Wireless Communication Devices

Wireless Communication Devices (WCDs) and Monthly Service Reimbursement for Employee – Owned Devices (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.

Who Must Comply

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

UNIT Responsibilities

The UNIT is responsible for the following:

1. 1. Determine eligibility by assessing whether a faculty or staff member requires a wireless communication device or service based on their job responsibilities and review the continued business need at the end of each fiscal year. Examples of appropriate business justifications 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.

1. 2. Determine the appropriate method of support, including whether a WCD or a MSR is the most appropriate option. If a WCD is selected, assess whether the selected wireless service plan is appropriate, cost‑effective, and aligned with the business need.
   3. Maintain appropriate documentation and records for WCD assignments, MSRs, and supporting business justification, in accordance with University recordkeeping requirements.
   4. MSRs must be approved prior to submission. Required approvals includes: 1) the employee’s direct supervisor, and 2) the Senior Finance Administrative Officer or designee.
   5. Process approved MSRs through the Accounts Payable system monthly, in accordance with University procedures.
   6. Ensure WCDs are managed as University property, including requiring devices to be returned to the supervisor or designee when they are no longer needed or when a faculty or staff member transfers or terminates employment with the University.
   7. Coordinate the discontinuation of MSRs by notifying Disbursements to close the voucher and stop monthly service plan reimbursements when a faculty or staff member terminates employment or changes departments.
   8. If an employee continues to receive a MSR after their employment with the University has ended, the employee may be required to repay the University for any payments issued after the effective date of termination.

Inappropriate Business Justification

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.

Faculty and Staff Responsibilities

Faculty and staff are responsible for the following:

1. 1. Provide information or documentation, upon request, to support the business need for a MSR and notify their department head if the business need changes significantly.
   2. Pay all charges owed to the communication service provider under their service agreement and discontinue a MSR when the device is no longer active.
   3. Use WCDs primarily for University of Florida business. Incidental personal use should be infrequent and non‑routine. Use for commercial, “for‑profit” activities are prohibited. Use inconsistent with applicable IRS rules is prohibited.
   4. Protect wireless devices from loss, theft, damage, or misuse to the best of their ability. This includes taking appropriate precautions to prevent physical damage and unauthorized use. Employees who are issued a WCD may be held financially responsible for damage to the device that results from negligence, misuse, or failure to exercise reasonable care. Employees may be required to reimburse the University for repair or replacement costs.
   5. Return WCDs when they are no longer needed or when the employee transfers to another department or terminates University employment.
   6. Comply with the University’s mobile device security policies for both employee‑owned and University‑owned devices.

Monthly Service Reimbursement for Employee-Owned Devices

Ownership

A wireless communication device acquired under this reimbursement method is considered the personal property of the employee and may be used at the employee’s discretion. Any service agreement entered by the employee for the acquisition or operation of the device is a personal agreement between the employee and the service provider. The University assumes no responsibility for, and makes no guarantees regarding, such agreements.

At the employee’s request, the University may provide a letter to a cellular service provider confirming that the device is used for University business, if such a letter enables the employee to receive discounts or University rates. Departments providing wireless device reimbursements must ensure that faculty and staff are familiar with the requirements of this directive.

Determination of Appropriate Reimbursement Amounts

Reimbursement amounts are not expected to cover the full cost of the service plan, as employee‑owned devices are anticipated to be used for both business and personal purposes. The reimbursement must not exceed $50 per month. This amount was determined using a standard rate based on State of Florida wireless device contract benchmarking. The maximum reimbursement amount is equivalent to the cost of providing a university-owned wireless device through these contracts.

UNITS must document:

1. 1. • How the reimbursement amount was determined, and
      • The non‑compensatory business purpose supporting the allowance.

Documentation must be retained in accordance with University recordkeeping requirements and made available for audit or review upon request. The Wireless Service Reimbursement Request form is sufficient documentation for this purpose.

Restrictions

Faculty and staff receiving a monthly communication service plan reimbursement may not receive reimbursement for the same or similar device or service from another University department or component unit.

Monthly communication service plan reimbursements may not be acquired or paid from federally funded projects unless a Cost Accounting Standards (CAS) Exemption Form has been approved by the Division of Sponsored Research for the applicable grant.

Records Disclosure

Employees who elect to receive a wireless communication device reimbursement or allowance should be aware that records related to University business conducted on their wireless communication device may be subject to public records requests.

In some circumstances, personal information or communications maintained on the device may also be subject to review or disclosure if they are commingled with University business or necessary to fulfill a public records request, unless an applicable exemption applies under Florida law.

Monthly Communication Service Plan Reimbursement

This reimbursement provides a monthly allowance for the operation of an employee‑owned communication device and may continue if the UNIT determines that the employee meets the requirements of this directive.

Reimbursement amounts must not exceed established limits.

Procedures for Processing Reimbursements

All payments must be entered in the Accounts Payable system and paid through a voucher process.

The monthly communication service plan reimbursement must be reviewed and entered annually for each fiscal year (July 1 – June 30). The duration of the monthly reimbursement service plan must not exceed 12 fiscal calendar months and must terminate on June 30 of each fiscal year.

UNITS must:

1. 1. Complete the Wireless Device Reimbursement Request Form, including all required signatures.
   2. If the employee is not currently a supplier for the wireless device reimbursement, submit a ticket through the Finance Hub Contact Form and attach the completed Wireless Device Reimbursement Request Form.
   3. Follow the steps outlined in the UF HR Toolkit – Creating a Recurring Invoice
   4. Attach the completed form to the voucher.
   5. Maintain the completed form within the department as documentation for audit purposes.

If changes in the required business use of the communication device occur, modifications may be required. Contact Disbursements with questions.

Resources

Mobile Device Security

Procurement Website

Wireless Device Reimbursement Request Form

Toolkits

UF HR Toolkit – Creating a Recurring Invoice

Contacts

Disbursements: (352) 392-1241

Directive Statement