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Regular and Substantive Interaction Requirements for Online Learning

The RSI guidelines can be complex, so we’ve pulled together exactly what you need to know about regular and substantive interaction for online learning.

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The U.S. Department of Education issued its Final Rule on Distance Education in September 2020, with rules in effect July 1, 2021. These regulations update the definitions of distance education and correspondence learning.

Background on Regular & Substantive Interaction

With the goal of providing more clarity on the differences between these two modes of course delivery, the DoE requires that all online courses for which students may use Title IV funds (federal financial aid) now include regular and substantive interaction (RSI) between instructors and students.

Regular and substantive interaction is one of the key distinguishing elements between distance education and correspondence education and one of the central determinants for using Title IV funds. In addition to RSI, there are other factors distinguishing distance education from correspondence courses. But to keep it easy, we can think of it like this.

For a correspondence course, an instructor will use mail, email, or electronic transmission

to provide students with course materials. Typically self-paced, it’s common for students to be at different stages of the course at any given time — making peer-to-peer communication and collaboration challenging. Instructors may interact with students to provide feedback on an assignment or answer questions via email, but such interaction is limited. Correspondence courses are not eligible for federal financial aid.

For distance education (online and hybrid/blended), instruction is delivered using technology/media and includes regular and substantive interaction between students and the instructor — meaning, interaction between instructors and students is more frequent and can happen in real-time. Throughout the course, students can ask questions, participate in polls and assessments, and contribute to discussions with their classmates. Instructors schedule predictable opportunities for interaction and facilitate more student-to-student interaction.

What You Need to Know about Regular and Substantive Interaction

There are five key criteria to keep in mind when attempting to identify if interaction within a distance education course is regular and substantive. Ask yourself:

  1. Is an appropriate form of media used?
  2. Do the course instructors meet your accrediting agency’s faculty requirements?
  3. Does the instructor schedule opportunities to interact in a predictable cadence?
  4. Are at least two of five substantive activities used?
  5. Are instructors responsive to students?

In the end, the concept of RSI is fairly simple, and aligns with many of the best practices for teaching & learning that most instructors and institutions already follow.

Assignments and learning activities within an online or hybrid course should create opportunities for the instructor to assess learning using substantive or meaningful feedback. Limited feedback, such as posting ‘good job’ or entering a numerical grade would not qualify as substantive. Feedback should be meaningful, both in areas where a student is doing well and where they could improve — both forms helping students stay engaged and motivated to continuously improve.

Meaningful, Scheduled & Predictable Interactions

For the purposes of this article, we’re going to focus on the nature of and level of interaction in an online course.

To be considered substantive, interactions should engage students in meaningful “teaching, learning, and assessment activities, consistent with the content under discussion,” and includes at least two of the following activities:

  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
  5. Other instructional activities approved by the institution’s or program’s accrediting agency

While the kind of activities that would qualify as substantive remain undefined by the DoE, WCET, the leader in the practice, policy, & advocacy of digital learning in higher education, contends that these most likely include synchronous instruction where both the instructor and student are present at the same time but also asynchronous activities, such as participating in discussions, providing feedback, and office-hour interactions in which the instructor talks to the student about coursework.

To be considered regular, the interactions should be scheduled, predictable, and initiated by the instructor.  Interactions with students should be frequently and consistently repeated throughout the semester. It is not strictly required that interactions take place on a weekly basis, but once a course begins, long intervals of time should not pass between the initial instructor interaction with students.

To be scheduled and predictable, course materials should describe the expected frequency of interaction with the instructor, including times and dates of virtual office hours if applicable, grading feedback, announcements, and potential email communications. An example of scheduled and predictable would be to say that a new lesson is released every {insert day of the week} and feedback will be provided to students one week later, or some equally predictable timeframe.

Why Regular and Substantive Interaction Matters

Institutions offering distance education and online courses for which students can use Title IV funds need to make sure they meet the regular and substantive requirements; otherwise, they risk losing funding and could face fines if found non-compliant. But regular and substantive interaction is more than just another federal requirement; it is the foundation of effective online teaching and learning.

Like in-person classroom learning, regular (frequent, consistent) and substantive (meaningful) interaction in the form of discussion, collaboration, feedback, and other learning activities impact a student’s engagement in the course. Studies show that engagement remains a leading indicator for student success when it comes to retention and advancement.

