Due to federal financial aid eligibility for students, UIS instructors must engage in regular and substantive interaction with students in online courses. The definition of distance education from the U.S. Congress and guidance on regular and substantive interaction from the U.S. Department of Education are general and discussed in detail below.
Origin of Regular and Substantive Interaction
In a word: Congress.
"For the purposes of determining institutional eligibility for federal financial aid, Congress created a distinction between the definitions of 'distance education' and 'correspondence education' for purposes of federal financial aid eligibility. The distinction is that distance education courses include 'regular and substantive interaction' (or RSI) whereas correspondence courses do not. Identifying the difference stemmed from concerns relating to consumer protection and potential fraud in correspondence education and the growth of distance education.
What this means is that institutions offering more than 50 percent of their total course offerings via correspondence education or enrolling more than 50 percent of their students in correspondence courses are not eligible to participate in Title IV financial aid programs."Regular and Substantive Interaction from WCET
Congress defined correspondence courses, noting that "Interaction between instructors and students in a correspondence course is limited, is not regular and substantive, and is primarily initiated by the student."
To ensure that UIS degree programs and courses qualify our students for federal financial aid, instructors must initiate regular and substantive interaction with our students.
Defining Distance Education
The U.S. Department of Education issued a definition of distance education in 2021.
The final definition of distance education in 34 CFR 600.2 in its entirety is as follows (emphasis added):
- Education that uses one or more of the technologies listed in paragraphs (1)(i) through (1)(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.
- The technologies that may be used to offer distance education include —
- The internet;
- One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices;
- Audio conferencing; or
- Other media used in a course in conjunction with any of the technologies listed in paragraphs (1)(i) through (1)(iii) of this definition.
- For purposes of this definition, an instructor is an individual responsible for delivering course content and who meets the qualifications for instruction established by the institution’s accrediting agency.
- 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—
- Providing direct instruction;
- Assessing or providing feedback on a student’s coursework;
- Providing information or responding to questions about the content of a course or competency;
- Facilitating a group discussion regarding the content of a course or competency; or,
- Other instructional activities approved by the institution’s or program’s accrediting agency.
- 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—
- 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
- 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.
These items have become known as the "five factors" of distance education:
- Appropriate form of media used. The institution’s online instruction is delivered through an appropriate form of media;
- Instructors must meet accreditation requirements. The instructors with whom students regularly and substantively interact meet the requirements of the institution’s accrediting agency for instruction in the subject matter;
- At least 2 of 5 “substantive” activities are used. Instructors engage in at least two forms of substantive interaction meeting the regulatory requirements for the course or competency;
- There are scheduled and predictable interaction opportunities. The institution has established scheduled and predictable opportunities for substantive interaction between students and instructors and create expectations for instructors to monitor each student’s engagement and substantively engage with students on the basis of that monitoring; and
- Instructor responsive to student requests. Instructors are responsive to students’ requests for instructional support.
What is Regular and Substantive Interaction?
The US provided updated guidance in November 2022 in response to a letter from WCET, OLC, UPCEA, and Quality Matters. The points below outline the combined guidance to this date.
(A) Instructor Qualifications
The instructor meets the "qualifications for instruction established by the institution’s accrediting agency." HLC and program accreditation bodies set instructor qualifications.
(B) "Substantive" interaction
"Substantive" interaction includes at least two of the five practices listed below. Accreditors may approve "other instructional activities" that qualify as substantive.
- “Providing direct instruction;” Direct instruction means "live, synchronous instruction where both the instructor and the student are online and in communication at the same time."
NOTE: Online courses where content is delivered using pre-recorded video lectures do not qualify as direct instruction, but quality online courses can easily meet the substantive interaction standards with the other practices.
- “Assessing or providing feedback on a student’s coursework;”
- “Providing information or responding to questions about the content of a course or competency;”
- “Facilitating a group discussion regarding the content of a course or competency; or”
- “Other instructional activities approved by the institution’s or program’s accrediting agency.”
(C) "Regular" interaction
"Regular" interaction includes both:
- “Providing the opportunity for substantive interactions with the student on a predictable and scheduled basis…”
NOTE: Scheduled "office hours" can fulfill part of the requirement for regular interaction between instructors and students, regardless of whether students choose to participate.
- “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.”
(D) Some questions were not answered
WCET notes that, "Many questions will have to be answered on a case-by-case basis." No new guidance was provided on:
- Determinations about the degree of activity in facilitating group discussions. They would not give set guidelines on how much activity satisfied this requirement of the "substantive" portion of the definition.
- The specific criteria for measuring compliance with the “promptly and proactively” requirement of the "regular" portion of the definition.
- Whether interactions are "commensurate with the length of time and the amount of content in the course or competency."
Definition of Online Learning for UIS
The Higher Learning Commission (HLC) defines online courses as those in which all or the majority (75% or more) of the instruction and interaction occurs via electronic communication or equivalent mechanisms, with the faculty and students physically separated from each other. UIS defines online learning as sections delivered online and asynchronously.
- WCET - Policy Guidance - Regular and Substantive Interaction
- 11/8/2022 - WCET Update - Regular and Substantive Interaction Update: Where Do We Go from Here?
- 8/26/2021 - WCET - Regular and Substantive Interaction Refresh: Reviewing & Sharing Our Best Interpretation of Current Guidance and Requirements
- 4/2/2020 - WCET - New Regulations Review #1: Regular & Substantive Interaction
- 9/30/2016 - Interpreting what is Required for “Regular and Substantive Interaction”
Resources from Other Institutions
- Ohio State - Regular and Substantive Interaction in Online and Distance Learning
- University of Louisville - Regular and Substantive Interaction in Online and Distance Learning
- University of Nebraska Lincoln - Regular and Substantive Interaction in an Online Course
- Regular and Substantive Interaction: Background, Concerns, and Guiding Principles [PDF]
- What Is Regular and Substantive Interaction? The Term that Has Defined Online Learning Still Lacks Clear Definition
- Columbia Gorge Community College - Regular and Substantive Interaction in Your Distance Class
- Regular and Substantive Interaction - An Overview for Instructors of Online Courses at Everett Community College