It’s been six months since new lobbying regulations in New York state took effect. Due to complexities and gray areas in the law, health care organizations operating in New York state frequently encounter questions regarding what may or may not constitute lobbying, as well as the registration and reporting requirements that follow.

Health care providers who are clients of organizations registered as lobbyists are not immune to potential scrutiny; and in this climate of heightened enforcement, it’s essential to make sure your practices comply with the detailed lobbying laws and registration requirements. Even past practices that did not qualify as lobbying may be considered lobbying under new guidelines from JCOPE, New York state’s regulator.

Here are key points gleaned from the past six months:

1. Corporations and nonprofits alike have stated they find the 92 pages of detailed regulations to be difficult to navigate.
2. We have seen an increased number of audits of both lobbyist and client filings – meaning it’s a good idea to organize and prepare all invoices, checks and internal compensation.
3. Confusion persists regarding whether board members of a hospital must be registered as “designated lobbyists.”
4. JCOPE’s new lobbying application and filing system may require increased time and attention.
5. JCOPE now requires greater specificity in disclosing the bills, public officials or bodies being lobbied.