Project Sunlight Overview
Background
Project Sunlight is a component of the Public Integrity Reform Act of 2011(Ch.399, Part A, Section 4, L2011) that became law effective January 1, 2013. It is meant to increase government transparency and accountability, it is an online database that gives the public an opportunity to see what individuals and entities are interacting with State entities in five categories: procurement, rate-making, regulatory matters, judicial or quasi-judicial and rule-making.
SUNY campuses are impacted by the procurement category. Procurements of $25,000 or greater with 1 vendor over a 12 consecutive month calendar period (Procurement Lobbying Act) are reportable on Project Sunlight if they meet the reporting requirements outlined below and in the Training Presentation (pptx).
The Procurement and the Risk Management and Administrative Compliance Departments are responsible for the administration of this program.
SUNY Poly employees are required to report appearances by individuals and firms who appear before procurement decision-makers or before the persons who advise the decision-makers ('advisers'). These appearances must be reported on Project Sunlight within 5 business days of the occurrence if feasible. Campus procurement decision-makers and advisers should complete the Reporting Form (pdf) and fax to Procurement (315-792-7831) or download, scan and email to Procurement at procurement@sunypoly.edu within 3 business days so that Procurement can report it on Project Sunlight within 5 business days of the occurrence.
Determining the procurement decision makers and advisors will depend upon the facts of a particular procurement and we should err on the side of caution in determining this.
People that are procurement decision-makers and advisers should view the Training Presentation (pptx) for training and then submit the Training Acknowledgement form (pdf) to Procurement. Procurement will maintain the required training record.
Procurement Appearances covered by this legislation are:
- In person meetings
- Conferences (other than in a public area involving multiple vendors)
- Video Chats
- Each meeting is a separate reportable appearance. Formal as well as informal conversations, sales pitches and cold calls are considered recordable appearances.
- Appearances that are for the purpose of procuring a state contract (including purchase orders) whether or not a specific procurement is anticipated must be recorded.
- Appearances by an individual appearing on behalf of him/herself must also be reported.
- Appearances at the request of a state entity that are purely informational don't need to be recorded UNLESS during the appearance the vendor/contractor begins to advocate its products and or services or the possibility of a state contract/purchase order.
- Appearances by individuals and/or representatives of existing state contracts do not need to be reported if pertaining only to those approved contracts.
- Written communications such as forms, faxes, letters and emails are not considered appearances. Appearances that occur during the Restricted Period as defined under the Procurement Lobbying Act need not be recorded.
Complete the Reporting Form (pdf) with 3 days after the appearance and submit to Procurement at procurement@sunypoly.edu or FAX to Procurement at 315-792-7831. Procurement will enter the data on the Project Sunlight state database.
Remember: These appearances must be reported on the Project Sunlight database within 5 business days of the occurrence when feasible.
- Written communications such as forms, faxes, letters and emails are not considered appearances.
- Communications at the request of the University that are purely informational are generally not appearances that need to be recorded UNLESS during the appearance the vendor/contractor begins to advocate its products and or services or the possibility of a state contract/purchase order.
- Appearances by individuals and/or representatives of existing state contracts do not need to be reported if pertaining only to those approved contracts or during restricted period (the restricted period is the time between the earliest written notice of a request for proposal or advertisement and the final contract award.)
- Communications with qualified Minority/Women Owned Business Entities (M/WBE) are exempt.
