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Telecommunications Management Policy

U.S. Department of Commerce
Office of the Chief Information Officer

Telecommunications Management Policy

What is telecommunications?
What is this policy and to whom does it apply?

Why is a policy on telecommunications required?

What planning for telecommunications is required?

How do operating units acquire telecommunications resources?

Are there contracts or services that Commerce operating units are required to use?

Are there constraints for using telecommunications resources?

May Commerce employees be compensated for use of their own telecommunications resources?

May Commerce telecommunications resources be used in private residences?

May telecommunications resources be authorized for personal use?

How do operating units ensure security of telecommunications resources?

May telecommunications transmissions or conversations be recorded or monitored?

How do operating units dispose of telecommunications resources?

How do operating units manage and control costs of telecommunications resources?

What Commerce officials have responsibility for implementing this policy?

Where can I get additional information?

Who can address questions regarding this policy?

What is telecommunications?

Telecommunications refers to any technology, service, system, or other resource that provides or ensures transmission of electronic data and information. Telecommunications resources may be voice and data networks, telephones (wired and wireless), other wireless services, messaging and directory services, high speed data communications, facsimile devices, personal digital assistants, network servers, switches, or any other device, service, or system used in the transmission of electronic communication, including the connectivity to and between devices. The locations of telecommunications resources are equally diverse, ranging from equipment in single buildings to nationwide or global networks, from a single telephone handset in a home to communications satellites in orbit.

Telecommunications that is either all or part of a system must be considered an information technology (IT) system for all planning, acquisition, policy, security, and functional purposes.

Within this policy, no distinction is made between voice-centric and data-centric telecommunications, or between wired and wireless services, unless specifically noted.

What is this policy and to whom does it apply?

This policy establishes and outlines relevant guidance related to the acquisition, management, use, and disposition of telecommunications resources within the Department of Commerce and applies to all operating units of the Department of Commerce, including the Office of the Secretary, and including contractors who are authorized to use Commerce resources. Where the term “employee” is used in this policy, it applies to both employees and contractors who are authorized to use Commerce services.

Nothing in this policy is intended to negate any provision in an existing collective bargaining agreement. Prior to implementation of this policy, all applicable labor relations obligations must be met. Refer questions regarding labor relations obligations to your servicing human resources office.

Why is a policy on telecommunications required?

This policy is required because telecommunications resources form one of the most essential elements in the operations of the agency. The Department of Commerce relies on telecommunications systems and services to support the mission and goals set out by the Secretary of Commerce, so it is vital that these resources be effectively managed.

The ability of telecommunications to increase productivity has grown tremendously. Management of telecommunications resources, therefore, should actively ensure that telecommunications benefits (speed, usefulness, and service availability) are emphasized even while steps are taken to manage risks and reduce costs.

Prior to the Government Performance and Results Act and the Clinger-Cohen Act, telecommunications policy was derived from the Federal Information

Resources Management Regulations (FIRMR), the Federal Property Management Regulations (FPMR), and the Federal Acquisition Regulations (FAR). Today, most telecommunications policy is built on the provisions of the following legislation, directives, and guidance:

These laws, directives, and guidance serve as the foundation for development of policy and management of Federal information technology, including telecommunications.

Until 2003, the Government-wide policy on telecommunications management was found in the Federal Property Management Regulations (FPMR). These policies are being revised and will be placed in the new Federal Management Regulations (FMR) Subchapter F.

What planning for telecommunications is required?

The acquisition and use of telecommunications resources, as a subset of IT Resources, must be included in the IT planning and IT acquisition processes. Since telecommunications resources are acquired and used in response to a strategic need or requirement, these resources, as systems or groups of systems, should be considered during development of IT architectures, IT planning, and IT acquisition initiatives. Telecommunications resources should never be acquired without consideration of the use and the ways in which the telecommunications will support and enhance the mission of the agency or program. For instance, directory services are enterprise resources and implementation and management must be consistent across all operating units within the Department of Commerce.

How do operating units acquire telecommunications resources?

