Lobby days, beginning-of-the-session receptions, end-of-session parties, etc., all have to be reported on the lobby reports of those who make the expenditures. These expenditures are often "split expenditures," and several people may be reporting a pro-rata share of the party's expense. If the event provides more than food and beverages (for example, if there is a band and dancing or a fireworks show), you have to break out and report separately the amount spent on entertainment and gifts - as those have annual limits, while food and beverage expenditures do not. Awards and mementos have a limit of $500 per award or memento.
Add that to the fact that you have to keep a close count of which people attend and the reporting category to which they belong (Senators, Reps, guests, spouses and dependent children, legislative or agency staff, etc.) and check to see if you crossed the detail reporting threshold for anyone for the day and before long you have an absolute compliance nightmare.
There may be a better way to ensure compliance. If you invite all members of the legislature to your event, you don't have to do any breakouts or do any counts (other than attributing the per-person entertainment costs and gifts costs to your annual totals). The law and rules don't specify what constitutes an "invitation" or how long you have to issue the invite before the event. Still, the best advice is to do it in writing and early enough so they can realistically attend the event. Remember you have to track any entertainment or gifts associated with the event against each reportable person’s $500 annual limit.
On your lobby activities form, report your portion in lump sum as an "Event to Which All Legislators Are Invited." PAAT Tip: You may subtract tax and tip.
The takeaway is that if you are hosting or co-hosting a big event where it will be hard to keep track of who attended, then make sure you have invited all legislators (all Senators, all Representatives) to the event and report the part of the event for which you paid, in full (no breakouts, no allocations) as a line item and you are through. This will lessen the chance of any unintended reporting errors and ensure greater compliance. AND, remember you have to track any entertainment or gifts associated with the event against each reportable person’s $500 annual limit.
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