review of county-wide cell phone authorization, use and ... audit... · duplication of landline...

Review of

County-wide Cell Phone

Authorization, Use and Oversight

Prepared for the Board of Supervisors of the

County of Santa Clara

Prepared by the Board of Supervisors Management Audit Division County Administration Building, East Wing, 10th Floor

70 West Hedding Street San Jose, CA 95110

(408) 299-6436

October 3, 2011

Table of Contents

Section Page

Transmittal Letter

Table of Contents

I Scope, Methods and Background ------------------------------------------------------------- 1

II 847 Underutilized Cell Phones --------------------------------------------------------------- 7

III 333 Cell Phones Used Mainly For E-mail Access ---------------------------------------- 11

IV 452 Cell Phones With Mismatched Calling Plans ---------------------------------------- 13

V Excessive Cell Phone Costs Require Improved Policies and Additional Managerial Oversight ----------------------------------------------------------- 16

VI Establishing Managerial Oversight and Accountability for County-wide Telephone Services ------------------------------------------------------------ 25

VII Summary of Recommendations ------------------------------------------------------------- 32

DEPARTMENTAL WRITTEN RESPONSES:

CONTROLLER-TREASURER DEPARTMENT ----------------------------------------------------------- 35

FACILITIES AND FLEET (FAF) ------------------------------------------------------------------------------- 45

INFORMATION SERVICES DEPARTMENT (ISD) ----------------------------------------------------- 51

OFFICE OF THE SHERIFF -------------------------------------------------------------------------------------- 54

OFFICE OF THE COUNTY EXECUTIVE ------------------------------------------------------------------- 55

PROBATION DEPARTMENT --------------------------------------------------------------------------------- 57

PROCUREMENT DEPARTMENT --------------------------------------------------------------------------- 61

SOCIAL SERVICES AGENCY --------------------------------------------------------------------------------- 64

VALLEY MEDICAL CENTER ---------------------------------------------------------------------------------- 73

Report on Cell Phone Usage in the County of Santa Clara

Board of Supervisors Management Audit Division

1

SECTION I

Scope, Methods and Background

On March 15, 2011, the Board of Supervisors requested the Management Audit Division to conduct a review of cell phone use and charges by County staff. This request followed an announcement by the Governor’s Office that the State was substantially reducing the number of phones issued to State employees. The purpose of the analysis was to determine if similar opportunities exist to reduce the number of cell phones issued to County staff, as a means of achieving savings, and to identify other recommendations to establish or improve policies regarding cell phone use and the growth of other mobile communication devices. The request also reflected the knowledge that the decision to provide cell phone service to employees in the County of Santa Clara is made by individual departments, who order the service from contracts negotiated by the Procurement Department. The Board of Supervisors has not adopted centralized policies addressing under what circumstances employees should be provided cell phone service, and there is no centralized organizational responsibility for oversight and management of the County’s more than 4,800 cell phone numbers that were in use as of December 31, 2010. Prior to authorizing individual cell phone assignments to employees, the type, purpose and extent of usage must be considered, as well as the existence of personal phone reimbursement policies, departmental pool phones and existing duplicative land-line telephones on employee desks, that could serve as alternatives to issuing individual cell phones. To conduct this analysis, Management Audit Division staff contacted representatives of the County’s three primary contract cell phone providers, Sprint Solutions, Inc., Verizon Wireless and AT & T. Each provider was requested to provide cell phone usage and billing data for all County cell phone numbers under its contract during Calendar Year 2010. Sprint Solutions and Verizon Wireless were able to provide the complete data requested. AT & T was not. According to an AT & T representative, its contracted phone numbers with the County are divided into Foundation Account Numbers (FANs). Because of a change in the firm’s computer systems, it was able to provide most



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of the data requested for all of 2010 for one FAN, covering most County phone numbers, but not data on the number of phone calls made and received from each number, which limited our analysis of those phone numbers to one based on the minutes of service used. For a second FAN, accounting for cell phone numbers assigned to the Santa Clara Valley Health and Hospital System, all the types of data were provided, but were only available for an eight-month period, from May to December 2010. As a result, our analysis of this data had to be annualized, to estimate the full year savings of any changes proposed to the phone service. In terms of overall cell phone use and costs, our analysis included 4,815 cell phone numbers among the three primary providers that were active as of December 2010. The following table includes the total costs per phone number and costs per minute incurred during CY 2010 for each provider:

Table 1

Annual Cell Phone Costs Per Phone Number and Per Minute By Provider for Three Cell Phone Providers, Calendar Year 2010

Active Phone Total Cost Cost Per Minutes Cost Per Provider Numbers For Actives Number of Use Minute Sprint 1,265 $519,967 $411 2,254,224 0.23 Verizon** 2,989 646,501 216 3,733,330 0.17 AT & T Main 477 205,182 430 491,375 0.42 AT & T SCVHHS 84 147,947* 1,761* 298,436 0.50

Total 4,815 $1,519,597 $316 6,777,365 0.22

Total (Excl. ROV) 3,591 $1,512,661 $421 6,696,775 0.23

*These numbers were calculated based on an annualized cost, calculated by Management Audit Division staff because AT & T was only able to provide nine months’ data, from May through December of 2010 for this account.

**Excluding the 1,224 Registrar of Votes phones used in elections, the average cost per number of Verizon phones was $362 per phone annually, or 18 cents per minute.



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Based on the data in Table 1, the distribution of cell phone service between three vendors is illustrated in the following chart:

Table 1 also shows that Verizon had the lowest cost per phone number, and per minute. However, this gross-level analysis of costs does not take into account differences in the mix of calling plans, usage and other factors among the three carriers. For example, the 2,989 numbers active as of December 2010 for Verizon included about 1,224 phone numbers assigned to the Registrar of Voters which had very little use, but also very little cost, as these phone numbers were used for phones provided for polling places during the election, and were only charged for actual use, rather than with a flat monthly rate, as occurs for most County cell phones. Eliminating that number of phones, the per phone service cost for Verizon is about $362 each, which is still the lowest per phone service cost. It should also be noted that the data AT & T provided for its account with SCVHHS, only covered May through December of 2010. Since there is a significant difference among different carriers in cost per phone, and cost per minute, the County should consider bidding cell phone service with an award to a single firm, based primarily by price, in order to achieve cost savings. Such a step would require development of a competitive bid by Procurement Department staff. Where circumstances exist that an employee’s job requires a significant amount of remote communications from locations not well served by the selected vendor, exceptions can be granted to use alternative equipment when justified and documented.

1,265

2,989

561

4,815 Active County Cell Phones as of December 31, 2010

Sprint 26%

Verizon 62%

AT & T 12%



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To provide additional perspective on the County’s use of cell phones, we also asked relevant County staff for information on the County’s use of land-line phones, those which are hard-wired and sit on people’s desks. Land-line phone service for all County departments is managed by the Information Services Department, except for the Santa Clara Valley Health and Hospital System and the Social Services Agency, which manage their own phones. Social Services Agency staff stated they believed that the Agency was given responsibility for its own phones because it is primarily State and federally funded, and managing its own phones would assist reimbursement of phone costs through the State and federal claiming process. SCVHHS staff reported that the Board of Supervisors gave the health system permission several years ago to separate from centralized land-line management and operate its own system, because of concerns over service response times. SCVHHS stated it has installed a different phone system than the rest of the County, which it manages and maintains with its own staff. ISD, SSA and SCVHHS staff provided information, which indicates that they have a combined 28,020 land-line phone numbers, with an approximate annual cost of $1,772,000, or about $51 per phone number annually, when the cost of toll-free incoming lines is excluded ($63 per phone number annually including the cost of toll-free incoming lines). Based on this information, land-line phone service is obviously substantially cheaper than cell phones, making it important to provide cell phones only to staff that need them for reasons that can’t be fulfilled by land-line service. Combining the land-line phone information with the cell-phone information previously described, the total scope of County phone services is shown in the table on the following page.



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Table 2 Summary of Annual Telephone Costs

For the County of Santa Clara Active Phone Total Cost Cost Per

Provider/Manager Numbers For Active Phones Number

Cell phones Sprint 1,265 $519,967 $411 Verizon 2,989 646,501 216 AT & T Main 477 205,182 430 AT & T SCVHHS 84 147,947 1,761 Subtotal-Cell Phones 4,815 $1,519,597 $316

Land-line Phones

Information Serv. Dept. 11,000 594,000 54 SCVHHS 14,720 720,000 49 SSA 2,300 458,000 199* Subtotal-Land-line Phones 28,020 $1,772,000 $63

Total-All Phones 32,835** $3,291,597 $100

*SSA’s high per-line cost reflects its operation of three toll-free lines, whose costs could not be easily separated from other telephone voice costs. However, SSA staff reported that a review of one-month’s bill showed that the monthly cost for one of the toll-free lines was $17,900, which would equate to an annual $209,800 cost. SSA staff stated that because it uses the same vendor as ISD for its phone service, it expects per line annual costs, excluding the toll-free lines, should be about the same as ISD’s, which are $54 per line annually, as shown above.

**Excluding 1,224 Registrar of Voters election phones, the total of all phones is 31,611 at a total cost of $3,284,661 or an average annual cost per phone of $104.

Based on the consolidated Countywide telephone data in Table 2, the County has a total (excluding limited use Registrar of Votes election cell phones) of about 31,611 land-line and cell phones, costing at least $3.3 million annually. Based on the Fiscal Year 2011-12 authorized Countywide staffing of approximately 14,917 positions, current telephone resources average 2.20 telephone numbers per position, which includes one cell-phone number for every 4.2 positions, after excluding the 1,224 seasonal phones of the



6

Registrar of Voters. Further, a substantial number of positions would generally not be assigned a telephone of any kind, due to the nature of their work, such as nurses, correction officers, cadets and many others.

Consequently, due to the significantly higher cost of cell phones and the potential duplication of land-line service, there may be some value in reevaluating the County’s approach to phone service generally, and potentially eliminating land-lines for staff whose duties primarily require cell-phone use, and vice-versa.

The remainder of this report describes key findings of the Management Audit Division analysis, and how it was conducted, along with recommendations regarding County cell phone policies going forward. The report identified several opportunities for potential savings by eliminating underutilized cell phones, better matching cell phone plans with actual usage, increasing pooling of cell phones, and reimbursing employees for use of personal phones when circumstances make this option the best choice for both the County and the employee. These issues are discussed in Sections II through IV. All of these opportunities can potentially generate significant cost savings for the County. However, the County’s three cell phone service vendors were unable to provide detailed information identifying, on a line-by-line basis, each line that is linked to another line for purposes of determining monthly overage minutes. Consequently, to the extent that the elimination of underutilized lines would affect overage charges for linked lines, savings from eliminating underutilized lines would be reduced, but could not be calculated for this report.



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SECTION II

847 Underutilized Cell Phones

Of the County’s 4,815 cell phone numbers, 847 phone numbers, or 17.6

percent, had limited use in Calendar Year 2010. Limited use was defined

as phones with minimal voice and data use, as follows: 1) average use of

six or fewer calls per month during 2010, 2) average use of 30 or fewer

call minutes per month during 2010, or 3) use that averaged greater than

six calls per month, only because the average was exceeded during three

or fewer months in CY 2010. Eliminating these phones entirely in favor

of land-line use, replacing them with a smaller number of pool phones,

or having users use personal phones with reimbursement for the limited

County use, would result in savings estimated at up to $239,847.

Using the cell phone usage and billing data obtained from each of the three cell phone providers, Management Audit staff created spreadsheets showing the 2010 usage for each cell phone number assigned to the County. We limited the analysis to phone numbers that were active as of December 2010, excluding phones whose service was cancelled during the calendar year. We then calculated the average monthly voice usage for each phone number, in terms of the number of telephone calls made or received by that number. The purpose of this analysis was to identify phones with very low frequency of use, which we defined as phones that received or made an average of six or fewer phone calls per month. This standard was arbitrarily selected, based on a conservative assumption that the average monthly cell phone service charge was about $30, and that therefore use of only six calls or fewer calls per month would cost a minimum of $5 per call, which we viewed as excessive. In fact, our review showed that



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cell phone plans used by the County generally ranged in cost from less than $20 per month to more than $100 per month, depending on the plan selected. In addition to analyzing the number of calls made or received by each phone number, we also looked at phones that made or received more than six calls per month, but had total usage of less than 30 minutes per month, which we again defined as very low usage, costing in excess of $1 per minute. Finally, we also identified what we termed “intermittent use” phone numbers, which are numbers where use averaged more than six calls per month, but had use exceeding that average figure in three or fewer months during the calendar year. Our thesis was that all these low use phones could be eliminated in favor of having staff used their assigned land-line phones, or replaced by reimbursements provided by the County to employees, on an as-needed basis, for use of their personal phones on County business. In departments where many cell phones have been issued, the option of establishing a cell-phone pool for sporadic needs could also be a more cost-effective solution. The following table and chart show the results of our analysis.