Acquisition of telecommunications services and products should be conducted in accordance with the provisions of the Commerce Acquisition Manual (CAM) and the Federal Acquisition Regulations (FAR). The IT planning process as noted above must be followed, as well, for larger systems and acquisitions.

Generally, telecommunications resources should be acquired using as efficient an acquisition process as possible. Operating units should use or consider using blanket or broad ranging, existing contractual programs, many of which have been competed and from which services may be easily acquired. Numerous acquisition vehicles, contracts, and agreements are available that meet these criteria, including the Washington Interagency Telecommunications System (WITS), Metropolitan Area Acquisitions (MAA), and many offerings from the Federal Technology Service (FTS), along with others. Most have been fully competed by either the General Services Administration (GSA) or by other agencies, which offer their acquisition vehicles to Commerce.

Telecommunications services may be ordered by a Designated Agency Representative (DAR) for FTS2001 services or a contracting officer through the normal acquisition process. Commerce credit card holders may purchase non-FTS2001 telecommunications equipment and services (e.g., cell phones, wireless Personal Digital Assistants, etc.) within their purchase limits, not exceeding $2,500 per year. Acquisition must be conducted by individuals who have been trained and authorized by the Office of Acquisition Management, in accordance with the Commerce Acquisition Manual and the Federal Acquisition Regulations.

No individual may order, contract for, or in any way obligate the government for telecommunications resources unless specifically authorized to do so. See the guidance for DARs.

Are there contracts or services that Commerce operating units are required to use?

No. There are presently no programs that are mandatory for use within the Department of Commerce. FTS2001 and COMMITS were previously mandatory for use or mandatory for consideration, so for clarity each is discussed below. Each still offers robust services with unique ease of acquisition.

FTS 2001:

FTS2001 continues as a broad, Government-wide contract for provision of local, long distance, and international telecommunications connectivity services. Along with FTS2001, there are numerous offerings under the GSA’s Federal Technology Services (FTS) Telecommunications program. All have been competed and can be acquired easily by operating units, using simplified acquisition methods, if they fulfill a telecommunications requirement.

Acquisition of services under the FTS2001 program requires the use of an official Designated Agency Representative (DAR), who is specifically authorized to order services. See the guidance for DARs.

COMMITS:

Commerce IT Services Nex Gen (COMMITS NexGen) is a government-wide acquisition contract (GWAC) between the Department of Commerce and small, small disadvantaged, 8(a), and women-owned small business contractors capable of delivering the IT requirements, including telecommunications services and equipment. The program and its use policy are outlined in the COMMITS Preferred Source Policy, of April 25, 2000.

Are there constraints for using telecommunications resources?

Yes. Government-acquired telecommunications resources are intended for the purpose of performing the mission of the Department of Commerce and its operating units. These resources are for the use of the Government in conduct of official business, when specifically determined to be in the best interest of the Government. Chief Information Officers (CIOs) and telecommunications managers are responsible for effectively managing the use of telecommunications resources to ensure that the business of the Government, within their mission area, is carried out effectively and efficiently. IT resources should be used in compliance with laws and regulations that apply to all Government IT resources.

May Commerce employees be compensated for use of their own telecommunications resources?

Under certain circumstances, some costs may be compensated. Government employees may be reimbursed for the use of their own, privately owned telecommunications services when no acceptable Government-owned service is available and when to do so is in the best interest of the Government. The amount of reimbursement must be the actual cost of service as shown on the employee’s billing statement. Reimbursement must be for the actual cost of the service, not an estimated or “flat” amount. Reimbursement may not cover the basic cost of service already owned by the employee, only the incremental, additional cost for use of the service for Government-related work. If an employee uses more than the allocated or permitted number of minutes under a vendor’s billing plan, the employee may be reimbursed at the “additional minute” rate multiplied by the number of free minutes used on Government calls. In all such cases, reimbursement must be approved by the employee’s management, either before or after use.

