Financial Policies

FN21 Non-Office Telecommunications Services

Policy Status: 

Active

Policy Steward: 

Office of the Corporate Controller

Contents:

PURPOSE:

This policy defines the responsibility for the coordination and usage of cellular services.

POLICY:

The University recognizes the importance and prevalence of cellular services for both personal and business communications and sets the following policy regarding cellular services.

The cost of a cellular voice/data plan/device is considered a personal expense for an employee and will not be directly paid for by the University unless certain business criteria are met. Budget executives and individual departments/units have the authority to set higher business requirements to provide cellular services and related devices than those outlined by this policy. This includes emergency text messaging subscriptions offered by Penn State as well as other services or apps that may be used for business purposes.

A unit has the authority to decide that it will not provide any cellular services or devices. Use of a personal cellular plan and device for business purposes will not be reimbursed unless it can be clearly documented that the employee incurred additional costs over and above the base plan for the employee.

An administrative area or unit must follow the policy outlined below to determine if it is appropriate to provide cellular services for an employee. The guiding principle for eligibility is that the use of a cellular plan/device by an employee is for the benefit of the University, rather than the convenience of the employee and that the employee cannot perform their work duties unless cellular services are provided.

Information Technology Services (ITS) is responsible for establishing University contracts for cellular services with various providers. These contracts generally provide for discounts for both University and employee-owned cellular services and equipment. ITS will not be involved in contracting for individual service contracts, even for University-owned cellular plans. When obtaining services or equipment, employees need to assure that Penn State negotiated pricing is being applied. Cellular providers will require verification of employment (i.e. Penn State ID) to have contracted discounts applied to services and equipment.

NOTE: Per policy FN14 - Use of University Tangible Assets, Equipment, Supplies and Services, any service paid or reimbursed by the University may not be used for any activities for personal gain (such as in the conduct of a personal business).

BUSINESS CRITERIA FOR CELLULAR SERVICE:

To be eligible for cellular service provided by the University, one or more of the following criteria must be met:

Key Personnel

  • The employee is considered key personnel for emergency or safety purposes.
  • Employee supports or is responsible for programs, services or systems that necessitate frequent and immediate communications throughout the day, after-hours or while away from the office on travel.

Technical Monitoring

  • The employee is required to be available 24/7 to monitor essential systems, which may include receiving text messages from such systems upon outages or conditions outside of operating standards.
  • The employee must be available immediately for service calls or trouble-shooting during the work day.

No other communication source

  • Employee does not have access to other communication devices while on the job either because the employee has no assigned office and/or primary work location changes based on assignments.
  • The employee is required to travel on a frequent basis and must maintain regular communication while in travel status.
  • The employee performs the majority of his/her job duties "in the field", where business either cannot be conducted by a landline telephone or it would be inefficient to use a landline telephone.

Most University employees will not be eligible for University-provided device and cellular service. There must be a strong and continuing business need before a department can approve issuing a University-provided cellular device and service.

CELLULAR SERVICE FOR BUSINESS PURPOSES:

University-owned Cellular Plans/Devices

A University-owned Cellular Plan/Device may be used where an employee or department has a need for University-owned cellular plans/devices, especially for situations where the devices are shared among employees.

Acquisition of Service:

Documentation of the business need for an employee/department to obtain a University-owned cellular plan/device is required through completion of the Cellular Usage Agreement (CUA) for University-owned cellular plans and devices. Different forms are required depending on how the service/device will be assigned:

  1. If the device will be pooled for general departmental use (signed out as needed), the department should complete the CUA for a Pooled Device , including documenting how the device will be tracked while in use and the business need for this service.
  2. If an employee will be provided a dedicated device, the employee should complete the appropriate CUA for a Dedicated Device with full documentation of the business need for this service.

The completed CUA form must be approved by the budget administrator, the budget executive and the Financial Officer. No plans or equipment should be contracted or purchased until the appropriate CUA form is fully approved.

The department must contract for service directly with the chosen cellular provider based on obtaining the most cost-effective plan based on expected business use. The choice of cellular device to purchase must be based on balancing the required business needs versus the most cost-effective device available.

The Purchasing Card would be the preferred method for purchasing cellular plans and devices as well as for monthly charges. A copy of the CUA form must be attached to the Purchasing Card Support Form for the purchase of the service/device and the monthly statements would be provided each month to settle the monthly service cost.

