Neither of these fields is available to import when updating phone information.  After phonathons we get a file of all the invalid phone types and do an import to change them to the appropriate Former type (e.g. Former Home, Former Cell) and would like to change the date and add a Comment that indicates this update came from Phonathon, but cannot do this.  The comment field can only be updated one-of and we have 1000's of updates, so this is not practical.