PURPOSE OF THIS POLICY
The purpose of this Policy is to provide mobile communications devices and services for use by University employees, primarily for non-compensatory University business purposes. Recognizing that these devices are susceptible to use for personal purposes and that a reasonable amount of personal use may be permitted without significantly increasing the University’s costs, it is necessary to adopt a policy governing such personal use and providing for business processes to implement the policy.
APPLICATION OF THIS POLICY
This policy applies to all University employees and associates who are authorized by their department heads to obtain a mobile communications device and related services that will be paid for with University funds, and to those who elect instead to receive a monthly allowance to cover the business use of their own, personal mobile devices and accounts.
EXEMPTIONS FROM THIS POLICY
Mobile devices other than cell phones, such as tablets or laptop PCs, that are in use as of June 1, 2013 and configured for a particular cellular service provider are exempt from this policy; however, no new devices that are incompatible with the University’s corporate service plans should be purchased unless the University’s official provider’s devices and plans are clearly unable to meet the department’s legitimate business needs.
DEFINITIONS USED IN THIS POLICY
Eligible employee: A CSU faculty, administrative professional, state classified, graduate assistant, or other salaried employee paid on a salaried basis (hourly employees are not eligible). All references herein to an “employee” are meant to refer to an eligible employee unless otherwise stated.
Mobile device: A cellular phone, tablet computer, or other device that uses cellular wireless connectivity for voice, text and data services.
Corporate plan: A cellular wireless service plan provided under the University’s agreement with its official service provider, where the University is the owner of the device and is liable to the service provider for the account, and the mobile device and service are offered to a University employee or department for official University business use or mixed business/personal use.
Allowance plan: A plan for providing a monthly allowance amount to an employee who chooses to use his or her own personal mobile device and service plan for mixed business and personal use.
Colorado State University has entered into an agreement with a provider of cellular wireless phone and data devices and services to act as the University’s official mobile communications provider. Eligible employees wishing to obtain a CSU-supplied wireless device and service plan for business use must comply with this policy. Existing University accounts with other providers may not be renewed or extended after the effective First Revision Date of this policy as noted above. In addition, this policy provides a “allowance option” for those employees who use their own personal mobile devices and accounts for University business purposes, and wish to seek reimbursement for that business use.
A. Business Need for Mobile Communications Devices and Services
Cellular phones and other wireless communications devices, such as those allowing access to the University’s online resources and the Internet, are provided to improve employee productivity and customer service, and to enhance business efficiencies. Cellular phones are not provided for primarily personal benefit. Before receiving a University-subsidized device or service plan, it must be established that the employee has a business need for the device, and an appropriate service plan must be approved by the employee’s department head or administrative supervisor.
In order to participate in the University’s mobile communications program, the employee must have a business need, defined and approved by his or her supervisor, including one or more of the following:
- Employee travels or works regularly in the field, and, while away from the campus workplace, needs to be accessible for communications and/or requires access to online resources, e.g. email, calendar, web, etc., via a mobile communications device;
- Employee is responsible for critical services or infrastructure, and needs to be accessible for communications and/or requires access to online resources via a mobile communications device; and/or
- Mobile access and/or access to information technology systems via a mobile communications device would, in the judgment of the supervisor, render the employee more productive and/or the service the employee provides more effective, and the cost of mobile communications service is therefore warranted.
B. Terms of Program Participation
- A communications device purchased with University funds remains the property of the University, and the employee may be required at any time to surrender the device. When a device is to be replaced or removed from service, it will be returned to the department that purchased it, and either reassigned to another employee, or treated as surplus property in accordance with applicable University policies and procedures.
