Project Sunlight Campus Compliance Plan
What is Project Sunlight?
Project Sunlight is a statewide initiative based on the Public Integrity Reform Act of 2011 and omnibus ethics legislation Ch. 399, Part A §4, L. 2011. This legislation is meant to increase government transparency and accountability by allowing the public to see who interacts with New York State employees with respect to five categories of activity:
- (1) procurement of goods and services,
- (2) rate-making,
- (3) regulatory matters,
- (4) judicial or quasi-judicial proceedings, or
- (5) rule-making per the State Administrative Procedures Act.
State agencies are required to utilize the Project Sunlight online database to report “appearances” by individuals and firms who appear before SUNY decision-makers or persons who advise decision-makers (known as advisors.) Given the nature of SUNY activities, we are most likely to be impacted in the area of (1) procurement of goods and services.
Campus Compliance Requirements
The Finance and Administration office is responsible for the administration of this program at the campus of Fredonia The State University of New York. Compliance requirements include the following:
Project Sunlight background, requirements, and other information, including FAQs, are available at the links below.
- Memorandum from SUNY dated December 21, 2012 explains the legislation.
- Project Sunlight webpage, managed by SUNY System Administration, provides comprehensive information about Project Sunlight requirements.
- Identification of Decision Makers and Advisors
Based on job titles and responsibilities, certain individuals are designated as potential Decision Makers and Advisors with influence in procurements of $25,000 or more. These individuals are notified of Project Sunlight requirements by the Finance and Administration Office via email.
Individuals who are identified as potential campus Decision Makers or Advisors are required to view the following training tool: SUNY Project Sunlight PowerPoint Presentation.
For an audio guide to the presentation from a previous Blackboard Collaborate training session view the training session here: Blackboard Collaborate Training Session
- Certification of Training
All Decision Makers must certify that they have reviewed training materials by submitting the Project Sunlight Training Certification Form to the Purchasing Department.
- Designation of Contact person
- Reporting of Qualified Appearances
Campus Decision Makers, Advisors, or others in an influential role are required to report qualified “appearances” with vendors or their representatives that could result in the purchase of $25,000 or more in goods or services (this applies to a single procurement or a multi-year contract). If several campus employees participate jointly in an appearance, all participants can be reported on one form. Multiple appearances involving a single procurement must be reported separately.
Appearances are to be reported to the Finance and Administration Office, using the, Project Sunlight Reporting Form within three (3) days of the appearance.
The Finance and Administration Office, using data from the Reporting Form, will post appearance information to the Office of General Services website within five (5) days of the appearance.
- Annual Campus Certification
- Campuses must provide yearly certification that all qualified “appearances” have been reported and that appropriate campus employees have been properly trained on their obligations under the law.
- SUNY will follow-up with individual campuses when the Project Sunlight website reflects a lower than expected level of actual Project Sunlight appearances.
Further information about Project Sunlight is available on the SUNY Project Sunlight website, including informative FAQs. Additional questions that might arise after review of the training materials may be directed to Shari Miller at 673-3438.