Reporting Meals and Beverages Under $50

One of the more frequent expenditure questions our office gets asked involves the lobbyists’ $50 threshold for meal and beverage expenditures.  A misconception is that meals and beverages costing less than $50 need not be reported.  This is not accurate.  Ohio law provides that lobbyists may spend up to $50 per legislator per calendar year without having to disclose the identity of the recipient.  Until the lobbyist has expended $50.01 on behalf of, or for the benefit of, a particular legislator the lobbyist will report the expenditure amount in the Meals Under $50 category on the lobbyist’s activity and expenditure report.  Once the lobbyist has spent $50.01 in a calendar year on that same legislator, all additional expenditures made for that legislator will be reported in the Meals and Beverages category of the lobbyist’s activity and expenditure report.  Those expenditures will disclose the date, name of recipient, a short description of the expenditure, the amount spent and the date the lobbyist notified the legislator that the expenditure was being disclosed.

Additionally, the $50 threshold applies to the recipient regardless of the number of clients a lobbyist represents.  For example, Lobbyist 1 represents Company A, Company B and Company C, while Lobbyist 2 represents Company D.  Both Lobbyist 1 and Lobbyist 2 take Legislator X to lunch at different times to discuss legislation of interest to their client.  Each may only spend $50 on Legislator X before having to disclose the legislator’s identity on their activity and expenditure report.  Lobbyist 1 may attribute a portion of the $50 to each client but Lobbyist 1 does not get to spend $50 on Legislator X for each of her clients before disclosing the legislator’s identity.   

Finally, the $50 threshold for expenditure reporting is only applicable to lobbyists.  Employers of lobbyists must disclose and itemize all Meal and Beverage expenditures regardless of the amount spent.