1. TED MORDHORST ASSISTANT DIRECTOR FOR POST AWARD FINANCIAL COMPLIANCE RESEARCH ACCOUNTING & ANALYSIS Fiscal Compliance Corner Cell Phones & Other Mobile Digital Devices MRAM July 2013

2. Cell Phones & Other Mobile Digital Devices  Applies to Cell phones, Smart phones, Tablets and other mobile digital devices  Purchase  Monthly Phone use  Monthly Data plans  Challenges associated with managing the costs of these devices.  High risk for abuse (i.e. excessive personal use, inaccurate allocation of costs)  Documentation for allowable use can be challenging  May be subject to export control regulations  May be target of audits

3. Cell Phones & Other Mobile Digital Devices May be an allowable cost on a sponsored project budget.  Not disallowed by the sponsor – Allowable  Cost of phone and plan is Reasonable based on the need to support project objectives.  Cost can be Allocated based on the direct benefit provided.  Departmental policy treats the cost Consistently as a direct cost regardless of funding source.

4. Cell Phones & Other Mobile Digital Devices Guidelines  Review university and sponsor policies  Advise recipients of their responsibilities  Use  Security  Data stored on the device  Based on need determine the best program  University issued device  Personal device use allowance  Plan for when sponsored funding ends or the device is no longer allocable to the funding being charged.

5. Cell Phones & Other Mobile Digital Devices Allowance using existing personal phone number  Advantages:  Reduce the potential for noncompliance  Greater adherence to deminimus use standard  Reduced monthly administrative burden  Eliminates need for both a personal and a work cell phone  Disadvantages  May not be appropriate in all situations.  Allocating costs to benefitting budgets may be more cumbersome  Requires periodic auditing of personal bill to determine if allowance amount should be adjusted.

6. Cell Phones & Other Mobile Digital Devices Resources:  Administrative Policy Statement (APS) 55.1  http://www.washington.edu/admin/rules/policies/APS/55.01.h tml http://www.washington.edu/admin/rules/policies/APS/55.01.h tml  University Mobile Device Guidelines  http://f2.washington.edu/fm/ps/mobile-device-guidelines http://f2.washington.edu/fm/ps/mobile-device-guidelines  Grant & Contract Accounting  http://f2.washington.edu/fm/gca/spending/allowable- expenditures/cell-phone-and-mobile-device-costs-grants- contracts http://f2.washington.edu/fm/gca/spending/allowable- expenditures/cell-phone-and-mobile-device-costs-grants- contracts