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Q: Can I reach out to the ��������Congressional Delegation or their staff to advocate for continued or uninterrupted federal research funding (or other related topics)?

Short Answer: Yes, but it is highly recommended that you do so using your personal time and resources. Using university time and resources - including your @alaska.edu email - requires additional disclosures and actions to comply with state and federal laws, and if done carelessly, may run afoul of them. For more, view these memos on ethics and political activity, and this guidance on the Federal Lobbying Disclosure Act. 

Detailed Answer: First and foremost, all UA system employees have a First Amendment right to petition their elected officials whenever they want. Consistent with that right, employees using their personal time and resources (including personal email addresses) can reach out, describing their personal experiences and impacts as they see fit. It is perfectly fine to say that you work at the University and are receiving federal agency funding when commenting in your personal capacity. 

The ��������Executive Branch Ethics Act does not prohibit lobbying efforts by employees using University resources. However, the Office of General Counsel has consistently recommended that employees use personal emails and resources when lobbying for several reasons, among them:

1. Compliance with the federal Lobbying Disclosure Act. To comply with the Lobbying Disclosure Act, UA employees who want to reach out in their official capacity as a University employee with a request for an elected official to take an action or position regarding any federal matter need to coordinate that effort with the University’s Federal Relations team.
   
   
1. For example, if a researcher wants Senator Murkowski to reach out to NSF to urge the agency to restore cut funding, we recommend contacting us first, as that request will be considered lobbying, which must be tracked and reported in accordance with the Federal Lobbying Disclosure Act.   
   
   
2. UA email accounts are also subject to the ��������Public Records Act (ARPA). They may be subject to requests for public records under the APRA and ultimately publicized without our consent in ways that are not consistent with the intent of our message. (Employee use of personal emails for individual outreach to legislators would not be subject to the ARPA.) 

For these reasons, it remains the recommendation of the Office of General Counsel that employees use personal resources and time when potentially engaging in lobbying activities. 

The Office of General Counsel has specific resources available on its website which provide some guidance on this topic. These memos can be found here (/counsel/ethics-information/ethics-and-politically-re/index.php).

In addition, employees can obtain more information and guidance on the federal Lobbying Disclosure Act on the UA Office of Government Relations website here (/govrelations/federal/lda-compliance.php). 

On January 27, the Office of Management and Budget (OMB) issued , which temporarily paused federal grants, loans, and other financial assistance programs. The memo was rescinded on January 29.

A lawsuit brought in federal court by nearly two dozen states challenged the legality of the funding freeze. This lawsuit has proceeded despite the rescission of OMB Memo M-25-13. 

On February 3, the court extended a temporary restraining order (TRO) that prevents the federal government from interfering with active awards unless they do so in accordance with the terms of each individual grant, and also prevents agencies from freezing or stopping funding while they review and evaluate current funding. This TRO remains in effect until further notice. Although the language of the TRO is directed at State institutions, the Department of Justice has determined that it applies to all award recipients.

This means that agencies will continue to review existing grants for compliance with recent executive orders. PIs should continue working according to the existing terms of their awards but be prepared to make modifications if requested to do so by the funding agency.

What to Know

Several executive actions from the federal administration concern DEIA. In the short term, blanket orders to stop DEIA work are covered under active temporary restraining orders (TROs) and can’t be executed. Agencies can review individual contracts and attempt to amend or change them in line with executive actions, but those amendments and changes need to have specific definitions and guidance from the federal government on what constitutes DEIA in order for us to make actual determinations about what qualifies.  

For non-research-related activities, we are waiting to receive specific definitions and guidance from the federal government on what constitutes prohibited DEIA activities or programs for us to make actual determinations about what current University activities might qualify, and that guidance from the federal government has not yet been provided.

UA Leadership and general counsel’s office are also exploring whether clarifying language on university websites may be necessary to make unambiguous our compliance with state and federal laws, as well as the inclusive nature of our activities. Responsible units will be contacted directly only if such changes are determined to be necessary.

What to Do

Researchers/Research-related activities

• Continue billing, working, and researching as usual. Refer to the appropriate Agency-Specific Guidance below for your funding Agency, if any, as well as any other directions on this page regarding research. 
• If you have further questions or concerns, engage with your grants and contracts office and contract administrator for clarity. 
• As needed, the grants and contracts offices may seek tailored guidance from the general counsel’s office. 

Non-research-related activities

• Continue working as usual. 
• If you have specific questions or concerns, reach out to your supervisor or Director, who may engage with the student services vice chancellors and general counsel as needed.
• Watch for further direction from your supervisor or University leadership.

