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System Management

CESP 10-10: Cellular Communications

Date Revised: 1-9-2020
Supersedes: 10-2-2008

Purpose
The purpose of this policy is to regulate the provision of institutionally-paid cellular communication devices and services to achieve the following goals:

  • Facilitate cellular communications for those with a justified need
  • Create a control structure that ensures appropriate administrative approvals
  • Provide necessary cellular service in an administratively efficient manner (i.e., approval, budgeting, payment, property management, and service plan review and management)

It is not the purpose of this policy to move away from future technology or inhibit future development of next generation communications. Cellular communications will continue to grow in frequency and importance. This policy will provide a framework for administrative oversight of cellular communications going forward.

Scope and Effective Date
It is intended to implement this policy in select units on a trial basis, with the intent of implementing for the entirety of CES. This policy shall be effective for the following units beginning January 9, 2020:

  • Facilities Management
  • Financial Services
  • Human Resources
  • Office of Chief Operating Officer
  • Office of Information Technology
  • Office of Sponsored Programs

Before January 9, 2020 or any time during the trial, thereafter, eligible CES employees from any unit may be included in the trial group upon written approval of the Senior Associate Vice President for Agriculture – Extension.

On or before April 30, 2020, an administrative review will be performed to determine the trial’s efficiency and effectiveness. A determination will be made regarding any necessary adjustments to and/or permanent implementation of the policy for all operating units of CES beginning July 1, 2020.

Eligibility Criteria
Cellular communication eligibility will be based on institutional need. Cellular devices and services will be provided when patterns of use meet one or more of the following criteria:

  1. Monetary Reimbursement for Cellular Service for Employee-owned Device (does not include purchases, upgrades, repairs, accessories, etc.):
    1. Where eligible employees use their own device for significant periods of time in order to adequately accomplish their duties.
    2. Where job duties routinely require employees to be away from their office for significant amounts of time for travel, field work, etc., and have a need to be accessible.
  2. CES-provided Cellular Service and Equipment:
    1. Provide for the protection of safety, health and property.
    2. Provide service for employees responsible for administering critical infrastructure or programming
    3. Comply with the rules and regulations of a governing organization to which CES is a member. Department heads and unit leaders will have the authority to designate employees within their respective divisions or units who are eligible to receive and use cellular devices and services.

A goal of this policy is to create and maintain a database of approvals and justifications for CES-supported cellular devices. Therefore, concurrent with the implementation of this policy, a review will be initiated for all CES-supported cellular service. Many CES employees are not eligible for CES-provided cellular service, and only appointed CES employees will be considered. There must be either a strong and continuing need for service that meets the criteria defined above or another well-justified need that has been granted approval as specified herein.

When an employee has been granted approval for CES-provided cellular service, CES reserves the right to publish the telephone number, as deemed appropriate, based on the purpose for which the device was approved.

Approval Authority and Funding
The Cellular Communication Justification and Approval Form is to be used for securing and documenting approvals. Supervisor approval must be granted through use of this form. Before providing approval via the request form, it is the responsibility of supervisors to obtain approval from the relevant budget authority for the funding source—by the department head, unit leader, etc. Relevant budget authorities will be notified of approved requests.

The Department or Unit will be responsible for payment for service, whether CES-provided or through personal reimbursement. A central funding source for institutionally provided cellular service does not exist.

Approval for institutionally-paid cellular communication devices and services is for a maximum of twelve months ending on June 30 of each fiscal year. The twelve-month period necessitates at least annual renewal of the administrative approval for institutionally-paid cellular communication devices and services. Proof of cellular service must be provided to the immediate supervisor at the time of the submission of the Cellular Communication Justification and Approval Form, which must be submitted on an annual basis.

Program Administration
Each department or unit with employee(s) authorized for CES-provided cellular service will have an identified cellular communications administrator to provide a central point of administrative contact. The administrator will ensure that devices are compatible with the requirements of the job to be performed on behalf of the Division and that the costs are commensurate with unit resources.

