Advocates wrote 830 individually scripted comments on regulations.gov, and sent separately over 8,000 letters to Congress – in just 60 days.
And they did it despite the trickier task of motivating advocates to post comments on regulations.gov rather than just writing to Congress.
Below is a walk-through of the methods they used.
Like You, SHRM Does Grassroots and Government Affairs
The Society for Human Resource Management (SHRM) is a professional society with 285,000 U.S. members, and over 575 chapters in all 435 congressional districts.
Like many government affairs departments, SHRM needs to actively monitor multiple major public policy issues, including healthcare, employee benefits, immigration, labor and employment, and workplace flexibility.
Turning Your Pain Points into a Strategy
When the Obama administration asked the Department of Labor (DOL) to reassess regulations on employee overtime, SHRM paid close attention.
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As a result, the DOL proposed regulations making changes to the overtime exemption, including an increase in the salary threshold to qualify for an exemption from overtime. In the past, such recommendations had updated the threshold by pegging it to the 20th percentile of full time salaried workers in lower wage industries and areas of the country.
But this time the DOL proposed to peg the new threshold at the 40th percentile, resulting in 113 percent increase in the salary threshold.
While acknowledging a need for modernizing the regulations, SHRM also knew that such a dramatic change would have a huge impact on all of its members, particularly ones who run small businesses, nonprofits, local governments, or are located in lower-wage geographic areas.
Plus, they knew there would be only a small window of time to rally their advocates to take action – the comment period for the proposed regulations was only 60 days.
In order to respond effectively, SHRM took inventory of what they were up against to turn their pain points into a strategy.
First, they considered their major pain points:
- Small window of time (60 days) in which to act
- The response would require a coordinated, enterprise-wide effort from their organization
- Letters to Congress would be needed, but letters alone would not move the needle on regulations
- Unlike legislation, very few people understand the regulatory process – getting members to take action on them would be a challenge
- To wage a sustained campaign, they would need to keep their members informed and active for two full months – without overloading them
Then, they turned those pain points into tactics:
How to Operate in a Small Window of Time (60 Days)
SHRM got their internal campaign underway by making sure everyone enterprise-wide was up to date on the campaign’s agenda.
“Was our HR team briefed on this? Was our legal team briefed on this? Was senior leadership, or anyone doing a presentation in front of members?” says Meredith Nethercutt, Senior Associate for Member Advocacy at SHRM.
“We wanted to make sure that they could answer questions. We prepared power points and slides everybody could use, so we could make sure our advocates would be well-versed on this, and on what we would need them to do.”
Once the proposed rule was released in June 2015, their legal counsel went through the entire regulation, then government affairs did a synopsis to determine the points they would focus on.
Then they crafted SHRM’s comments to the DOL, and prepped the editorial department covering the issue in printed material such as the magazine, eNewsletters and blogs.
That meant they were left with a little over a month to get their members and advocates comments collected for posting on regulations.gov.
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The individual comment period was the crux of SHRM’s grassroots campaign.
They already had a robust grassroots system in place with an advocate database powered by FiscalNote Advocacy, handled by Nethercutt and the government affairs team.
“Members and advocates don’t have time to read a proposal rule. We needed to tell them this is how it was going to impact them,” says Nethercutt. “That’s how SHRM is helpful to them, in offering guidance. So, inevitably there was a slight delay while we were getting our own house in order.”
As well as going through the entire regulation (hundreds of pages in length) SHRM began laying the backend groundwork so that everything would be in order when they went to their advocates with the “ask”.
What a Robust, Multi-Channel Advocacy and Engagement Campaign Looks Like
With all the internal communications systems in place, next came getting the hub, their online advocacy action center, up and running.
SHRM already had a sophisticated legislative action center operating through one of FiscalNote's advocacy solutions.
But they didn’t stop there.
They created a secondary microsite for the overtime regulation, so their advocates would have a place to go and take action and a resource going forward.
“We created a separate URL that could be easily remembered,” says Nethercutt.
"Then we had to figure out how we would communicate to the Department of Labor, during their public comment period. There were also several “heads up” emails to advocates.”
With everything in place, they sent out their call to action to all their members and advocates.
“We said, ‘Now is the time when you can raise your voice and share your potential impact as a result of this regulation.’”