Feb. 10, 2025

Recently, the Trump Administration revoked a long-standing policy that limited immigration enforcement activities in “protected” or “sensitive” areas, including traditionally on college campuses. As a result, we may begin to see ICE or other enforcement agencies (DHS, FBI, etc.) begin to conduct immigration enforcement actions on our campuses. Unlike other states, ��������does not have any laws or regulations regarding how individuals or organizations are to act when approached by federal enforcement agencies. If you encounter ICE or other immigration enforcement activities on campus, please keep the following general guidance in mind.

• As public institutions, much of our campuses are “public” spaces that are open to the public, either 24/7 or during normal business hours. Immigration enforcement agents do not need a warrant or other authorization to be present in such locations, or to conduct enforcement efforts in such locations, during times when such spaces are typically open to the general public. If you see such activities in locations that are generally open to the public, please report that activity to your campus leadership and/or the Office of the General Counsel (legal@alaska.edu).
  
  
• Examples of public spaces may include (non-exclusive):
  • Most Campus exterior spaces;
  • Libraries;
  • Classrooms (other than those in secured access facilities);
  • Building foyers and hallways (other than those in secured access facilities);
  • Student union or student commons locations; and
  • Dining, recreation, and shopping facilities (e.g., bookstores) open to the public.
    

• Access to private spaces, or any location in which an individual may have a reasonable expectation of privacy, typically requires a warrant or valid consent for access. If you receive a request to access private spaces without a warrant, please inform that individual that they should contact the Office of General Counsel and/or University Police, where applicable, to obtain consent and/or to arrange access. Avoid making any comments or promises that might be considered consent to enter. A statement such as the following would be appropriate in most situations: “I am not authorized by the University to consent to your access to this location for this purpose. Please provide me a copy of any warrant or other authorization you have to enter this private space, so that I can forward them on to someone with the necessary authority.” 
  
  
• Examples of private spaces may include:
  • Individual offices and non-public administrative locations that require access permission or have specific access controls (card or key access);
  • Personal residential spaces, such as student housing rooms, other than common areas which may be considered public spaces;
  • Locations where confidential services are provided, including, for example, counseling and healthcare examination or limited access spaces;
  • Secured research spaces where confidential, restricted, or controlled research is being conducted, unless such spaces are otherwise open to the public on a regular basis;
  • Locations where a reasonable expectation of privacy might attach, such as restrooms, locker rooms, lactation spaces, etc.

• If you are presented with a written warrant and ICE or the enforcement agents refuse to wait for you to contact leadership, please do not physically obstruct access and contact the Office of General Counsel (legal@alaska.edu and/or 907-450-8080) and your campus police, if any, immediately. 

• If you are unsure about a specific encounter, please contact your campus leadership and/or the Office of the General Counsel for additional guidance and direction.

• Federal agency submission portals are operational, and we will continue facilitating proposal submissions as usual.
• Proposal review timelines at sponsoring agencies may be extended during the transition period.
• Some federal agencies have canceled posted requests for proposals (RFPs) etc., pending program reviews.

General Information

• The terms and conditions of executed awards remain enforceable, but the ability to invoice and receive reimbursement currently varies. Where possible, work under executed awards should proceed business as usual. 
• Formal changes to awards will come through an amendment from the agency for review and execution via your university’s grants and contracts office.
• If there are changes made to research compliance requirements or award reporting requirements, we expect they will be made on a project basis pursuant to the terms of each individual grant or contract, as noted above. Work with your university’s grants and contracts office and General Counsel’s office if necessary to review these changes and determine how to comply with them if necessary.
• If specific programs are terminated or restructured, you may encounter difficulties accessing funds or meeting new criteria. Federal agencies managing these programs will typically issue guidance on how to proceed. Engage with your university’s grants and contracts office for further guidance.
• If a program or initiative is reduced or de-funded, there could be delays or pauses in payments for existing grants under those programs. This is rare, and would only potentially occur if funding for a program is rescinded or redirected.

What to do:

• Review your grant agreement: Ensure you understand the terms, especially clauses related to funding availability and reimbursement.
• Closely monitor budget obligations to avoid overspending award accounts while awaiting anticipated future funding.
• Attempt and document your efforts to communicate with your grant officer: Stay in contact with your program or grant officer to confirm that there are no changes affecting your award.
• Reports and deliverables: Continue to submit required reports and deliverables to your sponsoring agency on time. Prioritize the submission of any materials that may be past due.
• Monitor policy updates: Keep an eye on announcements from the agency overseeing your grant for any updates on funding or compliance updates.
• Review information on your granting agency in the Agency Specific Guidance and Information section below. You may need to review your project. You should be prepared to adapt or make modifications in consultation with your program officer.
• Contact your university’s grants and contracts office if you have questions about compliance with new guidelines or requirements