Options for Service

  1. Monetary Reimbursement for Employee-owned Device (the preferred service option) – Cellular service is established and paid by the user with monthly reimbursements made from funds identified and determined by a department for a pre-approved amount to compensate for business use of an employee’s equipment and service. Standard authorized reimbursement is $50 per month (including data and text plans), up to a maximum amount of $100 per month to accommodate the needs of heavy data users based upon additional justification and approval in accordance with the approval authority process. Lower levels of reimbursement may be set at the discretion of the approving authorities.
  2. CES-provided Cellular Service and Equipment – Cellular service and equipment are established in the name of CES, with the bill paid by CES. When personal use incurs additional costs, a reimbursement will be made by the employee to CES to cover the added expense.
  3. Reimbursement to Employee for Incidental Use of a Personal Cellular Device – Occasional reimbursements may be made for business use of a personal cellular device on an as needed basis. Reimbursement claims are to be submitted in accordance with CES regulations and supported with appropriate billing detail from the service provider using the PURCH-330 Request for Reimbursement form. Examples of such reimbursements could include unusually heavy data usage required to complete a work-related project or international service when managed properly to conserve CES resources.

Periodic Eligibility Review
An eligibility review should be performed whenever an employee’s work assignment changes to the extent that the approval criteria are no longer met. Reimbursement rates should be verified against source documents by the funding unit annually at a minimum.

Processing Monetary Reimbursement for Employee-owned Devices
Once final approval has been granted for monetary reimbursement for an employee-owned device, the requestor, employee, Department Head, and Financial Services will be informed of supervisor approval. Financial Services will develop a database of the approved reimbursements that will include the employee name, employee title, budgetary unit, funding source, the term of the reimbursement (not to extend beyond the fiscal year-end), and the monthly reimbursement amount.

Accounts Payable staff will then issue reimbursement to employees for which reimbursement has been approved at the end of each month. Accounts Payable staff will monitor the eligibility of employees receiving reimbursement by reviewing the payroll termination notices each month. If an employee terminates employment prior to the end of the month, a prorated reimbursement will be issued to the employee based on their termination date.

The identified cellular communications administrators are responsible for monitoring any other changes in the eligibility status of the employees in their departments or units and communicating those changes to Financial Services.

FOIA
Whenever CES-paid cellular service is used to conduct official business, whether on personal or CES-provided devices or plans, records of such communication should be considered subject to disclosure under the Arkansas Freedom of Information Act, unless the nature of the record is otherwise exempt under the law.

Data Security and Confidentiality
Security sensitive institutional data must be protected from unauthorized disclosure. Do not retain security sensitive institutional data on local or mobile devices. Password protect both CES-owned devices and those supported by allowances. Do not text private CES data or protected personal information such as social security numbers, passwords or credit card numbers. All mobile devices must be properly disposed of when no longer in use, with precautions taken to prevent disclosure of sensitive or confidential CES-related information.

Cellular Service Funded by Sponsored Agreements (Grants and Contracts)
Cellular equipment and services are generally not considered an allowable expense on sponsored agreements. However, they may be charged against such funding sources consistent with the regulations and guidelines associated with the award. Such expenditures must be specified in the budget, approved by the sponsor, and receive prior approval by the Office of Sponsored Programs (OSP) for charges against grants or contracts.

Contract Changes or Cancellations
CES will not accept responsibility for the cost of contract changes or early cancellation penalties for individual cellular plans except under extraordinary circumstances where justification has been provided and administrative approval granted by the Senior AVP for Agriculture Extension.

Property Management
State and institutional property management regulations will apply to all CES-owned cellular devices. Care should be taken to properly track and dispose of all institutionally owned devices according to surplus property disposal regulations.

Use of Cellular Devices While Driving
Arkansas Code Annotated §27-51-1504 states “(a) Except as otherwise provided in subsection (b) of this section, a driver of a motor vehicle will not use a handheld wireless telephone for wireless interactive communication while operating a motor vehicle”.

Subsection (b) of the code makes exceptions for emergencies and for persons performing official duties as a certified law enforcement officer, firefighter, ambulance driver or emergency technician.

CES employees driving on official business must comply with all applicable state and federal laws as well as university and Division policies.

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