ROWAN UNIVERSITY POLICY

Title: Cellular Device Policy
Subject:  Information Resources and Technology
Policy No: IRT:2018:06
Applies: University-Wide
Issuing Authority: Senior Vice President for Information Resources and Technology and Chief Information Officer & Senior Vice President for Finance and Chief Financial Officer
Responsible Officer:

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 Senior Vice President for Information Resources and Technology and Chief Information Officer & Senior Vice President for Finance and Chief Financial Officer
Date Adopted:  06/18/2018
Last Revision:

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05/

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31/

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2023
Last Reviewed:

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05/

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31/

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2023

I. PURPOSE

The purpose of this policy is intended to set guidelines for:

1. Authorizing reimbursement for personal cellular device usage by Rowan University employees.
2. Authorizing the purchase of cellular devices for use at Rowan University employeesAuthorizing reimbursement for personal cellular device usage by Rowan University employees  .

Rowan strives to provide employees with the right technology tools they need to do their jobs, to treat employees in similar roles equitably, and to use its resources wisely. The University recognizes that mobile phones are prevalent  and that many users want a single device that supports both their work and personal lives.  The University seeks to support employees’ business technology needs while allowing users enough flexibility to choose devices and service plans that meet their personal and family requirements.

II. ACCOUNTABILITY

Under the direction of the President, the Chief Information Officer, the Chief Financial Officer and the Director of Information Security shall implement and ensure compliance with this policy.

III. APPLICABILITY

This policy applies to all Rowan University employees. Employees who have been assigned a cellular device by the University under a previous version of this policy will be brought into compliance with this policy on a timeline determined by Information Resources & Technology and the Division of Finance.

IV. DEFINITIONS

Refer to Rowan University Technology Terms and Definitions for terms and definitions that are used in this policy.

