Joint Legislative Ethics Committee

Office of the Ohio Legislative Inspector General

Financial DisclosureLobbying

Gift Reimbursement

A reportable person may reimburse a lobbyist or employer for any expenditure made for their benefit. However, there is an important distinction to make when a reportable person partially reimburses the lobbyist or employer for a reportable gift.  A reportable gift is anything of value, excluding a meal or beverage, given to or made for the benefit of a reportable person that exceeds $25.00 in value. [See Ohio Lobbying Handbook p. 41]

When the original value of a gift is greater than $25.00, a reportable person must reimburse for the total value of the gift in order to avoid reporting on the lobbyist’s or employer’s activity and expenditure report (AER).  [See OAC 101-9-01]

For example, Company ABC presents Legislator Doe with a Legislator of the Year award valued at $40.  Legislator Doe must reimburse the total $40.00 value in order to avoid reporting on ABC Company’s corresponding AER.   If Legislator Doe reimburses only $15.00, Company ABC is still required to report the remaining $25.00 gift on their corresponding AER.

*The partial reimbursement scenario outlined above is specific to expenditures classified as gifts. 

**Lobbyists and their employers are reminded of the requirement to retain records and receipts of all expenditures.  [See R.C. 101.73(E), 121.63(F), 101.93(F)]