Project Sunlight

As part of an overall reform of the NYS ethics law, NYS enacted the Public Integrity Reform Act of 2011 (PIRA). Among the items called for was the creation and maintenance of a database by the Office of General Service to collect information from state agencies on substantive interactions between state decision makers and those seeking to influence the decisions made by the state decision makers (Project Sunlight).

The University is required to report appearances with outside parties within five (5) business days of the appearance. A reportable appearance is one which involves a "substantive interaction" between the University and an outside party. A "substantive interaction" is one which is meant to impact decision making and is before a decision maker or one who advises the decision maker. The interaction can be in-person or by video conference. Letters, e-mails, faxes and phone calls are not considered to be interactions for Project Sunlight.

The following types of appearances are reportable under Project Sunlight:

1. Procuring a state contract for real property, goods or services which could result in contracts of $25,000 or more;
2. Rate-making;
3. Regulatory matters;
4. Judicial or quasi-judicial proceedings; and
5. Adoption or repeal of a rule or regulation.

For procurement purposes, an appearance is reportable even if there is no planned procurement.

Appearances that are not reportable under Project Sunlight are:

1. Appearances by elected, executive or legislative officials;
2. Appearances during the restricted period of the procurement process;
3. Minority and women-owned business enterprise outreach;
4. Contact initiated by the University where the response is informational; and
5. Debriefings.

In the event of a planned procurement, the procurement must be for $25,000 or more and the appearance must occur outside of the "restricted period" for it to be reportable. The "restricted period" of the procurement process is the period of time commencing with the earliest notice of the procurement and terminating with the final approval of the procurement by the New York State Office of the State Comptroller. Reporting during the restricted period is subject to the State Finance Law and Public Officers Law.

Please see https://www.albany.edu/purchasing/procurement-lobbying-act.php for additional information.

Under Project Sunlight, the following information is to be reported:

1. Date of Appearance;
2. The Name(s) of all campus employees who attended the meeting;
3. Type of Appearance (in-person or video-conference);
4. Meeting Location (Street Address, City, State, Zip Code);
5. Meeting Reason (Procurement; Rate-making; Regulatory matters; Judicial or quasi-judicial proceeding; or Rule-making);
6. Vendor Information:
7. 1. Name of Vendor;
   2. Name of Individual(s);
   3. Vendor Street Address, City, State, Zip;
7. If an Outside Entity Represented the Vendor, please provide
8. 1. Name of Outside Entity;
   2. Name of Vendor they represent;
   3. Name of Individual(s);
   4. Outside Entity Street Address, City, State, Zip.

If you have a reportable appearance, or for additional information, please contact Internal Control.