1. A method for use in a wireless communications device, the method comprising: communicating, at the wireless communications device, wireless data using universal mobile telecommunications system (UMTS) technology; receiving, at the wireless communications device, a 3GPP radio access bearer has been activated (RABMAS-RAB-ESTABLISH) primitive; generating, at the wireless communications device, a Media Independent Handover (MIH) handover complete event based on the RABMAS-RAB-ESTABLISH primitive; and providing, at the wireless communications device, the MIH handover complete event to an upper layer.