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 A4, L. 2011. This legislation is meant to increase government transparency and accountability by providing the public with an opportunity to view certain types of interactions between state agency “decision-makers” and individuals or firms who could influence the agency’s decision-making process.
Project Sunlight requires certain campus personnel designated as “decision-makers” and any individuals or firms who could influence the campus' decision-making process to report interactions to the Project Sunlight database within five (5) business days of the interaction. It also requires those individuals to complete annual training.
There are five (5) different categories of appearances:
(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.
Given the nature of SUNY activities, we are most likely to be impacted in the area of Procurement. Reportable appearances in this area include interactions with the potential to result in procurements for goods or services that value $25,000 or more.
Project Sunight Policy
Project Sunlight FAQs
Project Sunlight Database
Identification of Decision Makers and Advisors to Decision Makers
Only government employees who have the power to exercise agency discretion or advise someone who has such discretion need to report appearances to Project Sunlight. The campus will maintain a list of those employees that are required to report appearances, which is based on their job titles and responsibilities. These individuals will be notified on a yearly basis of Project Sunlight requirements by the Finance and Administration division.
Training
Individuals who are identified as potential campus Decision Makers or Advisors to the Decision Makers will be required to complete Project Sunlight training on a yearly basis. The training consists of a PowerPoint presentation, followed by a brief 10 question quiz.
Certification of Training
All Decision Makers and Advisors will certify that they have reviewed the training materials by submitting the Project Sunlight Certification Form to the Purchasing Office on an annual basis.
Designation of Contact person
For questions on how Project Sunlight might apply to individuals, employees can contact the Campus Project Sunlight Liaison, which has been identified by the campus as:
Gretchen Fronczak
Director of Procurement and University Services
Email: Gretchen.Fronczak@fredonia.edu
Phone: (716) 673-3438
Reporting of Qualified Appearances
Campus Decision Makers or advisors to decision makers will be required to report qualified “appearances” with vendors and/or their representatives that could result in a 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, only one appearance will need to be reported. Multiple appearances involving a single procurement will be reported separately.
Appearances will be reported to the Campus’ Liaison, using the Project Sunlight Reporting Form within three (3) days of the appearance.
The Campus’ Liaison will report the appearance information to the Office of General Services (OGS) website within five (5) days of the appearance based on the information that was provided on the reporting form.