The Government may not require employees to acquire or use their own privately owned services for the purpose of performing their official duties. Employees may, however, with their own consent and with the prior approval of management, use privately owned resources on a one-time or recurring basis, when it is in the best interest of the Government to do so.

Some examples of appropriate reimbursements follow:

An employee who travels away from the office, locally or long distance, and uses his/her personal cellular device for official communications, may be compensated for the actual, incremental cost of that use.

An employee who, at the request or approval of management, works from home or away from the office may be reimbursed for the actual, incremental cost of telecommunications services incurred in such work.

May Commerce telecommunications resources be used in private residences?

Yes, under limited circumstances. In general, Government-provided telecommunications services will not be made available in private residences. However, in support of such functions or activities as telework, it is permissible to provide equipment or services where it is in the best interest of the Government to do so. Examples of permissible equipment or services include telecommunications modems, FAX equipment, high-speed data lines, wireless services, additional voice lines, or telecommunications devices for the hearing impaired. Examples of programs or activities that might be in the best interest of the Government include national security, homeland security, approved telework programs, or work-at-home for an employee with serious illness, injury, or disability.

Operating units may use appropriated funds to install telecommunications lines, equipment, or services and to pay monthly charges in any private residence of an employee who has been authorized to work at home in accordance with established Office of Personnel Management (OPM) or Department of Commerce guidelines. These may vary by operating unit. OPM and Commerce guidance on telework/telecommuting and other work/life matters can be found at:

Office of Personnel Management (OPM) Telework Website
Office of Personnel Management (OPM) Work/Life Website

Department of Commerce Telework Policy

Department of Commerce IT Security Policy

Telework/telecommuting circumstances may also vary widely from one case to another. Therefore it is the responsibility of the operating unit to establish guidance regarding telecommunications in private residences and to apply any guidance and standards consistently and equitably.

Managers and employees must be aware of and implement security procedures that ensure that information and data are not compromised. Work conducted outside the normal office environment may entail increased risk of disclosure of sensitive information, either electronically or physically. The information available through the above-referenced Web sites and policy provide appropriate guidance on security issues.

In all cases, approval of such programs or provisions must be granted by the appropriate authority determined by the operating unit. Approval should be granted based on need and best interest of the Government. Adequate safeguards must be in place to ensure that such services are placed and used in compliance with other regulations and laws pertaining to the use of Government-owned property and services, that there is no misuse or abuse of these resources, and that resources are returned to the Government after termination of the requirement.

May telecommunications resources be authorized for personal use?

Yes. Government telecommunications services (including cellular and other wireless services, and facsimile) are intended for the conduct of official business including limited personal use as outlined in this document. Employees are authorized to use these services for personal use subject to the constraints discussed in specific criteria below. Authorized calls may include emergency calls and calls that the agency determines are acceptable in the interest of the Government. Supervisors are responsible for the proper management of telecommunications service use by employees and others under their jurisdiction.

Personal use such as that described below in Examples of Authorized Use, placed using an employee’s own telecommunications device or service (wireless phone or personal calling card, for example) may not be reimbursed regardless of the time in which the use takes place, even if it is placed during normal work hours.

Examples of Authorized Use. Some examples of authorized use by employees that are consistent with the previously stated criteria follow:

Telephone calls to notify family, doctor, etc., when an employee is injured on the job;

Telephone calls to advise family of changes in schedule or to make alternate transportation or child care arrangements;

Telephone calls to locations within the local commuting area to speak to spouse, minor children, or other family members or to those responsible for family members, e.g., school or day care center;

Telephone calls to locations within the local commuting area that can be reached only during working hours, such as local Government agencies or physicians, or to arrange for emergency repairs to the employee’s residence or automobile;

While traveling on Government business, a telephone call to the employee’s residence (but generally not more than an average of one call per day), or to notify family of a schedule change;

Occasional personal telephone calls using government cellular phones and facsimile services for one of the purposes outlined in this guidance;

Occasional personal use of Personal Digital Assistant devices, such as Palm or Blackberry devices, that use wireless communications for e-mail or other supported functions;

E-mail or other electronic communications to or from home or other personal locations (refer to the Commerce Internet Use Policy).

