The FCC Said You Lost Money

Who is investing the time to carefully scrutinize your mobile costs?

The Los Angeles Times reported in June of 2015, that, "Wireless carrier AT&T could be forced to pay $100 million after the Federal Communications Commission found that the company had slowed data networks for unlimited plan holders without informing them, the agency said Wednesday.  Since 2011, thousands of customers had complained to the FCC that AT&T had drastically reduced their network speeds . . .

'Consumers deserve to get what they pay for,' said FCC Chairman Tom Wheeler in a statement. 'The FCC will not stand idly by while consumers are deceived by misleading marketing materials and insufficient disclosure.'

The proposed fine represents the largest in FCC history, according to FCC spokesman Neil Grace, and was calculated after the agency estimated that AT&T had earned billions from locking consumers into plans falsely advertised as 'unlimited.'"

The previous month, in May 2015, the Los Angeles Times also reported that all four major wireless carriers overcharged their clients, "Verizon and Sprint are paying a combined $158 million to settle investigations into unauthorized charges placed on their customers' phone bills. The practice is known as 'cramming,' and with [this] announcement, the Federal Communications Commission has now made cramming settlements with all four major wireless carriers — AT&T settled in October for $105 million, and T-Mobile settled in December for $90 million. Of [the] $158 million, $90 million will come from Verizon and $68 million will come from Sprint."

Let's talk about you. (503) 972-9999

BYOD Summarized - It's a Mobile World

Mobile devices are valuable business productivity tools for companies and their employees.  And, because mobile devices increase productivity, many organizations have administered and paid for their employees’ devices.  In a quest for financial efficiency, organizations shift the cost and administration of cell phones to the employees.  An employee’s use of a personal mobile device for business purposes is Bring Your Own Device (BYOD). 

Overall, how do you want BYOD to benefit your business?  Is the set of goals clear and measurable?  How do you measure the cost efficiency, progress, and performance, in your BYOD program?

            A First Look at BYOD

BYOD shifts the responsibility and cost of cellular devices from the employer to the employees.  The gains for the employer are reduced costs, reduced support, and reduced administration.  The gain for the employee is broader choice of mobile devices.  Also, if the employee was carrying two phones, one personal and one business, he or she can now carry one phone. 

For an organization to transition to BYOD: 1) Install security, and 2) Have employees sign policies and procedures.  Easy, right?

Good control is good business.  Careful planning for mobile device management is essential for a successful BYOD implementation.  Unfortunately, many companies migrate to BYOD without careful planning.

            Risks of BYOD  

What's your risk by migrating to BYOD, and how do you quantify it?

Anthony Diana, partner at the law firm Mayer Brown, addresses the risks of BYOD: "There are legal risks, such as the ability to access information responsive to document requests for preservation or production.  There are regulatory risks associated with information on those devices that may be subject to regulatory retention and supervision requirements.  There are information security risks associated with lost or stolen devices, as well as many different devices having access to the organization’s networks.  There are data privacy risks associated with the mix of personal information with business information on one device. The question for any organization is how to best mitigate and balance these risks in light of the business demand for BYOD flexibility.”

If your organization is associated with the health care industry, inappropriate use could cause you to violate rules and regulations of HIPAA.  Something as obvious as having records in an unsecured place, like an unencrypted device, or on someone’s kitchen table, would violate HIPAA regulations.  Confer with your compliance officer.  Violations are not worth the risk.

How much do you want to avoid risks, and will your efforts interfere with employee productivity?

          Cost of BYOD

The payments for the mobile device become the responsibility of the employee.  The employee pays for the monthly cost of the service plan, overages, downloads, device upgrades, accessories, international long distance, roaming, text overages, and the additional taxes.  Corporate discount plans are not available to individual plans.   

A potential revenue leak is employees who expense cell phone costs in creative ways.  This is counter-productive to the principle of BYOD saving money for the employer. Address this problem in your policies and procedures. 

The costs to the organization are security and support, if offered.  How much money needs to be allocated to support BYOD?  Will you use a Mobile Device Management (MDM) provider?  How are future costs contained? 

Every company culture is different.  If you are on a BYOD program, does your company offset the employee’s cost with a stipend?  Are employees happy with the arrangement?  Productivity increases when employees are happy.  Will they conform to the new policies and procedures?  Are your employees spending company time on maintaining and trouble shooting their mobile devices?  Is your organization saving hard-dollar costs under BYOD? 

