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Regular and Substantive Interaction

As per UHD's Online Education Policy "faculty teaching in an online course section must have regular and substantive interactions with students throughout the term in compliance with the Title IV requirements."

This webpage is a resource that provides the official regulation language and identifies the strategies that you can employ to ensure compliance in your online courses. While there are multiple strategies for you to choose from, please review your online course designs to be deliberate in including and maintaining these strategies. 

While regular and substantive interaction (RSI) includes many best practices you are employing in your courses, the US Department of Education has recently provided guidance on what constitutes regular and substantive interaction between students and instructors. UHD online courses must meet these guidelines to ensure that they are financial-aid eligible; the goal of the guidance is to more clearly distinguish "distance education courses" from "correspondence courses" which are not DOE financial-aid eligible. 

The primary requirements for RSI are as follows

  • Engagement must be faculty-initiated (e.g., individualized emails about progress; scheduled office hours)
  • Engagement must be regular, scheduled, and predictable (e.g., sending weekly announcements with reminders of upcoming work, regular discussion responses)
  • Engagement must be substantive, focused on the course subject or content (e.g., offering reading questions for chapters; providing an instruction video to describe an assignment)

Additional resources and guidance will be developed in consultation with faculty and academic leadership. 

Overview and Definitions:

The U.S. Department of Education issued Final Rules on Distance Education and Innovation in September 2020, with the rules going into effect on July 1, 2021. The new regulations update the definitions of distance and correspondence education to provide more clarity on the differences between these two modes of course delivery. The U.S. Department of Education requires that all online courses for which students may use Title IV funds (federal financial aid) include regular and substantive interaction (RSI) between students and instructors. RSI is one of the key elements distinguishing distance education from correspondence education and thus one of the central determinates for students’ ability to use Title IV funds.

According to the United States Department of Education's Regulations on Distance Education and Innovation (pages 338 & 339), the updated definitions are as follows:

Correspondence Education:
Correspondence education is comprised of correspondence courses which are defined by the US Department of Education as,

  1. A course provided by an institution under which the institution provides instructional materials, by mail or electronic transmission, including examinations on the materials, to students who are separated from the instructors. Interaction between instructors and students in a correspondence course is limited, is not regular and substantive, and is primarily initiated by the student.
  2. If a course is part correspondence and part residential training, the Secretary considers the course to be a correspondence course.
  3. A correspondence course is not distance education.

Distance Education:
Distance education is comprised of distance education courses which are defined by the US Department of Education as,

  1. Education that uses one or more of the technologies listed in paragraphs (2)(i) through (iv) of this definition to deliver instruction to students who are separated from the instructor or instructors and to support regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously.
  2. The technologies that may be used to offer distance education include—

    3. (i) The internet;
    (ii) One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices;
    (iii) Audio conference; or
    (iv) Other media used in a course in conjunction with any of the technologies listed in paragraphs 2(i) through (iii) of this definition.

  3. For purposes of this definition, an instructor is an individual responsible for delivering course content and who meets the qualifications for instruction established by an institution's accrediting agency.
  4. For purposes of this definition, substantive interaction is engaging students in teaching, learning, and assessment, consistent with the content under discussion, and also includes at least two of the following—

    5. (i) Providing direct instruction;
    (ii) Assessing or providing feedback on a student's coursework;
    (iii) Providing information or responding to questions about the content of a course or competency;
    (iv) Facilitating a group discussion regarding the content of a course or competency; or
    (v) Other instructional activities approved by the institution's or program's accrediting agency.

  5. An institution ensures regular interaction between a student and an instructor or instructors by, prior to the student's completion of a course or competency—

    6. (i) Providing the opportunity for substantive interactions with the student on a predictable and regular basis commensurate with the length of time and the amount of content in the course or competency; and
    (ii) Monitoring the student's academic engagement and success and ensuring that the instructor is responsible for promptly and proactively engaging in substantive interaction with the student when needed on the basis of such monitoring, or upon request by the student.


Substantive Interaction:
Substantive interaction is engaging students in teaching, learning, and assessment, consistent with the content under discussion, and include at least two of the following:

  1. Providing direct instruction;
  2. Assessing or providing feedback on a student’s coursework;
  3. Providing information or responding to questions about the content of a course or competency;
  4. Facilitating a group discussion regarding the content of a course or competency; or
  5. Other instructional activities approved by the institution’s or program’s accrediting agency.

Regular Interaction:
An institution ensures regular interaction between a student and an instructor or instructors by, prior to the student’s completion of a course or competency:

  1. Providing the opportunity for substantive interactions with the student on a predictable and scheduled basis commensurate with the length of time and the amount of content in the course or competency; and
  2. Monitoring the student’s academic engagement and success and ensuring that an instructor is responsible for promptly and proactively engaging in substantive interaction with the student when needed on the basis of such monitoring, or upon request by the student.

Examples of Regular and Substantive Interaction for Instructor of Record:

  • Participation in regularly scheduled learning sessions (where there is an opportunity for direct interaction between you and the student).
  • Provide personalized comments (in any medium) for an individual student’s assignment or exam.
  • Actively facilitate an online discussion.
  • Instructor posts announcements, email, or social media check-ins about academic aspects of the class.
  • Provide an overview video to accompany recorded lectures.
  • Identify students struggling to reach mastery through observation of discussion activity, assessment completion, or even user activity and offer additional opportunities for interaction.
  • Use small working/study groups that are moderated by the instructor
In general, RSI simply highlights best practices in online instruction. Design your courses from the ground up and ensure that your syllabus identifies regular due dates, readings, and methods for engagement with faculty members like office hours. Also ensure that some assignments include individualized feedback rather than fully automated grading tools. 

Contact: [email protected]


References:

Policy Matters | Department of Ed Issues Final Rule on Distance Learning, “Regular and Substantive” and Competency-Based Education (August 2020) | UPCEA