Table 3

Low Use Cell Phone Numbers In the County of Santa Clara By Cell Phone Provider for Calendar Year 2010

Numbers Numbers Cell Phone Numbers With With Intermittent Total Numbers Annual Provider Analyzed 6 or Fewer Calls 30 Min. or Less Numbers Eliminated Savings Sprint 1,265 286 78 8 372 $108,482 Verizon 2,989 285 19 109 413 99,088 AT & T 561 N/A* 60 2 62 32,277 Totals 4,815 571 157 119 847 $239,847 Percent 100.0% 11.9% 3.3% 2.5% 17.6%

*As noted earlier, AT&T was only able to provide minutes of use, not numbers of calls.



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As Table 3 shows, of the 4,815 phone numbers that were active as of December 2010, 848, or about 17.6 percent, had what we defined as low or intermittent usage, suggesting that these phones could be considered underutilized and potentially eliminated from County service. These employee cell phone requirements could be replaced by an arrangement in which County employees would receive reimbursement, probably on a per call basis, for use of their personal cell phones for County business. Alternatively, employees could use departmentally-pooled cell phones in some cases. Assuming the low-use phones identified were eliminated, the County, based on charges for these phones in Calendar Year 2010, would have saved $239,847. As noted earlier, in the case of phones that were active as of December 2010, but were only active for part of the calendar year, or in the case of the AT & T Health and Hospital System phone numbers for which only partial-year data was available, the savings was calculated on an annual basis, assuming 12 months of phone service. It should also be noted that we eliminated from the analysis any phones for which the annual savings was less than $10. This eliminated, for example, most of the approximately 1,200 phone numbers assigned to the Registrar of Voters. A review of the billings indicated that these phone numbers were generally only used in months when elections were held, and thus were probably assigned to election workers. Since the Registrar was only charged for the actual use of the phones, without a monthly charge in months where no use occurred, savings from eliminating these phones would be

0200400600800

1000

6 or Fewer CallsPer Month

(11.9%)

30 Minutes orLess Per Month

(3.3%)

Intermittent Use(2.5%)

Total Low UsePhones (17.6%)

847 (17.6%) of County Cell Phones Underutilized



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small. Furthermore, we would view having a temporary election worker using their own phone as problematic in a situation where it is very important that workers be able to contact the Registrar’s staff in the event of problems at an election precinct, for example. The savings shown in Table 3 would be offset by the reimbursements employees would receive for County calls on their personal phones. However, based on the low call volumes reflected in the analysis, those offsetting reimbursements would likely be very small. Retention of low-use cell phone numbers by departments could only be justified by departments based on some reason why cell phone access is needed for a particular employee regardless of use, such as a “zero tolerance” need for the staff member to be available to other department staff at all times. Based on the results of Table 3, the Board of Supervisors should direct County departments to review cell phone use by phone number and to provide justification for maintenance of cell phone numbers that had minimum use, as defined in this finding, as opposed to eliminating these phone numbers in favor of pooled phones, staff use of personal phones with reimbursement, or another approach.



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SECTION III

333 Cell Phones Used Mainly for E-mail/Data Access

An estimated 333 cell phones are used mainly to transmit or receive data,

probably for e-mail access, rather than voice communication. Savings

could be achieved by replacing these phones with reimbursements for

the costs of providing staff County e-mail access on their personal

phones, as is the current practice of the Public Health Department. This

approach would produce estimated net savings of up to $146,358,

reflecting the savings from eliminating phones, offset by the e-mail cost

reimbursement provided for staff to get County e-mail on personal

phones.

As part of our analysis of phone use, we identified phone numbers, separate from the phone numbers included in Section II, that had low voice use, in terms of the average number of calls or number of voice minutes used per month, but instead had significant use for data transmission. Our threshold for these phones was an average of about 500 kilobytes of data usage or more per month. To put that limit in perspective, information provided on AT & T’s website for wireless access estimated that checking e-mail requires about four kilobytes of data transmission, while reading a news headline requires about 10 kilobytes, and downloading a music tone requires about 120 kilobytes. Although the data we received did not permit assessing the use County staff made of data transmissions, our assumption is that most of it is probably County employees checking e-mail accounts. As in the case of Section II, savings in this area could be achieved by eliminating these phones being used primarily for data access, and instead reimbursing County staff for



12

the cost of carrying out this function for County business on their personal cell phones. A model for this approach is provided by the Public Health Department, which conducted a similar internal analysis to that we have carried out Countywide, and has already adopted new cell phone policies as a result. Specifically, the Department adopted a policy providing monthly reimbursement of $16.00 to $38.24 per month, depending on the cell phone carrier, to employees in order to add County e-mail access to their personal phones or similar devices. The following table shows the number of phones, by carrier, that were identified as being used primarily for data access, and the potential savings if those phones were replaced by giving employees a monthly reimbursement for County e-mail access on their personal phones (currently estimated at $16.00 per month). As noted earlier, these phones and savings are separate from the phones identified in Section II, which had neither significant voice nor data use.

Table 4

Primarily Data-Use Cell Phone Numbers In the County of Santa Clara By Cell Phone Provider for Calendar Year 2010

Cell-Phone Numbers High-Data Annual Potential Provider Analyzed Numbers Savings

Sprint 1,265 89 $36,417 Verizon 2,989 180 64,750 AT & T 561 64 45,191 Totals 4,815 333 $146,358

As the table shows, of the 4,815 phone numbers analyzed, 333, or about 6.9 percent, were phones used primarily for data access. If those phones were eliminated and replaced by a $16 per month reimbursement to employees to provide County e-mail access on their personal phones, the savings that would result total approximately $146,358 (To the extent that employee reimbursement for email access on their personal phones is more than $16 per month, this savings would be reduced). The savings per phone by provider ranges from $351 to $456, because of differences in the cost of the individual County phone plans that would be replaced.



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SECTION IV

452 Cell Phones with Mismatched Calling Plans

Our review of the County’s 4,815 cell phones identified 452 cell phones

with usage higher than the low-use thresholds established in Sections II

and III, but with usage of minutes that was regularly less than the

maximum pursuant to the calling plan purchased for these phones. By

switching these phones to lower cost plans that provide fewer minutes,

thereby better matching actual usage, the County could realize savings of

up to $72,926 annually, assuming current usage is consistent with usage

in CY 2010.

The County’s cell phones are purchased pursuant to contracts negotiated by the Procurement Department with three cell phone providers. When departments order cell phone service through those contracts, they have various options of service to order. Those options include cell phone plans that provide increased levels of minutes per month at correspondingly increased monthly fees. Typically, exceeding the limits at any level results in substantial additional charges for the overage. Accordingly, in addition to identifying phones with overall low use that could potentially be eliminated, our review also compared the average number of minutes used monthly for each cell phone number, for numbers that had some significant use, with the number of minutes permitted under the service plan assigned to that phone number. If the actual monthly usage was significantly below the plan minutes, we estimated how much money could be saved by shifting that phone to a plan that provided fewer minutes, but also had a reduced monthly service charge. We identified the number of minutes per month provided for each phone number either from specific



14

information supplied by the cell phone provider for each phone, or from the name of the service plan provided for the phone, where that name included a number reflecting the number of monthly minutes provided. In conducting this analysis, we noted that the data we received from the cell phone providers included few if any instances of penalty charges for exceeding the allowable minutes, even though the analysis identified phones that in fact exceeded the number of minutes provided, in some cases by substantial amounts. We asked representatives of the cell phone providers about this discovery, and were advised that the lack of penalty charges probably reflects the fact that many of the County’s cell phone numbers were ordered via plans that pool the minutes of multiple phone numbers together, in the same way that a cell phone plan for a family provides a pool of minutes that may be used by different family members who have individual phones with different phone numbers. We attempted to sort out this issue by reviewing data provided by one of the three providers, to try and identify phones linked together for purposes of sharing minutes, but were not successful in doing so. We suspect that the minutes being used without penalty on selected phone numbers, represent minutes acquired via the phones identified in Section II and Section III, that have very little voice usage. Therefore, one possible effect of eliminating those phones is to increase the likelihood of penalty charges on phones that exceed the minutes of use permitted by the service plan assigned to each phone. It will therefore be very important, going forward, to realistically assign individual phones to service plans that accurately reflect the minutes of service expected to be used each month, and to monitor employee use of phones against those limits. The following table shows, by service provider, the number of phones we identified where the average minutes used per month should permit a less-expensive service plan to be used, and the estimated annual savings from doing so.



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Table 5

Estimated Savings From Matching Service Plan Monthly Minutes To Average Minutes Actually Used, By Cell Phone Provider for Calendar Year 2010

Cell-Phone Numbers Numbers With Annual Provider Analyzed Plan Reduction Savings Sprint 1,265 135 $26,795 Verizon 2,989 293 41,416 AT & T 97* 24 4,715 Totals 4,351 452 $72,926

*AT & T provided calling plan information for only a portion of the cell numbers it provided to the County.

As the table shows, approximately 10.4 percent of the numbers analyzed had cell phone usage, in terms of minutes of service used, that would have permitted the phone number to operate under a calling plan with fewer minutes included, and a reduced monthly access charge, saving an estimated $72,926, based on Calendar Year 2010 use. Due to the difficulty in determining which phone numbers are linked to others for minute-sharing purposes, we cannot estimate the amount of reduced plan costs that would be offset by penalty charges on lines that exceed the plan minutes allowed.



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SECTION V

Excessive Cell Phone Costs Require Improved Policies and Additional Managerial Oversight

A review of the savings in Sections II through IV, on a departmental

basis, found that 79 percent of the savings was accounted for in 10

departments, and four departments (VMC, Office of the Sheriff, Social

Services and Probation) accounted for nearly 60 percent of the potential

County-wide cost savings. Much of the potential savings can be traced to

the need for more specific and comprehensive cell phone policies and

procedures. Such procedures should more specifically identify the job

titles and types of job duties that make staff eligible for a County-

provided cell phone, and promote use of pooled phones or staff’s

personal cell phones, with reimbursement, as an alternative to a County-

issued phone. Once in place, such policies will only be as effective as the

managerial oversight applied to the County’s $1.5 million annual cell

phone operations.

As noted at the beginning of this report, cell phone service in the County is ordered at the department level, with departments placing orders under contracts with the three cell phone providers that were negotiated by the Procurement Department. Accordingly, in addition to looking at use of phones provided by the three cell phone providers, we also combined the data provided by the three providers on a



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departmental basis, to show which departments, based on our analysis, have the greatest potential for savings by eliminating cell phones that get limited use. The following table provides this information for the 10 departments with the greatest potential for savings, based on Calendar Year 2010 use information provided by the three cell phone providers.

