URMC Compliance Program Policy Manual:
Political Contributions

URMC believes that our democratic form of government benefits from citizens who are politically active. For this reason, the System encourages each of its employees and staff to participate in civic and political activities in his or her own way.

An organization's direct political activities, however, are limited by law. Corporations may not make any contributions - whether direct or indirect—to candidates for federal office. Thus, a corporation may not contribute any money, or lend the use of vehicles, equipment, or facilities, to candidates for federal office. Nor may it make contributions to political action committees that make contributions to candidates for federal office. No URMC entity may require any employees or professional staff members to make any such contribution. Finally, no organization may reimburse its employees or professional staff members for any money they contribute to federal candidates or campaigns.

Violation of federal election laws carries potential criminal penalties of up to one year in jail and a fine of $25,000 or three times the amount of the illegal contribution, whichever is greater. Civil penalties also may be assessed.

New York law prohibits corporations from contributing more than $5,000 annually to political candidates or organizations. The law prohibits not only cash contributions, but also contributions "in kind" such as office space, goods or services, in excess of $5,000 annually.

Consistent with its charitable purpose, URMC entities should not carry on "propaganda" or attempt to "influence legislation," as these acts are defined under the Internal Revenue Code. The URMC entities and their representatives may not participate in or intervene in any political campaign for or against any candidate.