Specific criteria for authorized personal use of telecommunications resources are that the use:

Does not adversely affect the performance of official duties by the employee or the employee's organization;

Is of reasonable duration and frequency;

Is made to allow the employee to continue performance of work; or

Is provided for in a collective bargaining agreement.

Long Distance Telephone Use. Personal long distance telephone use that must be made during working hours, including facsimile calls, may be made over the commercial long distance network if the call is consistent with previously stated criteria. Generally, other personal long distance use should be made using an alternate payment methodology, such as:

Charged to the employee's home phone number or other non-Government number (third number call);

Made to a toll-free (800, 877, 888, etc.) number;

Charged to the called party if a non-Government number (collect call); or

Charged to a personal telephone calling card, personal credit card, or personal prepaid debit card.

Prohibitions. The following practices are specifically prohibited:

Use of Government telecommunications services for other than official business, except as provided above;

Use of any Government-provided telecommunications service, equipment, or facility for uses that are permitted in the criteria but significantly interfere with the conduct of Government business or the individual performance of the employee;

Unauthorized telecommunications use with the intent to later reimburse the Government;Use of Government telecommunications services for partisan political purposes or activities; or

Use of toll-based or similar calling services that places a toll burden on the Federal Government, such as 900 area code services.

Collect Telephone Calls. Generally, collect calls (calls placed from a non-Government number to a Government number, reversing charges) and third party calls are prohibited except for official business. A personal emergency call may be accepted without authorization, but should be reported to a supervisor. In mission locations and offices where a "call-in" capability is required, the use of a Government-provided toll-free (such as 800 area code) services should be considered.

How do operating units ensure security of telecommunications resources?

As a subset of information technology, telecommunications resources and systems are subject to the same security considerations as other IT resources. See the Commerce IT Security Policy. Give special note to the Remote Access Security Policy. Systems, services, and other resources must be given a level of security that is appropriate to the application for which the resource is to be used. Because the applications to which telecommunications resources are applied are often complementary to other IT applications, security should be applied to telecommunications resources based on the criteria applied to security of these other IT applications.

Consideration of security for telecommunications resources should also take into account the fact that telecommunications is an essential and critical resource for the function of the business of the Department of Commerce, and the applications and transmissions over telecommunications resources must be understood to be essential and critical as well. Just as a data or PC-based system must have appropriate security, so must the telecommunications network, which may provide connectivity for both systems.

Additionally, the information contained in a directory services database should not contain sensitive personal information (e.g., social security numbers); should be kept up to date and linked with human resources information, particularly for employee termination; and provide secure repository for employee public encryption keys.

In addition to specific IT security, as outlined in the IT Security Policy, there are other aspects of telecommunications security that must be considered. Guidance set forth under these programs must be followed.

Secure Telecommunications Equipment (STE): There are several types of secure telecommunications equipment, including Secure Telephone Unit (STU), an older technology, and STE, a currently used system. These are administered as programs by the Department of Commerce Office of Security, and subject to the restrictions set out by Office of Security policy and guidelines.

National Security and Emergency Preparedness: National Security and Emergency Preparedness direction derives from the National Communications System (NCS), which is charged with assisting the Government in the coordination of the planning for and provision of national security and emergency preparedness communications. NCS programs are developed in response to Executive Order 12472, and include Telecommunications Service Priority (TSP) and Government Emergency Telecommunications Services (GETS), along with other programs that may be found at the NCS Website.

The Telecommunications Service Priority (TSP) is a Federal Communications Commission (FCC) program that provides a methodology by which traditional voice-based telecommunications services may be provisioned and restored on a priority basis in the event of a national emergency. There are also priority services for wireless or cellular telephone service, which may be acquired and used in much the same way as other TSP.

