PURCHASE COLLEGE - SUNY

Project Sunlight Campus Compliance Plan (2013)

What is Project Sunlight?
Mandated by state law, 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:

- (1) procurement of goods and services,
- (2) rate-making,
- (3) regulatory matters,
- (4) judicial or quasi-judicial proceedings, or
- (5) 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 Finance and Administration office is responsible for the administration of this program at Purchase College. Compliance Requirements include the following:

Communication
Project Sunlight background, requirements, and other information are available at the link below.

  • The SUNY Project Sunlight webpage at                                                                                                       http://www.suny.edu/compliance/topics/projectsunlight/index.cfm provides comprehensive information about the 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 Business Office via e-mail. Project Sunlight background, requirements, and other information are available at the links below.

Training
Individuals who are identified as potential campus Decision Makers or Advisors are required to view the SUNY training tool at
https://sas.elluminate.com/site/external/launch/nativeplayback.jnlp?sid=2012301&psid=2013-05-30.0657.M.FBD48E344CB9517C985DA5B1E821F5.vcr

Certification of Training
All Decision Makers and Advisors must certify that they have reviewed the training materials by submitting the Project Sunlight training certification form to the Business Office. Please see the Certification Form.

Designation of Contact Person
For questions on how Project Sunlight might apply to you or your staff contact Joe Kyambadde, Internal Control Officer at extension 6016.

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 and services (this applies to a single procurement or a multi-year contract). 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 immediately following the conclusion of the appearance and no later than 2 days (NO EXCEPTIONS).

Completed forms should be mailed (as e-mail attachments) to projectsunlight.reporting@purchase.edu

The Business Office, using data from the Reporting Form, will post appearance information to the Office of General Services within five (5) days of the appearance.

Annual Campus Certification
o Campuses must provide yearly certification that all qualified “appearances” have been reported and that appropriate campus employees have been trained on their obligations under the law.
o 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 at http://www.suny.edu/compliance/topics/projectsunlight/index.cfm (the website includes informative FAQs). Additional questions that might arise after viewing of the training materials may be directed to Joe Kyambadde (Internal Control Officer), Joseph.Kyambadde@purchase.edu or ext. 6016.

Please see the College's External Reporting Form.