V. POLICY

1. The University provides a cellular device stipend program to subsidize the use of personal cellular devices for Rowan University business. 
   1. Cellular device stipends are intended to reimburse employees for the incremental cost of business use on a personal mobile phone and thus represent nontaxable compensation to the employee.  The stipend amounts will be set and reviewed periodically by the Division of Finance in conjunction with Information Resources & Technology. Program stipends are not considered additional base pay and therefore are not eligible for benefits calculated on base pay. Stipends will be paid to eligible staff via payroll. The current stipend rates are provided in Appendix A.
   2. Eligibility requirements.  The stipend program is available to full time employees of the University.  Part time, three-quarter time, graduate assistants, student workers and affiliates are not eligible for reimbursement under this program.  To be eligible for the stipend program employees of the University must meet one of the following criteria:
      1. 24/7 access employees: day to day job responsibilities require routine response to urgent (immediate action required) University business at any time of the day or night - e.g., Information Technology, Plant/Facilities, Marketing, Clinical, Emergency Management, Public Safety, and Executive Management who have 24/7 on-call responsibilities.
      2. Mobile employees: jobs require routine field work and need to communicate in real time with their office to give or receive direction or to conduct business - e.g., Admissions counselors, IT or Facilities field technicians, police officers assigned to the field., etc.  Employees who regularly work from a remote location, including their home, do not qualify as mobile employees.  Employees with remote work arrangements are expected to utilize the standard tools provided by IRT for communication and collaboration.  A list of these tools is available at on the IRT website.
      3. Other business cases proposed and justified by employee’s direct supervisor and approved by the Dean or Divisional Vice President; must meet at least ONE of the following criteria:
         1. Role requires staff member to routinely respond to urgent (immediate action required) University business while the staff member is away from the office; supervisor must explain the business necessity.
         2. Role requires staff member to be routinely available while in remote locations, supervisor must explain the business necessity.
         3. Other business cases; supervisor must explain the business necessity.
   3. Program stipends are categorized based on “Moderate Usage”, “High Usage” and “Rowan Medicine”.  The current stipend amounts and parameters for each category are provided in Appendix A and are reviewed periodically.
   4. Mobile phone equipment, including the device itself, accessories and app costs are the responsibility of the employee and are not reimbursable; the employee is responsible for any loss, theft, or damage.  The phone must be able to run current operating systems and software, must have an active cellular plan, must be capable of making and receiving cellular telephone calls, and must be capable of sending and receiving SMS and MMS messages.
   5. Stipend recipients must install the Duo two factor authentication and Outlook mobile client on their devices, and must agree to the baseline device security settings required by these applications.  The Duo and Outlook applications do not themselves require and will not enable the University to read or transmit any other data stored on the device.
   6. Employees may be required by their supervisors to carry a cellular device in order to fulfill the responsibilities of their position. 
   7. There is a limit of one cellular device stipend per employee.  Employees who require “MiFi” functionality or with tablets, laptops or other devices requiring mobile data access are expected to utilize the “Personal Hotspot” functionality on their personal device.  Personal MiFi devices or mobile hotspots are not covered under the stipend program.
   8. To participate in the stipend program, employees:
      1. Must attest that their position requires the regular use of a cellular phone.
      2. Will provide a justification for Rowan Medicine, moderate or high usage reimbursement based on the criteria defined in Appendix A.
      3. Agree to provide the sponsoring supervisor with current contact information within 3 business days of inclusion in the stipend program or within 3 days of a change in that information.
      4. Must renew their stipend requests annually.
      5. Must withdraw from the program when changes to their work assignment or responsibilities make them ineligible for participation in the program based on the criteria set forth in this policy.
   9. Supervisors of employees requesting to participate in the program
      1. Must review, approve and attest annually that the employee has a cellular device and that it is required for their work at a Rowan Medicine, moderate or high usage level.
      2. Must withdraw their approval when an employee is reassigned to another department, when their work assignment makes them ineligible for participation in the program, or if they fail to maintain a cellular device in compliance with this policy.
   10. Divisional Vice Presidents are required to approve all requests submitted within their divisions annually.
   11. Executive leadership, Vice President level and above, is considered pre-approved within the program at the “high usage” reimbursement based on the inherent responsibilities of these positions.
   12. Delays, lapses or oversights in the approval process will not warrant retroactive payment of stipends and may not be submitted for reimbursement via other means.
   13. Reimbursements for regular monthly cellular phone use via other means (Purchasing Card, Purchase Order, Reimbursement Request, etc.) are prohibited.
   14. Reimbursement for infrequent, extraordinary business use of a personal device that is ineligible for the stipend program or infrequent but significant personal communications expense while performing University business (e.g., while traveling) may be submitted in an expense report with proper supporting detail seeking reimbursement of the cost in excess of their normal monthly plan cost.  These reimbursements must be submitted in accordance with IRS accounting plan rules as with any other employee reimbursement, e.g., business travel expenses.

2. Rowan University Provided Cellular Devices

   1. Eligibility

      1. A University-owned device may be issued to employees who meet specific job-based eligibility criteria, including:

         1. Information Technology: Employees who are required for 24/7 on-call responsibilities, after-hours support, or additional communication needs regarding emergency technical services and support.

         2. Plant/Facilities: Employees who are required for 24/7 on-call responsibilities, are always in the field, or do not have access to a desktop phone.

         3. Marketing: Employees who must be available 24/7 for media and community relations, crisis management, or additional communication needs regarding the University’s public image.

         4. Clinical: Employees who must be available 24/7 for on-call responsibilities, patient care needs, or additional communication needs regarding emergency medical care.

         5. Emergency Management and Public Safety: Employees who must be available 24/7 for on-call responsibilities, emergencies regarding the safety of the University community, or additional communication needs regarding emergency services.

         6. Advancement:  Employees who are required to remain in constant contact with both the office and donors. These employees are responsible for obtaining donations from corporations and other entities.

         7. Executive Management: Senior level or executive management that directly support presidential initiatives and operations.

      2. In limited circumstances, employees who do not meet the criteria in V.1.a.i may be issued a University-owned device if at least one of the following two criteria is met:

         1. The job function of the employee requires considerable time outside of their assigned office or work area, and it is important to the University that they are accessible during those times.
         2. The job function of the employee requires them to be accessible outside of scheduled or normal working hours.

   2. Authorization

   1. Any requests for a new University-owned device must be initiated by a dean or departmental manager and approved by the appropriate area Vice President. To request a University-owned cellular device, fill out the Cellular Device Request Form and send it to support@rowan.edu. 

