In September 2020, the U.S. Department of Education issued Final Rules on Distance Education and Innovation with the rules going into effect on July 1, 2021. The new regulations update the definitions of distance and correspondence education and provide clarification between the differences of these two course modalities. In brief: The DoE now requires that all online courses for which students may use Title IV Financial Aid funds include regular and substantive interaction (RSI) between students and instructors.
What does Middle States say about RSI?
The Middle States Commission on Higher Education removed the 50% requirement for program evaluation in the Substantive Chance Guidelines (pdf). Once distance education is included within the institution’s scope of accreditation, all future accreditation activities will consider distance education as part of the institution’s offerings and teams and peer evaluators will review them. Additionally, on page 6, MSCHE states —
The Commission will evaluate that the institution can demonstrate that it has the capacity to deliver quality courses and programs, that instructors are qualified to deliver courses via the delivery method, and that the institution can support regular and substantive interaction between students and the instructors. The Commission expects that the quality of distance education is equivalent to face-to-face education and should include meaningful interaction, assignments, feedback, and quality instructional time.
Definitions**
An instructor is an individual responsible for delivering course content and who meets the qualifications for instruction established by an institution’s accrediting agency. Eligible programs can be taught by “the instructor or instructors.
A distance education course is one in which instruction is delivered by one or more types of technology, including the internet, various wired and wireless media, or audio conference to students who are separated from the instructor(s). These technologies “support regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously.
Predictable and Scheduled Interaction: Regular interaction requires an institution to ensure, prior to the student’s completion of a course or competency, that there is 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.
The institution also is responsible for 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.
Academic engagement requires active participation by a student in an instructional activity related to the student’s course of study as defined by the institution consistent with any requirements imposed by its state approval or accrediting agency. Academic engagement can include such activities as attending a class where the students and instructor can interact, turning in an academic assignment or taking a test, participating in an interactive computer-assisted instruction, participating in an institutional-directed group activity or online discussion, or interacting with the instructor regarding academic matters.
An emphasis on regular and substantive interaction is entirely consistent with well-documented research-based effective practices in online course design and delivery. In online teaching and learning environments of any kind, (asynchronous, synchronous, blended/hybrid), regular and substantive interactions must:
- Be with an instructor as defined by the institution’s accreditor.
- Be initiated by the instructor.
- Be scheduled and predictable.
- Be academic in nature and relevant to the course.
Substantive interaction assumes direct interaction between the learner and the instructor and requires direct instruction from the instructor including:
- Assessing or providing feedback on a student’s coursework.
- Providing information or responding to questions about the content of a course.
- Facilitating a group discussion regarding the content of a course or competency.
- Other instructional activities approved by the institution’s or program’s accrediting agency.
Promoting & Supporting RSI
A focus on Regular and Substantive Interaction aligns with effective practice in online course design and delivery, student learning, and student success in online learning.
Instructor Initiated Contact
To ensure interactions are not optional and left up to the student’s discretion, the instructor should expect to take an active part in initiating and guiding a range of interactions with the students throughout the semester.
- Examples: Individualized emails, instructor-facilitated discussions, scheduled virtual office hours, personalized feedback on assignments
Regular, Scheduled, and Predictable Contact
Interactions with students should be frequently and consistently repeated throughout the semester. Long intervals of time should not pass between the initial instructor interaction with students. To be scheduled and predictable, course design materials should describe the expected frequency of interaction with the instructor, including times and dates of the virtual office hours if applicable and potential email communication.
- Examples: Weekly course announcements written specifically for the course, weekly summaries or highlights of discussion posts, regularly scheduled online review or help sessions, grading feedback
Substantive Interactions
Interactions should be connected to the subject of the course and contribute to the students’ progress toward course, program, and college learning objectives. Routine procedural interactions, such as reminders of upcoming deadlines or activities like assigning grades are not ‘substantive’ on their own unless they are accompanied by personalized feedback or suggestions for improvement.
- Examples: Announcements previewing or reviewing difficult content, emails previewing concepts introduced in the next unit, listing questions for students reflect on when reading the textbook chapters
Example of Course Design & Delivery Strategies (from SUNY Empire State College)
The DoE regulations do not dictate what activities to use and how often to include them in the course to meet the RSI requirement. However, the regulations allow flexibility when we design and deliver our courses. For example:
| Activity | Adding RSI |
| Watching recorded lectures | Follow up with discussions on topics and issues raised in videos |
| Auto-graded quizzes without personalized feedback | Provide summary of most common mistakes and offer additional instructional support or ways for students to reach out with questions |
Citations & Attributions:
* Regular and Substantive Interaction documentation taken/adapted from the WCET Policy Playbook.
** The RSI graphic illustration and some content has been adapted and is used with the permission of the SUNY Online Team.
*** Retrieved from Regular and Substantive Interaction: Regulatory & Pedagogical Implications presentation by WCET.