In all likelihood, perhaps that isn't an ADM. So that person would be a designated public office holder with the attendant responsibility to file a monthly communication report—but that person alone; you're correct. Other people in an office like that, or in any government office, would not be designated public office holders. It doesn't mean there wouldn't be a need to register for lobbying activities, if you're communicating with them, but there would not be that need to file the monthly communication report.
On April 20th, 2010. See this statement in context.