Again we're into the difference between the need to file an initial registration.... If the individual is communicating with a public office holder on a registerable activity--it's defined in the act as someone who is receiving payment to communicate for the making, development, or amendment to any proposal or legislation, bill or regulation, or the awarding of any federal grant or contribution. The communication month captures all types of communication, so it's written communication, oral communication. All of those would determine whether an initial registration would then have to be filed. The monthly communication, according to the act, is with a designated public office holder.
On April 20th, 2010. See this statement in context.