The Government Emergency Telecommunications Services (GETS) program is administered by the Commerce Chief Information Officer. GETS provides emergency access and priority processing in the local and long distance segments of the Public Switched Network (PSN). Using a special priority calling card, its intended use is in an emergency or crisis situation during which the probability of completing a call over normal or other alternate telecommunication means has significantly decreased.

Red Switch Phone services are a Department of Defense (DOD) system, providing secure, assured connectivity during national emergencies. It uses specially provisioned direct circuits, which remain active throughout an emergency use period. This program has been made available to civilian agencies as an additional communications link between top-level agency officials and many agency security officials. Use of this system is extremely limited. The program is administered by the Department of Commerce Office of Security.

Priority Access Wireless Telephone service and Satellite Phone service are both administered by the Department of Commerce Office of Security.

May telecommunications transmissions or conversations be recorded or monitored?

Yes, other than for law enforcement, which is covered by Security policy and DAO 207-9, monitoring may be performed in certain circumstances, but with strict limitations.

Telephone Services: At times, in the conduct of business such as call center functions, there is a need to record or monitor voice transmissions or conversations for management purposes. This may be done only under very limited circumstances and only with the approval of both the Operating Unit CIO and the Department of Commerce CIO. The following circumstances must be present in order to permit such monitoring to take place:

Both parties to a conversation must be aware of the recording or monitoring of a conversation or transmission.

The caller must be notified that monitoring or recording will be performed. Notification must be made prior to initiation of the conversation itself, and may be accomplished by presenting a notice such as: “This conversation (or call or transaction) may be recorded (or monitored) for training (or supervision or other reason) purposes. Please notify the agent if you wish this conversation not be recorded.”

If a caller does not want the call recorded, provision must be made to ensure that the recording capability is disabled during the call.

Prior to establishing a system that will record or monitor conversations or transmissions, a request must be made to the Department of Commerce CIO and operating unit CIO, stating the need, and approval must be received from the Department of Commerce CIO and operating unit CIO.

Performance and Security of Networks, etc.: Routinely, voice and data networks, servers, routers, and other resources are monitored to ensure the performance of the systems, propriety of use, and security of the services. This monitoring is generally performed at the broader network level, but may include such activity as review of data or Internet system use to ensure that inappropriate use does not take place. Data networks, including those that use the Internet, are not considered private or privileged and are therefore subject to monitoring. See the Internet Use Policy for additional information.

How do operating units dispose of telecommunications resources?

Telecommunications physical resources (telephone units, controllers, switches, etc.) must be disposed of in accordance with the Department of Commerce Personal Property Management Manual, which is available through the Personal Property Division. The Personal Property Procedures Manual outlines the procedures that managers and program staffs must follow when disposing of telecommunications equipment.

In addition, you can find information on the full range of Federal property management in the Federal Property Management Regulations: 41 CFR, C 101.

How do operating units manage and control costs of telecommunications resources?

Telecommunications management is an active process composed of systems, services, policies, and programs that ensure that telecommunications resources are acquired, installed, used, and disposed of wisely, effectively, and efficiently.

Operating units of the Department of Commerce are responsible for the management of telecommunications resources in the way they are for the management of any other resource. In addition, there are specific requirements, as stated below.

Operating units will establish internal procedures to manage telecommunications fraud, waste, and abuse. Operating units should also implement cost-effective procedures and systems to minimize exposure to abuse. Examples would be the review and verification of IT services billing information, and the education of employees on acceptable use policies.

NOTE: As stated earlier, telecommunications services should be viewed as an asset, not simply an expense liability. Before constraints are placed on use or funding is expended on constraining employees and management, a value judgment should be made to determine the cost effectiveness of a program.

Billing and Accountability:

Telecommunications resources must be fiscally managed to ensure that the Government receives agreed-upon goods and services for money spent. Each operating unit must ensure that appropriate programmatic measures are in place to receive and evaluate billing or invoicing for telecommunications, determine its accuracy, and make timely and accurate payment.