   3. Multiple Devices

      1. Only in the event that a true business case is made to the approving authority will multiple cellular devices be allowed by employees. These business cases occur rarely and will only be approved where multiple devices are necessary for employees to pursue the effective performance of their jobs.

   4. Cellular Device Peripherals

      1. Rowan University will only cover the cost of a protective case for the cellular device. University funds may not be used to pay for other peripherals such as screen protectors or other items.

   5. Cellular Device Storage

      1. Rowan University only allows for the purchase of cellular devices with the basic/least amount of storage capacity available for that model. Larger storage sizes are not permitted. Users should utilize University-supported cloud storage for additional storage space, in accordance with policies governing the storage of sensitive data.

      2. Storage requirements will be reviewed annually by IRT to address current computing requirements or compliance.

   6. Personal Use of University-Provided Cellular Device

      1. Although the occasional use of a Rowan University cellular device for personal calls may be necessary, incoming and outgoing personal calls are discouraged.

         1. At the discretion of Rowan University, employees may be required to reimburse Rowan University for personal phone calls made from an institutional cellular device. Reimbursements should be processed through your supervisor.

         2. Rowan University will audit for international usage of cellular devices. Employees may have to reimburse the University for International Usage.

      2. Note that misuse of the cellular device — using it in ways inconsistent with Rowan University policy or with local, state, or federal laws — will result in immediate cancellation of the cellular device privilege.

   7. Replacement and Damaged Cellular Device 

      1. Employees are eligible for replacement of cellular device once every two years.

      2. Employees with damaged University-provided cellular devices will only be allowed one replacement during a two-year period. All approved replacements will follow the regular replacement cycle and they will be observed by the carrier. 

         1. It is the responsibility of the employee to replace accidentally damaged cellular

            devices, unless the damage occurs during a work activity.

         2. The replacement for a damaged cellular device can only be of the same make and model that the employee is currently using.  A damaged cellular device cannot be replaced with an upgraded model.

         3. It is the responsibility to immediately report lost cellular devices so that the service can be disabled as soon as possible.

      3. All University-owned cellular devices, whether damaged, replaced as part of the replacement cycle or change of carrier, must be returned to the University in compliance with the University’s Technology Ownership Policy.

   8. Deprovisioning University-Owned Cellular Devices

      1. Separating Employees

         1. If an employee has a device account previously provided through Rowan because of the employee’s job function, the University will discontinue providing that account when the employee separates from the University. 

         2. Human Resources must notify IRT of an employee’s last day once it has been determined.

         3. The employee must turn in the cellular device to the IRT Technology Services group for their campus. The return of the cellular device to IRT must take place prior to the close of business on their last day of employment. Failure to do so may result in legal action.

         4. Human Resources will be notified if issued equipment is not collected by IRT by close of business on the person’s last day of employment.

         5. If a separating employee wishes to retain their cellular device or their phone number, they may do so under the following guidelines:

            1. Cellular device will be wiped of all data prior to new setup/transfer. The original owner is responsible for preserving a copy of their own personal data.

            2. Cellular devices may be purchased from the University at their market value. IRT will provide the cost, and if the person wishes to retain the cellular device, he or she will issue a personal check to Rowan University in the amount of the cellular device market value and administrative related fees. The user is responsible for contacting IRT at least five business days prior to their last day of employment.

            3. Phone numbers and phone accounts may be transferred to the ownership of the employee who is separating from the University for a $100 Administrative Fee. The administrative fee of $100 will be paid regardless of whether or not the user owned the number at the beginning of this process. The cellular device user can arrange this by contacting IRT as described above at least five business days prior to the last day of their employment. At this time, the employee will arrange to pay the administrative fees incurred.

            4. In situations where an employee changes positions within the University, it is the responsibility of the department head of the vacated position to collect the cellular device.

            5. Payment is the responsibility of the separating employee and cannot be made with University funds.

      2. Current Employees

         1. If a current employee has a Rowan-owned device that is no longer required for their job function, the employee must turn in the cellular device to the IRT Technology Services group for their campus.