Table 6

10 County Departments With the Greatest Potential Cell Phone Savings Based on Calendar Year 2010 Usage Data, Ranked by Estimated Savings

Low-Use Data Wrong Call-Plan Total Total # Low Use Phone # Data-Use Phone Call-Plan Change Phone Potential Department Phones Savings Phones Savings Phones Savings Changes Savings VMC 124 $48,102 60 $45,815 134 26,977 318 $120,894 SSA 111 27,276 77 26,183 71 8,823 259 62,282 Probation 146 34,393 41 14,228 33 5,445 220 54,066 Sheriff 53 26,412 21 7,795 2 84 76 34,291 Public Health 35 14,734 11 4,772 4 990 50 20,496 District Attorney 24 9,297 25 9018 37 1,776 86 20,091 Facil.-Bldg. Ops. 47 12,661 3 1,155 24 4,869 74 18,685 Mental Health 28 10,055 3 1,104 0 0 31 11,159 Communications 15 7,267 6 2,330 9 1,262 30 10,859 Child Support 12 7,494 9 2,569 0 0 21 10,063 Total-10 Depts. 595 $197,691 256 $114,969 314 50,226 1,165 $362,886 Total-All Depts. 847 $239,847 333 $146,358 452 $72,926 1,632 $459,131

As the table shows, the 10 departments with the greatest potential savings, according to our analysis, included potential savings of $362,886 from eliminating phones with low use or primarily data use, or by changing to a more appropriate calling plan. This accounted for about 79 percent of the total savings identified in Sections II, III and IV of this report. In fact, about 59 percent of total savings was identified in only four departments, Valley Medical Center, the Office of the Sheriff, the Social Services Agency and the Probation Department. Projected potential savings by department is illustrated in the following chart:



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In addition to evaluating the potential for savings from various departments by changes in cell phone usage, we also reviewed the existence of Countywide and departmental policies regarding cell phone use. The review included several Countywide policies in effect at different times, and the current policies of nine different departments. The most current Countywide policy was issued by the Controller’s Office and is dated April 4, 2011. This policy was developed by the Controller’s Office working with a committee of representatives from various departments. A copy of the policy is provided as an attachment to the Controller-Treasurer’s response to this report. Key features of this Countywide policy include:

• Authorization of cell phones for all County department heads and elected officials.

• Authorization for other staff by department heads, with the following criteria:

$120,894

$34,291

$62,282

$54,066

$20,496 $20,091

$18,685

$10,859

$11,159

$10,063

$96,244

Potential Savings By Department SANTA CLARA VALLEY MEDICALCENTEROFFICE OF THE SHERIFF

SOCIAL SERVICES AGENCY

PROBATION DEPARTMENT

PUBLIC HEALTH DEPARTMENT

OFFICE OF THE DISTRICTATTORNEYFACILITIES-BLDG. OPERATIONS

SCC COMMUNICATIONS

MENTAL HEALTH DEPARTMENT

CHILD SUPPORT SERVICES

OTHER DEPARTMENTS



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a) the employee’s duties require wide mobility and simultaneous access to a communications network;

b) the employee requires business-critical two-way communication for which there is no reasonable alternative technology;

c) the employee is required to spend significant time away from their office, and is required to be reachable during those periods and/or outside of working hours;

d) the employee’s duties require access to County e-mail and calendar software while out of the office;

e) the employee must gather photographic evidence as part of their job;

f) the employee needs to request emergency support and back-up while in the field, and;

g) other special circumstances necessary for efficient and effective operation of County business that require use of a cell phone.

• A requirement that a specific call plan with a number of free minutes, a specific

data plan if needed, texting availability or other services be specifically requested as part of seeking a County cell phone.

• Permission for reimbursement to employees for use of a personal phone on

County business, if authorized by a department IT manager and department head, and if the employee agrees to follow County IT policies. This permission includes specific methods to calculate the employee’s reimbursement for County use of their phone.

• A requirement that departments provide written guidance to staff receiving phones, including the minutes and other features of their calling plan, and its cost. Departments also must review phone assignments annually, and provide an inventory of their phones to the Controller’s Office each August.

The April 2011 policies replaced a 2000 Controller’s Office policy specifically addressing reimbursement methods by employees using County phones for personal calls, and



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employees using personal phones for County calls, as well as a 1996 County Executive memo that authorized departments to order their own cell phone service, and provided some cell phone eligibility criteria. While the new Controller’s Office standards are appropriate, we believe they should further emphasize the need to discriminate between staff who are receiving phones based on a “zero tolerance” need for access, so that a phone, and the associated costs, are warranted even if they are rarely or never used, and phones whose need has to be justified through actual use, which should be reviewed annually, with the option of terminating the phone service if the expected use does not occur. Right now the concept of staff being given a phone based on the need for access, regardless of actual usage, is implied in the Controller’s criterion c.: “Requirement to spend a significant amount of time out of the office and required to be contactable during and/or outside of working hours,” criterion f.: “Emergency support and back-up from a mobile environment,” implying the need to provide certain staff a phone for safety reasons, and by the authorization for department heads and elected officials to have phones. However, providing a phone in these circumstances, regardless of actual usage, is not explicitly stated, and should be. For staff other than department heads and elected officials, providing a phone would need to be justified by a description of their duties in relation to the need for cell phone access. For other staff that receive cell phones based on a belief that mobile communications access would improve their efficiency, the policy should emphasize that these phones are subject to annual review and potential termination if the level of County business use does not justify providing a phone to the employee. Currently, the Controller’s policy is implemented by having staff who want a phone fill out a form that allows them to check one or more of eight criteria they believe justifies the phone. The form is then signed by the employee and the supervisor approving the issuance of the phone. We recommend that in addition to checking off the criteria that the employee believes supports receiving a phone, they provide on the form a short narrative description, one or two sentences, describing how the criteria selected applies to their job duties. The Office of the Sheriff, during the exit conference for this report,



21

provided information on phones it believes warrant retention, despite low use. It did so by providing a one sentence description of the staff position to which the phone was issued, how the phone is supposed to be used, and why the issuance was warranted. The Controller’s policy also should be expanded to include language stating that the right to a cell phone shall not be based solely on the funding source for payment, such as a grant, but must include a demonstrated need for a phone. The District Attorney’s Office’s cell phone policy includes this type of language. It also should include language emphasizing a preference for use of pool phones to the extent possible, rather than individually assigned phones, or the use of personal phones for County business, with the appropriate reimbursement, when this option is available and appropriate for the circumstances. A review of the cell phone policies in nine departments included the Santa Clara Valley Health and Hospital System (Valley Medical Center), Public Health, Mental Health, Social Services Agency, Office of the District Attorney, Office of the Sheriff, Probation, Facilities and Fleet Building Operations, and the Department of Child Support Services. Our review found many of these departmental policies largely parroted the language of the Countywide policy from the Controller’s Office, without providing significant additional guidance to staff. The Department of Child Support Services reported that it does not supplement the Controller’s Office policies with additional departmental guidelines. Based on our review, a departmental policy should also include the following features, which are generally not present, including the following:

• A list of positions entitled by right to cell phones, which would presumably be positions that would have the “zero tolerance” need for access described previously, the basis of which should be specified in the department policy. For example, the District Attorney’s Office policy provides cell phones to executive management, Supervising Deputy District Attorneys, lieutenants and “call out” investigators in the Bureau of Investigation, and support staff supervisors. The basis for providing phones for these positions should be provided in greater detail, but providing a specific list is a good start, and is not followed by all departments.



22

• A description of duties that would authorize other Department staff to have cell phones, providing some Department-specific description of the criteria provided in the Countywide Controller’s Office policy. For example, it is likely that a Child Protective Services or Adult Protective Services worker in the Social Services Agency would need a cell phone, because of their frequency of field work and associated safety concerns, but less likely that an Eligibility Worker would need a cell phone. Right now, the Office of the Sheriff’s policy authorizes cell phones for staff for whom two-way radio contact is not feasible, and notes that cell phone access is not meant to replace radio use. This policy could be expanded to talk about specific patrol beats in remote areas that justify cell phone access, or the need for cell phone use by under-cover investigators. Again, these descriptions of duties entitling staff to a County cell phone should discriminate between positions being given a phone because access at all times is necessary, even if the phone is never used, and positions being given a phone to increase efficiency. In the former case, employees should be required to carry the phone at all times. In the latter case, phone use should be reviewed annually, and should be terminated if the actual use does not justify the monthly cost of service access.

• All departments should provide some access to pooled phones for staff whose

need is occasional, and also should provide the ability to use a personal phone for County business, with reimbursement. The Public Health Department’s policies have emphasized this, including the ability of staff that need phones primarily for e-mail access to get it via personal phones, along with a monthly subsidy of their e-mail costs that still provides savings over providing a completely separate County phone.

• A description of the circumstances where texting, e-mail access or data access

may be added to an employee’s County phone service. E-mail and data access should only be provided based on reasons that an employee cannot access these systems through non-mobile means. The Public Health Department’s policy specifically states: “Texting shall be considered an emergency resource and not a normal business practice.”



23

• Procedures for staff to reimburse the County for personal use on County phones, or to receive reimbursement for County use on personal phones. These procedures should include having employees review and annotate the relevant cell phone bills, have a supervisor sign off on the reimbursement, and have the department maintain this documentation for a reasonable period of time. The policy should also include periodic spot auditing of phone bills by managers.

Also, both the Countywide and departmental policies should include suggestions and reminders to employees regarding the need to limit cell phone costs. For example, the Social Services Agency’s policies reminds employees not to make any kind of operator assisted calls, because of the cost, and requests that directory assistance calls be kept to a minimum.

During the exit conference process of this report, we met with representatives of the four departments with the largest percentage of total savings, as described above, in order to get their comments. These departments variously reported on specific aspects of their cell phone use, or steps they have previously taken to address use issues, as follows:

• The Social Services Agency acknowledged that this report had identified low use telephones and calling-plan issues that it had not previously identified through its own monitoring, and also agreed that improvements in Agency cell phone policies, to more specifically identify specific job titles or job duties that merited assignment of cell phones, would be a worthwhile addition to its internal monitoring. The Agency expressed concern about centralizing control over phone services, discussed in the next section of the report, because of a concern about service responsiveness, given the frequency of telephone contacts to SSA staff from Agency clients and related casework.

• Health and Hospital System staff noted that a substantial number of low-use

phones identified in our analysis had been eliminated after the end of 2010. For example, 51 of 83 such phones assigned to the SCVHHS Facilities Department were cut. This is consistent with the recent audit of SCVHHS administration and support services, issued in April 2011, which included cell-phone management



24

as a specific finding, including consideration of reimbursing staff for use of personal phones for business use when it would save money over a County-issued phone. SCVHHS agreed with the findings of that analysis.

• The Office of the Sheriff, after reviewing the analysis of low-use cell phone

numbers, reported that many of the 238 low-use phone numbers identified were actually numbers attached to data cards used for wireless Internet access primarily by computers in patrol cars. The computers are used by patrol deputies to access criminal records databases and other relevant information while on patrol, and remain with the computer installed in each patrol car.

• The Probation Department reported that prior to receiving the Management

Audit analysis, it had already begun identifying low-use phones, and developing alternative arrangements. These included shifting phones with less than 100 minutes of use per month to plans charged only for actual use, rather than a monthly fee, making greater use of pooled phones for probation officers to use when going into the field, and shifting the Department’s primary cell phone provider from Verizon to Sprint, based on an analysis showing that savings would occur. Department administrative staff stated that the timetable for implementing these alternatives is now being discussed with Department management. Probation staff also indicated a concern with centralized control of cell phones within the County, stating that cell phones are considered by staff as part of their safety equipment, with the phones’ walkie-talkie feature often used by staff for internal communication instead of two-way radios, and therefore availability of working phones when needed is very important.

More specific departmental policies, as described in this Section, would clarify which staff members are entitled to County-provided cell phones, on what basis, what the restrictions are for their use, and what the reimbursement requirements are when using a personal cell phone on County business. However, as evidenced by the current decentralized responsibility for and management of cell phones in the County, cost savings will only occur when and where departmental managers monitor and enforce these policies.



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SECTION VI

Establishing Managerial Oversight and Accountability for County-wide Telephone Services

Centralizing control over the issuance of cell phones and management of

cell phone costs in one County Department would permit additional

expertise to be developed regarding who should receive phones and with

what features in order to provide the necessary service at the lowest

possible cost. Further, centralizing cell phone management would

facilitate the competitive bidding of Countywide telephone services

under a multi-year contract with a single vendor to maximize

Countywide savings. Combining this oversight with the oversight of

land-line phones could produce even greater efficiencies by assessing

the combined needs of employees and eliminating excess equipment and

services from our present 32,835 total phones costing at least $3.3 million

annually. Substantial precedent exists in the County and in other

jurisdictions to achieve cost savings and improve control by centralizing

responsibility for telephones, vehicles and other equipment and services.