Creating an Effective Call to Action that Your Members Will Actually Follow-Through On
“The call to action was similar to one to contact Congress, but we chose to not offer a template comment letter,” says Nethercutt.
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There was an element of risk there. If they could pull it off the impact would be greater than using a form letter, because the individual comments would tell broader, more personalized stories. The regulation was likely to impact different HR professionals and employers in very different ways, so SHRM’s advocacy team wanted to show the many ways the regulation would have far-reaching effects in a way that would have an impact on the DOL.
But the risk was that without a template comment already created, advocates may not feel that they had the time to describe how the regulation would impact them, or go to the trouble of taking action at all.
There was also the danger that advocates might leave comments that the regulation wouldn’t affect them.
“We did not regulate any of the responses going to the DOL,” says Nethercutt. “So, if we had a member comment saying this regulation would not really have much impact on them, we didn’t screen it. We wanted to make sure the full response of the HR profession was appropriately shared with the DOL. But the vast majority of comments were that the rule would impact them in a significant and negative way.”
To make things as easy as possible for their advocates, SHRM offered 8 bulleted points they would be focusing on in their letter to the DOL, and made sure those were front and center on their advocacy action center.
“These are the top 8 potential impacts we think will have a huge effect on the profession and your employers and employees.”
To further drive home the message they also included those points in the communications they sent out.
These were used as writing prompts that advocates could incorporate into their individual comments.
“We offered suggested points that SHRM would be focusing on in our comment letter. But we really left a blank slate for them to craft their own comments, because we decided we wanted a quality over quantity effort.”
Multi-Channel Approach to Mobilizing Your Members
Because the DOL’s regulation had already been established as an organization-wide priority, the government affairs team had their call to action added to SHRM’s homepage, too. That ensured that not just their advocates, but ALL their members would see it if they visited the website for any reason.
They continue to keep the issue front and center as they fight it in Congress.
Make Things as Easy as Possible for Your Advocates to Take Action
Using FiscalNote Advocacy, the link to take action was hosted on their advocacy action center. Members could read a notice about the regulation and click “Take Action.”
From there they were redirected to an online form where advocates saw an issue alert calling for the submission of comments, similar to one they would use when sending a letter to Congress:
“We tried to make it as clear and as brief as possible,” says Nethercutt.
“They’d see a little bit of language about the proposed rule, the impact on the profession, and how it was critical to share the impacts of their organization in their area.”
When a potential advocate clicked on ‘Take Action’ they would be directed to a page with a vacant text box. Beside the text box were the 8 bulleted focus points and the words:
“Here are some of the potential impacts to the profession. Please feel free to address the following points in your letter to the DOL.”
The online form also told members to include the number of locations and employees they had. Then they would put in their name, address, company, and hit submit.
But that wasn’t all.
Save Members Time and Get More Action with the Two for One Method
After hitting submit, advocates would then be taken to another screen where they’d see that their comment was also going to their members of Congress using FiscalNote Advocacy zip code matching feature.
SHRM knew that the regulation wasn’t the only stop on this ride. There was likely to be congressional activity, too.
“We played a long game and proactively had a copy of these letters sent to members of Congress, the House, and Senate, too,” says Nethercutt.
“We wanted to make sure our members knew we were on the front lines from start to finish of this whole regulatory process.”
Use the Comment Period to Strengthen Your Message
For the month or so advocates were busy crafting their individual comments, behind the scenes SHRM’s government affairs team was doing a deeper dive into the regulation.
After SHRM had crafted their own comment letter to the Department of Labor, they sent it to their 50 state councils, as well as all of their chapters, and invited them to sign on as a way to show the regulation’s nationwide impact on all SHRM members.
The result was a new record for SHRM. All 50 state councils and 307 chapters signed on to SHRM’s comment to the DOL on the regulation.
The government affairs team also encouraged their state affiliates to send in their own organizations’ comment letters, to amplify the push.
In the meantime, the individual comments were racking up on regulations.gov
In less than 60 days the DOL had 830 individually-scripted comments from advocates telling their story, as well as SHRM’s own co-signed comment letter, and their chapters’ organizations comment letters.
But as the avalanche of comments continued to land at DOL’s door, SHRM didn’t stop with their push.
As part of a member service and education effort, the government affairs team and legal counsel presented two webcasts to members shortly after the rule was released.
