Costs associated with a Mobile Device are a in a class of expense that has a higher risk for abuse than most other costs and are highly susceptible to audits. These costs require added administrative effort to monitor and allocate the costs appropriately. For that reason, these cell phone & mobile device guidelines are being provided for managing these costs to reduce risk.
This guidance is provided subject to APS 55.1 http://www.washington.edu/admin/rules/policies/APS/55.01.html and is not intended to supplant or conflict with that policy in any way.
Cell phone cost allowability on sponsored programs:
The cost of cell phones and other mobile devices such as tablets is normally treated as an F&A cost and not as a direct cost to the project. This includes the cost of cell phone plans or the monthly allowance as described in the university Mobile Device Guidelines (http://f2.washington.edu/fm/ps/mobile-device-guidelines)
Per GIM 23, Cell phone costs are allowable on non-federal awards when permitted by the sponsor’s policies or are otherwise approved by the sponsor. For federal awards the costs may be allowable if the award meets the exceptional and unlike circumstance exception policy in OMB Circular A-21.
Exceptions to the basic rule include:
Cell phone costs are allowable under Regional Primate Center awards and as part of the PDC for the Applied Physics Lab.
Cell phone costs are allowable for off-campus awards when specifically identifiable to the project and when the following general conditions are met.
These costs must meet the general conditions of allowability that other costs expensed to Grants and Contracts must meet:
- The cost is Allowable under the terms and conditions of the award (not specifically identified as unallowable in the award or applicable terms and conditions).
- The cost is Reasonable. Would a normal person deem the cost appropriate given the intended use? Is the cost of the phone and the plan reasonable in reference to the intended use?
- The cost is Allocable. Will the use of the cell phone provide a direct benefit to meeting the project objectives?
- Consistent Treatment. Can the benefit to the project be determined without undue administrative effort?
In other situations where the cost is necessary for the efficient conduct of a sponsored project, is clearly identified in the proposal budget, justified in the budget narrative and funded by the sponsor, the cost would generally be considered allowable.
Best Practices for managing mobile device costs:
The costs associated with a Mobile Device are a in a class of expense that has a higher risk for abuse than most other costs so it may be the target of audits. For that reason, we provide the following guidelines in managing these costs to reduce risk.
Prior to approving an employee for mobile device charges, it is important to:
- advise him/her of their responsibility regarding use and safe guarding of the mobile device and any data stored on therein.
- For devices that may contain sensitive or controlled data, this may include compliance with Export Control regulations.
- Employees also need to be informed that the monthly bill must be provided for reconciliation and documentation upon audit.
Given the diversity of cell phone plans available, departments should develop standards for the most appropriate plans. Some projects may require a data plan, but it would seem this would be the exception rather than the rule. Most projects that require a cell phone would probably only require minimum communication capability.
- Be sure the cell phone plan period (if a contract is required) aligns with the period of the project the phone is needed for or that other funds are available to absorb the cost when the project period ends.
- When disposable phones are used, the unused time should be minimal therefore the cost does not need to be removed from the project. Unused talk time may be used for follow-on projects or for other university business.
In lieu of having one phone for university activities and another for personal use the employee should be directed to these Mobile Device Guidelines.
- This should reduce the potential for personal calls on a university paid plan that exceed a deminimus personal use standard.
- When personal use of the cell phone is more than deminimus it will be necessary to allocate some of the costs to non-sponsored funds or personal funds.
Monthly bills must be received and reconciled to ensure proper allocation of the costs to the benefitting budgets.
Use and allowance payments should be reviewed no less frequently than quarterly to ensure charges are appropriate for the use.
Copies of monthly bills must be retained in the award file for the required retention period.