Q. INFORMATION TECHNOLOGY SERVICES
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Cellular Device Policy
Revision Date: September 15, 2022
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Cellular Device Policy
I. Purpose
Depending upon the business need and established eligibility requirements, the
University of Kentucky (UK) may pay an allowance to an individual employee, provide
a department contract, or reimburse incremental business expenses for cellular
devices.
II. Definitions
• Wireless communication devices: mobile telecommunication equipment (e.g., iPad,
iPhone, Android, MiFi and similar devices - list is illustrative and not intended to be
comprehensive of all tools covered by this policy).
• Business Use: use in the course of performing specific job-related duties on behalf
and for the benefit of UK
• Incremental business expenses: costs above and beyond the employee's normal
calling plan (e.g., excess minutes, roaming charges)
III. Policy
This policy promotes prudent fiscal practices across UK, but also allows each
department the reasonable flexibility to provide cell phones and other portable
electronic resources to employees when there is a legitimate business need.
Departments may establish more restrictive procedures than those outlined, but
should balance any efforts to economize against additional administrative burden on
faculty and staff. This policy is also intended to protect UK and its employees from tax
liability by ensuring compliance with the Internal Revenue Code and its corresponding
regulations.
A. Allowance
Under this option, employees are responsible for purchasing the cell phone and
related service contract with their personal funds. The allowance is intended to
provide reimbursement for the business use of the personal device, but is not
intended to fund the cost of the device nor pay the entire monthly service fees.
The assumption is that most employees also use the device for personal use.
1. Departments must conduct annual reviews of the necessity of allowances for
cellular uses for business purposes;
2. The decision to incur business expenses for cellular devices must be
evaluated from a cost/benefit perspective. Departments must consider other
viable options such as landline phones, Microsoft Teams phone lines, pagers,
or other less expensive communication devices;
3. The dollar amount of the cellular device allowance is established annually by
Information Technology Services (ITS) and approved by Executive Vice
President for Finance and Administration (EVPFA). For current allowance
amount always refer to the Cellular Device Allowance Request Form
. The
amounts are provided in Section I. and vary by Type – either Voice, Data,
Text or Data Plan for Other Devices.
4. Supervisor and business officer must approve Cellular Device Allowance
Request Form;
5. Allowances will be processed through payroll but amounts will not be
considered wages and will not be subject to any payroll taxes. The value of
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Cellular Device Policy
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any personal use which would be covered by the allowance is considered a
working condition fringe benefit. The allowances are not included in an
employee’s compensation for purposes of determining UK’s retirement
coverage or other benefits;
6. Allowances must be eliminated should the bona-fide business purpose no
longer exist; and
7. UK faculty and staff receiving the allowance for mobile device services will
be required to self-register their cell phone contact information through
UK
Alert.
B. Equipment Costs for Employees Receiving Allowance
1. Contracts entered into by authorized employees are personal contracts that
are the responsibility of the employee, not UK;
2. The employee assumes ownership and maintenance responsibility for all
equipment;
3. In all cases, billing for expenses for non-departmental phones must be
directed to the employee for payment. Departments may not allow
employees to have their monthly cellular device or cellular smart device
expenses billed directly to UK or charged to a UK pro-card.
4. Upgrades and new purchases of cellular devices and smart device’s will be
the financial responsibility of the authorized employee;
5. Departments will not reimburse actual expenses for cell phones, equipment,
or accessories;
6. Departments will not purchase cellular device accessories (e.g., batteries,
chargers, covers, holsters, head/ear phones, etc.) for personal cellular or
smart devices;
7. Employees are responsible for paying for any service upgrade. In rare cases,
a department may determine that the cost of the equipment poses a
hardship on the employee. In this case, the department may request a one-
time payment to the employee through the payroll system for the cost of
the equipment no more frequently than once every three years.
C. Departmental Contracts
Personal contracts may not be practical in certain circumstances. Cellular device
purchases and contracts where UK is the official billing entity should be approved
only for those situations where there is substantial documented business need for
providing an employee with phone and service. In these cases, employees do not
receive an allowance or expense reimbursement, and the equipment is the
property of the department, used primarily for business purposes, and returned
to the department daily after the employee’s work shift.
1. This contracting method will not be an option for administrators or faculty
members except in UK HealthCare.
2. Data plans for data devices such as laptops, notebooks and iPads may be
departmental contracts (MiFi devices).
3. Pagers may be obtained by departments where management of the pagers
and payment of related contract fees are the responsibility of the
department.
D. Eligibility guidelines
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1. To qualify for the allowance, the employee must have a business need that
includes one or more of the following:
a. Employees whose duties and responsibilities require them to be readily
accessible for frequent contact with the public or the UK community
and whose job limits his/her access to regular landline telephones
would satisfy the required business communication need;
b. Employees whose duties require that they be immediately accessible
outside of normal business hours;
c. The employee is responsible for critical infrastructure and must be
accessible at all times;
d. The employee travels and needs to be accessible or have access to
information technology systems while traveling; or
e. Access via voice and/or access to information technology systems via a
mobile communication device would, in the judgement of the
supervisor, render the employee more productive and/or the service
the employee provides more effective therefore, the cost of
communication service is warranted.
