As questions about purchasing cellular phones and applying cellular service charges to sponsored projects become increasingly common, please be aware of the following state and federal regulations regarding cell phones/cellular service charges, and read on to find out how to request an exceptional purchase request.
UW-Madison/State of Wisconsin Policies/Procedures
Information regarding campus and state policies regarding cell phones and related service charges can be found at: www.doit.wisc.edu/telephone/cellular/policy.asp. In general, the University discourages assigning University-funded cellular service to individual employees. However, the policy also addresses options regarding when phones/services may be appropriate/allowable. Individuals should refer to the full campus policy for additional information, including details regarding the State of Wisconsin mandatory contract for the purchase of cellular service/phones.
Personal use is unallowable, except for essential personal calls of minimal duration and frequency. The policy referenced above includes information regarding oversight, monitoring and requirements regarding reimbursement of costs for excessive personal use.
Allowability on Sponsored Projects
Any sponsored project (federal or non-federal, grant or gift) is subject to UW-Madison policy and State of Wisconsin regulations regarding application of costs to the project. Cellular phones are considered an equipment purchase, and like any equipment purchase, must be used specifically for the particular project the cost is charged to.
Application of cell phones and service charges to a sponsored project are allowable if use is dedicated to the project. Per OMB Circular A-21 section J.9., communication costs related specifically to a project are allowable. J.9 states: Costs incurred for telephone services, local and long distance telephone calls, telegrams, postage, messenger, electronic or computer transmittal services and the like are allowable when the costs can be documented and allocable to the project to which costs are applied.
If the cell phone and related charges are for general purpose use and cannot be determined as allocable to the project, then the cost is unallowable on a sponsored project and should be applied to an unrestricted funding source or treated as an F&A (indirect, overhead) cost per OMB Circular A-21 section F.6.b.(3) and J.18.a (4): Items such as office supplies, postage, local telephone costs, and memberships shall normally be treated as F&A costs. “General purpose equipment” means equipment, which is not limited to research, medical, scientific or other technical activities. Examples include office equipment and furnishings, modular offices, telephone networks, information technology equipment and systems, air conditioning equipment, reproduction and printing equipment, and motor vehicles. Cellular phones and services are not specifically named in the circular, but are considered in the same category as telephone and related communication costs and services.
Exceptional circumstances: requests for cellular phones and service charges on sponsored projects
Although generally unallowable, it may be possible to assess cellular phones and service charges to a sponsored project. Permission can be requested as an “exceptional circumstance.” The need for cellular phones and related services should be recognized and included in the budget justification at project proposal stage, detailing the specific nature of the situation. An “exceptional circumstance” should be requested and approved prior to submission of the proposal to the sponsor. Documentation showing the dedicated nature and exceptional need of a cellular purchase must accompany any cellular purchase, and prior approval is required. If the request is not detailed in the proposal stage and approved as an exception at the time of application, an exception request is required prior to purchasing the phone/service and applying charges to the project.
The process for submitting an exceptional circumstance request can be found at https://cals.wisc.edu/research/management/monitoring.html?4?Cp4.