As described earlier in this report, approval and ordering of cell phone service is carried out by individual County departments, ordering service from contracts that have been negotiated with the County’s three cell-phone providers by the Procurement Department. This authority has been provided since at least October 1, 1996, when the former county executive issued a policy that included the following statement:



26

“Effective immediately, department/agency heads have the authority to approve the procurement of cellular telephone equipment. This authority may not be delegated to other employees. The actual procurement transaction must be handled by the Purchasing Department.” Subsequent policies, including the April 2011 policy issued by the Controller’s Office, have amplified procedures for staff reimbursement of personal calls on County cell phones, and staff use of personal phones for County business, as well as criteria for departments to consider in deciding whether to provide staff with phones. However, the basic decision to issue a County-paid cell phone to staff still rests with individual departments. In fact, the Probation Department provided the 1996 County Executive policy as part of the policies it says it follows. Given the previous findings in this report regarding the potential savings from avoiding the issuance of underutilized cell phones, and monitoring cell-phone plans to more appropriately match actual use patterns, the Management Audit Division believes that centralizing management of cell phones in the County is warranted. Centralized control of cell phones would provide the following benefits:

• It provides an objective decision-maker on the question of whether a staff member should be issued a cell phone, based either on improvements in the staff members work efficiency, or the staff member’s “zero tolerance” need to be accessible at all times for County business, as opposed to giving a staff member a phone as a job-related benefit, regardless of the business need. Centralized management would also provide a means of independently analyzing staff use of cell phones, identifying those whose use, based on alleged efficiency improvements, does not justify the cost, as is potentially the case with the limited-use phones discussed in Section II.

• It provides an objective decision-maker to assess overall changes in the County’s

overall use of telephone technology. The National Center for Health Statistics, as part of its 2009-10 National Health Interview Survey, reported that 23.9 percent of adults nationwide lived in households without land-line phones. In Santa



27

Clara County, the percentage was 17.7 percent, and had nearly doubled since early 2007. Centralized management of County telephone service, including both cell phones and land-lines, may determine that there are instances where staff should be issued only a cell phone, and not a land-line. Based on the data reported earlier in this report, land-line costs of about $51 annually per phone, would partially offset cell phone costs of about $316 per phone.

• It would provide a centralized unit whose mission is to develop a high level of telephone and mobile device technology, usage and cost expertise and apply that expertise on a Countywide basis to all departmental needs in accordance with telephone issuance and usage policies approved by the Board of Supervisors. The centralization of this expertise would also facilitate the standardization of equipment, which is an essential element of establishing centralized management of and accountability for telecommunications while maximizing cost savings. The centralization of telecommunications services could be accomplished by assigning this responsibility to a single County department thereby establishing managerial accountability which currently does not exist, and financial accountability through the use of a Telecommunication Services Internal Service Fund. In addition, the availability of a Countywide cell phone pool could be created to benefit smaller departments that do not currently have cell phone pools.

There is precedent for such centralized control of cell phones, both in other equipment issued to staff in the County of Santa Clara, and cell phone practices followed in other counties. In the County of Santa Clara, the closest parallel to our suggestion is the management of County vehicles, which is overseen by the Facilities and Fleet Department, in accordance with the Comprehensive Vehicle Policy adopted by the Board of Supervisors in 2010. This policy includes the Department’s preparation of an Annual Vehicle Plan, in which the Facilities and Fleet Department must “determine the cost effectiveness of departmental assigned vehicles, as compared to pool and private vehicle costs,” with decisions to remove vehicles from departmental assignment subject



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to an appeal by departments to the County Executive. We envision a similar approach to managing both cell phone and land-line telephone use and the establishment of an Internal Services Fund (ISF) comparable to the Fleet Management ISF. Meanwhile, a review of cell phone policies for other local government agencies, obtained by Management Audit staff through an Internet search, indicated that some jurisdictions do manage cell phones centrally. For example, Clackamas County, Oregon has an Electronic Services Manager that oversees both cell phone and land-line services. According to its cell-phone policy, departments are advised to “please consider consulting with the Electronic Services Manager when choosing cell phone services for a department, group of employees or perhaps even inter-department. . . . Plans change so rapidly, and Electronic Services, already the provider for Clackamas County phones, may be more knowledgeable about creative cost-effective solutions.” Similarly, the City of Spokane, Washington policy states that “the determination of which phone and plan is appropriate for each employee will be made by the Management Information Services Department . . . This determination will be made by taking into account the employee’s individual job duties and wireless communications needs. These needs will be determined by consulting with the department/division head and when necessary, the employee.” Spokane’s policy applies to all City departments except police and fire, which make their own determinations. Other sizeable local governments with centralized control of cell phones include Nashville and Davidson County, TN (approval by the Office of Management and Budget) and Everett, WA (cell-phone services controlled by Facilities and Property Management Department Telecommunications Division). Assuming the Board of Supervisors wishes to centralize control over cell phone service in this manner, there are several options for the placement of this function. One is in the Information Services Department, which currently has a staff of two Telecommunications Services Specialists who are responsible for processing changes in land-line phone services, and monitoring and paying land-line phone bills for most County departments. In addition, ISD has nine technical staff whose duties include cabling, telephone installations, changing passwords and similar work. Furthermore, the Health and Hospital System, which oversees is own land-line phone service, also



29

has an authorized staff of 10 telecommunications personnel devoted to land-lines, including a Telecommunications Operations Manager, a Telecommunications Engineer, a Telecommunications Services Specialist that works with the land-line vendor on service orders and new service, a Senior Telecommunications Technician, three Telecommunications Technicians and three Associate Telecommunications Technician positions. In addition, staff in the SCVHHS Accounts Payable Unit are responsible for land-line payments while other staff in the SCVHHS Information Services Department are responsible for cell phones. Similarly, the Social Services Agency also has staff dedicated to telephone service and payment activities. Assuming ISD only assumes control over cell phone service, in addition to its current role, and without taking over any additional land-line responsibilities, an evaluation of additional staffing requirements for ISD would have to be made, as well as an evaluation of existing staff currently dedicated to this function throughout County departments. The other alternative is to centralize control over all phone services in the Facilities and Fleet Department, based on its current responsibility for centralized management of County structures, vehicles and other assets. ISD’s two Telephone Services Specialists, and its nine-person technical staff would be moved to the Facilities Department, as would staff now responsible for telephone services at SCVHHS and SSA. In all, more than 20 staff would be centralized in the Facilities Department with responsibility for managing Countywide phone services, both land-line and cell phones. Under this scenario, it’s possible sufficient economies of scale would be achieved, through co-locating all telephone staff, that additional staffing to oversee cell phone services would not be necessary. Both of these alternatives would be viable, and Management Audit Division staff believes that consolidating management of both cell phone and land-line telephone services within a single entity would provide the greatest opportunity for efficiency and cost savings. As an example, the FY 2011-12 deleted 503 positions from the budget. Of those 503 positions, how many had desks with land-lines that remain active on monthly invoices only? In considering the centralization of all telephone services, it is important to note that the County currently operates three large land-line telephone systems, based on equipment produced by three different manufacturers. While immediate transition to a single manufacturer would result in a loss of a significant portion of the useful life of the equipment that was abandoned, everyone interviewed agreed that a single system would be the most cost-effective approach in



30

the long run, on an ongoing basis. Consequently, if the Board chooses to centralize all telecommunication services, the land-line services should be transitioned over time, as existing equipment is replaced. Furthermore, combining all County cell phone services under the management of a single unit within the Information Services Department or the Facilities and Fleet Department would facilitate pursuing a competitive bid among cell phone vendors for a single-vender multi-year contract, which could generate substantial additional savings beyond the elimination of underutilized phones and improved matching of plans to actual usage. Based on the data in Section II, Table 1, there currently exists a significant variance in the average cost per minute for cell phone service pursuant to the contracts with the three current vendors as shown in the following chart:

Eliminating 847 phones with low use, and another 333 phones primarily used for data access, as proposed in Sections II and III of this report, would reduce total minutes of use from about 6.6 million annually to about 4.5 million. Achieving a cost per minute of 17 cents, the Verizon rate, versus the average rate from all providers of 22 cents per minute, would result in additional savings of $237,522 on 4.5 million minutes of use, in addition to any savings from eliminating phones. This figure is extremely conservative, given that the phones that would be eliminated as proposed in Sections II and III are likely to be phones with low minutes of use, and therefore lower rates would probably

$0.00

$0.10

$0.20

$0.30

$0.40

$0.50

Verizon Sprint AT & T

Average Cell Phone Cost Per Minute By Provider

Average CostPer Minute



31

end up applying to more than 4.5 million minutes, even with the sharp reduction in the number of phones in service. If the Board approves the recommendation to consolidate all telephone services in one department, a Countywide assessment of all cell phone equipment and all staff resources currently dedicated to telephone services would need to be made, as would an organizational and staffing plan for the new telecommunication services division of the Information Services Department or the Facilities and Fleet Department. A logical source for this analysis would be through the County’s Center for Leadership and Transformation (CLT), a joint project of the Board of Supervisors and the County Executive’s Office. According to its website, CLT “will equip Santa Clara County employees with the tools and processes to lead change and transformation across all divisions. It will encourage adaptability at every level of the organization, from executive management to each individual employee, cultivate cross-boundary thinking and collaboration, establish a commitment to innovation and develop metrics for measuring the progress and success of transformation efforts.” The CLT website has reported on an Information Technology Rapid Transformation effort within the program, which found in a 2010 analysis that departments were making IT-related decisions in isolation, leading to fragmentation, redundancies and unnecessary costs. Projects within this IT initiative have included development of a common e-mail system across the County. Given the need for standardization of cell phone and other mobile device technologies identified by several respondents to this report, and the need for buy-in among a wide range of County departments in arriving at an acceptable range of standard options, the CLT technology group, which has included an Interim Information Technology Rapid Transformation Governance Committee that included representatives of the County Executive and 12 County departments, would be a logical place to start the necessary analysis.



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SECTION VII

Summary of Recommendations

Based on the findings in this report, the Board of Supervisors should direct the County Executive to:

Section II: Underutilized Cell Phones

1. Direct County departments to identify underutilized cell phone numbers, following the criteria used in this report, eliminating them in favor of more appropriate and less costly options, or providing additional written justification for any underutilized cell phone proposed to be retained, and report the number of phones eliminated. (Potential Savings $239,847) Priority 2

Section III: Cell Phones Used Primarily for E-Mail/Data Access

2. Direct County departments to replace cell phones used primarily for e-mail access with a monthly reimbursement (currently about $16.00 per month) to employees to get County e-mail access on their personal phones (as described in this section), as the Public Health Department has done. (Potential Savings $146,358) Priority 2

Section IV: Cell Phones with Mismatched Calling Plans

3. Direct County departments to review the cell phone minutes used by phone number, versus the calling plans provided, and to switch cell phones to lower-minute, lower-cost plans where appropriate based on actual use. (Potential Savings $72,926) Priority 3

Section V: Improving Policies and Managerial Oversight 4. Direct the Controller’s Office to expand the cell-phone policy issued in April 2011

to further emphasize and clarify the difference between cell phones issued to staff based on the need for constant communications access, and those issued for



33

efficiency, which must be justified by actual phone use, and to express a preference for departments to use pooled phones and use of staff members’ personal phones when practicable, as opposed to providing a County-paid phone. The Controller’s cell phone policy should then be brought to the Board of Supervisors for its review and inclusion in the Board’s Policy Manual. Priority 3

5. Direct County departments to update departmental cell phone policies to follow

the Controller’s Office policy, but amplify with additional detail and examples reflecting the job titles and job duties of the individual departments, as described in Section V of this report. Priority 3

Section VI: Establishing Oversight & Accountability for Countywide Telephone Services 6. Consider centralizing control over both land-line and cell phone services as

described in Section VI, using either the Information Services Department (ISD) or the Facilities and Fleet Department (FAF) to manage and oversee the authorization and deactivation of cell phones and land-lines, the selection of plans, equipment and features, and the monthly payment of invoices. The implementation of this recommendation would be accomplished through the centralization of responsibility for telephone services in one of the proposed departments establishing managerial accountability which currently does not exist, and financial accountability through the use of a Telecommunication Services Internal Service Fund. If implemented, the telecommunication services division of ISD or FAF should prepare an annual report to the County Executive and the Board of Supervisors on the number and cost of telephone services on a departmental and Countywide basis, including the approximately annual savings from the FY 2011-12 base year. Priority 1

7. Refer to the Center on Leadership and Training a project to assess all cell phone

equipment and other mobile devices as well as all staff resources currently dedicated to telephone services, to be followed by preparation of an implementation plan for the organization and staffing of a new telecommunications division in either the Information Services Department or the Facilities and Fleet Department. This assessment is necessary for creation of



34

the centralized unit responsible for Countywide telecommunication services, and is a project that is in keeping with existing efforts by the Center on Leadership and Training to address fragmentation and associated redundancies and unnecessary costs in acquisition of information technology by County departments. If this recommendation is not approved, but recommendation number 6 is approved, the designated department responsible for centralizing telecommunications services should perform the assessment and planning activities described in this recommendation. Priority 3

8. Direct Procurement Department staff to competitively bid the County cell phone

service contracts as a single-vendor contract obtaining bids for optional periods of one, three and five years. (Potential Savings $237,522) Priority 2

Board of Supervisors: Mike Wasserman, George Shirakawa, Dave Cortese, Ken Yeager, Liz Kniss County Executive: Jeffrey Smith

County of Santa Clara

Finance Agency Controller-Treasurer Department

County Government Center 70 West Hedding Street, East Wing 2nd floor San Jose, California 95110-1705 (408) 299-5200 FAX 289-8629

September 30, 2011

To: Roger Mialocq,

Harvey Rose Accountancy Corporation

From: Irene Lui, Controller‐Treasurer

Subject: Response to the Management Audit of the Santa Clara County

Review of County‐wide Cell Phone Authorization, Use and

Oversight.

