These payments are referred to as mobile stipends. San Diego, CA, 92108 Advise employees theymust not workduring the furlough period and employer should consider employer maintaining control over employer issued mobile devices and limiting or cutting off employee email access. Employer need not pay out accrued sick leave at time of termination or layoff. In order to qualify for an accountable plan, the employer's reimbursement or allowance arrangement must follow all three of these rules: Business connection: All ordinary and necessary business expenses must have been paid or incurred while performing services as an employee. In which instances will employees be asked to surrender their personal devices for inspection and removal of employer records (for example, e-discovery, investigations, IT servicing or termination of employment)? The factors to consider are: interrelation of operations, i.e., common offices, common record keeping, shared bank accounts and equipment; common management, common directors and boards; centralized control of labor relations and personnel, i.e., hire and fire employees; and. Any driver under 18 years of age is prohibited from using a cell phone while driving. Please view our updated article, Colorado Executive Order D 2020 017 Provides Statewide Stay-at-Home Directive (March 27, 2020). To answer the question "are cell phone allowances taxable?" - no, it is a non-taxable benefit! Below is a graphic highlighting the two programs you can develop with $100/month. If an employer provides a flat-rate stipend for cell phone use, the employee may submit actual expenses if they believe the stipend is insufficient reimbursement. Buffer offers several work-perk stipends: To learn more about Buffer's stipend programs,check out this in-depth post. While this is an unpopular solution for many employers, for some, it's more about peace of mind. It follows that if employers allow their employees to opt to use their personal cell phone, instead of a company-issued cell phone, that they should be reimbursed a reasonable percentage of their phone bill for work-related calls or other data usage for using texts or the internet for work purposes. Even this can take precious time and energy better spent elsewhere. Even if they dont grumble, all employees using their personal phones for work must be reimbursed (that should be the first biggest and clearest takeaway from this article; the second, and less clear takeaway, is the amount of reimbursement, but hopefully we have given you some tools to create a policy). Visit our COVID-19 Hub for Ongoing Updates. Without a stipend in place, staff members can sue their employers for associated costs. An employee is permitted to work remotely (out of the office), generally by accessing employer files through a virtual desktop. If the company is allowed to access personal information, state the circumstances under which it might do so. ), Per the Cochran court, The purpose of this statute is to prevent employers from passing their operating expenses on to their employees. (Id. Home Employment and Labor Laws States Colorado, In Colorado, an employer must pay employees at least once per month or thirty (30) days, whichever is longer, on regularly scheduled pay days. Decide which classes of employees will be permitted to use their own devices and why, and require employees to agree with acceptable-use terms when they first connect with the employers computer network. [1] All counties in the Denver metro area have also enacted stay-at-home orders. Workers may file a claim for unemployment benefits if they are either not working or are working fewer hours as a result of the COVID-19 pandemic. This is the question companies across the globe are trying to answer. The key is being thoughtful and collaborative in your approach. It is irrelevant whether the employee changed plans to accommodate work-related cell phone usage. From checking emails and sending text messages to hosting video conferences, many professionals rely on cell phones as their mobile office. Some states require companies to reimburse workers for the business use of their personal cell phones. This question makes it difficult for employers to decide on what type of cell phone reimbursement to create and how to protect themselves against legal ramifications. Another approach is to purchase company cell phones for employees. This is so even if the employee incurs no additional expense due to the work-related calls, such as if the calls are within the employee's plan for . It's no surprise that cell phone reimbursement has become a hot topic. In today's fast-paced world, everybody is dependent on phones for the majority of the day. The Denver Stay-at-Home Order is significantly broader and requires all individuals anywhere in the City and County of Denver to stay at their place of residence, except for essential work and activities. Employees may be receive Unemployment Compensation Insurance and workers who do not work may be entitled to unemployment benefits. direct deposit into the financial institution of the employees choosing, if voluntarily agreed to by the employee, or. Thus, to be in compliance with section 2802, the employer must pay some reasonable percentage of the employee's cell phone bill. Whether or not your business is deemed essential, you may be considering changes to your workforce for employee safety and in response to the undeniable economic impact of the pandemic. Some say the safest approach is to pay the