2. Incremental business expense reimbursement
a. Employees may submit expense reimbursements for occasional,
incremental business expenses according to section IV.A.2
.
3. Departmental contracts
a. Certain Departments may have special needs that justify departmental
ownership of cellular devices (e.g., UK Police, Physical Plant Division,
ITS, Housing and Dining). Other areas must justify device is shared or
rotated among multiple employees.
E. Motor Vehicle Safety
The employee is expected to avoid using a cellular phone or any other type of
electronic communications equipment under any circumstances where such use
might create or appear to create a hazard, including use while operating a motor
vehicle. Please refer to
BPM D-1-2 Use of Motor Vehicles When Conducting
University Business for guidance.
1. This requirement does not apply to emergency response personnel, e.g.,
police, fire, traffic enforcement, environmental health and safety, health
care; and disaster response personnel, including facilities management
personnel who may use a cellular telephone for emergency purposes; and
2. This requirement does not apply to any UK employee who uses a cellular
telephone for emergency purposes, including, but not limited to, an
emergency call to a law enforcement agency, health care provider, fire
department, or other emergency services agency or entity.
F. Special Situations
1. Health Insurance Portability and Accountability Act (HIPAA) and Open
Records Requirements
a. The requirements promulgated under HIPAA applies to personally-
owned cellular devices that contain UK business records and protected
data;
b. The Kentucky Open Records Act requires UK to disclose specified public
records. In response to requests for such disclosure, it may be
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necessary to examine electronic communications records that users
consider to be personal to determine whether they are public records
that are subject to disclosure;
c. UK Guidelines for HIPAA Security Rule Compliance establish security
controls, such as encryption and password protection, covering the
storage or remote access of electronic protected health information
(ePHI) on home computers, laptops, smart devices, and other portable
devices; and
d. Consistent with current practice governing UK-provided equipment,
departments will need to enforce similar procedures to remove all
protected information from employee-owned cellular devices when the
devices are replaced or no longer used for UK business purposes. The
equipment memory should be cleared of all protected data using a data
removal product or similar technology.
2. International Expenses
For employees that receive an allowance, this policy allows for
reimbursement of incremental expenses incurred when international travel
is involved for official business calls and data transfer.
3. Sponsored Projects
a. The allowance may not be charged to sponsored project accounts (i.e.,
WBS/grants starting with 3);
b. Equipment costs may not be charged to sponsored project accounts
(i.e., WBS/grants starting with 3);
c. Reimbursement for specific international calls or for incremental
business expenses may be reimbursed from a sponsored agreement as
laid out in IV.A.2
;
d. In rare instances where a Principal Investigator (PI) or project has met
all requirements in III.D
and the cellular device is required:
1) To meet programmatic goals of the project where no other
feasible option exists;
2) The use is tied to a specific sponsored project; and
3) The proper budgetary and sponsor approval to charge cellular
expenses as direct expenditures was included in the proposal
budget and justification and subsequent approval has been
obtained; then
4) A Cellular Device Department Contract Request Form may be
completed.
G. Exclusions
Departments may establish more restrictive procedures than outlined in this
BPM, but should balance those efforts to economize against additional
administrative burden. Departments are not allowed to establish policies or
procedures that are less restrictive than this UK-wide policy.
H. Discontinuing the allowance
1. If there is a change in an employee's responsibilities that would disqualify
them from continuing to receive the allowance, the department must
discontinue the allowance, effective at the date that the employee’s
responsibilities changed by completion of new cell phone allowance request
form;
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Cellular Device Policy
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2. If, prior to the end of the cell phone contact, a personal decision by the
employee; employee misconduct; or misuse of the phone results in the need
to end or change the cell phone contract, the employee will bear the cost of
any fees associated with that change or cancellation. For example, the
employee voluntarily leaves UK and no longer wants to retain their current
cell phone contract for personal purposes; or
3. If, prior to the end of the cell phone contract period, a UK decision
(unrelated to employee misconduct) results in the need to end or change
the cell phone contract, UK will reimburse employee up to 50% of the cost
of any fees associated with that change or cancellation. For example, the
employee's supervisor has changed the employee's duties and the cellular
device is no longer necessary for UK purposes. If the employee does not
want to retain the current contract, up to 50% of change or cancellation
fees will be reimbursed by UK, see IV.C
.
