Wireless Communication Devices

Directive Statement

UNITS (college units and their departments, faculty, and staff, all administrative units and respective staff including any direct employee of the University of Florida) have two options for supporting the business use of cell phones and similar wireless communication devices.  This directive provides guidance on these options and outlines the responsibilities of each UNIT that uses wireless communication for University of Florida business.   Only individuals in an active pay status with the University of Florida are eligible for the wireless communication options described in this directive.

Wireless communication devices will be issued, or wireless services reimbursed, only when a University of Florida employee has a documented non-compensatory business reason. These options may be initiated, modified, or discontinued at any time based on business needs and the discretion of the supervisor or administrative business unit finance officer. To ensure ongoing business necessity and appropriate use, all approved wireless communication arrangements must be reviewed and renewed annually.  UNITS must maintain appropriate documentation for all issued devices and service reimbursements regardless of option selected.

  1. University Issued Wireless Communication Devices (WCD) UNITS may issue University owned wireless communication devices and services to faculty and staff that have a demonstrated and documented need for such equipment and service.  Documentation supporting the justification for each device must be maintained.
  1. Monthly Service Reimbursement for Employee-owned Devices (MSR)UNITS may provide a non-taxable monthly reimbursement for wireless services of an employee-owned wireless communication device.  A documented non-compensatory business reason is required for all employees receiving a reimbursement.

Reason for Directive

WCDs and MSRs can be essential for staff and faculty to effectively perform their job duties. However, wireless communication costs represent a University of Florida expense and must be managed responsibly and are subject to IRS, state, and audit review, which require consistent documented support to ensure all costs are directly related to an employee’s official job duties. If provided, these two options are intended to qualify as non-taxable working-condition fringe benefits under Internal Revenue Service (IRS) guidance. These two programs can only be provided for substantial non-compensatory business reasons and must not be used as a substitute for compensation or other intended employment benefit.

Determination of Appropriate Monthly Reimbursement Amounts

MSRs are not expected to cover the full cost of an employee’s personal service plan, as employee-owned devices are anticipated to be used for both business and personal purposes. The standard reimbursement amount is set to not exceed $50 per month and must be reasonably estimated in relation to the employee’s documented non-compensatory business needs. This amount was determined using a standard rate based on State of Florida wireless device contract benchmarking. The maximum reimbursement amount of $50 approximates the cost to provide a University-issued wireless device through a State of Florida contract.  This benchmark amount will be reviewed, confirmed, and may be updated by University Procurement Services on an annual basis.  Any change to the benchmark amount will be communicated in this directive. Please note that the reimbursement amount needs to be commensurate with need and can be issued for less than the $50 maximum amount.

Each UNIT is responsible for the following:

  • Determine the best option for each individual situation and job requirement.
  • Determine how an individual’s reimbursement amount was determined, and the non‑compensatory business reason supporting the reimbursement (why needed).
  • Ensure amounts applied consistently across similarly situated employee needs.
  • Documentation retained in accordance with University of Florida recordkeeping requirements and made available for audit or review upon request.
  • Ensure the use of the Wireless Communication Service Reimbursement Request form. This form can also be used for recordkeeping requirements.

Reimbursements are limited to wireless service costs only and may not be used to cover the purchase, upgrade, or replacement of a wireless communication device(s). UNITS requiring a device for business purposes must provide University-owned equipment.

Employees may not receive both a MSR and a separate reimbursement for mobile hotspot or data services or a WCD.

Mobile hotspot (MiFi) devices and associated service plans must be University-owned and managed. UNITS requiring mobile connectivity solutions must procure and issue University-owned equipment in accordance with University procurement policies.

Determination of Eligibility

Each UNIT is responsible for determining employee eligibility by assessing whether a faculty or staff member requires either a WCD or MSR based on their job responsibilities. Additionally, a review must be completed of the continued non-compensatory business reasons at the end of each fiscal year. Examples of appropriate business reasons may include, but are not limited to, the following:

  • Positions that require the employee to be reachable outside of normal business hours to respond to operational, safety, academic, or research needs.
  • Roles that require on-call responsibilities, including emergency response, facilities operations, IT support, public safety, or critical system support.
  • Positions that require regular off-site, field-based, or mobile work where reliable access to University communication systems or workstations is not consistently available or practical.
  • Positions with supervisory or managerial responsibilities that require ongoing availability to address time sensitive personnel, operational, or financial matters.

Personal convenience, including remote or hybrid work arrangements, do not constitute a non-compensatory business reason under IRS guidance. Employees who work remotely or from home are generally reachable through University‑supported communication tools such as Microsoft Teams, Zoom, Slack, soft phones (e.g., Webex), email, or other web‑based collaboration platforms. These tools provide sufficient means for communication and availability without the need for a WCD or a MSR.

WCDs or MSRs must not be provided in lieu of wages, as a form of additional compensation, or as part of a recruitment or retention incentive.

A MSR may be approved only when a documented non-compensatory business reason exists that cannot be reasonably satisfied through existing University communication platforms.

Failure to comply with these requirements may result in the reimbursement being treated as taxable income to the employee in accordance with IRS regulations.

Approval Process for Reimbursement

MSRs must be approved by the following ahead of submitting the Wireless Communication Device Reimbursement Request

  • The employee’s direct supervisor
  • The responsible Finance Officer for the funding source
  • The Senior Finance Administrative Officer or designee

Procedures for Processing Reimbursements

MSR payments must be entered into the University Accounts Payable system and paid through the designated voucher process.

MSRs must be reviewed, approved, and reentered for consideration on an annual basis covering each fiscal year (July 1 – June 30). The duration of an MSR must not exceed 12 fiscal calendar months and must terminate no later than June 30 of each fiscal year.

When reimbursements are provided under a fixed, reasonable allowance and supported by a documented non-compensatory business reason, employees are not required to submit detailed usage records. However, UNITS must retain documentation supporting eligibility and business justification(s).

Employees may not receive multiple MSRs for the same purpose from University, Direct Support Organization (DSO), or affiliated entity funding sources.

The employee’s direct supervisor is responsible for ensuring that no employee receives duplicate reimbursements. Supervisors must promptly terminate a WCD or MSR when an employee separates from the University, transfers to another position, experiences a change in job responsibilities that no longer meets eligibility requirements, or is on an approved leave of absence that exceeds twelve (12) consecutive weeks.

Employees are required to attest that they are not receiving a similar allowance or reimbursement from any other source for the same intended purpose.

Refer to the Wireless Communications Devices Procedures and Best Practices document located on the CFO website for detailed operating procedures which support this directive.

 Who Must Comply

All University UNITS and employees participating in, administering, or receiving a WCD or MSR under this directive.

Resources

Mobile Device Security

Procurement Website

Wireless Service Reimbursement Request Form

Procedures & Best Practices

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