  • Students who are highly engaged are 1.5 times more likely to complete a degree. Svanum and Bigatti (2009)
  • Engaged students, on average, require one fewer semester to complete their degree. Svanum and Bigatti (2009)
  • Students who actively participate are more motivated (Frisby & Myers, 2008; Junn, 1994), engage in more critical thinking (Garside, 1996), and show improvement in communication skills. (Dancer & Kamvounias, 2005)

Unlike in-person classroom learning, online learning presents distinct barriers to participation and student engagement, amplified by the actual distance between the learners, their peers, and the instructor. Those barriers include:

  • the often transactional delivery of material
  • a lack of built-in connection and communication with others
  • less opportunity to build classroom community

As a result, students in online courses can experience a growing sense of isolation, which often inhibits performance and shows itself in the form of declining engagement and retention. Student success is at the core of RSI and presents an opportunity to operationalize online student engagement.

Strategies for Including RSI in Course Design & Delivery

Regulations don’t dictate what activities to use and how often to include them to be considered regular and substantive interaction. Rather than overly prescriptive, the regulations can be viewed in terms of a scale, allowing flexibility and creativity when designing online courses.

There are many strategies for incorporating RSI in online courses through course design and delivery. Course delivery components can be designed in advance and added as elements to guide instructors’ interaction with students. A solid mix of design and delivery components can help you achieve RSI — and in the process, address many of the common barriers to online student engagement.

Course Design and Delivery Elements

  • Courses include the option and tools needed for instructors to hold optional virtual office hours.
  • Syllabi include clear expectations for interactions, how frequently students can expect to hear from the instructor, and how quickly they can expect a response to questions and to work they submit. Any synchronous meetings/requirements can be identified in the syllabus, detailing the preferred method of communication. Participation expectations for students can be included as well.
  • Courses include easily accessible instructor contact information with instructor name, email, and preferred phone number.
  • Courses include announcements that offer one-way, public communication from instructor to students. Courses can include recommended announcements written by the course developer to provide additional guidelines for instructors teaching the course for the first time.
  • Q&A forums are included in the course for students to openly ask questions about the weekly course material, answered by the instructor and/or other students. Instructors should encourage students to use the forum and regularly check for questions and provide responses.
  • Courses include at least one high-engagement activity within the first two weeks of class, allowing students to get to know one another and begin to build community. Consider an icebreaker discussion in which students introduce themselves via video or at the first synchronous session.
  • Instructor-facilitated discussions can be included throughout the course and applicable to the course context and outcomes. The discussions are designed to allow for the instructor to engage with students, and students to engage with each other. Instructors regularly post to course discussion forums to pose guiding questions related to the course subject, propose alternative points of view students may not be considering, establish connections among student’s ideas, and provide encouragement.

To keep discussions varied and engaging, consider different discussion response techniques such as individual responses, summary responses, student-facilitated discussions, and posting an announcement with new ideas, most common misconceptions, and counterpoints.

  • Learning activities/assessments that require timely instructor feedback via detailed rubrics and written comments.
  • A survey midway through the course that provides instructors with feedback as to the content of the course, issues with concepts or assignments, need for additional resources, etc. You can also achieve this with ongoing class polls. Instructors review the survey or poll responses from students and can make adjustments as the course moves forward.
  • Courses include recorded lectures that are accompanied by discussion forums or other activities allowing students to engage with the instructor about the content of the videos.
  • To be able to deliver these things, courses should use online tools, like discussion & collaboration tools within their LMS, and support environments that make interactions easy and documentable.

Technology Considerations for RSI

While the DoE has stated that it does not expect institutions to document the exact amount of time spent on any substantive interaction, it is recommended that institutions document any policies, procedures, or actions taken to establish expectations around instructors substantively and regularly interacting with students.

A suite of discussion and collaboration tools can help with this. With tools that can effectively facilitate chat, surveys, polls, Q&A, discussions, and all sorts of synchronous and asynchronous online learning activities, you’ll have a record of instructor and student interactions. What’s more important, you’ll have clear indicators for when RSI can benefit students the most.

For example, what if you knew which students in an online course were struggling or needed more attention? What if you could tell which topics and activities worked best? If you could track the engagement of students over time? When you have access to engagement insights right from the very tool that powers the interactions of your online course, you’ll enable instructors with the data they need to initiate outreach to the students who need it most.

RSI Resource Kit

For other helpful resources on RSI, we’ve compiled this list below. And if you’re exploring ways to leverage tools within your LMS to better engage students, drive RSI, and further support student success, we’d love to connect with you.