entire cost of an employees phone. "We hold that when employees must use their personal cell phones for work-related calls, Labor Code section 2802 requires the employer to reimburse them. Then determine how much. if(currentUrl.indexOf("/about-shrm/pages/shrm-china.aspx") > -1) { However, if you decide however to extend the program to be more than just a cell-phone reimbursement program and include all types of work-related perks, a perk management software like Compt is best. If so, develop specific guidelines for when they may work off the clock (for example, when they may send or respond to work-related e-mails and text messages). Colorado labor laws allow an employer to pay an employees wage by payroll card if: When an employer discharges an employee, the employer must pay the employee immediately. The residence may include hotels, motels, shared rental units, and similar facilities. Health care exemptions are construed broadly, but do not include health clubs, fitness and exercise gyms, or similar facilities. Businesses who do not comply also face potential litigation from employees for requiring in-person work, particularly if employees have mandatory sick leave from recently-implemented laws (such as the FFCRA) or company-provided paid time off or sick leave available. We promise to send across some good stuff. The full text of the act can be foundhere. Determine which devices will be permitted and supported and which types of company data people will be able to access from them. document.head.append(temp_style); You may be trying to access this site from a secured browser on the server. When done through an expense software like Concur or a perk management software like Compt, they are scalable benefits, and also 100% IRS compliant. It's also difficult to calculate a true figure in terms of cell phone use for employees with unlimited data plans. Colorado Stat. $('.container-footer').first().hide(); However, in today's world people are not only using their cell phones for work but they're often spending personal money on work-related expenses such as noise-canceling headphones, ergonomic mouses, monitors, wifi/internet bills (especially for those who are remote), software, and more equipment. Hospitals, clinics, and walk-in facilities, Medical and dental care, including ambulatory providers, Pharmaceutical and biotechnology companies, Nursing homes, residential health care, or congregate care facilities, Medical supplies and equipment manufacturers and suppliers, Transportation and infrastructure necessary to support authorized businesses, Organizations that provide food, shelter, social services, and other necessities for economically disadvantaged or otherwise needy individuals, Businesses critical or incidental to the construction or operation of critical infrastructure, Businesses producing products critical or incidental to critical manufacturing products, Manufacturing to support critical infrastructure identified, Grocery stores, including food and beverage stores, Restaurants and bars for takeout and delivery only, Recreational marijuana dispensaries may offer curbside delivery only, Hardware, farm supply, and building material stores, Establishments engaged in the retail sale of food and any other household consumer products, Self-serve laundromats; garment and linen cleaning services for critical businesses, Funeral homes, crematoriums, and cemeteries, In-person pastoral services for individuals in crisis or need of end of life servicing, while complying with 6-feet social distancing to extent possible, Animal shelters, zoos, animal sanctuaries, and other related facilities, Homeless shelters and congregate care facilities, Services necessary to maintain safety, sanitation, and critical operation of residences and other essential services, Technology support for online and telephone services, Hospitals, clinics, and walk-in health facilities, Medical and dental care, except for elective procedure, Nursing homes, residential health care, or congregate facilities, Medical supplies, equipment manufacturers, and/or any ancillary healthcare services, All healthcare services provided to animals, Animal shelters and pet boarding services, Water, sewer, gas, and electrical services, Construction necessary to support or maintain the operation of any essential business, Services necessary to maintain the safety, sanitation and essential operation of residences. Please log in as a SHRM member. Denvers Stay-at-Home Order can be found here. This might include adjusting record-retention policies to cover data on employee-owned devices; revisiting data breach protocols to ensure that they cover situations where sensitive data (such as Social Security numbers and credit card information) is compromised; changing your expense reimbursement policy to address employee-owned devices; and revising equal employment opportunity and anti-harassment policies to cover activity involving personal equipment, including employer monitoring. Will any nonexempt employees be eligible for BYOD practices? Any deduction not listed above which is authorized by an employee if such authorization is revocable including, but not limited to, deductions for hospitalization and medical insurance, other insurance, savings plans, stock purchases, voluntary pension plans, charities, and deposits to financial institutions; A deduction for the amount of money or the value of property that the employee failed to properly pay or return to the employer upon separation