         2. If a current employee wishes to retain their cellular device or their phone number, they may do so under the following guidelines:

            1. Cellular device will be wiped of all data prior to new setup/transfer. The employee is responsible for preserving a copy of their own personal data.

            2. Cellular devices may be purchased from the University at their market value. IRT will provide the cost, and if the person wishes to retain the cellular device, he or she will issue a personal check to Rowan University in the amount of the cellular device market value and administrative related fees.

            3. Phone numbers and phone accounts may be transferred to the ownership of the employee for a $100 Administrative Fee. The administrative fee of $100 will be paid regardless of whether or not the user owned the number at the beginning of this process. The cellular device user can arrange this by contacting IRT. At this time, the employee will arrange to pay the administrative fees incurred. Payment is the responsibility of the employee and cannot be made with University funds.

3. Reimbursement for Use of Personal Cellular Devices

   1. Full Authorization

      1. The appropriate area Vice President may authorize a cellular device reimbursement for an employee who carries a personal cellular device for Rowan University business.

      2. If authorized, employees required to carry a personal cellular device for Rowan University business will receive compensation for cellular usage in the form of a cellular device reimbursement. Reimbursement will not be paid for the cost of cellular device itself.

      3. Simple convenience is not a criterion for a cellular device reimbursement. A reimbursement may be authorized if at least one of the following two criteria is met:

      1. The job function of the employee requires considerable time outside of their assigned office or work area, and it is important to the University that they are accessible during those times.

      2. The job function of the employee requires them to be accessible outside of scheduled or normal working hours.

      4. The use of a cellular device is not a work requirement for most employees.

      5. Employees who are not issued a Rowan University cellular device, and/or are not receiving cellular device reimbursement per this policy, will not be reimbursed for the use of their personal cellular device unless otherwise agreed upon and are expected to make business calls from outside the office.

   2. Limited Authorization

      1. In certain circumstances, the appropriate area Vice President may authorize a cellular device reimbursement for an employee for a limited period of time.

      2. These authorizations will be considered on a case-by-case basis.

   3. Requesting a Personal Cellular Device Reimbursement

      1. A cellular device reimbursement may be requested using the Cellular Device Reimbursement Request Form, following the Mobile Device Reimbursement Procedure.

      2. The form must be approved by the Vice President for the area in which they work and forwarded to Administrative Services of the Office of Finance to begin the reimbursement. This must be repeated at the beginning of every fiscal year, with the exception of limited authorizations.

   4. Reimbursement Payments         

   5. Reimbursements are paid on the portion of the cellular device bill attributable directly to the employee’s cellular device only.  Appropriate area Vice President is responsible for regularly monitoring approved use of the cellular devices.  All appropriate documentation must be included with the Cellular Device Reimbursement Request Form to initiate the reimbursement. 

   6. To determine the dollar amount of the cellular device reimbursement for qualified employees the supervisors should use the following device reimbursement price tiers:

      1. Tier 1 - $24/month or 30% of cell phone bill attributable to the employee: This reimbursement is for an employee who has light usage of the cellular device for business purposes (less than 450 minutes).

      2. Tier 2 - $44/month or 55% of cell phone bill attributable to the employee: This reimbursement is for an employee who has heavy cellular device usage (450 minutes or more) plus extra phone services such as email and calendar integration for their job.

      3. Tier 3 - $64/month or 80% of cell phone bill attributable to the employee: This reimbursement is for an employee who is out in the field a significant amount of the time (50% plus). This reimbursement is specifically for cellular device usage and mobile broadband for wireless card/laptops (not internet usage for their phone). Hardware and any additional costs are not the responsibility of Rowan University.

      4. Tier 4 - 100% of cell phone bill attributable to the employee: This reimbursement is only for executive management who are required to be available 100% of the time. This reimbursement is specifically for cellular device usage and mobile broadband for wireless card/laptops and internet usage for their phone. Hardware and any additional costs are not the responsibility of Rowan University.

   7. Under no circumstances should the approved monthly reimbursement amount exceed the actual monthly cell charges incurred by an employee.

