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. The office of Finance and Administration is responsible for reporting qualified campus interactions, referred to as "appearances", to the public database. Our obligation, for the most part, will be the reporting of meetings of influence ("appearances") having to do with procurement and large scale contracts over $25,000. We are mandated to report these interactions within five days of the appearance. Those employees who are identified as potential "decision makers" and "advisors" are required to participate in Project Sunlight training and report any qualified appearances to the Finance and Administration office.
Identification of Desision Makers and Advisors
The Business Office will designate campus Decision Makers and Advisors based on title and job function, according to guidance provided by SUNY. Each Decision Maker and Advisor will be contacted individually and provided instruction as to Project Sunlight Requirements. However, there may be times when an employee not initially identified temporarily becomes a decision maker.
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:
- Procurement of goods and services
- Regulatory matters
- Judicial or quasi-judicial proceedings, or
- 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 Business Office is responsible for the administration of this program at the SUNY ESF campus. Compliance requirements include the following:
- Communication: Project Sunlight background, requirements, and other information, including FAQs, are available at the links below.
- 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 Business Office via email.
- Training: Individuals who are identified as potential campus Decision Makers or Advisors are required to view the following training tool: SUNY Project Sunlight PowerPoint Presentation.
- Certification of Training: All Decision Makers and Advisors must certify that they have reviewed training materials by submitting the Project Sunlight Training Certification Form to the Business Office.
- Designation of Contact Person: For questions on how Project Sunlight might apply to you or your staff contact David Dzwonkowski, Director, Business Affairs, x6642
- 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 Business Office, using the, Project Sunlight Reporting Form within three (3) days of the appearance. The Business 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.