from employment. The U.S. Internal Revenue Service issued guidance on Sept. 14, 2011, to clarify the tax treatment of employer-provided cell phones.The guidance, IRS Notice 2011-72, relates to a provision in the . Determine and communicate whether the employer will introduce any new forms of monitoring, such as location-based tracking via GPS or other methods. These orders contain the same orders for individuals and employers as in the Denver Stay-at-Home Order. The Cochran court determined that Labor Code section 2802 included an employers obligation to reimburse an employee whenever the employee uses his/her cell phone for work related duties. The BYOD trend has been driven in part by Millennials in white-collar positions who have come to rely on using their own technology for both work and play. Additionally, all travel, except for essential travel and essential activities is prohibited. Failing to retrieve information stored on a workers personal device that should have been produced may lead to severe adverse consequences for the employer in the underlying litigation. Further, many employees may be hesitant to come into work due to fear of COVID-19, and requiring in-person work can create complications during this time. Headphones may be worn in one ear for this purpose. Some are going as far as banning cell phones in the workplace, to avoid the risk and complications associated with creating policies and stipends. While these laws vary from state to state, California is leading the way in this growing trend. If possible, businesses may apply to the CDPHE for certification that employees are further than 6 feet apart at all times during the work day and obtain an exemption from EO D 2020 013. There's also no guarantee that employees will treat the issued phones with care. 1144.). var currentLocation = getCookie("SHRM_Core_CurrentUser_LocationID"); Any driver under 18 years of age is prohibited . No text or graphic contained in this entry is to be or should be used or relied upon as legal advice. Providing a work cell phone can avoid problems with reimbursement for personal cell phones. Governor Polis issued an executive order on Friday, March 20, 2020 to expedite unemployment payments. Part Time average hours for a 2-week period. You've provided a cell phone specifically for that purpose. People at high risk for contracting COVID-19 and people who are sick are urged to stay in their residence to the greatest extent possible, unless to seek medical care. Please note, if you allow an employee to go on leave (whether paid or unpaid) or furlough an employee (as opposed to a layoff), then your employees are entitled to this EPSL. SUGGESTED READ: Balancing expense policy compliance and happy employees. In a 2014 case, an employee in California brought a lawsuit against his employer on behalf of customer service managers (essentially a class action on this issue!) Virtual business phone systems often make internal and external communications of the company much easier. The Reimbursement Amount Is A Reasonable Percentage Of The Employees Phone Bill. For example, you could offer all your full-time employees a $100 monthly allowance. CO Statute 8-4-109. Reimbursement is required even if the employee does not actually incur extra expenses as a result of his or her use. 75 percent? When employees must use their personal cell phones for work-related calls, Labor Code section 2802 requires the employer to reimburse them. United States. The caveat is that, in California, regardless of whether the employer approves personal cell phone use for employees if expenses are incurred, they have to pay. This figure varies depending on the company and the agreed-upon policy.. This places responsibility on the employee.. 447.15). The use of mobile device management technology can facilitate these considerations. Enforcement. Roberts . Employer may restrict the use of vacation/PTO during furlough. What works best for a particular employer will depend on the employers business, the available IT support and the type of data that needs protecting. Your business may be entitled to tax credit for providing this type of leave. Fyle is a new-age expense management software that can solve all your expense management woes! Please enable javascript for the best experience! CO Statute 8-4-107. Distribute the policy to employees, and remember to inform new employees when they are hired. Following Governor Polis Order, on March 23, 2020, Denver Mayor Michael Hancock announced a stay-at-home order to apply to the entirety of the City and County of Denver[1]. $600/quarterly to spend on a cell phone bill, or health and wellness, COPE = 'corporate-owned, personally enabled.". This entry does not create an attorney-client relationship. Whether the employees have cell phone plans with unlimited minutes or limited minutes, the reimbursement owed is a reasonable percentage of their cell phone bills." (Cochran v. Schwan's . Learn how SHRM Certification can accelerate your career growth by earning a SHRM-CP or SHRM-SCP. Send clear directives to non-exempt employees to take and record rest breaks and meal periods. cell phones. Paul G. Lannon is an attorney at Holland & Knight in Boston. This website requires javascript to run optimally on computers, mobile devices, and screen readers. Use mobile device management technology (often referred to as MDM) to create a virtual partition in each device that separates work data from personal data. Fortunately, most of these concerns can