NAO 212-10A: Telecommunications Management - Telephone Use Policy

Issued 07/30/99; Effective 07/22/99

SECTION 1. PURPOSE.

This Order provides guidance for using Government-owned, leased, and managed telephone systems, cellular telephones and wireless technology, and Federal telephone calling cards. The Order addresses cost recovery procedures and other management considerations.

SECTION 2. SCOPE.

This Order applies to all NOAA employees and covers NOAA contractors unless excluded by other contract language. The term "employee" used hereafter in this Order is inclusive.

SECTION 3. BACKGROUND.

.01 A number of factors have changed the long-held criteria for using the telephone. Since divestiture of American Telephone and Telegraph Company and deregulation of the telecommunications industry in 1984, increased competition and rapid technological developments have produced significantly lower rates for telecommunications services and products. These developments and changes have become standard in modern offices. They have improved administrative efficiency, effectiveness, and mission accomplishments in remarkable ways.

.02 Lower per-minute costs for traditional long-distance services have influenced the relaxation of Federal regulations. The Information Technology Management Reform Act (ITMRA) and the Government Performance and Results Act (GPRA) have changed the Government's perspective on Information Technology (IT) Management.

SECTION 4. POLICY/OBJECTIVES.

.01 It is NOAA's policy that its telecommunications services and systems are corporate resources, and as such, are to be managed in the most cost-effective manner possible and in the best interest of the Government. NOAA managers have flexibility in developing objectives to achieve this policy.

.02 NOAA managers shall reasonably balance employees' personal needs with NOAA's needs as an organization. Reasonableness and common sense shall be guiding principles in all situations.

SECTION 5. RESPONSIBILITIES.

.01 The Information Technology Officer (ITO) issues policy guidance for managing NOAA's IT resources.

.02 The Information Systems Office (ISO) develops telecommunications management policies and guidance as detailed in NOAA Administrative Order (NAO) 212-10, Telecommunications Planning, Acquisition, and Management. ISO also develops and promulgates electronic telecommunications analysis techniques that support NOAA managers and improve management effectiveness and efficiency.

.03 Managers and supervisors are responsible for reasonable review of telecommunications bills, billing exception reports, financial system cost data, and other similar information. To accomplish this, managers and supervisors must:

SECTION 6. GUIDELINES.

.01 Using Government Telecommunications Resources.

a. NOAA employees shall use Government telephones only for official business, including personal calls that NOAA determines are necessary and in the best interest of the Government. Some examples of appropriate calls that are in the best interest of the Government include the following:

  1. calls to alert household members about working late or other schedule changes;
  2. calls to make alternative child care arrangements;
  3. calls to talk with doctors, hospital staff, or day care providers;
  4. calls to determine the safety of family or household members, particularly in an emergency;
  5. calls to make funeral arrangements;
  6. calls to reach government agencies (state, local, etc.) that can only be contacted during work hours; and
  7. calls to make emergency repairs to vehicles or residences, etc.

b. All personal calls that are made under the provision of this Order, including toll or local calls made from Government telephones:

  1. must not adversely affect the performance of employees' official duties or the organization's work performance;
  2. must be of reasonable duration and frequency; and
  3. could not reasonably have been made during non-working hours.

c. NOAA employees may make a limited number of purely personal calls (those determined not to be necessary in the best interest of the Government) from Government telephones. Employees may not make purely personal long-distance calls expecting to reimburse the Government later. In making purely personal calls, employees shall:

  1. ensure that all long-distance calls are made at their own expense (e.g., charged to personal calling or credit cards, home telephones, or other non-Government telephone numbers);
  2. ensure that the calls do not adversely affect the performance of official duties or the organization's work performance; and
  3. ensure that the calls are of reasonable duration and frequency.

.02 Reasonableness Determinations for Telephone Call Duration(s) and Frequency. Supervisors and managers shall determine whether personal telephone calls are reasonable and in the best interest of the Government based on employees' work schedule, co-worker needs, office work demands, length of work day, etc.

.03 Using Government Telecommunications Resources when Traveling.

.04 Cost Recovery for Unauthorized Long-Distance Telephone Calls and Disciplinary Action.

a. When telecommunications abuse occurs, there are two concurrent considerations: (1) recovery of NOAA's out-of-pocket and administrative costs to rectify telecommunications management program abuses; and (2) formal disciplinary action for misconduct in accordance with Human Resources Management Office (HRMO) regulations and penalty guides.