          Managing Mobile Devices Owned by Employees

The employee’s use of a personal mobile device becomes subject to restrictions of the organization’s policies.  How much authority does your organization have over an employee’s personal property?  Prepare employees with clear communication for the transition to their responsibility of the cost and policy restrictions.

Anthony Diana also states that BYOD imposes risk in that, “… organizations find themselves almost entirely dependent on policies and their employees’ compliance with such policies to manage the considerable risks associated with electronic data.”  An organization “…is forced to rely more heavily on employee participation and compliance with policies to manage risk.” 

Diana highlights the need for clear policy, and also audit procedures, “Because an employee’s use of his or her personal device is largely outside of the employer’s control, critical components of any BYOD program include a clear, concise policy that is developed with the input of all the relevant stakeholders, together with audit procedures that validate and ensure compliance with that policy.”   The organization should set policies and enforce its policies.  

Your employees expect to use their devices and applications at all times.  How much support will you offer to your employees?  Is your help desk ready to assist with the variety of devices?  Many companies find that centralized management and support of BYOD is not practical, because of the variety of devices and carriers, therefore each employee becomes responsible for his or her own device and technical support. 

Employee Productivity – some staff need more support than others.  Are there employees who have less ability to fix his or her cell problems?  Should fixing cell issues be considered company time or personal employee time?   You will rely on employees to be responsible for lost, stolen, and malfunctioning devices.  You want your employees to invest time to trouble shoot problems and manage invoices? 

BYOD is easier without corporate applications, because the corporate applications add a layer of complexity.  Your applications must meet the demand of employees.  Will applications cause technical constraints and difficult deployment?  Do corporate applications work on all devices and platforms?  What limitations are there on applications?  How well defined is the company’s policy? 

What are the side effects of BYOD, if any?  For example, think about telephone numbers as a company asset.  Would you port-out your main corporate phone number to one of your former employees?  How about the number to your purchasing department?  The point is that a mobile number used for business is your organization’s property.  Whatever that employee does for your organization, the employee may be terminated, and the phone number is property of the employee, not your business.  Clients and vendors will use the mobile number to contact the employee, terminated or not.  

Overall, how much accountability to you expect from your employees?  What are your audit procedures that validate to ensure compliance with the policies?  

          Security

Security and data loss remain top concerns for companies that allow BYOD.

A recent statistic from Canada reveals that 58 per cent of Canadian organizations are losing corporate information through laptops, smart phones and tablets used by employees.   

Ensure that basic security includes: Requiring employees use a complex password, or better, a pass phrase, if the device can accommodate it.  Use encryption.  Enable GPS tracking to help find lost devices.  Wipe business data from lost devices, ask the employee if he wants the personal information wiped from the lost device.

If unmanaged, BYOD can allow hacker access to your network resulting in data loss. You need effective network access controls and policies to secure your data.  One part of policy is to require employees to install mobile security solutions on their personal mobile devices.  But, how will you recognize and fix data leaks?  What do you say to an auditor if information is compromised?  How do you protect against malware and viruses entering your network? 

An issue as simple as forwarded emails to personal accounts opens the risk of corporate information traveling outside your organization.  Can you limit the ability to forward a corporate email to a personal account?  How can you ensure that company data is encrypted and deleted according to policy you set?  Do you have a plan to keep your corporate data and network secure?  What if the plan doesn't perform as intended?

The good new is that there are many resources for security related to your BYOD program. 

            Professional Help is Available

Like every project, know what you want, how you will measure it, and how you will reach your objectives.  Assistance from outside your organization can increase your success.  A Mobile Device Management (MDM) provider is an important component of any successful BYOD program. Your MDM provider enables you to achieve the right balance between providing enterprise security while maintaining employee convenience and privacy.  An MDM provider can supply functional and flexible MDM tools that addresses the fundamental concerns about your BYOD program.

          Thank the Experts

The law firm of Mayer Brown served as a resource from an article titled, ”Electronic Discovery & Information Governance – Managing the Risks of Bring Your Own Device” by Anthony Diana and Therese Craparo.  Click here for article.