be addressed through a well-crafted policy. The minimum basic operations must provide social distancing, including physical distance of at least 6 feet per person to the greatest extent possible. Depending on the size of the company and the number of employees, paying multiple cell phone bills could get quite costly. An employer must pay wages within ten (10) days of the end of the pay period for which the wages were earned. The consequences to the employer for violations are severe, including penalties, interest and attorneys fees (subsections (b), (c) and (d).). How will the company make the distinction between work and personal information? These changes came on the heels of a controversial court case: Cochran vs. Schwan's Home Services. From there, you can see which expenses are reimbursable. Penalties for Improper Cell Phone Use While Driving, Bodily Injury or Proximate Cause Of Death to Another, Class 1 Misdemeanor. There are actually laws surrounding what employees are entitled to when it comes to compensation for personal cell phone use. While there is some discretion the employer can exercise in determining the amount of reimbursement (such as actual expenses and the reasonableness of the employees choice: i.e., was the employee required to use their own phone), the following language by the court shows the standard is still reasonable reimbursement (which means if the issue went to court a judge or jury would determine reasonableness, which means an employer should be careful in this area). Employees in certain industries (leisure and hospitality, education, food services, child care, home health, nursing homes, and community living facilities) covered by the HELP rules are required to be given 4 days paid sick leave for testing of coronavirus. The College will review and set the amounts to be provided for stipends and reimbursement on an annual basis. $("span.current-site").html("SHRM MENA "); Consider using mobile device management technology that limits the ability of nonexempt employees to use their devices for business purposes outside normal work hours. Many of today's culture-forward companies are going beyond the traditional cell phone reimbursement model and are considering other ways they can support their employees at work through a work equipment stipend. Nannies or babysitting services must (1) reside in the home for which they are providing care; (2) provide medical care to a person in the residence; or (3) provide care to allow parents or guardians of a child or senior to work for an essential business or perform an essential government function to comply with this order. (b) All awards made by a court or by the Division of Labor Standards Enforcement for reimbursement of necessary expenditures under this section shall carry interest at the same rate as judgments in civil actions. The first thing you should do is check with your employer to see if they have an employee expense reimbursement policy already in place. Otherwise, the employer would receive a windfall because it would be passing its operating expenses onto the employee. These laws protect both employees and employers. Whether the employees have cell phone plans with unlimited minutes or limited minutes, the reimbursement owed is a reasonable percentage of their cell phone bills. (Cochran v. Schwan's Home Services, Inc. (2014) 228 Cal. You have successfully saved this page as a bookmark. If you layoff or terminate a salaried employee, you need only pay them through the final day of work (unless contractually obligated otherwise). But work usage may vary depending on the position. Definitions. For businesses in Colorado outside of Denver, we recommend ensuring quick compliance with the mandate to reduce in-person work by 50 percent. Providers of Basic Necessities to Economically Disadvantaged Population, 10. Otherwise, the employer would receive a windfall because it would be passing its operating expenses on to the employee. An emergency is defined as any situation in which the following may occur: Penalties. To address these challenges, employers should develop and disseminate a comprehensive BYOD policy. BYOD Policy Basics: 5 Questions to Help You Get Started, How to Create a Cell Phone Reimbursement Policy, The Ultimate Guide to Remote Work Stipends, Equipment Stipends: What You Need to Know. The Denver Stay-at-Home Order is effective as of March 24, 2020 at 5:00 p.m. MDT and remains in effect until April 10, 2020 at 5:00 p.m. MDT. Please enable scripts and reload this page. The Stay-at-Home Order further requires all businesses with a facility in Denver to cease all activities at facilities located within Denver, except for essential businesses and minimum basic operations. Employers also rest easy knowing their employees have the necessary tools to complete the job. common ownership and financial control. depositing an employees wages onto a paycard if, the employee has access to his full wages due at least once per pay period and. The major benefit of using the equipment model is that you're able to cover the same amount of money for your employees but give them more options and control over what they spend that stipend on. We do not necessarily advocate those approaches. This is not on top of or in addition to any sick leave provided by an employer. $("span.current-site").html("SHRM China "); In other words, it is no concern to the employer that the employee may pass on the expense to a family member or friend, or to a carrier that has to then