  1. Recovery of NOAA's Out-of-Pocket and Administrative Costs. When it is cost-effective to do so, NOAA managers and supervisors shall recover NOAA telecommunications costs as reported on bills with any discounts applied and taxes added, rounded to the nearest dollar. An administrative processing cost of one hour at the GS-12, step 4, rate using the locality pay table where the employee works, rounded to the nearest dollar (approximately $25.00 currently) will also be recovered for each telephone bill reflecting abuse. Supervisors can waive cost recovery only if they determine it is in the best interest of the Government to do so. NOAA managers and supervisors should consult with their SHRO to make these determinations. If multiple bills are settled at one time, or if it is not cost effective to collect one-time charges, the administrative fee may be imposed once.
  2. Formal Disciplinary Action for Misconduct. In addition to telecommunications cost recovery, NOAA management may pursue formal disciplinary action, up to and including removal. Supervisors should consult with their SHRO to determine appropriate corrective action.

b. Employees shall make reimbursement checks payable to NOAA in the amount specified by their supervisors who will:

  1. Annotate on the check (either at the top or on the reference line) the accounting code to be credited and how the funds should be allocated (e.g., "$25.00 Administrative Fee/ $43.59 AJ2320/9P1B2300.2337"); and
  2. Forward the check with a brief memorandum to the organization's Servicing Finance Office (SFO) for processing (the memorandum must state that the payment reimburses the Government for telecommunications and administrative costs).

c. The SFO will deposit the check and distribute the proceeds according to the office's allocation instructions on the check. Generally, the amount recovered for telecommunications costs will be restored to the office's accounting code. The amount recovered for administrative processing, however, must be deposited in the U.S. Department of the Treasury's General Fund to comply with the "miscellaneous receipts" statute, 31 U.S.C. Section 3302(b).

.05 Collect Calls.

Collect calls shall not be accepted by Government employees unless there are extenuating or unusual circumstances that are not continuing. When there is a recurring program need to accept collect calls, such as in Damage Assessment or Hazardous Materials reporting, offices shall consider a toll-free number.

.06 Toll Free Numbers.

NOAA employees shall use toll free numbers when offered by Government contractors and others.

.07 900 Numbers.

As a rule, NOAA employees may not make calls at Government expense to 900 numbers. Many Government systems block outgoing calls to 900 numbers. In instances where technical assistance is only available using 900 numbers, NOAA offices shall use unblocked lines such as modem lines that are outside Government systems to place the calls.

.08 Directory Assistance Calls.

NOAA employees shall use telephone directories to determine necessary telephone numbers rather than routinely calling long-distance or local providers who provide numbers for a fee. When area codes are unknown, NOAA employees shall use cost-effective nationwide operator-assisted directory services. Managers shall note excessive directory assistance calls on bills.

.09 Listening-In On or Recording Telephone Calls.

Under no circumstances may calls be recorded or monitored unless the conditions and processes outlined in Department Administrative Order (DAO) 207-9, Monitoring Conversations, are met. Call monitoring or recording should be coordinated with DOC Office of General Counsel (OGC), and in some cases, may require approval by the Secretary of Commerce. Any questions about recording telephone calls should be directed to the DOC OGC.

.10 Privacy Act.

DOC has established a Privacy Act System of Records, COMMERCE/DEPT-21-CALL DETAIL RECORDS. It includes telephone call detail records that specify calling and called telephone numbers, telephone numbers identified by employee name(s) and equipment locations, including personnel and administrative actions that result from telephone abuse. All Privacy Act procedures and safeguards must be followed in handling telephone call detail records. Specifically, the records must be secured, properly destroyed, and restricted to NOAA managers and employees who have a need for the records in the performance of their duties. Managers who handle these records must maintain a copy of, and be familiar with, the COMMERCE/DEPT-21 notice (currently available at www.access.gpo.gov/nara/index.html#pa which is the site to gain access to Privacy Act data) and understand its content.

.11 Employment Changes.

When NOAA employees leave or transfer to other agencies, they must acknowledge whether or not they have Federal Calling Cards on Personnel Checklists. As part of the clearance process, SHROs must advise the appropriate NOAA manager to cancel cards. Employees transferring within NOAA may retain cards in unusual circumstances and if the losing office agrees to bear the interim costs until billing is realigned.

.12 Federal Calling Cards or PrePaid Calling Cards.

a. Employees who travel must use either a Federal or a PrePaid Calling Card to make authorized calls home. Federal Calling Cards must be ordered through FTS2000 (or a follow-on contract) ordering agents, Designated Agency Representatives (DARs). PrePaid Cards may be ordered directly by administrative staffs in minimum order quantities and in $5 increments. The Federal and PrePaid Cards may be charged to Government Purchase Cards.

b. For network security reasons, Federal Calling Cards shall be in individuals' (not offices') names, and shall not be shared within offices. Offices must track all Federal Calling Cards and cancel them when employees terminate. Regaining physical possession of the card is insufficient control.

c. PrePaid Calling Cards may be ordered for an office and must be kept in a secure location.