Due to their efforts to contact members and advocates regarding the regulation, they had a phenomenal response rate of 12,000 people joining the webcast.
“As it would really affect them, we also followed up with a specific webcast to the nonprofit community,” says Nethercutt. “We wanted to make sure they were aware of what was coming.”
How to Get Your Members to Keep Taking Additional Actions
Part of SHRM’s engagement strategy with the regulation was to push breaking news notifications with their advocacy app, on social media and through emails.
As the comment period came to an end, they looked at other ways to keep their advocates and members engaged on the issue. One was through a blog on their advocacy action center.
“That got a lot of traction particularly with the overtime issue,” says Nethercutt.
SHRM already had an advocacy blog feed set up through FiscalNote Advocacy that they used as a way for members to submit an entry about how much the regulation was going to impact them.
“Or they could submit a blog about how they were going to take action on this regulation. It had a bearing because it wasn’t coming from SHRM. It’s peer to peer and in our members’ own words.
“We encourage any kind of blog content. It could be someone’s first trip to D.C., or how they had a legislative meeting, but we made sure to encourage submitting a blog as part of this overtime campaign, and then we showcased those posts.”
The government affairs advocacy team also used social media as a way to issue alerts, keep members informed on updates, and encourage them to take further action.
Simultaneously, through FiscalNote Advocacy, they ran a Twitter alert on the overtime issue so members could tweet their members of Congress, and anyone else, about the issue.
Don’t Wear Your Advocates Out
“We definitely didn’t want to burn our members out with too many calls to action, so we initially sent out the big push for comments, which had a clear cut deadline. But then, within an alert, we also said here’s how else you can take action, and listed “Tweet Your Lawmakers” as one of them,” says Nethercutt.
As SHRM’s members are very active on Twitter, they included the advocacy Twitter feed on their action center, giving supporters another chance to engage.
Another action alert called on members to “Share Your Story” by asking them to repurpose what they had posted on the regulations.gov site.
“We needed to collect testimonials from our members because the comments were going to the DOL, but we didn’t want to poach from their comments. We had a great response to that,” says Nethercutt.
The team also encouraged advocates to meet with their member of Congress back home, and talk to them about the regulation. They then linked them to an article on district meeting best practices.
They also regularly encouraged members to download the advocacy app to stay up to date.
“Our major focus initially was to get comments, but we always made sure to give them something else to do,” says Nethercutt.
How to Get 8,000 letters to Congress
By early this year advocates would have something else big to do.
SHRM knew that legislation on overtime pay was about to be introduced in Congress.
In mid-March, they briefed the 200 members attending their annual fly-in day to Capitol Hill.
The next day the legislation was introduced and their members who had visited were fired up and ready to rally the troops in their districts.
“We knew legislation was about to be introduced so we were able to say to our members ‘Senator Scott is about to introduce this bill.’
Because SHRM’s broader membership and advocates had already been primed on the DOL’s regulation in 2015, and were getting regular updates using all of the tools above, they were ready to take action in the more traditional way of writing to Congress as soon as the legislation was introduced.
In just one month, from mid-March to mid-April, 8,000 letters had been sent to Congress by SHRM’s advocates, through their advocate action center, hosted by FiscalNote Advocacy.
“It’s all about building the advocacy base and bringing members into our efforts,” says Nethercutt.
We’d been keeping them up to date as best we could, and they’d been paying attention to what SHRM had been putting out, so they were very prepared when something happened. But it was pretty fantastic.”
For the legislation action, SHRM didn’t want to waste a lot of time before they took action. Because they’d already laid the groundwork, they didn’t have to.
“When it was time to hit “go” they didn’t have any questions, and didn’t need any background information,” Nethercutt says of SHRM’s advocates. “They were ready to go.”
Measuring the Impact on Member Satisfaction (Which Soared)
SHRM surveys their membership regularly throughout the year and has a research team that monitors member satisfaction.
“We always include government affairs in our surveys and quarterly benchmarking,” says Nethercutt. “And it always scores very highly because most of our members don’t have the time, expertise or bandwidth to monitor everything that’s going on at the state and federal level, so the appreciation of our existence in the organization is typically very high. But this past year our membership was particularly positive for our resources, thought-leadership, and general government affairs existence and tools.