Non-Business Use:

University-owned cellular plans and devices must be used primarily for business purposes. Any additional charges resulting from personal use must be reimbursed by the employee.

Termination of Service:

If an employee is terminated, resigns, transfers or no longer has a need for a University-provided cellular plan/device, the employee is required to promptly return equipment to the department through which the cellular device was issued and the department will either reassign the service/device or end the service contract.

REIMBURSEMENT FOR BUSINESS USE OF A PERSONAL PHONE:

As with all personal costs, reimbursement can be provided for business use of a personal cellular phone for business purposes, as is done for use of a home landline for business, when additional charges are incurred. For costs incurred while traveling, the travel policy would apply. Otherwise, the following reimbursement policy would be applicable:

  • No reimbursement would be provided for business use of a cellular phone (including text messaging) which falls under the normal calling plan for the employee.
  • Cellular plans would only be reimbursed if business use results in additional costs to the employee over the base plan. Reimbursement would be based on the percentage of business versus personal calls resulting in the overage. The assumption would be that all personal calls would be accounted for within the base plan first, and then business calls.
  • Data plans would only be reimbursed if overages resulting in additional costs to the employee occurred because of business use.
  • Reimbursements would be accumulated until the total amount payable is $10.00 or more, given the high cost of processing reimbursements.

The employee would be required to submit his or her monthly bill, indicating all business calls, text messages and data usage and documenting that business use resulted in an overage. Reimbursement would be based on the number of minutes used for business which resulted in the overage, assuming that all personal minutes are first to be covered. For data plans, the employee would need to demonstrate that the business usage resulted in additional cost to the employee.

  • Illustrations of Business Use of Personal Phone Reimbursement Calculation
    1. An employee makes 20 minutes of business calls on a personal phone, and incurs no overage charges. No reimbursement would be made.
    2. An employee used 25 minutes on their cellular plan for business, and incurred an additional cost of $25 for a 50 minute overage, the University would reimburse 50% of the overage (25 minutes of 50 minute overage) or $12.50.
    3. An employee makes 60 minutes of business calls on a personal phone from a total of 200 minutes used, with a base plan of $45 per month, but incurs no overage. No reimbursement would be made.
    4. Employee makes 105 minutes of business calls on a personal phone from a total of 600 minutes used, with a base plan of $45 per month. The employees plan permits 550 "free" minutes per month. The 600 minutes used results in additional cost of $25 for a 50 minute overage above the 550 monthly minutes permitted under the plan. The employee would be reimbursed the $25 cost for the 50 business minute.

CONTRACT CHANGES OR CANCELLATIONS:

For university-owned cellular plans and devices, the University will bear the cost for any associated fees related to modifying or terminating the contract, with the exception of such costs arising from employee misconduct or misuse of the plan.

DATA SECURITY AND CONFIDENTIALITY:

All institutional data must be protected from unauthorized disclosure and must be protected with the same granularity of security control provided by the originating host system. This includes institutional data on mobile devices, including personal devices which may be used for business purposes. Certain private data, such as social security numbers, may not be retained on local or mobile devices unless an exception has been granted by the University Privacy Officer. Additionally, mobile devices must be properly disposed of when no longer being used.

It is recommended that University-owned phones be password-protected.

Text messages should never be used to send private University data, or protected personal information (PII), such as social security numbers, passwords or credit card numbers.

NOTE: Employees using University issued devices should understand that any records they create related to University business—including text messages, voicemail messages, emails, and other electronic communications—are University records. These records therefore (1) should be managed according to University records retention policies, and (2) may be subject to disclosure if someone requests them.

All cellular devices which are issued for University use must subscribe to the PSUAlert emergency messaging system, if the device provides for text messaging services. To subscribe, follow the instructions listed at https://psualert.psu.edu/psualert/.

Communications sent from University-owned devices or systems must never contain any offensive, abusive or inappropriate language, even if falling under the de minimus personal use provisions.

When traveling, users must follow all state and federal regulations regarding the use of cellular devices while driving.

