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.
We are required to utilize the Project Sunlight online database to report "appearances" by individuals and firms who appear before SUNY Potsdam 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 Purchasing & Payables Office is responsible for the administration of this program at the SUNY Potsdam campus. Compliance requirements include the following:
Project Sunlight background, requirements, and other information, including FAQs, are available at the link below.
- Memorandumfrom 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 Compliance Training Coordinator via email.
Individuals who are identified as potential campus Decision Makers or Advisors are required to take the mandatory training bi-annually at WeComply Sign in.
- Certification of Training
All Decision Makers and Advisors will receive a certificate at the end of the WeComply training module that can be printed, but is not necessary to do so.The College will automatically receive confirmation that you have completed the module.
- Designation of Contact Person
For questions on how Project Sunlight might apply to you or your staff contact Mark Martinchek, Director of Procurement, x3106
- 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 Office of Procurement & Travel Services, using the Project Sunlight Reporting Form within three (3) days of the appearance.
The Purchasing & Payables 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 Mark Martinchek at firstname.lastname@example.org or ext. 3106.
Requirements for Designated Decision Makers and Advisors
All designated Decision Makers and Advisors are required to participate in Project Sunlight and report and qualified campus interactions with vendors or others.
All qualified appearances must be reported to the Purchasing & Payables Office within three days of the appearance using the form below.The internal deadline enables the campus to report to the Office of General Services (OGS) within the five day requirement.