Weeks before Election Day, Sen. Roger Marshall’s reelection campaign was spending heavily while reporting no payroll. The Kansas Republican’s latest Federal Election Commission filing showed no outgoing payments labeled as payroll or salary from July through September, despite spending $5 million during that period.

That spending represented a striking leap from just under $50,000 in the previous quarter. It came as Marshall’s once safe Kansas seat became competitive and his Democratic challenger, Adam Hamilton, began gaining momentum.

Operating a campaign without paid employees is legal because candidates can rely on consultants, vendors and volunteers. Still, the arrangement is highly unusual in a Senate contest and leaves unanswered questions about who is handling the daily work of Marshall’s campaign.

It also raises questions about whether Marshall’s taxpayer funded official staff is performing campaign duties. Senate rules prohibit official staff from campaigning on government time or with government resources, although aides may volunteer for their employer’s campaign during their own time.

Previous reporting suggests Marshall may have used taxpayer funded congressional staff during his 2020 Senate campaign. A joint investigation published earlier this month by MS NOW and the Kansas Reflector obtained recordings, photos, videos, text messages and calendar entries that appeared to show congressional staff and government resources being used in ways experts said likely crossed the boundary between official work and campaigning.

One example involved a 2020 trip to Dallas. Notes from a former staffer indicated that Marshall used campaign money for flights and taxpayer funds for a meal, while the only official event on his calendar was a Zoom meeting placed among campaign events.

The investigation also found that nobody working for Marshall’s campaign had received a paycheck during the past five years. A lawyer for the campaign previously said Marshall and his team “fully comply with both FEC rules and Senate ethics.”

Marshall chief of staff Brent Robertson told MS NOW at the time of the Oct. 9 report that the campaign had some paid staff. A section on Marshall’s campaign website also says he “has a full campaign team that is separate from his official office staff.”

The new filing, however, identifies nobody receiving a salary through the end of September. It does show $6,000 paid to a Virginia based firm for “communications consulting” and $2,000 for “campaign consulting” to a woman who identifies herself on LinkedIn as a press assistant in Marshall’s Senate office.

Neither payment is specifically labeled as salary or payroll. When MS NOW asked about staffing, the campaign referred the outlet to an Axios report about Republicans scrambling to protect the seat.

That report noted the recent hiring of Chris Grant, who worked on Marshall’s 2020 campaign and helped lead the main super PAC supporting President Donald Trump in 2024. The campaign did not immediately answer whether Grant would appear on its next FEC filing.

Craig Holman, a government affairs lobbyist at Public Citizen who works on ethics and campaign finance rules, said the filing “just doesn’t make sense.” Holman added, “I’ve never heard of a candidate for Senate not hiring campaign staff. It sounds like Marshall is just abusing his regular staff.”

Brendan Fischer, director of strategic investigations at the Campaign Legal Center, called the lack of listed payroll expenses “certainly anomalous for a U.S. Senate campaign.” He said some consulting expenses could be included in the millions of dollars reported for television and digital advertising.

Fischer also said Marshall may not have treated the contest as serious until recently, meaning some staffing costs might appear in the next report. Another possibility he raised was that some workers may not be paid until after the campaign.

MS NOW found that incumbents in other closely watched Senate contests reported tens of thousands of dollars in payroll for multiple staff members during the same three months. They included Sens. Jon Husted, Dan Sullivan, Susan Collins, Darline Graham and Jon Ossoff, with Ossoff the only Democrat in the group.

Even incumbents in races considered nearly decided in New Jersey, Delaware, West Virginia and South Dakota reported payroll expenses. Sen. Tom Cotton was an exception, reporting tens of thousands of dollars in consulting payments but no entries specifically identified as salary or payroll.

Hamilton campaign spokesperson Glynnis Harvey called the contest one of the nation’s most competitive Senate races and said Marshall had never reported paid campaign staff. Harvey argued that the emerging details warranted an ethics investigation.

Kansas has not elected a Democrat to the Senate since 1932. Marshall won his Senate race six years ago by 11 points, and Trump carried Kansas two years ago by more than 16 points, but recent polls show Marshall and Hamilton neck and neck.