We thank the Board of Supervisors’ Management Audit staff for their hard work

and commitment on this review. We received the first draft report on September

19, 2011, and the latest revision last evening, September 29, 2011.

Audit findings from year 2010 data vs. Implementation of the 2011 revised policy The review and audit findings from the management auditors were based on data

from May to December 2010 which was prior to the issuance of the revised Cell

Phone Policy in April 2011. The revised policy was the culmination of two years of

significant effort by the Cell Phone Policies Committee, which included

representatives from many County departments including: Controller‐Treasurer,

Health and Hospital System, Social Services Agency, Probation, Employee

Services Agency, County Counsel, Information System Department, and others.

The Committee members had performed the following during the review process:

Reviewed and compared policies of many other counties,

Incorporated input and review from the management auditors who

performed the management audit of Santa Clara Valley Health and

Hospital System Administration and Support Services,

Considered operational needs, laws and regulations, labor contract

constraints, and various aspects of county operations.

The Committee implemented additional control activities including the

requirement to complete an Assignment Form (signed by individual employees

35

CONTROLLER-TREASURER DEPARTMENT

and their supervisors) and the requirement to complete an annual departmental

review and reporting process. The revised policy effective April 4, 2011, together

with the enhanced control activities, has improved overall control and monitoring

in the following manners:

County cell phones will be issued to county employees when certain

criteria are met, as noted from the attached CP1 form.

Departments shall provide written guidance to employees who are issued

with County cell/smart phones.

Departments are responsible for conducting periodic review, at least

annually, of the business necessity for assigning designated employees the

County cellular/smart phones.

Departments will maintain an updated inventory of County‐owned

cellular/smart phone devices and furnish the annual updated list, as

specified per attached CP2 form, to the Controller’s Office.

The Controller will perform a review and/or audit when appropriate.

The 2011 revised policy provides a cost‐effective guideline that has significantly

improved the overall controls on cell phone usages without adding unnecessary

or unreasonable burdens to county departments. More importantly, the

Committee review process provided valuable education and information sharing

opportunities among the departments. While the audit report indicates the total

active cell phone numbers (excluding ROV’s phones used during elections) was

3,816 in calendar year 2010, the active phone numbers for calendar year 2011, data

that was gathered from the county departments’ annual reports, has decreased by

about 800, a 20% decrease. This displays the effectiveness of the Cell Phone Policy

as significant improvement was achieved through the required review process

and the collaborative efforts of county departments.

Based on the significant improvements harvested from the revised 2011 policy, we

are submitting our responses for recommendations 2, 4, and 5.

Recommendation #2

Direct County departments to replace cell phones used primarily for e‐mail

access with a monthly reimbursement (currently $16) to employees to get

County e‐mail access on their personal phones, as the Public Health Department

has done. (Potential Savings $146,358) Priority 2

Response: pending review

The use of stipends may increase the taxable compensations to the respective

employees. The Employee Services Agency should be consulted as the stipends

may need further review or negotiations with labor unions.

36

Recommendation #4

Direct the Controller’s Office to expand the cell‐phone policy issued in April

2011 to further emphasize and clarify the difference between cell phones issued

to staff based on the need for constant communications access, and those issued

for efficiency, which must be justified by actual phone use, and to express a

preference for departments to use pooled phones and use of staff members’

personal phones when practicable, as opposed to providing a County‐paid

phone. The Controller’s cell phone policy should then be brought to the Board

of Supervisors for its review and inclusion in the Board’s Policy Manual.

Priority 3

Response: Partially agree.

We agree to update the April 2011 policy if there are changes recommended by the

County CLT, as noted from recommendation #7. For inclusion in the Board’s

Policy Manual, the policy should be broad enough to allow flexibility for the rapid

technology changes and the business needs from individual departments.

As noted above, the audit findings were based on data from May to December

2010 which was prior to the issuance of the revised Cell Phone Policy in April

2011. The significantly improved data noted above displays the effectiveness of

the revised Cell Phone Policy.

Recommendation #5

Direct County departments to update departmental cell phone policies to follow

the Controller’s Office policy, but amplify with additional detail and examples

reflecting the job titles and job duties of the individual departments, as

described in Section V of this report. Priority 3

Response: Agree

We agree that County departments should update their policies to follow the

Controller’s Office policy. The annual reports filed by county departments, as

noted from the attached CP2 form, have already addressed many concerns

identified in the audit. The 2011 reduction in cellular phone lines recently reported

by the county departments demonstrates that effective controls have been put in

place.

Enc. Revised Cell Phone Policy effective April 4, 2011 and forms CP1 and CP2

37

Finance Agency Controller-Treasurer Department Policies and Procedures Manual

Procedure Number: 20.1000.17 Date Issued: April 4, 2011

Date Last Revised: April 4, 2011

SUBJECT: Smart or Cellular Phones Policy

PREPARED BY: Manager, Disbursement Division

APPROVED BY: Controller‐Treasurer

POLICY: County‐Owned Smart or Cellular Telephones and Business Use of

Employee‐Owned Devices

SCOPE (if applicable):

This policy applies to all county employees and county departments.

POLICIES AND PROCEDURES:

1. County‐Owned Equipment – smart or cellular phone

The County assigned smart/cellular telephones are for County business. Personal use,

if incidental or de minimis (irregular use with a value so small that accounting for it is

unreasonable or administratively impractical), will be allowed. Users are required to

comply with applicable County IT Security Policies. In accordance with County IT

Security Policies, users are prohibited from allowing individuals who are not County

employees to utilize the device for purposes unrelated to County business. Should

personal use exceed incidental or de minimis use, reimbursements for personal calls

on County‐owned phones should be based on a methodology approved by the

Controller‐Treasurer that fully reimburses the County.

Eligibility criteria:

All agency/department heads and elected officials are eligible to receive a

cellular/smart phone device.

Department heads shall determine the staff members who will require cellular/smart

phone devices and the respective add‐on features (like texting) for business use

related to their functional area. Sufficient justification exists for assignment of cellular

phone and smart phone service when the department head or elected official

determines that the person’s business use involves:

a. Wide mobility and simultaneous access to the communications network;

40

Finance Agency Controller-Treasurer Department Policies and Procedures Manual



b. Timely, business critical two‐way communication for which there is no reasonable

alternative technology;

c. Requirement to spend a significant amount of time out of the office and required

to be contactable during and/or outside of working hours;

d. Requirement to use the County email and calendar software while out of office;

e. Require photographic evidence as part of their job;

f. Emergency support and back up from a mobile environment; and/or

g. Special circumstances necessary for the efficient and effective operation of County

business.

Monitoring and Control

Departments shall provide written guidance to employees who are issued with

County cell/smart phones including appropriate information such as the call and/or

data plan minutes or capacity, cost of text messaging, and other add‐on features if

applicable.

Departments are responsible for conducting a periodic review, at least annually, of the

business necessity for assigning designated employees the County cellular/smart

phones. The functionality and accountability review should include, but not be

limited to, the following:

a. Require the Cell Phone and Wireless Personal Digital Assistance Device

Assignment Form (CP1) for all users that should be updated when applicable;

b. Maintain an updated inventory of County‐owned cellular/smart phone devices

(see form CP2) and furnish the annual updated list to the Controller’s Office

annually by the end of August. The Controller’s Office will perform a review

and/or audit when appropriate.

When the employee is terminated from the County employment or there is a relevant

change in the employee’s employment status, the assigned phone device shall be

returned back to the department.

2. Reimbursement for Business Use of Personal Smart/Cellular Telephones

With the evolving changes in technology and the widely adopted use of cellular

phones by most employees, departments may use the reimbursement method that can

41

County of Santa Clara Finance Agency Controller-Treasurer Department Policies and Procedures Manual



20.1000.17 Cell/Smart Phones Policy Page 3 of 3

avoid unnecessary spending on cellular phone services when the employees do not

have extensive business usage.

Employees will be reimbursed for business use of smart/personal cellular telephone

equipment when the following conditions are met:

The department head has specifically authorized (in writing) that the employee

may use a personal cellular telephone for County business phone calls.

If the device is used to access a County network or information system, the

provisions of Section 4 of the Santa Clara County Information Technology User

Responsibility Statement apply, and Attachment B – Personally‐Owned Device

Signature Page of that Statement must be executed to document said

authorization.

Each “business” use must be identified on the bill to support the total amount

claimed. For a data plan accessing the County network or information system, the

employee will estimate and certify the percentage used for business (with

justifications) that the department will review and approve.

When the above conditions are met, the reimbursement amount is limited to the

actual cost with business use plus applicable taxes. If the cost of airtime is not

itemized on the bill because the business uses were made within the plan minutes

allowance associated with the phone service, then the per minute rate should be

calculated by dividing the monthly call phone access charge by the number of plan

minutes used. When the data plan is charged at a flat rate with unlimited use, the

employee should be reimbursed at the pre‐approved estimated percentage that was

justified, reviewed and approved by the department, as noted above.

Reimbursements, with the employee’s original bill and certification of business usage

on call and data plans retained as supporting documentation, should be processed

through SAP using SAP accounts payable process with the Direct Pay code E2. The

reimbursement will be made to the employee via ACH.

REFERENCE:

County IT Security Policies

Cell Phone and Wireless Personal Digital Assistance Device Assignment Form (CP1)

Inventory of County‐owned Cellular/Smart Phone (CP2)

42

Form CP1 (Ref# __________)

Cell Phone and Wireless Personal Digital Assistance (PDA) Device Assignment

Employee Name: ______________________________________ Employee ID: ____________

Title: ____________________________ Dept: ______________ Phone/Ext:____ _____

Please review and indicate the description(s) applicable to the user:

The County assigned smart/cellular telephones are for County business. Personal use, if incidental or

de minimis (irregular use with a value so small that accounting for it is unreasonable or

administratively impractical), will be allowed. Users are prohibited by County IT Security Policies

from allowing individuals who are not County employees from utilizing the device for purposes

unrelated to County business.

Assignment of cellular phone/PDA to the above mentioned employee is for business use that

involves:

1) ____ Necessity of using the mobile device for agency/department head or elected officials;

2) ____ Wide mobility and simultaneous access to the communications network;

3) ____ Timely, business critical two‐way communication for which there is no reasonable

alternative technology;

4) ____ Requirement to spend a significant amount of time out of the office and required to be

contactable during and/or outside of working hours;

5) ____ Requirement to use the County email and calendar software while out of office;

6) ____ Require photographic evidence as part of their job;

7) ____ Emergency support and back up from a mobile environment; and/or

8) ____ Special circumstances necessary for the efficient and effective operation of County

business. Please specify

The employee will be eligible for the following monthly plan:

Call Plan ( minutes); Texting ( )

Data Plan ( GB); Others

___________________________________________________________

I have read, understand, and agree to comply with County Policy on Business Use of Cellular/PDA

devices. I acknowledge that the assigned cell phone/PDA account records may be considered

disclosable public records by law. The County reserves the right to terminate the employee’s cell

phone/PDA or this assignment for any reason including, without limitation, excessive personal calls

or a change in employment status. I understand that I am responsible for returning the assigned cell

phone/PDA upon termination or at the direction of my supervisor.

