Office of Internal Control

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.

The New York State Project Sunlight Resources webpage provides comprehensive information about Project Sunlight.

Campus Compliance Requirements

The Finance and Administration office is responsible for the administration of this program at Purchase College. Compliance requirements include the following:

Identification of Decision Makers and Advisors

Any Purchase College SUNY employee who is a potential decision maker or advisor with influence in procurements of $25,000 or more are required to report appearances. 

SUNY employees who are decision makers or decision advisors report (within 5 business days):

• • • • • • All Substantive “appearances” with non-governmental entities (individuals and firms)
          • On a “covered subject matter”

Please Note:  
It does not matter who initiates the appearance (the campus or vendor/advocate).

What is considered an “Appearance”?

An “Appearance” is a substantive interaction that is meant to have an impact on the decision-making process.

• • • • • Must be between a State Agency and an outside party
        • Must be in person or a video conference between covered individuals
        • Must be related to one of the 5 following categories
          1. 1. 1. Procurement - goods, services, construction, real property
                2. Rate-Making - setting rates for public utilities or services (Not Applicable to SUNY)
                3. Regulatory Actions - investigative or enforcement actions
                4. Judicial/Quasi-judicial - adjudicatory agency hearings
                5. Rulemaking - adoption or amendment of regulations

Please Note:
Procurement is the category most likely to affect Purchase College SUNY.

• • • • • • • When making a purchase or going to purchase
            • Where Purchase College SUNY is entering into a revenue contract
            • Sale of Land contracts involving SUNY land
            • Facilities use contracts where SUNY is paid for use of space
            • Any other potential state contracts with an aggregate value over $25,000

Scenarios that require reporting:

• • • • Appearances for the purpose of advocating for the receipt of discretionary state funds that have already been appropriated.
      • Meetings with new vendors for products, goods and services, prior to a contract being in place.
      • Meetings with existing vendors for new products or services, or products and services outside the scope of the current contract agreement with vendor.
      • Meetings involving substantial re-negotiations of contracts.
      • Meetings with organizations, unions, and other associations that are advocating on behalf of another business.

Reporting Exclusions

• • • • Appearances by other government officials.
      • Meetings with the Media.
      • Appearances by individuals under the age of 18.
      • Medical practitioners (specific to SUNY).
      • Individual student meetings about tuition, charges, fees.
      • Employee disciplinary meetings or proceedings.

Sample Scenarios

• • • • Faculty member meets with a microscope vendor and advises campus procurement on the best microscope to purchase.
      • ITS meets with a 3rd party vendor to see a demo on the vendor’s software platform.
      • A VP meets with a local school district official who has requested a lease of campus facilities for an off-site community education program.
      • A Registrar’s office meets with a vendor they plan to contract with to processes enrollment and degree verifications on behalf of the campus. The contract results in the generation of revenue.
      • The VP for Finance receives phone call from a software vendor who wants to discuss their cloud-based software that can be used to assist with financial planning. The vendor tells the VP about the product and the cost.

Please Note:
In all these cases a decision maker/advisor must inform the campus Project Sunlight Liaison/Reporter of the interaction, and the liaison must submit the report to Project Sunlight via the NY.gov site.  See below for what must be reported.

Reporting Requirements

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.

• • • • • All covered appearances (one per meeting) must be logged in Project Sunlight by the Campus Designated Project Sunlight Liaison/Reporter
        • The Campus Designated Project Sunlight Liaison/Reporter must report all appearances using their Project Sunlight login credentials
        • Only report in appearances that could result in purchase/contract of $25,000 or more in goods and/or services
          • • If you do not know how much the value of the procurement will be, err on the side of reporting
        • You do not need to aggregate purchases in the absence of a contract
        • A single matter may have multiple appearances and each appearance must be reported

What must be reported?

• • • • • Date of Appearance
        • Type of Meeting (in person or video conference)
        • Location of Appearance
        • Purpose of Meeting
        • Name of Purchase College SUNY Employees Present
        • Company Name
        • Company Location
        • Names of Company Contacts Present

Appearances are to be reported to the Business Office immediately following the conclusion of the appearance and no later than 2 days.  Email the required information to:  projectsunlight.reporting@purchase.edu

Any questions regarding Project Sunlight should be directed to the Campus Designated Project Sunlight Liaison/Reporter.

Project Sunlight Resources

Project Sunlight FAQ

Project Sunlight Policy

Project Sunlight Online Database