Responsible Office: Associate Vice President for Budget & Business Affairs
Policy Type: Business Affairs
Policy Number: 224
Last Date Revised: 6/26/17
Project Sunlight Overview
Project Sunlight is a component of the Public Integrity Reform Act of 2011(Ch.399, Part A, Section 4, L2011) that was was effective January 1, 2013. 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 $25K or greater with one 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 Binghamton University Training PowerPoint (320KB, pptx). Purchasing and the Risk Management and Administrative Compliance Departments are responsible for the administration of this program.
What are Project Sunlight Procurement Requirements?
Binghamton University employees are required to report appearances by individuals and firms who appear before purchasing 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 purchasing decision-makers and advisers should complete the Reporting Form (pdf 115KB) and fax to Purchasing (X72338) or download, scan and email to Purchasing at email@example.com within 3 business days so that Purchasing can report it on Project Sunlight within five business days of the occurrence.
How Do I know if I am a Procurement Decision-Maker Or Advisor? What About Training?
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 purchasing decision-makers and advisers should view the Binghamton University Training PowerPoint (320KB, pptx) for training and then submit the Training Certification Form (docx, 20KB) to Purchasing. Purchasing will maintain the required training record. It is anticipated that at a future time we will use online training for Project Sunlight through WECOMPLY and training will be automatically recorded.
What Types Of Procurement Appearances Are Recorded On Project Sunlight?
Procurement Appearances covered by this legislation are:
- In person meetings
- Conferences (other than in a public area involving multiple vendors)
- Video Chats
When should a Procurement Appearance be recorded on Project Sunlight?
- 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
When Isn't a Procurement Appearance Recorded on Project Sunlight?
- 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.
How Do I submit the Appearance Data?
Complete the Project Sunlight Reporting Form (pdf, 115KB) within three days after the appearance and submit to Purchasing at firstname.lastname@example.org or FAX to Purchasing at 777-2338. Purchasing will enter the data on the Project Sunlight state database. Remember: These appearances must be reported on the Project Sunlight database within five business days of the occurrence when feasible.
Items that do NOT count as an Appearance?
- 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.