Project Sunlight - Integrity Reform

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Project Sunlight is part of the New York State Public Integrity Reform Act of 2011. It requires state entities, including UB and other SUNY campuses, to report any appearances by firms and individuals who meet with state decision makers into a database where they can be viewed by the public.

How Does Project Sunlight Affect UB?

Any substantive in‐person or video‐conference meetings between UB decision‐makers and vendor representatives or advocacy organizations, where the intent of the meeting is to influence the decision to procure real property, goods and/or services with a value or potential value of $25,000 or more in State funds, must be reported to the OGS database. These appearances are required to be reported within five (5) business days of the appearance.

What Is a Substantive Appearance?

Substantive appearances are meetings where the specifics of a procurement or potential procurement are discussed. This is opposed to a ministerial meeting, such as an appearance to set up a future meeting to discuss the procurement or share contact information. When determining if an appearance should be reported, it is irrelevant as to who initiated the appearance, where the appearance took place, how formal or informal the meeting was, or whether or not there is a planned procurement at the time of the appearance.

Who Is a Decision Maker?

A decisionmaker is a UB employee (State, RF or UBF) who is in a position to authorize the procurement of real property, goods and/or services with a value or potential value of $25,000 or more. This also includes any UB employee who advises the person with the authority to authorize such a procurement.

What to report:

  • Report appearances that occur in person or by video-conference BUT not written contacts by letter, e-mail or fax.
  • If you initiate a contact that is purely informational (e.g. market research), reporting is not required.
  • If you reach out to an M/WBE firm to determine interest in or availability to provide goods or services, reporting is NOT required.
  • P-card purchases are not required to be reported.
  • Procurements less than $25,000 will not need to be reported.

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