Anthony Diana is a partner at Mayer Brown, and focuses his practice on commercial litigation, electronic discovery, internal and regulatory investigations, and bankruptcies.  He is a co-leader of Mayer Brown’s Electronic Discovery & Information Governance practice.  Click here for Anthony’s bio.

Therese Craparo is an experienced litigator at Mayer Brown, whose practice focuses on complex commercial litigation, including technology and telecommunications and electronic discovery.  Therese is a member of Mayer Brown’s Electronic Discovery & Information Governance practice.  Click here for Therese’s bio.

Wrestling for Results

A company with geographically diverse locations reduced monthly telecommunications expense by renegotiating a contract with their primary carrier.  So far, so good.

Problem.  The company, and the carrier, did not follow through to carefully examine the new billing.  The company did not notice the problem, because their costs dropped.  No one had the time to verify the invoices against the contract terms.

After the company hired CMS, we caught numerous billing errors.  Wrong rates were inconsistently applied.

CMS wrestled with the carrier, and did all the legwork.  The carrier issued checks totaling $60,031.87 to the client.  The money was refunded, because CMS caught the 6 months of billing errors.  We tenaciously followed up to get the credits for our client.  The account now bills correctly.

The on-going savings, and credits from the past, belong 100% to the client.  CMS does not charge a contingency fee, or accept payments from carriers.

This may not represent a situation of every company.  But, where there are telecom and cellular problems, we will achieve measurable results.  We have since 1989.

Look at us behind our back. 

Give Credit Where Credit is Due

CMS generated a $2,137.84 credit for this client.  The Director of Network Operations sent an email to us:

                                        Thank you Renee!  CMS rocks!!!!!!!!!!!!!!

Here's what happened: A human error by the carrier caused two analog phone lines to be set up incorrectly, and bill incorrectly.  CMS identified the problem, worked to completely solve the problem, and confirmed the client received the credit.  This was 10 months of follow through, working with a large, slow moving, carrier. 

This client manages skilled nursing facilities and assisted living communities located throughout the western United States.  

In this example, the client saved $2,137.84.  Pure savings.  CMS never takes a commission from carrier or client, so there is no conflict of interest.  CMS did all the legwork, and follow through, on this problem. 

CMS’ sole business is to reduce your staff workload while also reducing your monthly hard-dollar costs, by carefully managing your telecom and cellular.  For a better look at our business model, and the measurable results we deliver, look at www.CMSenterprisesinc.com.  Or, talk to us (503) 972-9999.

Cancel Your Corporate Cellular Accounts and Save Money

Look at your corporate cellular cost, and divide by number of devices to determine your average per device cost.  Are corporate smart phones an employee perk?  Should you pay for data plans for tablets? 

The obvious.  If an average per employee cost to your organization is $75 per month, and you transition to employee liable cellular with a $40 stipend, you save $35 per month per device.  Importantly, you simplify your organization, and eliminate the risk of fraud and overages costs. 

Save time, too.  Employee liable cell devices cut support costs.  Your staff can focus on more strategic projects.  Eliminate: Trouble tickets, move-add-change-disconnect, accessories, add new employee, terminate employee, user error support, upgrade eligible, pooling, fraud, expense code allocation, taxation issues, finding and correcting carrier errors. 

Nothing can be this easy.  There are reasons to keep corporate plans, such as HIPAA compliance, perceived data security risks, employee perceptions, company access to phone records, terminated employees keeping a corporate phone numbers, and early termination fees are some reasons why organizations choose to keep control with corporate liable cellular plans. 

Why do you have corporate cell phones?

Should you like to transition to employee liable phones, or simple reduce staff time and monthly hard-dollar costs, please contact CMS.  (503) 972-9999  info@CMSenterprisesinc.com 

Problem Solved with Persistence

A carrier's faulty network caused intermittent outages of phone service for one of our clients.  

The carrier denied that it had any responsibility for the problem.  Repeatedly, the carrier’s testing and technicians stated that no problem existed.  Unfortunately, the denial of the problem did not solve it, and the problem continued.  The carrier’s standard trouble ticket resolution process failed to solve the problem of intermittent dropped calls.  We chose to solve the problem outside the carrier’s trouble ticket process. 

We invested hours of time, and solved the problem.  On behalf of our client, we pursued a credit.  The carrier initially refused.  After many calls and emails, and still denying there was a problem, the carrier issued a credit of $2,638.73. 

