We consider a biaxial macrospin with an easy and hard axis, and study its dynamical evolution under the combined effects of thermal noise and spin transfer torque. The spin-torque is associated with both a perpendicularly magnetized polarizer and an in-plane magnetized reference layer, leading to an effective tilt between the easy and spin polarization axes. Using techniques based on energy averaging over the relevant dynamical trajectories, we analyze the effects of tilt on the dynamics and derive the conditions for the occurrence of stable out-of-plane precessionary states. The presence of these states and their predicted stability boundaries can be tested in experiments on orthogonal spin-transfer devices, and may also serve as a test of the applicability of the macrospin model to real devices, which have internal magnetic degrees of freedom. ; Comment: 28 Pages, 11 Figures