OVERVIEW UNIVERSITY AT ALBANY

What is Project Sunlight? Project Sunlight is an online database that provides the public with an opportunity to see what individuals and entities are interacting with New York State government. Project Sunlight is a requirement for all state agencies under the Public Integrity Reform Act of 2011.

What Interactions are Covered Under Project Sunlight? For an interaction to be covered by Project Sunlight, it must Be an appearance, Be between covered individuals, and Concern one of the five subject areas covered by Project Sunlight Procurement – State Purchases Only Rate making Regulatory matters Adoption or repeal of a rule or regulation Judicial or quasi-judicial proceedings Given the nature of SUNY activities our sole focus is on Procurement.

What is an Appearance? An appearance is an interaction that is meant to have an impact on the decision making process of the University for a potential procurement of $25,000 or more. Project Sunlight is a state procurement requirement only. Procurements using Research Foundation or affiliated corporation funds do not need to be reported.

Appearances The only appearances covered are: In-person meetings. Phone calls (only if you communicate with the person – for example, a voice mail does not need to be reported). Video chats Written communications such as letters, faxes, forms, and emails are not considered appearances unless you answer them.

Who/What is a “Covered Individual”? University at Albany An individual with the power to exercise procurement discretion for state funds or an individual who advises someone who has discretion Anyone on campus with control over a budget where they are the decision maker on procuring goods or services  Vendor/Outside Party Appearances by either direct employees of the vendor/outside party (salesperson) or a representative of a vendor/outside party (lobbyist, outside salesperson) must be reported

Entities and Individuals that are Excluded from Reporting The following entities are excluded from reporting: Appearances by other state and local agencies and authorities, tribal governments and federal government representatives. Appearances by NYS elected officials, executive or legislative employees, or judges or employees of the judiciary. Representatives of the media. Persons under the age of 18.

Procurement under Project Sunlight that Do Need to be Reported Appearances that are for the purpose of procuring a state contract Sales pitches and cold calls may be considered appearances if they are before a decision maker If at an unrelated meeting a potential vendor begins to advocate its product and/or the possibility of a state contract, that appearance now needs to be reported

Procurement under Project Sunlight that Do Not Need to be Reported Appearances that are at the request of the University that are purely informational, such as market research or verbal quotes. Appearances allowed under a Request for Proposal or Request for Information process do not need to be reported. Appearances once an RFP or RFI process begins are governed by the NYS Procurement Lobbying Act. Appearances following an award of a state contract do not need to be reported so long as the topic of the appearance is the product or service awarded in the contract. If the vendor begins to advocate for a different product or service, the appearance must be reported Appearances related to emergency procurements do not need to be recorded

How Do I Report an Appearance? Each time you have a qualified appearance, complete the Project Sunlight Reporting Form located on the internal controls website. Return via e-mail to the jstclair@albany.edu of the Controller’s Office within three (3) days of the communication/appearance. Please contact Jonathan St. Clair at jstclair@albany.edu if you have any questions.