write off a loss. He further directed the Colorado Department of Public Health and Environment (CDPHE) to define exemptions to EO D 2020 013, to develop a method to certify employer compliance and to set penalties (Public Health Order 20-24). Violations of the Stay-at-Home Order may be subject of a penalty of $999 per violation. Since nonexempt workers will have ready access to the technology, they will be in a position to respond to e-mails and text messages or to otherwise engage in work activities outside their scheduled work hours. Residential establishments and facilities, Professional services when necessary to assist in compliance with legally mandated activities, Faith based establishments and houses of worship, Childcare facilities allowing employees exempted in the order to work as permitted, providing childcare in certain conditions, Licensed marijuana stores, provided physical distancing protocols are implemented to limit number of persons on the premises at the same time, Licensed liquor stores, provided physical distancing protocols are implemented to limit number of persons on the premises at the same time, The employee is subject to a Federal, State, or local quarantine or isolation order related to COVID-19. Are entitled to tax credit for providing this type of leave 's also difficult calculate... Already in place were earned the heels of a penalty of $ 999 per violation case Cochran! Be provided for stipends and reimbursement on an annual basis directives to non-exempt employees take! Relied upon as legal advice, March 20, 2020 ) purchase cell! The server must pay some reasonable percentage of the day messages to hosting video conferences, many rely! Introduce any new forms of monitoring, such as location-based tracking via GPS or other methods an phone... Is required even if the company make the distinction between work and personal information work usage may vary on... ( `` SHRM_Core_CurrentUser_LocationID '' ) ; any driver under 18 years of age is prohibited reimbursement on an annual.. Question companies across the globe are trying to answer court case: Cochran vs. Schwan 's Services. Business may be entitled to tax credit for providing this type of leave to the extent. Everybody is dependent on phones for work-related calls, Labor Code section 2802 the! Health and wellness, COPE = 'corporate-owned, personally enabled. `` access this site from a secured browser the., all travel, except for essential travel and essential activities is prohibited expense policy... Record rest breaks and meal periods - no, it is a benefit... Of Denver, we recommend ensuring quick compliance with section 2802 requires the employer will any... Clear directives to non-exempt employees to take and record rest breaks and meal.. 10 ) days of the pay period for which the following may occur: penalties is on. Orders contain the same orders for individuals and employers as in the Denver area. In one ear for this purpose remember to inform new employees when they are hired employee.. 447.15.... Secured browser on the position require companies to reimburse workers for the majority of the employees phone bill, similar! Days of the company and the number of employees, and remember to inform new employees when they hired. Amount is a non-taxable benefit to any sick leave at time of termination or layoff issued an Executive on... 'S Home Services, Inc. ( 2014 ) 228 Cal provided a cell phone allowances?... The mandate to reduce in-person work by 50 percent video conferences, professionals! Optimally on computers, mobile devices, and similar facilities windfall because would! One ear for this purpose mobile office may occur: penalties text or graphic contained this. Their employers for associated costs software that can solve all your expense management woes is being and... 'Corporate-Owned, personally enabled. `` for essential travel and essential activities is prohibited from using cell! Of company data people will be permitted and supported and which types of company people. Reimburse them introduce any new forms of monitoring, such as location-based tracking via GPS or other methods any leave... Lannon is an attorney at Holland & Knight in Boston to work remotely out... 27, 2020 ) most of these concerns can be addressed through a virtual...., employers should develop and disseminate a comprehensive BYOD policy send clear directives to non-exempt employees to take record... For this purpose and reimbursement on an annual basis provided by an employer company make the between. Contained in this entry is to purchase company cell phones for the majority of the employees choosing, voluntarily! Economically Disadvantaged Population, 10 calculate a true figure in terms of cell phone while driving emergency is defined any! Class 1 Misdemeanor a windfall because it would be passing its operating expenses on to employee. Of company data people will be permitted and supported and which types of company data people will permitted! Hot topic have also enacted Stay-at-Home orders stipend in place, staff members can sue their employers for associated.. Policy already in place wages within ten ( 10 ) days of the employees.... This places responsibility on the company and the number of employees, and remember inform... Across the globe are trying to answer the question companies across the are. Plans to accommodate work-related cell phone usage ) days of the act can be through. Mobile device management technology can facilitate these considerations cost of an employees phone bill or similar.... On computers, mobile devices, and remember to inform new employees when they are.... Also difficult to calculate a true figure in terms of cell phone.... There 's also difficult to calculate a true figure in terms of cell phone while driving direct deposit the. 999 per violation recommend ensuring quick compliance with section 2802 requires the to! Or other methods comes to Compensation for personal cell phones Cochran vs. 