_______________________________________ _____________________

Employee Signature Date

_______________________________________ _____________________

Manager/Supervisor/Director Approval Date

Date Phone Received: _____________ Cell Phone Number/Device ID:

43

___________________, County of Santa Clara

Form CP2

Inventory of County Owned Cellular/Smart Phone ‐ CP2 Form

BU

EEID

Job Title

Name

Cell Phone

number

CP1 DateEligibility

Criteria per

CP1

Call Plan

Minutes

Texting

Data Plan

GB (or % for

reim

)

Others

Invoice

stmt date

June

posting

EE reim.

(if an

y)

Example (for illustration only)

110

12345Agency Director

Sharee Doe

408‐111‐2222

n/a

4/1/11

1 to 5

750

Yes

0.5 GB

n/a

6/20/11

120.00

$

‐$

110

12346Dep

artm

ent Hd.

Ron Doe

408‐111‐2223

n/a

4/1/11

1 & 5

inc. above

Yes

0.5 GB

n/a

6/20/11

50.00

$

(10.00)

$

110

12348Fiscal Officer

Sally Doe

408‐111‐2224

n/a

4/1/11

8inc. above

Yes

0.5 GB

n/a

6/20/11

50.00

$

‐$

110

12350Fiscal Service Mgr

Pau

l Doe

408‐222‐3333

Yes

n/a

n/a

Actual

n/a

10%

No

6/12/11

8.00

$

n/a

110

12351Division M

anager

Sam Doe

408‐222‐3334

Yes

n/a

n/a

Actual

n/a

n/a

No

6/5/11

2.00

$

n/a

GLA5205100

230.00

$

(10.00)

$

Your Department Info:

Service Plan

Latest Review

Dated April 30, 2011

Approved

for reim.

of using

personal

phone

County issued phone

44

CELL PHONE RE

PORT

‐ FA

F

SE

CT

ION

A

UD

IT R

EC

OM

ME

ND

AT

ION

ST

AF

F R

ES

PO

NS

E

1D

irec

t C

oun

ty d

epar

tmen

ts t

o id

enti

fy

un

der

uti

lize

d c

ell p

hon

e n

um

ber

s, f

ollo

win

g th

e cr

iter

ia u

sed

in t

his

rep

ort,

eli

min

atin

g th

em in

fa

vor

of m

ore

app

rop

riat

e an

d le

ss c

ostl

y op

tion

s,

or p

rovi

din

g ad

dit

ion

al w

ritt

en j

ust

ific

atio

n f

or

any

un

der

uti

lize

d c

ell p

hon

e p

rop

osed

to

be

reta

ined

, an

d r

epor

t th

e n

um

ber

of

ph

ones

el

imin

ated

.

FA

F: A

gree

.

D

evel

opm

ent o

f cr

iter

ia to

est

abli

sh w

hich

cla

ssif

icat

ions

/job

dut

ies

requ

ire

thes

e to

ols

is th

e m

ost c

riti

cal a

spec

t of

this

str

ateg

y. S

taff

do

not r

ecei

ve th

ese

tool

s ju

st b

ecau

se th

ey w

ork

for

the

coun

ty; t

he p

rovi

sion

of

thes

e to

ols

has

to

be b

ased

upo

n a

busi

ness

nee

d. P

lans

that

are

sel

ecte

d m

ust

be f

lexi

ble

enou

gh

to a

llow

for

cha

nges

due

to a

ddit

iona

l wor

kloa

d as

sign

ed, o

r el

imin

ated

po

siti

ons.

Ear

ly te

rmin

atio

n fe

es s

houl

d be

neg

otia

ted

out o

f th

e ag

reem

ent.

2D

irec

t C

oun

ty d

epar

tmen

ts t

o re

pla

ce c

ell p

hon

es

use

d p

rim

aril

y fo

r e-

mai

l acc

ess

wit

h a

mon

thly

st

ipen

d (

curr

entl

y $1

6) t

o em

plo

yees

to

get

Cou

nty

e-

mai

l acc

ess

on t

hei

r p

erso

nal

ph

ones

, as

the

Pu

bli

c H

ealt

h D

epar

tmen

t h

as d

one.

FA

F:

Dis

agre

e.

The

opt

ion

for

a st

ipen

d sh

ould

be

elim

inat

ed. S

taff

sho

uld

choo

se to

use

a

Cou

nty

devi

ce o

r pr

ovid

e th

eir

own.

Em

ploy

ees

who

rej

ect a

Cou

nty

devi

ce

mus

t sig

n a

wai

ver

stip

ulat

ing

thei

r ob

liga

tion

to r

espo

nd to

cal

ls/e

mai

ls o

n th

eir

pers

onal

dev

ice

in th

e sa

me

way

that

they

wou

ld b

e fo

r a

Cou

nty

devi

ce. I

f th

e us

e of

a C

ount

y de

vice

res

ults

in a

n em

ploy

ee o

win

g th

e C

ount

y a

reim

burs

emen

t, th

is r

eim

burs

emen

t sho

uld

com

e as

a r

esul

t of

a pa

yrol

l de

duct

ion.

1

45

FACILITIES AND FLEET (FAF)

CELL PHONE RE

PORT

‐ FA

F

SE

CT

ION

A

UD

IT R

EC

OM

ME

ND

AT

ION

ST

AF

F R

ES

PO

NS

E

3D

irec

t C

oun

ty d

epar

tmen

ts t

o re

view

th

e ce

ll

ph

one

min

ute

s u

sed

by

ph

one

nu

mb

er, v

ersu

s th

e ca

llin

g p

lan

s p

rovi

ded

, an

d t

o sw

itch

cel

l ph

ones

to

low

er-m

inu

te, l

ower

-cos

t p

lan

s w

her

e ap

pro

pri

ate

bas

ed o

n a

ctu

al u

se.

FA

F:

Agr

ee.

Thi

s an

alys

is s

houl

d co

nsid

er d

ata

plan

usa

ge b

y st

aff

in a

ddit

ion

to c

all u

sage

. E

ach

coun

ty d

epar

tmen

t wil

l nee

d to

mon

itor

the

usag

e of

thei

r ow

n st

aff,

and

re

ly u

pon

the

depa

rtm

ent t

hat h

as c

entr

aliz

ed c

ontr

ol (

FA

F/I

SD

) to

adv

ise

them

ab

out d

iffe

rent

pla

n op

tion

s. I

f an

y de

part

men

t is

not m

onit

orin

g th

eir

staf

f’s

usag

e, th

en F

AF

/IS

D w

ill s

tep

in a

nd p

erfo

rm a

mor

e co

mpr

ehen

sive

des

k au

dit

to r

evie

w u

sage

. FA

F/I

SD

wil

l per

form

des

k au

dits

of

all d

epar

tmen

ts to

spo

t ch

eck

usag

e on

a p

resc

ribe

d sc

hedu

le. D

ue to

bud

get a

ctio

ns, j

ob d

utie

s fo

r so

me

staf

f m

ay c

hang

e an

d pl

ans

mus

t be

flex

ible

eno

ugh

to a

ccom

mod

ate

thes

e ch

ange

s. F

inal

ly, f

or F

AF

Ver

izon

pla

n, f

or a

cel

l pho

ne th

at h

as n

o P

TT

pla

n, if

it

has

no

call

ing

acti

vity

, the

mon

th c

harg

e is

$0.

17 p

er m

onth

. It w

ill b

e im

port

ant t

o pr

ovid

e th

e ap

prop

riat

e re

sour

ces

both

at t

he d

epar

tmen

t lev

el a

nd

at th

e le

vel o

f ce

ntra

lize

d co

ntro

l for

the

mon

itor

ing

of u

sage

of:

cal

ling

/dat

a pl

ans;

sof

twar

e; s

ecur

ity

and

hard

war

e. A

naly

sis

mus

t be

done

to r

evie

w th

e da

ta/p

hone

rec

ords

of

thos

e st

aff

that

hav

e de

vice

s to

det

erm

ine

whi

ch p

lan

is

appr

opri

ate

for

thei

r cl

assi

fica

tion

. Ju

stif

icat

ion

mus

t be

prov

ided

for

thos

e st

aff

who

se jo

b du

ties

are

not

typi

cal,

requ

irin

g ut

iliz

atio

n of

a h

ighe

r m

inut

e/hi

gher

cos

t pla

n.

2

46

CELL PHONE RE

PORT

‐ FA

F

SE

CT

ION

A

UD

IT R

EC

OM

ME

ND

AT

ION

ST

AF

F R

ES

PO

NS

E

4D

irec

t th

e C

ontr

olle

r’s

Off

ice

to e

xpan

d t

he

cell

-p

hon

e p

olic

y is

sued

in A

pri

l 201

1 to

fu

rth

er

emp

has

ize

and

cla

rify

th

e d

iffe

ren

ce b

etw

een

cel

l p

hon

es is

sued

to

staf

f b

ased

on

th

e n

eed

for

co

nst

ant

com

mu

nic

atio

ns

acce

ss, a

nd

th

ose

issu

ed

for

effi

cien

cy, w

hic

h m

ust

be

just

ifie

d b

y ac

tual

p

hon

e u

se, a

nd

to

exp

ress

a p

refe

ren

ce f

or

dep

artm

ents

to

use

poo

led

ph

ones

an

d u

se o

f st

aff

mem

ber

s’ p

erso

nal

ph

ones

wh

en p

ract

icab

le, a

s op

pos

ed t

o p

rovi

din

g a

Cou

nty

-pai

d p

hon

e. T

he

Con

trol

ler’

s ce

ll p

hon

e p

olic

y sh

ould

th

en b

e b

rou

ght

to t

he

Boa

rd o

f S

up

ervi

sors

for

its

revi

ew

and

incl

usi

on in

th

e B

oard

’s P

olic

y M

anu

al.

FA

F: A

gree

.

T

he P

olic

y sh

ould

be

a B

oard

Pol

icy,

and

not

incl

uded

in c

olle

ctiv

e ba

rgai

ning

ag

reem

ents

. The

Boa

rd P

olic

y sh

ould

be

a br

oad

poli

cy, l

eavi

ng e

lem

ents

of

flex

ibil

ity

for

depa

rtm

ents

to a

ddre

ss s

peci

fic

busi

ness

nee

ds.

5D

irec

t C

oun

ty d

epar

tmen

ts t

o u

pd

ate

dep

artm

enta

l cel

l ph

one

pol

icie

s to

fol

low

th

e C

ontr

olle

r’s

Off

ice

pol

icy,

bu

t am

pli

fy w

ith

ad

dit

ion

al d

etai

l an

d e

xam

ple

s re

flec

tin

g th

e jo

b

titl

es a

nd

job

du

ties

of

the

ind

ivid

ual

dep

artm

ents

, as

des

crib

ed in

Sec

tion

V o

f th

is r

epor

t.

FA

F:

Agr

ee.

Pol

icie

s cl

arif

ying

thos

e jo

b cl

assi

fica

tion

s an

d du

ties

that

war

rant

eit

her

a m

obil

e de

vice

for

cal

ling

and

or

data

usa

ge b

ased

upo

n a

busi

ness

nee

d w

ill

resu

lt in

mor

e ap

prop

riat

e us

age

of c

ount

y re

sour

ces,

and

red

uce

the

risk

of

expo

sure

for

the

mis

use

or lo

ss o

f de

vice

s. F

AF

has

beg

un to

def

ine

the

clas

sifi

cati

ons

and

duti

es th

at r

equi

re th

e us

e of

mob

ile

devi

ces.

Con

tinu

ed

refi

nem

ent w

ill b

e ne

cess

ary

over

tim

e.

