Cell Phone Subsidy Policy

As an organization which operates 24/7 throughout the year, Saint Joseph’s College requires a workforce equipped to support its continuous and mission-critical safety, security and operating needs. To meet these demands, the College has identified select employees who are required to be immediately or routinely accessible to perform their assigned job duties, and provides a subsidy of $35 per month to support cellular service.

General Comments

The provisions of this policy must comply with IRS requirements for avoiding tax liability for the College and for the employee, and therefore, may not be altered in its execution. The policy is intended to promote 1) optimally required coverage at the lowest cost to the College, 2) administrative efficiency, and 3) equity among employees with like requirements.

The cell phone subsidy plan provides direct payment to an eligible employee for the anticipated business use of a personally owned cellular phone. The allowed subsidy amount is $35 per month.

The cell phone subsidy is non-compensatory, in that it may not be authorized in lieu of compensation. It is not included in decisions regarding raise amounts, job changes or upgrades, and is not applied in calculating pension or other wage-based benefits.

Cell phone subsidy recipients must agree to and comply with the terms of this policy and must complete and submit a Cellular Phone Subsidy Request Form.

The phone number associated with any cellular device covered by the Plan must be listed in the College emergency contact directory, and employees are expected to keep their cellphone and emergency contact information updated in ADP.


An employee may qualify for a cell phone subsidy if his/her assigned duties and associated documentation indicates the existence of a substantial non-compensatory business reason (“business reason”) as identified by the employee’s Dean or Director, and approved by the employee’s Vice President.

The following specific criteria are applied to identify employees having a business reason to be provided with a cell phone subsidy:

  • SJC needs to be able to contact the employee at all times for work-related issues
  • SJC requires the employee be available to speak with customers at times when the employee is away from the office or at times outside of the employee’s normal work schedule.
  • The employee is required to be available to make and communicate critical decisions affecting the safety and security of students, employees, and campus guests, or the protection of critical physical infrastructure, and/or;
  • The employee is required to be “on call,” regularly or on occasion, to respond to campus events affecting the personal safety and security of students, employees, and campus guests, or the protection of facilities and critical infrastructure, and/or;
  • The employee is required to be available to manage social media accounts or to communicate with the media, and/or;
  • The nature of the employee’s work requires significant travel away from campus and the employee must be accessible to the College or its customers during those travels, and/or;
  • The employee’s ability to access email and basic web resources while mobile is critical to the employee’s responsibilities, and/or;
  • Reliable communication during regular work hours will provide significantly better service to the community AND will significantly increase the individual’s productivity.

An employee may request to be enrolled in the cell phone subsidy plan by submitting a completed SJC Cellular Phone Subsidy Request Form to his/her Dean or Director. A request may be submitted at any time. The Dean or Director will assess whether the employee meets one or more of the specific criteria constituting a business reason. The completed form is then forwarded to the employee’s Vice President for final approval.

The employee’s enrollment is valid through the term of employment in a specific position, and where criteria has been previously identified and met, and at the sole discretion of his/her Dean, Director, or Vice President, or unless terminated for other reasons described herein.

After proper approval steps have been taken, the authorized monthly subsidy will be paid by Accounts Payable on the first payroll date of each month following its approval, provided the approval is submitted to Accounts Payable by the 15th of the preceding month.

Employee Rights and Responsibilities

Phone and carrier selection. The employee who receives a cell phone subsidy is responsible to purchase an appropriate device, and to select a service carrier. The chosen carrier should provide coverage in areas where the employee is likely to conduct or be available to conduct College business. The employee may freely choose service levels and plans, accessories, and phone features. The employee’s name must be associated with at least one eligible device on the carrier bill. The employee is solely responsible for all payments to the carrier, all service contract provisions, and for the repair or replacement of a covered phone which has been lost or damaged. SJC does not assume any liability for claims, charges, or disputes between the employee and the carrier.

If the employee’s service contract terminates for any reason, s/he is required to notify his/her Dean or Director within 5 business days to terminate the subsidy.

Maintenance of device and service. The employee who receives a cell phone subsidy must maintain service throughout the life of the subsidy. The employee is responsible for ensuring the phone is properly charged and in good operating condition at all times.

Record-keeping. The employee is not required to maintain or submit a detailed usage log for the covered device, provided s/he is able to produce a copy of selected carrier billings upon request.

IT Support. Employees are to address any issues involving a device or service directly with the carrier. Support from Information Technology (IT) is limited to providing assistance in connecting the phone to College-provided services, such as email, calendar and contacts. The employee is responsible for downloading and installing all updates and patches when they become available.

Data Security. Devices covered by this policy are used to conduct SJC business and/or to create, receive, send, or store College data. As a result, information stored on data-enabled devices is subject to Federal data maintenance and protection laws (e.g., FERPA, records retention requirements), as well as all College policies, including those pertaining to data security, acceptable computing use, and email.

A data-capable phone or device must be secured according to standards established by IT, including password protection and encryption. The loss or theft of a data-capable phone must be immediately reported to IT, and to the carrier. As a security measure, the College may require a phone’s data be “wiped,” in the event the device is lost or stolen, or the employee is terminated. In enrolling for the cell phone subsidy plan, the employee agrees to hold the College harmless for the loss of any personal data which may occur in conducting a “wipe.”

Legal Compliance. The employee receiving a SJC cell phone subsidy agrees to assist the College in complying with requests by government officials for information about or stored in a covered device.

Employees must comply with applicable laws regarding the use of cell phones while driving and avoid uses that may jeopardize the safety of the employee or others. Use of a covered phone in any manner contrary to local, state, or federal laws constitutes misuse, and will result in immediate termination of the cell phone subsidy.

Dean and Director Responsibilities

The Dean or Director is responsible for overseeing and assessing employee cell phone needs, and for conducting the periodic review of each subsidy to determine if it should be continued, changed, or terminated. Cell phone subsidy costs are funded by the employee’s department.

Effect of Termination, Leaves or Change in Job Requirements:

The SJC cell phone subsidy will be immediately cancelled:

  • When the employee terminates qualifying cell phone service;
  • Separates employment with SJC, at which time the phone’s data will be wiped;
  • The employee has engaged in misconduct or misuse of the device for which the subsidy has been approved;
  • Upon a change in jobs, unless a new SJC Cell Phone Subsidy Request is approved.