IV. Procedures
A. Approval
1. Allowance
a. Departments must review and affirm that an employee has business
need that meets eligibility for initial and on-going allowance;
b. Authorization of the allowance is recommended by the employee's
supervisor and approved by the department business officer;
c. Annual renewal authorizations are required by the same management
level;
d. For employees who qualify, this policy authorizes an allowance for
cellular devices paid across effective future pay periods (no retroactive
adjustments);
e. Employees who receive an allowance may not receive reimbursements
for cellular devices or cellular expenses except for international calls
III.F.2
; and
f. The amount of the allowance is reviewed periodically by ITS, refer to
the current Cellular Device Allowance Request Form for the
reimbursement amounts.
2. Incremental Business Expense Reimbursements
a. Provide a copy of the employee’s bill, clearly listing the incremental
costs that are above and beyond the employee’s normal calling plan
(e.g., excess minutes, roaming charges);
b. An invoice must be submitted to verify the incremental business
expenses costs incurred;
c. Notate on the bill who was called and the business purpose of calls
where reimbursement is being requested;
d. Employee certifies on billing document that they do not receive the cell
phone allowance (except in the case of international call
reimbursement);
e. Department prepares a PRD for reimbursement to the employee;
f. Documentation is routed to the approver; and
g. ACH direct deposit will be processed after approval.
3. Departmental contracts
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Cellular Device Policy
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a. The Cellular Device Departmental Contract Request Form should be
completed, clearly documenting justification for departmental contract.
b. The department head or designee must approve the request. Annual
review and renewal must occur to ensure most economical option that
meets department’s business needs.
c. For cellular devices, contracts, and services acquired through ITS,
charges will be billed to UK. The user’s cost object (not allowed on
Sponsored Projects see IV.D) will be charged the appropriate amount
on their ITS monthly statement;
d. For department contract devices, departments may purchase cellular
supplies directly from the vendor (e.g. batteries, chargers, covers,
holsters, head/ear phones etc.) using a Procard; and
e. The user’s department is responsible for terminating the cellular plan
when the service is no longer required by the department.
B. Equipment costs
When a department determines that the equipment should be paid by the
department:
1. The department confirms and documents the reason for the equipment
purchase (e.g., financial hardship for the employee);
2. The department submits an approved Cellular Device Allowance Request
Form to the department payroll administrator; and
3. The department payroll administrator will set up the one-time payment
through the Payroll system for the cost of the equipment.
C. Discontinuing the supplement
If a department head determines there is no bona-fide business reason for
continuation of the allowance and
1. If the personal contract is terminated before the contract expiration date
due to this decision, the employee can request reimbursement from their UK
department for up to 50% of the contract termination fee; and
2. The department must receive written verification from the vendor outlining
the exact termination fees; and
3. Reimbursable amount will be paid through the PRD reimbursement process
with appropriate supporting documentation.
D. Sponsored Projects
1. Approval of Department Contract:
a. Route to obtain the signatures of the Associate Dean for Research;
b. The Office of Sponsored Project Administration (OSPA); and
c. OSPA will forward the approved form ITS for processing.
2. If the request for a departmental contract has been approved, the following
procedures are required to transfer costs to a WBS/grant:
a. A journal voucher (JV) will be completed monthly to allocate the
charges for the mobile device;
b. The following g/l accounts must be used for the reallocation of the
charges to a WBS/grant from an approved departmental contract:
• 639020 – Cell phone services allocated to grant
• 639021 – Data plan services allocated to grant
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Cellular Device Policy
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• 639022 – Air card services allocated to grant
• 639023 – Cell/Smart device equipment charges allocated to grant
c. The invoice from ITS;
d. The allocation of 100% of all phone charges must be individually
identified on the sponsored projects phone allocation form
; and
e. The detailed billing from the carrier.
V. Responsibilities
A. UK Employee
1. Responsible for equipment and contact payments.
2. Responsible for properly documenting reimbursable expenses if not
receiving an allowance.
3. Responsible for registering cellular phone contact information through UK
Alert.
4. Responsible for maintenance and security of cellular devices.
5. Responsible for compliance with HIPAA and Open Records regulations.
6. Responsible for retaining an active cellular contract as long as an allowance
is in place. Because the cellular device is owned by the employee, the
employee may use the phone for both business and personal purposes. The
employee may add extra services or equipment features, as desired.
7. Any use contrary to local, state, or federal laws will constitute misuse, and
will result in immediate termination of the allowance.
B. Supervisory/Management Personnel
1. Determine, document, and recommend the initial and annual eligibility of
employees to receive the allowance.
2. Ensure updates to Payroll are made for the allowance, as appropriate
through the Cellular Device Allowance Request Form.
3. Cancel the allowance when employee leaves the Department or is no longer
authorized.
4. Review and approve individual reimbursement requests from non-qualifying
individuals.
C. Department Business Officer
1. Verify budget authority and cost object.
D. OSPA
1. Review of Cellular Departmental Device Request for sponsor approval.
E. ITS
1. Responsible for review of allowance.
2. Assisting with acquisition of departmental contract devices.
F. University Financial Services
1. Review of Cellular Departmental Device Request.