Please call us if you have problems with telecom or cellular.  (503) 972-9999  For a one page overview, click here.   

Accounting Problem Scenario: The misapplied payment by a telecom carrier.

It's not your fault, but it's now your problem.  Another company's error costs you staff time to resolve.  Staff time is company money. 

Your accounting department correctly pays the carrier on time.  Problem: The carrier misapplies your payment to your other accounts.  This means that in the carrier's system, you haven't paid this particular invoice on this particular account.  The carrier, hopefully, issues a disconnect letter to you. 

Upon receipt of the non-payment letter, your staff must determine and reconcile what the problem is.  Time: 15 minutes to 1 hour.

You contact the carrier, and explain the problem.  Time: 15 minutes to 1 hour.

You must produce a copy of the check or proof of payment, and submit it to the carrier.  Time: 15 minutes to 1 hour.

You solved a problem that your carrier caused.  Your company spent 45 minutes best case, to 3 hours, worst case.  If you don't act fast enough, or are not diligent with the carrier, your service, and phone numbers associated with that account, may be disconnected.

Then, the re-establishment of service begins.  Time: 1 hour to 4 hours.

You don’t need to spend staff time on telecom and cellular problems.  We solve problems, and manage day-to-day administration of telecom and cellular. 

We will augment your staff, and guarantee to reduce your staff workload, while simultaneously reducing your monthly hard-dollar cost.  Email CMS.  Call 503-972-9999.  

Managing Telecom and Cellular, and Drinking Coffee

Based on experience with upper management in accounting and IT, we see the difficulty of broad responsibilities vs. limited staff time. A busy department means it's plausible that your telecom and cellular don’t get sufficient attention, which results in unnecessarily higher costs.

You and your staff can invest the time to solve the problems to lower monthly costs, but you may need to drink several cups of coffee.

There have been discrepant findings on the association between coffee consumption and risk of incident heart failure. Doctors of the Cardiovascular Epidemiology Research Unit at Harvard Medical School wrote an article that appeared in "Circulation: Heart Failure," which is published by the American Heart Association.

Doctors and researchers concluded that moderate coffee consumption is inversely associated with risk of heart failure, with the largest inverse association observed for consumption of 4 servings per day. Four servings per day is about two large cups of coffee at the popular coffee chains.

Find the published article at http://circheartfailure.ahajournals.org.

Go ahead and drink the coffee. Call your doctor to manage risk of heart failure.  Call CMS to manage your telecom and cellular. (503) 972-9999.  Click here for one page overview.

Dull Story about Disconnected Internet Circuits

Telecom and cellular administration can get tedious.  That is one reason why it gets ignored.  Or, sometimes it gets de-prioritized because of urgent problems.   

CMS saved a company an additional $3,533.66 per month. 

Problem.  The company’s telecom manager, the accounting staff, the telecom carriers, and the agent did not have the time or inclination to examine billing associated to circuits.

The company did not notice the over billing, because their costs had remained about the same. 

After the company hired CMS, we concluded that several internet circuits served no purpose.  The rub was that a vendor convinced the client that two specific circuits must not be issued disconnect orders.  CMS provided the client with photos showing that nothing was connected to those circuits. 

CMS wrestled with the carriers and vendors, and did all the work.  The savings belong 100% to the client.  The account now bills correctly. 

We remove at least 90% of telecom and cellular tasks from your to-do list, and simultaneously reduce your hard-dollar costs.  Click here for background.

Let us achieve measurable results for you.  www.cmsenterprisesinc.com

$209,000 Credit

A jaded CIO exclaimed, “It’s a miracle” because the carrier credited $209,000 to his company's account. 

Prior to engaging CMS, the client’s internal telecom manager had pursued this credit for 3 years.  The carrier previously refused to issue a credit, or even partial credit.   

CMS’ time, expertise, and enthusiasm resulted in the credit to client.  And, CMS has freed staff time to pursue other key objectives.  The CIO recognized CMS’ efforts, “Thanks for continuing to drive this to completion.” 

CMS never takes a commission from carrier or client. 

What if an audit company recovered this credit?  A contingency fee of 20% to 50% would have been charged. 

Pay us a flat fee for our work, and you keep 100% of the results.  


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