited. Rather, any events involving an elected official, political candidate, or a surrogate or advocate should be educational in nature.
The elected official, political candidate, or surrogate or advocate will be introduced by a University representative (which may include student leaders of clubs and organizations), and the introduction and all communication concerning the political guest’s appearance cannot include comments on their qualifications and must explicitly state that the University neither supports nor opposes the candidate.
No banners, placards, or other signage typically found at a political rally are allowed in or around the venue where the elected official, political candidate, or surrogate oe advocate is being hosted.
Only invited elected officials, political candidates, and surrogates or advocates may speak. Surrogates or advocates must be approved as participants in advance. No political leaders, endorsers, or elected officials other than the invitee may participate.
Other politicians or celebrities who support candidates may attend and receive special seating, and be introduced, but they may not speak on behalf of a candidate.
If a candidate is invited to speak on campus, the University must provide equal opportunity to all candidates for that particular office to speak on campus in accord and consistent with University policies. The same parameters and provisions must apply for all such candidates.
Should a political campaign seek to send a surrogate or advocate to campus to speak on behalf of a candidate, that appearance will be conducted under these rules as if the candidate were speaking.
A sponsoring University academic unit or officially recognized organization is expected to comply with the above policies related to fundraising, neutrality, signage, attendance by other political figures and celebrities, and equal opportunity to all candidates.
B. Candidate Campaigning, Endorsement and Fundraising
Except where otherwise noted, the following prohibitions apply to all University entities supported in whole or part by University funds, including registered student organizations.
Candidate campaigning (solicitation) on University property is prohibited. This includes, but is not limited to posting or distribution of posters, fliers, or leaflets, or transmission of materials over the Internet. No posters, fliers, or leaflets should be visible during University classes or meetings conducted by video teleconference. No school, department, or unit of the University may post hyperlinks to a Candidate's website or Campaign websites on a University website. The prohibition on posted hyperlinks on University websites does not apply to the College Republicans or College Democrats.
No Candidate may be endorsed by the University, or by a school, department, or unit of the University.
Funds or other contributions to support a Candidate, Campaign, political party, or PAC may not be solicited or made in the University's name, on University property, or using University Resources. All such contributions by faculty, staff, or students may be made only in a personal capacity.
Campaign paraphernalia may not be sold, distributed, or made available by schools, departments, or units of the University. This prohibition does not apply to the College Republicans or College Democrats.
C. Event Communications and Postings
Student organizations, officially-constituted campus groups, or other units of the University that are sponsoring an approved discussion, forum, talk, or political debate, or an approved voter education or registration activity, may use campus communication mechanisms to announce that event. All such communications and postings must comply with the University's Technology Use Policy and Posting Policy.
D. Student Organizations
It is desirable to have student organizations remain engaged and active in the political process, and it is understandable that organizations such as the College Democrats and College Republicans are interested in supporting Candidates represented by the respective political parties. However, no student organization has the authority to represent the views of The Catholic University of America. Neither the College Democrats nor the College Republicans exist simply to support one Candidate over another, and the Office of Campus Activities will not register a student organization that has as a goal the support of a particular Candidate.
Whenever a student organization hosts, sponsors, or publicizes an event on behalf of a political campaign or a political party, the sponsoring student organization must deliver a disclaimer explaining that the use of University facilities or resources for this event does not constitute an endorsement by the University, the views of those invited to speak on campus are the views of the speaker and not of the University, and that the University does not endorse or oppose any candidate or organization in connection with this or any other political campaign or election.
The University's Presentations Policy must be followed in addition to this policy.
E. Voter Education and Registration Activities
Voter education and registration activities are permissible so long as such activities are focused on increasing public understanding of the electoral process or encouraging participation in that process. Such activities must be conducted in a non-partisan manner, and may not focus on a particular Candidate or party.