3

47

CELL PHONE RE

PORT

‐ FA

F

SE

CT

ION

A

UD

IT R

EC

OM

ME

ND

AT

ION

ST

AF

F R

ES

PO

NS

E

6C

onsi

der

cen

tral

izin

g co

ntr

ol o

ver

bot

h la

nd

-lin

e an

d c

ell p

hon

e se

rvic

es a

s d

escr

ibed

in S

ecti

on V

I,

usi

ng

eith

er t

he

Info

rmat

ion

Ser

vice

s D

epar

tmen

t (I

SD

) or

th

e F

acil

itie

s an

d F

leet

Dep

artm

ent

(FA

F)

to m

anag

e an

d o

vers

ee t

he

auth

oriz

atio

n

and

dea

ctiv

atio

n o

f ce

ll p

hon

es a

nd

lan

d-l

ines

, th

e se

lect

ion

of

pla

ns,

eq

uip

men

t an

d f

eatu

res,

an

d

the

mon

thly

pay

men

t of

invo

ices

. If

imp

lem

ente

d,

the

tele

com

mu

nic

atio

n s

ervi

ces

div

isio

n o

f IS

D o

r F

AF

sh

ould

pre

par

e an

an

nu

al r

epor

t to

th

e C

oun

ty E

xecu

tive

an

d t

he

Boa

rd o

f S

up

ervi

sors

on

th

e n

um

ber

an

d c

ost

of t

elep

hon

e se

rvic

es o

n a

d

epar

tmen

tal a

nd

Cou

nty

wid

e b

asis

, in

clu

din

g th

e ap

pro

xim

atel

y an

nu

al s

avin

gs f

rom

th

e F

Y 2

011-

12 b

ase

year

.

FA

F: A

gree

.

C

entr

aliz

ed c

ontr

ol m

ust b

e su

ppor

ted

by th

e ne

cess

ary

reso

urce

s to

man

age

this

ef

fort

on

an o

ngoi

ng b

asis

. In

add

itio

n, it

mus

t be

wri

tten

in a

way

that

take

s in

to a

ccou

nt th

e ra

pid

evol

utio

n of

tech

nolo

gy a

nd th

e fo

rese

eabl

e ch

ange

s to

th

e to

ols

util

ized

by

Cou

nty

staf

f. T

his

tech

nolo

gy w

ill r

esul

t in

conf

iden

tial

in

form

atio

n be

ing

mov

ed a

roun

d w

irel

essl

y. P

roto

cols

and

pol

icie

s m

ust b

e de

velo

ped

to g

uide

the

wir

eles

s tr

ansf

er o

f in

form

atio

n, t

o se

cure

dev

ices

as

staf

f m

ove

abou

t the

ir b

usin

ess

thro

ugho

ut th

e co

unty

, and

to

iden

tify

the

proc

edur

es s

taff

mus

t fol

low

if a

dev

ice

is lo

st o

r st

olen

. FA

F f

eels

that

ce

ntra

lizi

ng th

e co

ntro

l of

serv

ices

for

bot

h ca

llin

g an

d da

ta a

cces

s by

cel

l ph

ones

/tab

lets

and

oth

er d

evic

es is

to th

e C

ount

y’s

adva

ntag

e. F

urth

er F

AF

ag

rees

that

ove

rsig

ht o

f th

e in

stal

lati

on o

f ph

one

line

s an

d w

irel

ess

rout

ers

is

mos

t app

ropr

iate

in F

AF

. Ins

tall

atio

n an

d co

nstr

ucti

on to

sup

port

land

line

s sh

ould

be

coor

dina

ted

thro

ugho

ut th

e di

scip

line

s in

clud

ing

elec

tric

al a

nd

plum

bing

. Cod

e co

mpl

ianc

e is

als

o a

fact

or. F

AF

is w

illi

ng to

man

age

the

coun

tyw

ide

use

of v

ario

us c

alli

ng/d

ata

plan

s, if

the

nece

ssar

y re

sour

ces

are

prov

ided

. T

he a

cqui

siti

on o

f bo

th h

ardw

are

and

soft

war

e ca

n be

det

erm

ined

by

a co

mm

itte

e co

nsis

ting

of

four

or

five

maj

or C

ount

y us

er d

epar

tmen

ts.

The

co

mm

itte

e sh

ould

lim

it th

e ch

oice

of

Sm

art /

Bla

ckbe

rry

phon

es to

no

mor

e th

an th

ree

choi

ces,

dec

ide

the

soft

war

e pl

atfo

rm f

or C

ount

ywid

e co

nsis

tenc

y,

lim

it th

e ch

oice

of

base

cel

l pho

nes

to n

o m

ore

than

thre

e ch

oice

s, a

nd li

mit

the

choi

ce o

f m

ilit

ary

grad

e ph

ones

for

trad

es p

eopl

e to

no

mor

e th

an th

ree

choi

ces.

B

y li

mit

ing

the

choi

ces,

it s

impl

ifie

s th

e ne

goti

atio

n fo

r be

tter

equ

ipm

ent a

nd

acce

ssor

ies

pric

es.

It i

s al

so e

asie

r to

trai

n de

part

men

t cel

l pho

ne

adm

inis

trat

ors

to m

aint

ain

and

trou

ble

shoo

t pho

ne p

robl

ems.

4

48

CELL PHONE RE

PORT

‐ FA

F

SE

CT

ION

A

UD

IT R

EC

OM

ME

ND

AT

ION

ST

AF

F R

ES

PO

NS

E

7

The

impl

emen

tati

on o

f a

cent

rali

zed

unit

res

pons

ible

fo

r C

ount

ywid

e te

leco

mm

unic

atio

n se

rvic

es w

ould

re

quir

e an

ass

essm

ent o

f al

l cel

l pho

ne e

quip

men

t an

d al

l sta

ff r

esou

rces

cur

rent

ly d

edic

ated

to

tele

phon

e se

rvic

es, a

s w

ell a

s pr

epar

atio

n of

an

impl

emen

tati

on p

lan

for

the

orga

niza

tion

and

sta

ffin

g of

the

new

tele

com

mun

icat

ions

div

isio

n of

IS

D o

r F

AF

. We

reco

mm

end

refe

rrin

g th

is a

naly

sis

to th

e C

ente

r on

Lea

ders

hip

and

Tra

inin

g as

a p

roje

ct th

at is

in

kee

ping

wit

h it

s ex

isti

ng e

ffor

ts to

add

ress

fr

agm

enta

tion

and

ass

ocia

ted

redu

ndan

cies

and

un

nece

ssar

y co

sts

in a

cqui

siti

on o

f in

form

atio

n te

chno

logy

by

Cou

nty

depa

rtm

ents

.

FA

F:

Agr

ee.

A C

LT

Gro

up m

ay b

e th

e m

ost e

ffic

ient

met

hod

to a

naly

ze C

ount

y-w

ide

depa

rtm

enta

l bus

ines

s ne

eds

and

to d

evel

op r

ecom

men

dati

ons

for

a br

oad

base

d po

licy

.

5

49

CELL PHONE RE

PORT

‐ FA

F

SE

CT

ION

A

UD

IT R

EC

OM

ME

ND

AT

ION

ST

AF

F R

ES

PO

NS

E

8D

irec

t P

rocu

rem

ent

Dep

artm

ent

staf

f to

co

mp

etit

ivel

y b

id t

he

Cou

nty

cel

l ph

one

serv

ice

con

trac

ts a

s a

sin

gle-

ven

dor

con

trac

t ob

tain

ing

bid

s fo

r op

tion

al p

erio

ds

of o

ne,

th

ree

and

fiv

e ye

ars.

FA

F:

Agr

ee in

Con

cept

.

T

his

scop

e is

too

narr

ow; c

ell p

hone

s ar

e ju

st o

ne o

f th

e to

ols

that

Cou

nty

staf

f w

ill n

eed.

Tab

lets

, lap

tops

and

dat

a pl

ans

need

to b

e co

nsid

ered

. S

taff

is

alre

ady

util

izin

g ta

blet

s fo

r: r

eadi

ng/s

endi

ng e

mai

l, ac

cess

ing

atta

chm

ents

to

emai

ls, c

alli

ng v

ia v

ideo

cha

t or

Sky

pe, c

reat

ing

docu

men

ts.

Fut

ure

expa

nsio

n to

incl

ude

tele

mat

ics

and

smar

t pho

ne a

ppli

cati

ons,

(e.

g. E

lect

ric

Veh

icle

C

harg

e L

ocat

ions

). F

urth

erm

ore,

one

con

trac

t may

not

mee

t the

nee

ds o

f al

l de

part

men

ts; c

over

age

and

opti

ons

may

be

insu

ffic

ient

. T

he a

bili

ty to

cal

l a

grou

p vi

a th

e tw

o w

ay r

adio

s w

hile

ver

y co

nven

ient

is n

ot n

eces

sary

giv

en c

ost

of p

er m

inut

e ca

lls

redu

ced.

FA

F n

eeds

a tr

ue “

Mil

itar

y G

rade

” ph

one,

(A

T &

T

adv

erti

ses

a m

ilit

ary

grad

e ph

one

but i

t was

not

rug

ged

enou

gh).

Cur

rent

ly,

FA

F –

Bui

ldin

g O

pera

tion

s D

ivis

ion

has

a V

eriz

on W

irel

ess

call

ing

plan

for

re

gula

r ce

ll p

hone

s: N

o m

onth

ly c

alli

ng p

lan

fees

, Fre

e an

ytim

e ca

llin

g be

twee

n V

eriz

on to

Ver

izon

cel

l pho

nes,

$0.

06 p

er p

eak

min

ute

char

ge w

hen

call

ing

land

line

and

non

-Ver

izon

Wir

eles

s ph

ones

, $10

per

mon

th f

lat c

harg

e fo

r un

lim

ited

pus

h-to

-tal

k (P

TT

) ca

lls,

FA

F-B

uild

ing

Ope

rati

ons

is p

ooli

ng a

ll th

e B

lack

berr

y/S

mar

t pho

nes

call

ing

min

utes

wit

h da

ta /c

ell p

hone

pac

kage

at

$50.

97 p

er m

onth

incl

udin

g un

lim

ited

dat

a pa

ckag

e an

d 40

0 ce

ll p

hone

min

utes

fo

r pe

ak h

our

call

s to

non

-Ver

izon

Wir

eles

s ph

ones

, fre

e ca

lls

to V

eriz

on

phon

es. T

echn

olog

y is

cha

ngin

g; th

e im

pact

of

soci

al m

edia

req

uire

men

ts w

ill

requ

ire

flex

ibil

ity

to a

ddre

ss s

peci

fic

depa

rtm

enta

l nee

ds.

6

50

M E M O R A N D U M September 29, 2011 To: From: Joyce Wing, County CIO

Dean Linebarger, County Networks Manager Subject: ISD Responses to Cell Phone Audit Report Recommendations This memorandum outlines the ISD responses to the Board of Supervisors Management and Audit Division recommendations concerning cell phone authorization, use and oversight. The responses follow the eight outlined recommendations at the end of the report.

1. ISD is in agreement with this recommendation.

2. There are challenges presented to the IT support function and the overall organization

by allowing the use of personal devices to conduct County business. The primary use of many cell phones is for data and not voice services and this creates significant IT security and support requirements that are not a consideration with cell phones used exclusively for voice calls. There is also a question as to how, or if, this use of personal devices can be required of employees, which is not an IT concern but is a legal and labor relations question.

Personal devices used for access to county IT systems, including just email, require the device to be managed following IT security policies and industry best practices. In addition, there are rules that govern access to the device by county IT staff and management. The employee is required to sign off on a special section of the County IT User Responsibility Statement and thereby agrees to follow the security and access requirements. The devices are managed as computing platforms much like laptops and this is difficult to accomplish and enforce with personally owned devices.

Today, much of the data oriented activity on cellular devices (phones and tablets) involves email and access to Web sites, but there is a significant shift underway to also provide access to business and mobile applications, which ISD is beginning to develop. This increased access to business applications from personal cellular devices will further exacerbate the security and management concerns over the use of personal devices to conduct business.


4. No comment at this time.


51

INFORMATION SERVICES DEPARTMENT (ISD)

6. ISD agrees that control over both land-line and cell phone services should be

centralized. However, support of cellular devices (including phones and tablets) and land line phone systems are an IT function that needs to reside in the IT organization. These systems are highly integrated with the overall IT infrastructure and in particular with data network and server infrastructure. Support requirements often involve staff from across the IT organization and that have telephony, network, server and applications knowledge and skills. The current generation phone systems that are being installed in the County are based on the Voice Over Internet Protocol (VOIP) and the individual handsets reside on the data network much like workstations. They communicate with data packets across the network and the systems themselves are server and network device based as opposed to the older switch based systems.

