THE CHIEF EXECUTIVE OFFICER RECOMMENDS:
That the Chicago Board of Education (“Board”) amend Board Report 05-1116-PO1 the E-Rate Management Policy.
The purpose of this December 2019 amendment is to reflect changes to the E-Rate Management program and to correctly identify the name of the office that centrally manages the program.
The purpose of this Policy is to: (a) require a district-wide application(s) for E-Rate funding in lieu of various individual school applications; (b) identify a central point of management and accountability for E-Rate applications and compliance; (c) identify protocols for the Chicago Public Schools’ participation in the Federal E-Rate program; (d) optimize funding opportunities and maximize participation in the E-Rate program to address the technology needs of Chicago Public Schools; and (e) ensure that schools satisfy the complex rules and compliance requirements associated with E-Rate funding.
E-Rate is a federal program that supports bringing technology to the classroom and is currently administered by the Schools and Libraries Division of the Universal Administrative Company (“SLD/USAC”). Under E-Rate, schools may receive discounts for eligible telecommunications products, services, Internet access, as well as internal connections and managed internal broadband services and basic maintenance for internal connections. Overall nationwide E-Rate annually provides $3.9 billion in technology discounts based on the percentage of students eligible for the National School Lunch Program the school’s location according to the Second Modernization Order approved by Federal Communications Commission (“FCC”). Chicago Public Schools has participated in the E-Rate program since 1998 and has been one of the largest recipients of E-Rate discounts. In previous years, individual schools, along with the District, each concurrently submitted independent applications to receive E-Rate discounts on their eligible technology purchases. Due to program changes, the District has elected to submit a district-wide E-Rate application on behalf of all schools and operating units in the District which aggregates the technology needs of all schools and units into a single application.
- E-Rate Discount or E-Rate Funding — means the percentage of total costs that eligible schools may receive from SLD/USAC to subsidize the acquisition of eligible telecommunication services, Internet access and internal connections and basic maintenance for internal connections as determined by the SLD/USAC in any Funding Commitment Decision Letter (FCDL).
- Non-Discounted Portion — means the portion of the total cost for the acquisition of eligible telecommunication services, Internet access and internal connections, as well as managed internal broadband services and basic maintenance for internal connections not covered by an E-rate funding subsidy as determined by the SLD/USAC in any Funding Commitment Decision Letter (FCDL).
2. General Provisions
- Central Point of Management. Information & Technology Services (“ITS”) shall be the District’s central point of management for all E-Rate related applications and processes for products and services that are designated as E-Rate eligible by SLD/USAC. In addition, ITS shall be responsible for the establishment and maintenance of an equitable E-Rate request process. The centralization of the E-Rate program management by ITS shall not imply that each school’s technology initiatives or services being sought shall receive funding or be deemed eligible for an E-Rate discount by the SLD/USAC.
- Filing of E-Rate Applications. Applications for E-Rate benefits shall be filed on a district-wide basis. No school or unit shall submit an independent application for E-Rate benefits directly to SLD/USAC. Upon request, schools shall timely submit to ITS all necessary data and documentation required to properly complete the District’s E-Rate application(s).
- Documentation. Schools shall maintain up-to-date school improvement plans, which shall include school technology plans, and other necessary documentation, specified by ITS in order for schools to benefit from E-Rate subsidies.
- Compliance. ITS will provide schools with regular information, instructions and guidelines regarding the various compliance requirements associated with the implementation of an E-Rate project. Schools, with the assistance of ITS, shall ensure that that its E-Rate funded products and services comply with E-Rate requirements, rules, regulations and procedures as well as applicable Board policies and rules. In particular, under the federal Children Internet Protection Act (“CIPA”) no school may receive E-Rate discounts unless it certifies that it is enforcing a policy of Internet safety that includes the use of filtering or blocking technology. Schools must protect its students from accessing any obscene, child pornography or other materials harmful to minors on the Internet. ITS shall monitor school compliance with this requirement and shall certify for the District whom is the recipient of E-Rate funding that all schools within the District utilize filtering or blocking technology on any computers used by minors in compliance with CIPA and the Board’s Policy on the Student Acceptable Use of the CPS Network, as amended from time to time.
- Financial. ITS shall periodically evaluate each school’s technology initiatives and services in order to optimize funding opportunities and maximize participation in the E-Rate program. The costs associated with the central administration of the E-Rate Program are assumed by ITS. Individual schools may be responsible for the non-discounted portion of the costs of E-Rate eligible services and/or products or the individual schools’ share associated with new purchases through the E-Rate program as determined by ITS. All requests for E-Rate funding are subject to approval by SLD/USAC.
- Guidelines. ITS will issue guidelines to schools that outline the protocols and responsibilities for projects and initiatives subsidized under the E-Rate program.
|Legal References||Factors which influence this policy include, but are not limited to, various federal statutes governing the E-Rate program, FCC Program Rules, U.S. Code of Federal Regulations, SLD/USAC policy and procedural changes, Board rules, policies and directives, and funding capacities and authorities.|
|Public Comment||Pursuant to Board Rule 2-6 this Policy was subject to Public Comment from 9/27/19 -11/8/19 and adopted at the December 11, 2019 Board Meeting [Board Report 19-1211-PO1].|