- The use of cellular service, including voice, text and data service, must be primarily for the employee’s business conducted on behalf of CSU. When this is not the case, then the provision of service must be discontinued and the employee can choose the allowance option instead (provided that the business case is established). When an employee's personal calls or personal data use causes the monthly plan limits to be exceeded, the employee must reimburse the University for the difference between the actual bill and the subscribed monthly plan amount, including all applicable taxes, surcharges, and all other billed charges related to the excess use. In addition, employees must reimburse the University for personal charges, such as international coverage related to personal travel, the purchase of smart phone applications not related to work, purchased ringtones, non-business roaming charges, etc. All such reimbursements shall be made by cash or check paid by the employee within 15 days of receipt and reconciliation of the monthly statement.
- Departments establishing corporate plan accounts for employees, or agreeing to pay allowances for employees, are responsible for establishing procedures to periodically review the status of employees participating in mobile communications options outlined in this policy to assure that the business case is still valid, and for ensuring compliance with this policy.
- While on University business, employees are responsible for operating vehicles or potentially hazardous equipment in a safe and prudent manner. Use of a cell phone or other wireless device while operating vehicles and equipment creates substantial risks, and therefore, employees shall refrain from using these devices while operating such vehicles and equipment.
C. Program Options
- Corporate Plan Option
Eligible employees with recurring business use of one or more mobile devices may enroll in the corporate plan. Under this plan, a cellular phone, wireless tablet, or other mobile device may be selected by the employee from the service provider’s website, together with the service plan that is most economical for the approved business use.
Two options are offered for employees who are provided with a device and plan under the University-sponsored corporate plan:
- For employees who will use the device and service for University business only, with no personal use at all, the employing department will pay 100% of the charges; or
- For employees who elect to use the University-sponsored plan but also wish to use the device and services for some personal use, the employee may elect to pay a low, flat monthly rate to cover the personal portion of the services (so long as business use remains primary). The rate is determined by the agreement between the University and the official provider; current rates may be found online on the Department of Telecommunications website. If the personal use option is selected, then, unless the personal use charges exceed the business use charges, the charge to the employee initially will be based on the service plan for which the employee is approved and subscribed. The University will automatically deduct this amount from the employee’s payroll on a monthly basis as long as the account is active. The amount charged to the employee opting in for the personal use option may be reviewed annually by the University and is subject to change from time to time. The employee’s home department is responsible for collecting any amounts owed if for any reason the payroll deduction is unable to be made.
- Using a cell phone during international travel can be extremely expensive. The University’s official provider offers an international calling and data plan that can be activated when traveling, which greatly reduces these costs. It is the employee’s responsibility to assure that the carrier’s international service has been added before leaving the US. Any amounts incurred as a result of failing to do so will be the employee’s personal responsibility.
- Allowance Option
- Eligible employees requiring a mobile phone are encouraged to use the University’s corporate plan with the official provider, as this should result in lower cost to the employee and the University. However, the University recognizes that some employees may prefer an allowance arrangement that allows for reimbursement to the employee for CSU-business use of their own personal mobile communications device and service. CSU’s official provider will offer a discounted personal plan for CSU employees who wish to take advantage of low pricing.
- In lieu of receiving a University-subsidized device and cellular service plan, where determined appropriate by the department head, an employee may opt to use his or her personal cell phone for University business purposes and receive a fixed allowance from the University to cover such business use, so long as there is a legitimate and approved business need as described in Section A above. The employee will be responsible for all equipment and service charges, and for establishing and maintaining a personal contract with the carrier for cellular services. The employee owns the device and is the customer on the plan.
- An allowance will be added to the employee’s monthly payroll deposit, at a flat rate, according to the following schedule:
- $25/month for cellular service, with text messaging; or
- $40/month for cellular service with text messaging and a data plan.
- Only one allowance is permitted per employee at any one time. Allowances are not allowed during any month when the employee is ineligible or is not earning any pay.
- The University has the authority to raise or lower the allowance amount from time to time for all employees (not on an individual basis) based on market price and/or changes to applicable tax laws and regulations.