.13 Lost or Stolen Federal Calling Cards.

a. Employees must report any instance of lost or compromised Federal Calling Cards promptly using the toll-free number on the reverse of the cards, if known, or to the provider's 800 number obtained from directory assistance.

b. Employees will not be held liable for unauthorized calls made by third parties if the lost or stolen cards are reported promptly. PrePaid Calling Cards are like cash and will not be replaced by NOAA if employees lose them.

.14 Telephones in Homes.

Government regulations presently do not allow installation of telephone services or equipment, including data lines, in private residences at Government expense unless employees are working under approved Flexiplace Agreements in accordance with DOC's Flexiplace Program.

.15 Management Review Considerations.

NOAA managers shall identify reasonable dollar thresholds, sampling methodology, screening techniques, or some other method for determining when telecommunications bills will be reviewed more closely. Problem indicators typically include widely varying monthly bill totals, large numbers of off-net calls, long or repeated calls made before and after work hours, and large numbers of directory assistance calls. Long-hold calls should be reviewed to determine if they are transmissions that could be aggregated to reduce costs. Managers shall investigate bill irregularities.

.16 Reimbursement for Telecommunications Expenses.

If approved in advance by supervisors, SFOs can process employees' reimbursement claims for official and authorized telephone calls billed to homes, cellular telephones, or personal credit cards and can include reimbursement for taxes. Service providers should bill recurring telecommunications expenses directly to NOAA. Typically, recurring charges should not be charged to Government Purchase Cards.

.17 Cellular Telephones and Wireless Telecommunications Services.

a. Cellular telephones and other wireless services, such as intelligent pagers and Personal Communications Systems (PCS) technology, shall be used and managed as a telecommunications system and a NOAA resource. Cellular phones shall be ordered when there is a business reason that calls be made away from the office. Cellular phones may also offer affordable emergency backup telephone services. Because cellular and wireless services are more expensive and may be charged in full minute increments, managers shall establish threshold criteria for reviewing wireless bills in more detail.

b. Employees shall be particularly diligent and use cellular telephones only when required to do so for official business, and when the calls are in the best interest of the Government.

c. If NOAA employees have recurring needs to use personal cellular telephones to make calls that are in the best interest of the Government, and if cost-benefit reviews support the needs, the office should consider acquiring Government-owned cellular telephones that can be checked out.

.18 International Calls.

NOAA offices shall use cost-effective telecommunications services to contact locations outside the contiguous United States and overseas. Cost-effective dedicated voice or data circuits to overseas locations shall be coordinated with DOC through ISO, Systems Division, Telecommunications and ADP Security Branch (TASB).

.19 Telecommunications Use and Electronic Commerce and Administrative Support Systems.

When possible, NOAA offices shall use electronic ordering and billing practices for procuring telecommunications services and products, and consolidate telecommunications bills. These practices support NOAA's electronic commerce goals and improve administrative efficiency.

SECTION 7. REFERENCES.

  1. Public Law 104-106, the Information Technology Management Reform Act (ITMRA), Division E, effective February 10, 1996.
  2. Public Law 103-62, the Government Performance and Results Act (GPRA) of 1993.
  3. General Services Administration's Federal Property Management Regulations (FPMR), part 101-35.1 of title 41 of the Code of Federal Regulations (41 CFR 101-35.1), Use of Government Telephone Systems.
  4. DOC Information Technology Management Handbook, Chapter 8, Telecommunications Management Policy.
  5. Office of Management and Budget Guidance, 52 FR 12990, Guidance on the Privacy Act Implications of Call Detail Programs to Manage, Employees' Use of the Government's Telecommunications Systems.
  6. 5 CFR 2635.704, Use of Government Property.
  7. DAO 207-9, Monitoring Conversations.
  8. U.S. DOC, Office of Administration, Guidelines for Flexiplace Participation, currently available at http://ohrm.doc.gov/flexiplace.html.
  9. DOC Cash Management and Procedures Handbook, Chapter 6-58b, Recurring Payments.
  10. U.S. Department of the Treasury Manual of Procedures and Instructions for Cashiers, Section 7, Purchases and Miscellaneous Cash Payments.
  11. DOC Travel Handbook Special Transmittal (ST) 98-3, Change to DOC Travel Regulations.
  12. NOAA Travel Advisory 99-2 (Personal Phone Calls While on Travel).

SECTION 8. EFFECT ON OTHER ISSUANCES.

This Order supersedes NAO 212-2, Telecommunications Resources - Telephone Usage Policy, dated August 25, 1989.

SIGNED,

Chief Financial Officer/Chief Administrative Officer

Office of Primary Interest:
Office of Finance and Administration
Information Systems Office