2329 Mobile Device Guidelines

Document purpose

To govern University payments for the purchase and use of cellular telephones. For the purpose of this policy, the term "University" also includes the Health System.

effective

November 2006

revised

September 2024

Reviewed

September 2024

Responsible Office

Comptroller

Approval

Comptroller

Scope

These guidelines apply to all University and UPHS faculty and staff. They serve as a framework for schools and centers to incorporate into their policies to meet the University’s obligation to comply with Internal Revenue Service (IRS) requirements. Individual schools and centers may adopt mobile device policies that are more, but not less, restrictive than the below guidelines. Schools and centers should exercise caution in extending a University-provided mobile device as a nontaxable benefit. Inappropriate characterization of a taxable benefit as nontaxable may result in additional taxes and penalties applied to the school or center.

Guidance

  1. A mobile device is a cell phone or other device capable of connecting to the institutional network and storing data. All mobile devices used to access University data must comply with the IT Security Policy.

  2. Devices Provided by the University of Pennsylvania

    1. The University may issue mobile devices to employees whose school or center can justify a substantial business reason for doing so. A written justification of the business reason must be provided in advance by the requester through the appropriate Business Administrator to either the Dean or Vice President, as appropriate, for their written approval. Grant or contract funds may not be used to cover the purchase or installation of any equipment or device unless specifically authorized in the grant award and approved, in advance, by the Office of Research Services. The “Wireless Communication Device University Equipment or Plan/Request Change Form” must be completed for each individual receiving a University-provided device and this form must be maintained by the department, School, or Center.
    2. Taxability: The value of University-provided mobile devices can be excluded from the employee’s wages if there is a substantial business reason relating to the employer’s business. Any mobile device provided to an employee without a substantial business reason is additional compensation and must be reported to the Payroll Office for imputed income purposes. University-provided mobile devices must be returned to the employer upon separation of the employee in order to be excluded from employee wages. Reimbursement for cellular service on University-provided devices is also excludable from wages
  3. Allowance for Personal Cellular Service Plan

    1. Schools and centers may provide a taxable allowance for the business use of personal cellular devices. The employee’s school or center is responsible for determining the employee’s eligibility to receive a cellular service plan allowance based on job responsibilities. The employee engages their service provider directly and is responsible for all payments to the provider. Determination of the dollar amount of the allowance is made at the department level but should not exceed $50 and should be preapproved by Human Resources. The “Wireless Communication Device Allowance Request/Change Form” should be completed to document the business justification for the allowance and should be attached the employee’s record in Workday.
    2. Taxability: This allowance is processed through Payroll as taxable income but is excluded from base pay for retirement and other benefits. The total allowance received during the year is reported on the employee’s W-2 form.
  4. The employee may receive either a University-provided device and plan or an allowance for the use of their personal device, but not both.

  5. Employee Discounts

    All University employees are eligible for discounts on their personal cellular service plans through the University’s negotiated rates, whether they are eligible for an allowance or not. Visit the Cellular Services page for more information.

  6. Auditability of Charges

    Schools and centers should review device and allowance recipients annually to ensure compliance with established policies and procedures.