‘Ticket-Splitting’ is Common

Lobbyists can obscure the identity of officials entertained

Disclosure reports released last month show that Virginia lobbyists use an accounting procedure that can obscure the identity of legislative and executive officials who accept free meals.

The procedure – legal under Virginia law – involves splitting the cost of meals among different lobbying clients. This transforms a single outing into multiple, less expensive meals that fall below the $50 per-person threshold for disclosing recipients’ names.

Ticket-splitting occurred in more than half of 118 meals and social outings of 20 people or fewer reported during the 2022 General Assembly session.

Share of General Assembly Dinners with Split Tickets

Note: Percentage of meals and social outings of 20 or fewer people during the annual legislative session in Richmond that involved lobbyists splitting the cost among two or more clients.


How 'split tickets' work

In Virginia, lobbyists can provide free meals and entertainment to legislative and executive officials. Lobbyists are required to disclose officials' names when the cost per person exceeds $50. In practice, most lobbyist entertainment disclosures do not name names.

This winter, 7 of 118 Entertainment Reports Contained Names

Note: Based on 118 meals and social outings of 20 or fewer people disclosed in lobbyist entertainment reports covering the 2022 legislative session in Richmond.


Not every dinner is expensive enough to trigger a lobbyist to disclose the names of officials entertained. Some meals take place in BBQ joints or pizza parlors, where one would be hard-pressed to spend more than $50 a person. Some legislators pay for their own meals.

But the biggest reason during the 2022 General Assembly session was bill-splitting. More than half of the 118 dinners and gatherings of 20 or fewer people involved split bills. Here is how it works:


How one meal can turn into three meals

Virginia's disclosure rules allow two or more lobbyists to split the costs of a single meal. A lobbyist can distribute the cost of a single meal across multiple clients. This can drive down the per-person cost to $50 or less.

In the hypothetical example above, a Senator was treated to a $90 dinner. The lobbyist split the bill among three different clients. Later, the lobbyist filed three separate entertainment reports, each with a per-person cost of $30. As a result, there was no requirement to disclose the Senator's name.


More information on lobbyist entertainment:


The Richmond Restaurant Scene

* The calendar includes all lobbying entertainment reported from May 2021 through April 2022, not just those that took place in Richmond during the 2022 General Assembly

Source: Schedule A (Events, Entertainment, Meals and Travel) listed in lobbyist disclosure statements covering activity from May 1, 2021 through April 30, 2022 filed with the Virginia Ethics Council

Aug. 24, 2022