{"resourceId":"frederick-county-md-regulation-124-01-ai-student-staff-operational-use-20261022","versions":[{"version":"external-fe2a86445bca0ea06a45410bd2fee16d269dcec373ee2b15bd7469340ddec0df","resource":{"id":"frederick-county-md-regulation-124-01-ai-student-staff-operational-use-20261022","title":"Frederick County Public Schools (MD) adopts Regulation 124-01 implementing its student AI ban: approval paths, no AI grading, no detector-led discipline, vendor contract terms","organization":"Frederick County Public Schools (Maryland)","sector":"K-12 district AI regulation: student access, staff and operational use, procurement and data security","geography":"Frederick County, Maryland, United States","publishedAt":"Regulation 124-01 adoption date 10/22/26 (regulation history); Policy 124 revision date 10/22/26","publicationDate":"2026-10-22","eventDate":"2026-10-22","sourceName":"Frederick County Public Schools Legal Services","sourceLabel":"Primary district regulation text (PDF)","sourceUrl":"https://apps.fcps.org/legal/documents/124-01","evidenceClass":"standards-guidance","outcomeClass":"emerging","topics":["governance-procurement","data-security","accessibility-workforce","operating-model"],"finding":"On October 22, 2026, the day of Maryland's AI Ready Schools Act deadline, FCPS adopted Regulation 124-01 and revised Policy 124 to reference it. The regulation keeps the PreK-12 student ban on AI products but defines approval paths: courses where the curriculum office says AI is required, AI literacy lessons, IEP or 504 plans when other assistive technology is unavailable, and other uses approved by curriculum and IT. Approved tools must be on the Approved Digital Tool List and reachable only after sign-in to the FCPS network, with inputs and outputs subject to monitoring. Prohibited uses include entering student or employee PII without a data-sharing agreement, AI making consequential decisions on its own, and staff grading learning tasks with AI outside approved computer-scored platforms. Staff may not rely on AI detectors as the primary integrity tool. Annual AI literacy is required for grades 2-12 and annual role-specific staff training. Procurement must evaluate ten criteria, including whether FCPS data trains vendor models and total cost of ownership; contracts must limit data use and prohibit advertising, profiling and unrelated model training. Operational AI affecting student services must be bias-evaluated before adoption.","sledRelevance":"The most detailed primary implementation text yet from a Maryland district at the state deadline; it turns a headline ban into specific access, procurement, oversight and incident-reporting rules that vendors and integrators will have to meet.","evidence":"Primary regulation text, opened in full. It is a rule set, not an evaluation; no data on usage, approvals or outcomes.","architectureImplications":"Approved AI products are accessible only after sign-in to the FCPS secure network, managed by the IT department, with monitored inputs and outputs; approved tools are flagged on the Approved Digital Tool List. Interpretation: this implies identity-gated access, logging and an allow-list tied to the digital tool approval process.","governanceImplications":"Board policy plus superintendent regulation; curriculum office maintains a list of courses requiring AI; curriculum and IT approve other uses; an advisory group of teachers, administrators, students, union representatives and community members monitors implementation; approval is described as an ongoing process aligned to MSDE rubrics.","securityPrivacyImplications":"No PII into AI products without a legal basis and executed data-sharing agreement; compliance with FERPA, COPPA, PPRA and the Maryland Student Data Privacy Act; staff have no expectation of privacy in prompts; incident reporting for AI errors, unlawful content and suspected breaches; vendor contracts must cover retention, deletion and breach notification.","caveats":"Adopted text only; how approvals, monitoring and enforcement work in practice is not yet known. The regulation's history lists adoption on 10/22/26, but no board minutes or press coverage of the adoption were opened. The earlier Policy 124 adoption (October 7) is already archived; this record covers the new regulation, which is a separate document.","streamIds":["k12"],"roles":{"sales":"Sales framing: Frederick County has turned a broad student AI ban into concrete rules, and the procurement section is the opening. Any AI vendor must document training-data use, retention, limits, accessibility and evaluation, and accept contract terms against advertising, profiling and unrelated model training. A bounded offer is help building the evaluation rubric and approved-list workflow. Do not claim the ban or regulation improves learning, integrity or safety; it is newly adopted text with no results.","engineering":"Engineering framing: approved AI must sit behind FCPS network sign-in with monitored inputs and outputs, and student access is managed by IT for approved purposes only. Pre-sales should confirm single sign-on, logging export, data-processing terms and whether the vendor trains on district data. Proof of value is a tool that passes the ten procurement criteria with documented evidence, enforces grade and course gating, and produces reviewable prompt and output logs.","delivery":"Delivery framing: the regulation creates recurring work, including course approvals, an approved-tool list, annual AI literacy for grades 2-12, annual staff training, bias checks for operational AI and incident reporting. Ownership sits with the curriculum office and IT. Acceptance means the course list, approved-tool list and incident channel exist and are used. Risks are approval backlogs, uneven teacher practice and monitoring obligations outrunning staff capacity."