• SLD Notice on Deadline Extensions and Funding Priorities
• Form 500s and Form 486s for PY2 Out-of-the-Window Funding
• CIPA Comments: Internet Safety Policy vs. Acceptable Use Policy

The following is a summary of the E-rate News for the Week of July 2, 2001, prepared by E-Rate Central. Official SLD news appears in the "What's New!" section of the SLD's Web site . Additional and archived information appears elsewhere on this Web site.

SLD Notice on Deadline Extensions and Funding Priorities

The SLD's summary of last week's FCC decisions regarding the September 30^th deadline for utilizing non-recurring service discounts and the pro rata PY4 funding for internal connection services has been posted in the "What's New!" section of the SLD's Web site . The same topic was discussed in our E-rate News for the Week of June 25, 2001

Click here to read a copy of the actual FCC Order which the SLD's notice indicated is not yet available.

Form 500s and Form 486s for PY2 Out-of-the-Window Funding

Since PY2 out-of-the-window funding awards were only issued last April, the FCC's deadline extension decision gives applicants until September 30, 2002, to use any grants for non-recurring services. To take advantage of the extension, an applicant may have to extend the termination date of an earlier contract. Once this is done, the applicant should advise the SLD of the contract extension by filing a Form 500.

To fully activate PY2 out-of-the-window funds, an applicant must file a Form 486 to certify receipt of service. If the contract was extended, the Form 500 should be filed first. Applicants who have already filed PY2 Form 486s should be aware that, until very recently, the SLD's system was unable to process out-of-the-window PY2 Form 486s. It may be a few weeks before these Form 486s can be data entered and suppliers can be notified.

CIPA Comments: Internet Safety Policy vs. Acceptable Use Policy

One question we've heard recently from schools is: Can our existing Acceptable Use Policy ("AUP") be used as the Internet Safety Policy required under the Children's Internet Protection Act ("CIPA")?

The answer is "possibly." Unlike the criteria set forth for technology plan approval, there are no specific SLD or FCC guidelines in place for determining the acceptability of a CIPA-approved Internet Safety Policy. So far, and for the foreseeable future, the FCC seems content to simply let E-rate applicants certify that they have an Internet Safety Policy that complies with the CIPA requirements. On this basis, an existing AUP may suffice (assuming it was adopted after a public hearing as required by CIPA).

Applicants seeking greater certainty may want to review and/or rewrite their existing AUPs in light of the following suggestions:

• Since CIPA calls for an "Internet Safety Policy," consider using that title rather than "Acceptable Use Policy."
• Recognize that the filtering provisions of CIPA apply to both minors and adults. Schools and libraries, like many companies and governmental agencies, should consider Internet (and e-mail) policies for their staff as well as for their students.
• Policy discussions of improper use should incorporate specific CIPA language concerning access to material defined as obscene, pornographic, harmful to minors, or otherwise "inappropriate for minors." Improper use should also include hacking, "other unlawful activities," and unauthorized disclosure of personal information.
• Conditions under which filtering can be disabled are an important part of CIPA. Policies should discuss the conditions, and authorization procedures, under which filtering can be disabled for "bona fide research" and educational purposes. Since the E-rate portion of CIPA does not technically provide for disabling filters for minors, it is suggested that such language be broadened to include all actions taken to permit access to any otherwise blocked sites (i.e., a "relaxation," not necessarily a "disabling," of filtering).
• The N-CIPA requirements for E-rate purposes require, but do not define, "monitoring" of online activity. There is no indication that electronic monitoring is required; staff supervision is apparently sufficient. Policies that discuss staff supervision of student Internet use, therefore, may want to refer to both "supervision" and "monitoring" together.

Finally, although not specifically related to CIPA, we have noticed that many older AUPs make only minor references to certain types of inappropriate usage that have become more problematical in schools in recent years. While rewriting policies, it may make sense to expand sections dealing with such issues as plagiarism, use of copyrighted material (by students or staff), and disparagement of students or staff.