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.