},"roleDetails":{"sales":{"customerProblem":"A district with a student AI ban must now approve, procure and monitor the AI it does allow under detailed rules and limited staff.","stakeholders":["Department of Curriculum and Instruction","Department of Information Technology","Supervisor of Digital Learning Experience","Legal Services","AI advisory group","Special education leaders"],"discoveryQuestions":["How many approval requests are expected this year?","Which tools are already on the Approved Digital Tool List?","How will the ten procurement criteria be scored?","How will monitoring of student inputs and outputs be staffed?","Which operational systems use predictive analytics today?"],"valueHypothesis":"A documented evaluation rubric and approval workflow could make vendor reviews faster and more consistent; no source measures this.","potentialEngagement":"A short engagement to build the AI product evaluation rubric, vendor documentation checklist and approval workflow against Regulation 124-01.","unsupportedClaims":["No evidence the ban or regulation improves learning or integrity.","No usage or approval data.","No cost or time-savings figures."]},"engineering":{"fit":"Fits AI tools that support single sign-on, network-gated access, logging and district-controlled data terms.","architectureIntegration":"Gate approved AI behind FCPS sign-in, roster by course and purpose, export prompt and output logs for monitoring, and flag AI products on the approved tool list.","prerequisites":["Approved Digital Tool List process (Regulation 500-08)","Identity provider and rostering","Executed data-sharing agreements","Logging and retention plan"],"constraints":["Student use only for approved purposes","No AI grading of learning tasks outside approved platforms","No vendor training on district data without contract terms","Maryland and federal student privacy law"],"security":"Block PII entry without agreements, retain monitored logs, report suspected breaches, and contract for deletion and breach notification.","proofOfValue":["Vendor answers all ten evaluation criteria with documents","Access limited to approved courses in a test roster","Logs available for review","Bias check documented for operational AI"]},"delivery":{"work":"Stand up the approval, procurement, literacy, training and incident processes the regulation requires.","dependencies":["Curriculum office capacity","IT monitoring capacity","Vendor documentation","Advisory group formation"],"ownership":"Department of Curriculum and Instruction with the Department of Information Technology.","skillsAdoption":"Annual role-specific staff training and teacher guidance on task design that reduces AI over-reliance without detectors.","governanceCheckpoints":["Course approval list published","Approved tool list review","Bias evaluation before operational AI adoption","Advisory group review","Annual transparency communication to families"],"acceptanceCriteria":["Proposed: approval decisions within 15 school days","Proposed: AI literacy delivered to all grade 2-12 students yearly","Proposed: no integrity finding based mainly on a detector","Proposed: annual family notice lists AI products and data retention"],"risks":["Approval backlog","Monitoring without staff to review","Inconsistent enforcement across schools","Students using unapproved AI off network"]}},"retrievedAt":"2026-10-22T22:09:24-05:00","enrichedAt":"2026-10-22T22:14:26-05:00","enrichmentBasis":"retrieved source","accessibilityWorkforceImplications":"Explicitly preserves AI-enhanced accessibility tools and IEP or 504 use; requires annual staff training and prohibits AI replacing legally required evaluations, services or language access.","procurementImplications":"Ten evaluation criteria, vendor documentation requirements and mandatory contract terms; approval is ongoing, not one-time.","operatingModelImplications":"Curriculum and IT jointly gate student AI, with an advisory group, incident reporting and annual transparency to families.","sourceVerification":{"openedUrl":"https://apps.fcps.org/legal/documents/124-01","referenceExcerpt":"Consistent with guidance from MSDE, staff shall not rely on AI detection tools as the primary means of enforcing academic integrity, given their documented unreliability.","promptVersion":"sled-research-v4.0","model":null,"basis":"agent-reported inspection"}}}]}