Please refer to the following policies for additional information:

AD19 - Use of the Penn State Identification Number and Social Security Number

AD23 - Use of Institutional Data

AD20 - Computer and Network Security

AD35 - University Archives and Records Management

BS15 - Disposal and Purchase of Obsolete, Surplus or Scrap University-Owned Equipment, Supplies and/or Materials

INTERNET SERVICES:

The University will not pay for or reimburse employees for the cost of internet services at home, such as DSL or satellite services, from any University funds.

FURTHER INFORMATION:

For questions, additional detail, or to request changes to this policy, please contact the Office of the Corporate Controller.

CROSS REFERENCES:

Other Policies in this manual should also be referenced, especially the following:

FN14 - Use of Tangible Assets, Equipment, Supplies and Services

HR91 - Conflict of Interest

Effective Date: February 12, 2016
Date Approved: February 1, 2016
Date Published: February 12, 2016

Most Recent Changes:

  • February 12, 2016 -

    Major changes have been made throughout the entire policy, including clarifications pertaining to:

    • Business criteria to be eligible for cellular service
    • If eligible, requirements for:
      • Acquisition of Service
      • Non-Business Use
      • Termination of Service
    • Reimbursement for Business Use of a Personal Phone
    • Contract Changes
    • Data Security and Confidentiality
    • Removal of reimbursement for internet services at home

Revision History (and effective dates):

  • September 27, 2013 - Editorial changes. Addition of policy steward information, in the event that there are questions or requests for changes to the policy.
  • January 18, 2011 - Revisions made to the "Options for Cellular Service for Business Purposes," "Combined Cellular/Data Devices (Smartphones), and "Data Security and Confidentiality" sections, to reflect the discontinuance of taxing cell phone allowances, per legislative changes regarding the use of cell phones for business and taxability.
  • January 26, 2010 - Editorial change in the "Data Security and Confidentiality" section, providing the appropriate link for subscribing to the PSU TXT emergency messaging system. Applies to all cellular phones which are issued for University use or are supported by a taxable allowance, if the phone provides for text messaging services.
  • January 15, 2010 - Revised the "Data Security and Confidentiality" section to further clarify the appropriate use of University-owned phones as well as those supported by taxable allowances.
  • January 3, 2008 - Major revisions made to the entire policy, including change from a Business Services policy (was BS19) to an FN (Financial) policy. Revised to be in compliance with Internal Revenue Service regulations regarding cellular phone service
  • February 4, 2005 - Editorial change to eliminate "General Forms Usage Guide" and correct bad links.
  • June 8, 2004
    • The section NUMBER PORTABILITY was added regulating the transfer of phone numbers between services.
    • The section CELLULAR PHONE SERVICES was renamed CELLULAR SERVICES to emphasize that all cellular services, including data, are covered by this policy.
  • January 6, 2004 - Substantial rewrite that now allows pre-paid calling cards for international calls only, new guidelines for personal use of non-office telecommunications, and procedural changes for arrangement and financial settlement of recurring services.
  • June 3, 2002 -
    • 'Office of Telecommunications' changed to 'Information Technology Services'.
    • Allows certain cellular carriers to directly send bills to departments for monthly fees rather than going though ITS.
  • May 16, 2001 -
    • New Policy; previously was published as Policy AD31 Cellular Telephone Service at the University .
    • Additional changes:
      • Substantial rewrite that now includes other forms of non-office telecommunications in addition to cell phones.
      • New delegation of authority to establish services and delegation of authority for signing service contracts.
      • While the policy emphasizes that services are primarily for University business purposes, it now recognizes that some personal usage may occur and thus provides for reimbursement to the University of personal costs.
      • Provides reimbursement rules for employee use of University-paid services, as well as reimbursement rules for University use of services paid for by the employee.
      • Allows monthly fees for non-OTC services to be charged to University Purchasing Card.
      • Added cross references
  • August 26, 1997 - (published as AD31):
    • Consulting on the appropriateness of cellular service was added as an OTC responsibility.
    • Removed the section regarding the Department of PurchasingServices involvement for contracts.
    • The approval of the TSR was changed from "senior University officer" to " budget administrator and the Financial Officer."
    • Prohibits costs of private vehicle installation or non-University use of a cellular phone.
  • October 11, 1989 - Requests for 'long-term' service must be approved by senior University officer; budget administrator approval valid for short-term rentals and change or discontinuance of service.
  • November 27, 1988 - New policy.