- The employee is responsible for advising his or her supervisor, and the supervisor shall advise the department head, when the employee no longer has the business need for which the allowance option was approved, or discontinues receiving the cellular services being used for CSU business. The employee will provide copies of billing statements whenever requested to assure proper accounting and plan selection. Knowingly accepting an allowance payment when you are no longer paying for a service plan that you use for CSU business is a serious violation of policy that may result in disciplinary sanctions, up to and including dismissal from the University, and may be a criminal offense.
D. Reimbursement for Business Use Not Otherwise Covered
- Employees whose recurring business use cannot reasonably be compensated under either the corporate plan with personal use option, or the allowance plan (usually due to business need for extensive international travel in coverage areas not adequately served by the University’s official provider), may request approval by the responsible senior administrator (department head, dean or director) for a department-liable account with another carrier who provide service coverage where needed by the employee. The department will own the device(s) and be responsible for handling all billing and payment under the selected plan, which shall be the least expensive plan available that adequately meets the approved business need. In these arrangements, the device is provided for business use only, not for personal use of the employee, and the department will implement reasonable procedures to assure this limitation is being met.
- Employees whose business travel results in business use that exceeds the amount of the approved allowance plan, but who otherwise are adequately served by the plan, may submit charges for business use of their personal device on their travel expense report for the period in which the charges were billed. Reimbursement for such charges shall not exceed the reasonable and necessary amounts incurred for business purposes. If this becomes a recurring type of reimbursement request, the employee may be required to switch from the allowance to a corporate plan.
E. Insurance/Equipment Replacement Plans
The insurance and equipment replacement plans offered through the official provider are not mandatory. For expensive devices such as smart phones, the ordering department may wish to consider purchasing this coverage. In cases where insurance is not purchased, the ordering department will be responsible for any loss of a University-owned device. The University assumes no liability for loss or damage to an employee's personal wireless device, and no reimbursement of such loss or damage shall be allowed.
F. Responsibilities of the Department Head
- Each Department Head who authorizes an employee to use a wireless device and/or plan, or to receive an allowance, should exercise discretion to assure that the device and plan selected are appropriate and economical. The Department Head is responsible for annually reviewing the business case to assure that the business need continues to exist, and shall make changes to the device, plan or allowance approval as appropriate. The department head shall assure that the Human Resources Payroll Unit is notified immediately when an allowance or corporate plan is to be changed or discontinued.
- If the corporate plan on an opt-out basis is not justified by the business need for such an employee, the department head may wish to consider obtaining one or more mobile devices with the corporate plan, on an opt-out basis, in the department’s name, to be temporarily assigned to employees who only need the phone for occasional on-call, travel, or other temporary purposes. The department will be billed directly and will be responsible for collecting any amounts owed by an employee for personal use not authorized under the plan. This arrangement can also be used for employees who are non-salaried (hourly) and occasionally require a cell phone for business use.
- Department Heads are responsible for obtaining CSU-owned mobile phones and devices back from employees when the devices are no longer in service. Employees may not keep CSU-owned phones for personal use or when terminating employment. Devices removed from service must be returned by the department to CSU Surplus Property or reassigned to another employee within the department. Note: employees who switch from a corporate plan under the Sprint agreement to an approved Allowance Option plan, and who choose to remain with Sprint on a personal service contract, may retain their Sprint phones until their Allowance Plan is no longer active.
Compliance with this policy is required. An employee whose use of a University-provided cell phone or acceptance of an allowance is not justified by the legitimate business needs of the University may be subject to tax liability for the value of the benefit. Failure to comply with this policy may also result in a denial or revocation of a wireless device, service, or allowance, and may include personal liability for any amounts improperly incurred by the University as a result of a policy violation.
FORMS AND TOOLS
The WIRELESS DEVICE ATTESTATION FORM must be completed properly for use in obtaining a University-issued wireless device, plan or allowance. The form may be revised from time to time, as needed, in the discretion of the University Controller.
Approved by Amy L. Parsons, June 27, 2014