Use of NIH Funds for Advocacy and Lobbying - Key Reminders for Recipients

NIH’s Grants Policy Statement, a term and condition of award, reminds recipients that NIH award funds may not be used for lobbying or advocacy activities. This includes efforts to support, oppose, or influence legislation, regulations, or other government actions at the federal, state, or local level. Recipients and subrecipients using non-federal funds for lobbying must disclose covered activities during the application process and, when changes occur, post-award. 

NIH funds (both direct and indirect costs) may not be used to:

• Create or distribute materials intended to support or oppose laws, regulations, or government actions—except communications expressly permitted under applicable lobbying restrictions, such as certain communications by state or local government recipients conducted as part of their normal and recognized executive-legislative relationships
• Influence legislation, regulations, or executive actions at the federal, state, or local level
• Encourage the public or other entities to support or oppose specific action proposed or pending before the U.S. Congress, state, or local governments, also referred to as grassroots lobbying
• Present materials relating to public policies that may require legislative or executive action that do not include an objective, balanced presentation of evidence
• Lobby in connection with the award, extension, continuation, renewal, amendments, or modification of the funding mechanism from the federal government

Activities that do not meet the definition of lobbying or advocacy may include nonpartisan analysis, study, or research reports, as well as providing research results upon formal written request of a legislative body or committee for technical advice and assistance. NIH’s Lobbying Guidance for Recipient Activities provides additional information on allowable and prohibited activities, including exceptions based on organization type, and disclosure requirements. 

Recipients should regularly review the allowability of costs and activities, including lobbying restrictions, outlined in the NIH Grants Policy Statement. To support transparency and improve tracking, recipients engaging in advocacy or lobbying activities with non-federal funding should separate these funding streams from federally funded activities. To avoid potential violations of the Grants Policy, recipients are encouraged to carefully prepare public communications to avoid the appearance of attempting to influence public policy and consider documenting the internal review process and funding mechanism to ensure activities are consistent with federal funding requirements.

Please reach out to your grants management specialist early to discuss how these restrictions apply to your work.

Additional Resources:

• NIH Grants and Funding site: Lobbying Guidance for Recipient Activities 
• Uniform Guidance: 2 CFR 200.450 — Lobbying
• HHS Implementing Regulation: 45 CFR Part 93
• NIH Grants Policy Statement 4.1.18 Lobbying Prohibition
• Notice of Legislative Mandates in Effect for FY 2026: NOT-OD-26-060