Policy FN21 - CELLULAR SERVICES (Formerly Non-Office Telecommunications Services, BS19)

Policy Steward:  Office of the Corporate Controller


  • Purpose
  • Policy
  • Business Criteria for Cellular Service
  • Cellular Service for Business Purposes
  • University-owned Cellular Plans/Devices
  • Acquisition of Services
  • Non-Business Use
  • Termination of Service
  • Reimbursement for Business Use of a Personal Phone
  • Contract Changes or Cancellations
  • Data Security and Confidentiality
  • Internet Services
  • Further Information
  • Cross References


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


    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).


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

    •  Key Personnel

    •  Technical Monitoring

    •  No other communication source

    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.


    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:

    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.


    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:

    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.


    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.


    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


    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


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


    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:

    Revision History (and effective dates):

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