   8. Reimbursements will begin on the first day of the month after the reimbursement is authorized.

   9. The cellular device reimbursement is paid quarterly through accounts payable and is non-taxable.

   This reimbursement does not increase the employee’s base salary and will not be included in the calculation of any Rowan University benefits. This reimbursement is subject to all applicable non-taxable items.
   10. The reimbursement is not an entitlement. The amount can be changed or withdrawn without notice at any time.
   11. The cellular device service is personally owned by the employee.  An employee receiving a cellular device reimbursement program stipend must maintain an active cellular device contract with their a carrier for the life of the reimbursement.

       Discontinuance of Reimbursement

   12. If an employee is terminated, resigns, transfers, or is no longer eligible for a cellular device reimbursement, the employee’s supervisor should submit a revised Cellular Device Reimbursement Request Form noting “Discontinue reimbursement as of date of separation” in the business justification section.

   Rowan University data will be wiped once the employee is no longer eligible for the cellular device reimbursement
4. The University will continue to provide cellular services and devices, potentially including MiFi devices, and are approved based on IRT’s determination of need in alignment with the following guidelines:
   1. Situations that meet any of the following criteria:
      1. There is a business need for a cellular device that is used by multiple individuals on a regular basis in which personal cellular devices cannot reasonably be substituted.  This is generally limited to “duty” phones which are physically passed from individual to individual on shift changes and “pop up” service centers or other mobile field work in which personal cellular device hotspots do not reasonably meet the business need.
      2. Cellular devices installed in fixed locations to facilitate communications.  This is generally limited to security cameras or emergency phones affixed to standalone poles or posts.
      3. Cellular devices installed in University owned vehicles.  This is generally limited to Rowan patrol cars.
      4. In other circumstances with the written approval of the Vice President for Information Resources & Technology.
   2. The University may regularly monitor information on and communications from University owned cellular devices to ensure they are being used in compliance with this policy.  University owned cellular devices are not considered the property of an individual and there should be no expectation of privacy.
   3. Expenses associated with these University owned devices will be planned for and allocated to the appropriate University cost center through the standard, annual budgeting process.  Expenses will not be billed monthly.
5. The University does not provide a pager program to employees.  Pager services are not considered a reimbursable personal expense by the University.  Individual business units are not permitted to contract for or otherwise acquire pager services.
6. Exceptions to the stipend program must be approved by the Vice President for the Division of Finance.  Exceptions to the University owned cellular device program must be approved by the Vice President for Information Resources and Technology.
7. Cellular Device Use
   1. Employees are encouraged to take appropriate safety precautions when using their cellular telephone. If your job requires that you keep your cellular device turned on while driving, you must use a hands-free device.

   2. Under no circumstances should employees place calls while operating a motor vehicle while driving on University business and/or during University time.

   3. In addition, writingWriting, sending, or reading text-based communication —including text messaging, instant messaging, or email — on wireless or cellular devices while driving is a violation of this policy.
   4. If you must conduct Rowan University business while in your vehicle, then safely pull off the road or do so while parked. Employees are expected required to comply with applicable state and local laws regarding the use of cellular devices.
8. All electronic information, including communications, related to Rowan University business are considered legally discoverable regardless of whether or not the employee is on a University owned device or a personal device with or without a stipend.  Employees subject to legal requests are expected to produce any records that may exist.  All communications related to University business should take place on an approved platform as outlined in the Acceptable Use Policy. 

VI. POLICY COMPLIANCE

Violations of this policy may subject the violator to removal from the program and disciplinary actions

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up to or including termination of employment

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, subject to applicable collective bargaining agreements and may subject the violator to penalties stipulated in applicable state and federal statutes.

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Sanctions shall be applied consistently to all violators regardless of job titles or level in the organization.

By Direction of the CIO:

Mira Lalovic-Hand,
SVP and Chief Information Officer

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appendixa appendixa

Appendix A: Usage & Reimbursement Schedule

Monthly stipends will be provided to approved employees on a biweekly basis through the payroll process.  Biweekly reimbursements are calculated on an annualized basis in alignment with standard payroll practices.  The parameters for “Rowan Medicine”, “Moderate Usage” and “High Usage” are provided below.  Employees must meet one of the previously specified criteria to be eligible for participation in the program.

Reimbursement amounts will be reviewed and potentially adjusted annually on July 1st.