Project Sunlight—Integrity Reform

Project Sunlight requires designated university personnel—specifically those serving as 'decision-makers' or 'advisors to decision-makers'—to report any interactions (qualified appearances) with individuals or firms that could influence the university’s decision-making process. 

UB complies with Project Sunlight by reporting qualifying appearances into the Project Sunlight database, which is hosted by the Office of General Services (OGS). Project Sunlight compiles the data reported and makes it publicly available. 

UB decision-makers and their advisors have three (3) days from an interaction to submit the Project Sunlight Reporting Form. The campus Project Sunlight Reporter must report the interaction in the Project Sunlight database within five (5) business days of the interaction. Decision-makers and advisors to decision-makers are also required to complete training.

UB must report any substantive in‐person or video‐conference meetings between UB decision‐makers/advisors to decision-makers and vendor representatives or advocacy organizations, where the intent of the meeting is to influence decisions made regarding one of the following five subject areas covered by Project Sunlight:

1. Procurement of real property, goods and services valued at $25,000 or more.
2. Rate-making.
3. Regulatory matters.
4. Agency-based judicial or quasi-judicial proceedings.
5. Adoption or repeal of a rule or regulation.

In most cases, the obligation will be triggered by a meeting with representatives to discuss procurements valued at $25,000 or more. 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 there is a planned procurement at the time of the appearance. There can be numerous appearances related to a single matter.

A decision‐maker is a UB employee (State, RF or UBF) who has the power to exercise agency discretion in one of the five covered categories or advises someone who has such discretion.

Any interaction that is an in-person meeting or a video conference between UB decision-makers or advisors to decision-makers and covered individual(s) outside of a state entity, related to one of the previously listed five covered categories. The law permits the Project Sunlight Reporter five (5) business days to submit an interaction into the Project Sunlight database. Therefore, all interactions must be reported by decision-makers or their advisors via the Project Sunlight Reporting Form within three (3) days of the meeting or appearance.

Examples of appearances that do not need to be reported; this list is not exhaustive and is subject to change:

1. Ministerial or informational appearances, such as communications to schedule meetings or requests for information. 
2. Written communications such as letters, faxes, or emails. 
3. Telephonic conversations.
4. Appearances regarding legislation or the budget. 
5. Any appearance related to individuals or matters that are treated by a state entity as confidential pursuant to federal or state statute, rule or regulation.  
6. Any appearance that if disclosed could endanger the life or safety of any person or any appearance that if disclosed could subject an individual to a risk of retaliation or adverse employment action.
7. Participation in meetings which are open to the public, such as conferences or meetings subject to the Open Meetings Law or where a record of the meeting is otherwise publicly available. 
8. Appearances between a covered individual at a state entity and an agent of the agency, such as a consultant. 
9. Procurements under $25,000 or emergency procurements.
10. Procurement appearances during the Restricted Period—whether they are bid clarification meetings or bid interviews or any other permissible contact under the State Finance Law.
11. Minority- and women-owned business enterprise outreach.

Use the Project Sunlight Reporting Form to report a qualified appearance within three (3) days of the meeting or appearance.

The University at Buffalo is expected to train all appropriate staff members on the substance and technical aspects of Project Sunlight. Upon request by Project Sunlight, the University at Buffalo will be required to report which personnel has received Project Sunlight training.