Operating units must establish and maintain management systems that account for telecommunications resources, reconcile the billed costs for these resources with their use, and ensure that payment is accurately made. Operating units must establish such systems and measures as are required to be in compliance with the laws, regulations, and procedures of the Federal Government and the Department of Commerce.

To effect these measures, operating units should, to the maximum extent possible, use automated processes, including the acquisition of billing detail in automated format and the use of automated systems to examine billing data for improper billing or use. Operating unit managers should work closely with telecommunications vendors and the General Services Administration (Federal Technology Service) to obtain vendor participation and assistance in this effort.

Billing and accountability for wireless services should receive particular attention. At the time of this policy, these services are more expensive than terrestrial-based services and their costs may vary greatly depending on the vendor and use “plan” selected. Operating unit managers should evaluate use and billing data to determine the most cost-effective acquisition and use “plan” for each user of wireless services.

Records Management and Access to Records:

Under the Federal Records Act, stored, retrievable telecommunications messages, such as e-mail, as well as telecommunications use and inventory records, in both electronic and paper form, are federal records. As such, they must be managed, protected, and disposed of in accordance with the General Records Schedule or the applicable Department of Commerce or operating unit records schedule. Questions regarding records management should be referred to the operating unit or Department Records Management Officer.

The creation and retention of telecommunications records generally are performed in response to a need for the recorded information for purposes of managing telecommunications resources. Frequently, Call Detail Records (CDRs), for example, are created and retained to ensure appropriate sizing and facilitating of telecommunications systems. While specific types of records are not required under this policy, operating units must determine their records needs, given their management requirements. Once records are created, their retention and disposition are governed by the appropriate records schedules.

What Commerce officials have responsibility for implementing this policy?

The Department of Commerce Chief Information Officer will:

  • Establish this policy and procedures for the management and cost control of telecommunications services and systems;
  • Provide management or oversight of programs and functions that the CIO deems necessary;
  • Provide advice and assistance to operating units and staff offices regarding telecommunications services and facilities; and
  • Serve as liaison for telecommunications-related activities and interchange between Department of Commerce and other Government-wide agencies, including the National Communications System (NCS) and functions dealing with national security and emergency preparedness.

The Operating Unit Chief Information Officer will:

  • Manage the acquisition, use, and disposition of telecommunications resources (services, facilities, and equipment);
  • Provide advice and assistance to offices regarding telecommunications services and facilities;
  • Serve as liaison for telecommunications-related activities and interchange between the operating unit and Department of Commerce;
  • Ensure that the appropriate level of telecommunications service is furnished to each employee;
  • Ensure that the telecommunications services, including the Government-provided long distance network, are used for official Government business and authorized purposes by authorized personnel;
  • Ensure that effective security controls are in place;
  • Ensure that the monitoring provisions of this policy are followed; and
  • Establish policy and procedures for the management and cost control of telecommunications systems, subject to guidance from the Department of Commerce CIO.

Where can I get additional information?

See the related Broadcast E-Mail Policy (Intranet Only), Internet Use Policy, and Designated Agency Representative Policy.

Also, contact the following specialists:

Telecommunications, and specific telecommunications programs, including FTS2001: Office of Telecommunications Management, Ricardo Farraj-Feijoo, 202-482-0941, RFarrajFeijoo@doc.gov.

IT Security: Office of IT Security, Infrastructure and Technology, Tim Hurr, 202-482-4288, THurr@doc.gov.

Secure telecommunications services: Office of Security, Mike Allen, 202-482-2394, mAllen@doc.gov.

Government Emergency Telecommunications Services (GETS): Office of IT Security, Infrastructure and Technology, Dave Jarrell, 202-482-5344, djarrell@doc.gov.

Personal Property: Department of Commerce Personal Property Division, 202-482-8246.

Who can address questions regarding this policy?

Contact Lisa Westerback, 202-482-0694, lwesterback@doc.gov.

Supersedes policy dated: September 27, 1993
Origination date: March 8, 2004
Approved by: Thomas N. Pyke, Jr., Chief Information Officer, March 11, 2004
Revision status: March 17, 2006