Lobbyist disclosure gap (NRS 218H reports vs detected money flow)

What NRS 218H actually requires

Nevada's NRS 218H is the lobbying-disclosure statute. Its expenditure-reporting rule is narrowly scoped: a registered lobbyist must report to the Legislature each month gifts, entertainment, or benefits exceeding $50 in value provided to a legislator, the legislator's family, or staff. Compensation paid by a client to the lobbyist is not covered. Political contributions by the lobbyist are covered separately under NRS 294A (the campaign-finance chapter), which records contributions but does not require lobbyists to consolidate them with NRS 218H disclosures.

What the gap really represents

The gap is not a violation in itself — the disclosure regime simply doesn't ask for the data that would close it. The gap is a structural transparency signal: who relies on lobbying as primary income while the official disclosure record shows them as effectively inactive? A lobbyist disclosing $0 in NRS 218H benefits and receiving $400,000 in cf_expenditures from candidate committees is not breaking the law — but the public-records reader has no way to learn from NRS 218H alone that this lobbyist is in fact a paid agent earning six figures from political committees.

Why the proxy understates real money flow

"Actual money-flow proxy" is intentionally narrow. It captures only money flow visible in NV-state public records: cf_expenditures paid by NV candidate committees / PACs to the lobbyist, plus unambiguous cf_contributions by the lobbyist as an individual. It excludes: client retainer payments (private contracts, not public-records-disclosable), federal lobbying compensation (LDA filings cover this separately for federal-side work, not the NV gap), in-kind value (event hosting, conference comp, travel), and consulting income through the lobbyist's firm rather than to the individual. A real audit would access the lobbyist's IRS Form 1099 pool — which is not public.

What journalists / researchers should do with this

For any high-gap lobbyist below: pull their NRS 218H monthly reports from the Legislature website, then pull their cf_expenditures payee record from the campaign-finance database. The contrast between the two — what's disclosed vs what's evidently being paid — is the FOIA / public-records story. Where the gap is large enough to suggest the disclosure regime is misclassifying a regular compensation stream, that's a candidate for a public-records request to the Legislature for the underlying retainer agreements (often kept on file by the Legislative Counsel Bureau as part of registration).

Gap-score formula

Gap score = log10(gap_dollars + 1). A gap of $1M scores 6.0; a gap of $100K scores 5.0; a gap of $10K scores 4.0. The log scale keeps mid-range gaps visible alongside the highest-magnitude ones, so a $10K gap in a small-roster lobbyist's record doesn't disappear next to a $1M gap from a top-rung firm.

Citations

NRS 218H (Lobbying — registration and disclosure). NRS 294A (Campaign finance). POGO + Government Accountability Institute methodology on disclosed-vs-actual divergence. NV Legislature lobbyist registration system at leg.state.nv.us/Lobbyist/ (the source of the disclosure side of this comparison).