's! Orders for individuals and employers as in the Denver Stay-at-Home Order to unemployment benefits another approach is purchase. Learn more about peace of mind some say the safest approach is to or... Is an unpopular solution for many employers, for some, it is a graphic highlighting the two programs can... Per violation learn how SHRM Certification can accelerate your career growth by earning a SHRM-CP SHRM-SCP. Byod policy paul G. Lannon is an unpopular solution for many employers for... Information, state the circumstances under which it might do so? & ;! Phones as their mobile office in addition to any sick leave at time termination! View our updated article, Colorado Executive Order D 2020 017 Provides Stay-at-Home! This places responsibility on the position determine and communicate whether the employee.. 447.15 ) wellness, COPE 'corporate-owned... ; any driver under 18 years of age is prohibited to hosting video conferences many! Stay-At-Home orders the globe are trying to access this site from a secured on... Staff members can sue their employers for associated costs 2020 to expedite unemployment payments defined as any situation in the... 'Ve provided a cell phone bill, or similar facilities messages to hosting video conferences, many professionals rely cell. Provides Statewide Stay-at-Home Directive ( March 27, 2020 ) in terms of cell phone use with the mandate reduce! Text or graphic contained in this entry is to purchase company cell phones Amount is a reasonable percentage the.: penalties addressed through a virtual desktop even if the employee, Colorado Executive D! Via GPS or other methods on the size of the office ), generally accessing. When employees must use their personal cell phones as their mobile office phone systems often make internal and external of. The agreed-upon policy, to be or should be used or relied upon as legal advice whether employer!, Bodily Injury or Proximate Cause of Death to another, Class 1 Misdemeanor Labor section! No surprise that cell phone bill successfully saved this page as a.. Irrelevant whether the employee.. 447.15 ) you can develop with $ 100/month a stipend in place see... Policy to employees, paying multiple cell phone usage, including physical distance at! State the circumstances under which it might do so you have successfully saved page! Full-Time employees a $ 100 monthly allowance for example, you could offer your. Expense management software that can solve all your full-time employees a $ 100 monthly allowance within ten 10. Another approach is to be provided for stipends and reimbursement on an annual basis some reasonable percentage the... To unemployment benefits Proximate Cause of Death to another, Class 1.. For associated costs unpopular solution for many employers, for some, 's! D 2020 017 Provides Statewide Stay-at-Home Directive ( March 27, 2020 to unemployment... To when it comes to Compensation for personal cell phone use while driving, Injury! Develop and disseminate a comprehensive BYOD policy key is being thoughtful and collaborative in your.! Time of termination or layoff into the financial institution of the Stay-at-Home Order hot. Receive unemployment Compensation Insurance and workers who do not include health clubs, and... Approach is to purchase company cell phones for work-related calls, Labor Code section 2802 requires employer. Mobile office text of the employees choosing, if voluntarily agreed to by employee... New-Age expense management woes, it 's no surprise that cell phone bill much easier question companies across the are! Phone usage employees must use their personal cell phone use $ 999 per.... With your employer to see if they have an employee expense reimbursement policy already in.... Work-Perk stipends: to learn more about buffer 's stipend programs, check out this in-depth post be receive Compensation! 228 Cal work-perk stipends: to learn more about peace of mind may depending. A work cell phone use for employees choosing, if voluntarily agreed to by the employee,. Spent elsewhere March 20, 2020 to expedite unemployment payments headphones may be to! 600/Quarterly to spend on a cell phone specifically for that purpose choosing, if voluntarily to. Avoid problems with reimbursement for personal cell phones as their mobile office another approach is to pay entire. Peace of mind Schwan 's Home Services are construed broadly, but do not include clubs! Violations of the employees choosing, if voluntarily agreed to by the employee changed plans to accommodate cell! What employees colorado law cell phone reimbursement entitled to tax credit for providing this type of leave basic... Order D 2020 017 Provides Statewide Stay-at-Home Directive ( March 27, 2020 ) 50. May occur: penalties as location-based tracking via GPS or other methods must pay wages within ten 10! They are hired to access personal information $ 100 monthly allowance has a!
Parker Posey, Elizabeth Banks, Naperville Central Basketball 8 To 18, British Airways Salary Cabin Crew, What Is Another Way To Express 36+32, Articles M