Most County departments do not have the capability to technically support cellular devices. This is a significant concern from a fiscal, IT support and security perspective. There is a need for a central management system to control and track cellular device inventories, distribute software installs and upgrades, back-up devices, control and lock down device configurations, enforce security and detect compromised devices. There are software tools that can help manage the devices that would be required. It makes sense for this capability to be centralized so that support and required skill levels can be provided and maintained in the most cost effective and efficient manner.

IT standards need to be established for cellular/mobile devices with only pre-approved devices supported. It is not possible to efficiently manage and cost control an inventory that includes every device available from every cellular provider. Also, some devices are not able to provide required security or functional capabilities and thus should not be considered for use. Many organizations have shown that it is be possible to support a reasonable but limited range of devices that meet most user needs and business requirements. New devices proposed for support should be vetted with respect to functionality and security before approval. ISD is currently testing newer smart phones and tablet technologies, and investigating software management products that can provide the needed services to manage many and multiple types of devices. The use of these mobile technologies to perform business functions is growing rapidly and may even take the place of workstations and laptops. It is important that the County develops a more formal communication and mobile business and technology strategy in order to take advantage of this rapidly changing technology. This will increase the usage of these types of devices to better and more readily support our services. Hence, the need to plan appropriately to select, standardize, manage and support. ISD is currently developing Mobile Applications for County department use; this will only increase and will need to be procured in a way to achieve economies of scale.

7. ISD is in agreement with this recommendation. Currently ISD manages the County

desktop standards committee that develops requirements and standards, manages the

52

desktop contract and exception requests to the contract. A similar on-going structure can be setup and/or centralized.

8. ISD is in agreement that a competitive procurement for cell phone services and devices is needed and in past years has partnered with the Director of Procurement in recommending such a process. However, the procurement process needs to be a strategic and collaborative effort that is driven by the business requirements of the county organizations that are significant users of cell phone services as well as by costs. However, the current and future business requirements need to be based on the business strategies that would cover all mobile technologies. A competitive procurement may or may not identify a single vendor as the best and lowest cost option for the county. Also, due to coverage issues and other technical differences between the various vendor offerings a single vendor offering may not be a viable alternative for the county. ISD certainly agrees that the number of cell phone vendors in use by the county should be reduced to the minimum possible. There is an opportunity to rationalize the cellular plans in use by the County and thereby realize savings. It will be important to have available outside expertise concerning best practices and negotiating strategies to use with the cellular providers. This is an area where access to special expertise not available within the County will be important. As noted in the audit recommendations there is also a need to improve the controls and rules concerning the issuance and management of cell phones. The same outside expertise should be very helpful for this purpose by providing guidance with respect to best practices and will be needed to help establish the centralized support function that is also recommended.

53

Office of the Sheriff 55 West Younger Avenue

San Jose, California 95110‐1721

(408) 808‐4900

______________________________________________________________________________________________

Laurie Smith

Sheriff

September 30, 2011

To: Roger Mialocq

Harvey Rose Accountancy Corporation

From: Martha Wapenski

Director of Administrative Services

Subject: Response to the Management Audit of the Santa Clara County Review of Countywide Cell Phone Authorization, Use and Oversight

Regarding the identification and elimination of underutilized cell phones, the Sheriff’s Office concurs with this recommendation. As part of the Harvey Rose review of our existing phones, we have identified a number of phone numbers that can be deactivated. Regarding Recommendation 6, the centralization of oversight and accountability for countywide telephone services, the Sheriff’s Office does not agree with this recommendation. As a law enforcement agency, we already have different, more restrictive policies than the County policy. For instance, our policy prohibits the use of cameras in cell phones. If the ordering of cell phones is centralized, the Sheriff’s Office may be forced to use cell phones with cameras because the central administrator for the program deems it appropriate or presents it at the least costly option. Regarding Recommendation 8 about competitively bidding the County cell phone service contracts as a single-vendor contract, the Sheriff’s Office has concerns that this approach is too limiting. A phone service that covers the remote Mt Hamilton area may not be able to simultaneously cover a Santa Cruz mountain. Speedy communication is essential in these outlying patrol beat. Of special concern is the fact that many of our patrol areas cover remote parts of the county. A patrol deputy who calls for an additional patrol unit during a serious incident needs reliable coverage to minimize the time for backup units to arrive, if the radio does not get reception in that area. Another example of the importance of reliable phone coverage is during a critical incident, like the investigation of a shooting at a remote marijuana grow site, the investigators need reliable phone access to the command center and headquarters building. Investigations sometimes last several days.

54

OFFICE OF THE SHERIFF

55

OFFICE OF THE COUNTY EXECUTIVE

SECTION VII





PROBATION DEPARTMENT RESPONSE: Agree - Probation has conducted an internal audit/analysis to determine efficiencies in Cell phone usage department wide and can respond to this requirement if deemed appropriate.


2. Direct County departments to replace cell phones used primarily for e-mail access with a monthly reimbursement (currently $16) to employees to get County e-mail access on their personal phones, as the Public Health Department has done. (Potential Savings $146,358) Priority 2

PROBATION DEPARTMENT RESPONSE: Agree - Probation has conducted an internal audit/analysis to determine efficiencies in cell phone usage department wide and can respond to this requirement if deemed appropriate.

Section IV: Cell Phones with Mismatched Calling Plans

3. Direct County departments to review the cell phone minutes used by phone number, versus the calling plans provided, and to switch cell phones to lower-

57

PROBATION DEPARTMENT

minute, lower-cost plans where appropriate based on actual use. (Potential Savings $72,926) Priority 3

PROBATION DEPARTMENT RESPONSE: Agree - Probation has conducted an internal audit/analysis and has identified which cell phones can shift to more cost effective plans if deemed appropriate. Section V: Improving Policies and Managerial Oversight 4. Direct the Controller’s Office to expand the cell-phone policy issued in April 2011

to further emphasize and clarify the difference between cell phones issued to staff based on the need for constant communications access, and those issued for efficiency, which must be justified by actual phone use, and to express a preference for departments to use pooled phones and use of staff members’ personal phones when practicable, as opposed to providing a County-paid phone. The Controller’s cell phone policy should then be brought to the Board of Supervisors for its review and inclusion in the Board’s Policy Manual. Priority 3

PROBATION DEPARTMENT RESPONSE: Agree 5. Direct County departments to update departmental cell phone policies to follow


PROBATION DEPARTMENT RESPONSE: Agree Section VI: Establishing Oversight & Accountability for Countywide Telephone Services 6. Consider centralizing control over both land-line and cell phone services as

described in Section VI, using either the Information Services Department (ISD) or the Facilities and Fleet Department (FAF) to manage and oversee the authorization and deactivation of cell phones and land-lines, the selection of

58

plans, equipment and features, and the monthly payment of invoices. The implementation of this recommendation would be accomplished through the centralization of responsibility for telephone services in one of the proposed departments establishing managerial accountability which currently does not exist, and financial accountability through the use of a Telecommunication Services Internal Service Fund. If implemented, the telecommunication services division of ISD or FAF should prepare an annual report to the County Executive and the Board of Supervisors on the number and cost of telephone services on a departmental and Countywide basis, including the approximately annual savings from the FY 2011-12 base year. Priority 1

PROBATION DEPARTMENT RESPONSE: No Comment 7. Refer to the Center on Leadership and Training a project to assess all cell phone

equipment and all staff resources currently dedicated to telephone services, to be followed by preparation of an implementation plan for the organization and staffing of a new telecommunications division in either the Information Services Department or the Facilities and Fleet Department. This assessment is necessary for creation of the centralized unit responsible for Countywide telecommunication services, and is a project that is in keeping with existing efforts by the Center on Leadership and Training to address fragmentation and associated redundancies and unnecessary costs in acquisition of information technology by County departments. If this recommendation is not approved, but recommendation number 6 is approved, the designated department responsible for centralizing telecommunications services should perform the assessment and planning activities described in this recommendation. Priority 3

PROBATION DEPARTMENT RESPONSE: Agree 8. Direct Procurement Department staff to competitively bid the County cell phone


59

PROBATION DEPARTMENT RESPONSE: Agree

60

61

PROCUREMENT DEPARTMENT

64

SOCIAL SERVICES AGENCY

SECTION VII





SCVHHS Response: Agree. . All managers are provided the monthly billings and are expected to manage the use.


2. Direct County departments to replace cell phones used primarily for e-mail access with a monthly reimbursement (currently $16) to employees to get County e-mail access on their personal phones, as the Public Health Department has done. (Potential Savings $146,358) Priority 2

SCVHHS Response: Partially Disagree. It is not feasible to restrict personal cell phones to meet the HIPPA Requirements, nor to require the same level of confidentiality afforded by County owned equipment. This process of utilizing personal phones would mean the relaxing of County policies. Owners of personal cell phones would be required to have there cell phones password protected in order for this process to ensure confidentiality. Section IV: Cell Phones with Mismatched Calling Plans

73

VALLEY MEDICAL CENTER

3. Direct County departments to review the cell phone minutes used by phone number, versus the calling plans provided, and to switch cell phones to lower-minute, lower-cost plans where appropriate based on actual use. (Potential Savings $72,926) Priority 3

SCVHHS Response: Agree. SCVHHS is conducting an internal analysis and will take the appropriate action once the analysis is complete.

Section V: Improving Policies and Managerial Oversight

4. Direct the Controller’s Office to expand the cell-phone policy issued in April 2011 to further emphasize and clarify the difference between cell phones issued to staff based on the need for constant communications access, and those issued for efficiency, which must be justified by actual phone use, and to express a preference for departments to use pooled phones and use of staff members’ personal phones when practicable, as opposed to providing a County-paid phone. The Controller’s cell phone policy should then be brought to the Board of Supervisors for its review and inclusion in the Board’s Policy Manual. Priority 3

SCVHHS Response: Agree

5. Direct County departments to update departmental cell phone policies to follow



Section VI: Establishing Oversight & Accountability for Countywide Telephone Services 6. Consider centralizing control over both land-line and cell phone services as

described in Section VI, using either the Information Services Department (ISD) or the Facilities and Fleet Department (FAF) to manage and oversee the authorization and deactivation of cell phones and land-lines, the selection of

74

plans, equipment and features, and the monthly payment of invoices. The implementation of this recommendation would be accomplished through the centralization of responsibility for telephone services in one of the proposed departments establishing managerial accountability which currently does not exist, and financial accountability through the use of a Telecommunication Services Internal Service Fund. If implemented, the telecommunication services division of ISD or FAF should prepare an annual report to the County Executive and the Board of Supervisors on the number and cost of telephone services on a departmental and Countywide basis, including the approximately annual savings from the FY 2011-12 base year. Priority 1

SCVHHS Response: Disagree. County policy and oversight can be effectively managed from a central group of members from each department (Agency) in the organization through centralized interactivity and policy implementation at the executive manager level without the centralization of systems. Each organization has its own unique needs based upon the service that it provides and many of these needs are not equally compatible across the organization. Centralizing complete control of the cell phones and the Telephone systems would have adverse effects to the organizations ability to provide appropriate care to its citizens. It is imperative that the use of telephones and of the staff providing that service be knowledgeable of the organizations specific needs. Should this be the direction that the County chooses to go, we would suggest that the centralization be limited to the manager level. 7. Refer to the Center on Leadership and Training a project to assess all cell phone

equipment and all staff resources currently dedicated to telephone services, to be followed by preparation of an implementation plan for the organization and staffing of a new telecommunications division in either the Information Services Department or the Facilities and Fleet Department. This assessment is necessary for creation of the centralized unit responsible for Countywide telecommunication services, and is a project that is in keeping with existing efforts by the Center on Leadership and Training to address fragmentation and associated redundancies and unnecessary costs in acquisition of information technology by County departments. If this recommendation is not approved, but

75

recommendation number 6 is approved, the designated department responsible for centralizing telecommunications services should perform the assessment and planning activities described in this recommendation. Priority 3


8. Direct Procurement Department staff to competitively bid the County cell phone


SCVHHS Response: Disagree There are several areas throughout Santa Clara County that coverage is limited to only a certain carrier. To limit the County to only a single carrier would limit the ability for staff that live in those areas to communicate. With all County workers being designated as disaster workers it is imperative that those who are designated as essential have ability to communicate with the county no matter where they are. The County needs the flexibility of carriers to ensure that is available.

76

review of county-wide cell phone authorization, use and ... audit... · duplication of landline...

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