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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:
a. define office practices consistent with this guidance,
develop techniques to determine whether telecommunications
bills are reasonable and within expected thresholds,
and investigate irregularities when it makes good business
and economic sense to do so. Given the relatively low
cost of modern telecommunications services, NOAA managers
need not perform detailed reviews of bills as long
as the managers define the criteria or dollar thresholds
where closer scrutiny will occur; and
b. contact their Servicing Human Resources Office
(SHRO) for assistance in determining whether to notify
local union representatives of plans to establish local
policies and practices, and whether involving the union
in the development of those policies and practices
is necessary.
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.
a. Calls Home. Employees may call home when on official
travel, but they must do so using least-cost-to-the
Government methods: Federal or PrePaid Calling Cards.
Employees shall not expect host offices to bear their
phone-home costs. Employees will not be reimbursed
on travel vouchers for daily calls home or calls charged
to hotel rooms unless the calls are due to emergency
conditions, the employees did not have sufficient time
to acquire Federal or PrePaid Calling Cards, or for
other extenuating circumstances. In these instances,
NOAA managers may set dollar limits for calls home.
b. Calls Other than to the Home. Other necessary long-distance
calls (defined in Section 6.01a. of this Order) may
be made using Federal or PrePaid Calling Cards. These
are calls that must be made before employees return
from travel. In most cases, these calls would have
been made from home phones if the employees were not
on travel.
c. Calling Home on Cellular Telephones. Except in
unusual circumstances, cellular telephones shall not
be used to telephone home, at Government expense, when
on official travel.
d. Calls from Airplanes. Federal Calling Cards should
not be used to make business telephone calls when airborne.
If authorized to do so for business purposes, employees
should make domestic airborne calls using Government
travel cards. These offer lower per minute rates and
low price caps on outgoing calls regardless of their
length. The service also allows employees to receive
domestic airborne calls.
.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.
.01 Public Law 104-106, the Information Technology
Management Reform Act (ITMRA), Division E, effective
February 10, 1996.
.02 Public Law 103-62, the Government Performance
and Results Act (GPRA) of 1993.
.03 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.
.04 DOC Information Technology Management Handbook,
Chapter 8, Telecommunications Management Policy.
.05 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.
.06 5 CFR 2635.704, Use of Government Property.
.07 DAO 207-9, Monitoring Conversations.
.08 U.S. DOC, Office of Administration, Guidelines
for Flexiplace Participation, currently available at
http://ohrm.doc.gov/flexiplace.html.
.09 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
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