Regulations from the U.S. Department of Education require regular and substantive interactions (RSI) between instructors and students in distance learning courses. For UIS instructors, this regulation applies to synchronous and asynchronous courses taught in fully online, blended, and hyflex modalities.

The U.S. Department of Education may review distance learning courses at any institution receiving federal funds. Institutions risk losing federal funding, including student federal financial aid eligibility for students, if they fail to meet the RSI requirements. Proposed changes will expand the Department's and accreditation agencies ability to review our offerings.

To maintain accreditation and federal funding, UIS instructors must provide opportunities for regular and substantive interactions with learners at least once per week in 16-week courses and twice per week in accelerated courses.

What is Regular and Substantive Interaction?

Substantive Interaction means engaging learners in teaching, learning, and assessment consistent with the course content. Substantive interactions include at least two of these activities:

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

Regular Interaction requires consistent engagement between the learner and instructor through:

  1. Engaging in substantive interactions on a predictable and regular basis, aligned with the course length and content.
  2. Monitoring the learner's academic engagement and success, and promptly engaging in substantive interaction based on this monitoring or learner requests.

Note: Grading, feedback, assessment, or instruction provided by 3rd party tools (e.g. textbook homework systems), rather than directly from the instructor, do not qualify as substantive interactions.

Regular and Substantive Interactions Must Be Instructor Initiated

To qualify as "regular and substantive," interactions must be initiated by the instructor. This does not mean that learners should be discouraged from asking questions! Rather, instructors should actively initiate interactions with learners throughout the term. Course interactions cannot be optional or left to the learner's discretion; rather, they are an essential component of the instructional plan for the course.

Note: The phrase "instructor initiated" does not mean that students should be discouraged from asking questions!

Examples of Instructor-Initiated Regular and Substantive Interaction

  • Creating discussion questions and actively facilitating conversation
  • Inviting a student to office hours or scheduling a phone call or Zoom meeting
  • Posting personalized comments on individual learner assignments.

Course Interactions that are not RSI

  • A learner deciding to drop by regularly scheduled office hours
  • Entering numeric grades to the gradebook without further comments and feedback.
  • A learner submitting a quiz that is automatically graded.

Frequency and Consistency of Interaction

Interactions should be frequent and consistently repeated throughout the semester. Once the course begins, no more than a week should not pass between interactions initiated by instructors. Consistent engagement ensures that students remain actively involved and supported throughout the course.

  • Frequency: Aim to interact with each learner at least once per week. In accelerated courses, interactions should occur at least twice per week. This does not necessarily mean daily communication but ensures regular touchpoints.
  • Consistency: Establish a regular pattern of interactions. Logging into the course every 1-2 days allows for timely responses and ongoing engagement. The method of interaction can vary (e.g., announcements, discussions, review sessions) but should be consistently applied throughout the course.

Examples of Frequent and Consistent Instructor-Initiated RSI:

  • Conduct bi-weekly, one-hour online review sessions to offer real-time interaction and clarify course materials.
  • Regularly share course-specific announcements and updates that align with learners’ progress.
  • Actively facilitate required online discussions for each course unit to maintain ongoing engagement.

Examples of Infrequent and Inconsistent Interactions:

  • Offering learners an optional, one-time online review session before the final exam without any other regular contact.
  • Sending a welcome message at the start of the course and a mid-semester update around week seven with no other interactions in between.

Focus on the Subject of the Course

Most interactions should be directly related to the course subject and aim to enhance student understanding of and progress toward the course objectives. Routine procedural interactions are necessary, but they must be complemented with interactions that lead to increased academic performance.

  • Engagement: Make the subject more relatable for students by using examples, case studies, and other real-world applications .
  • Relevance: Design interactions that are pertinent to the course content and deepen learners' ability to understand and apply key concepts.
  • Feedback: Feedback on assignments and assessments should be detailed and constructive and guide students on how to advance in their studies.

Examples of Course Subject Instructor-Initiated RSI:

  • Sending messages that preview upcoming concepts and pose questions for learners to consider as they engage with course materials.
  • Posting real-world examples in discussions, such as illustrating the concepts of friction and gravity in physics through recent sports events, to make abstract ideas more tangible.

Examples of Non-Course Subject RSI:

  • Sending reminders to learners about administrative matters, like the attendance policy.
  • Sharing announcements about assignment deadlines without additional substantive content.
  • Participating in non-academic discussions, such as personal commentary on events unrelated to the course subject.

The Details: Definitions, Regulatory Language & History

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 in the accordion 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):

  1. 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.
  2. The technologies that may be used to offer distance education include —
    1. The internet;
    2. One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices;
    3. Audio conferencing; or
    4. Other media used in a course in conjunction with any of the technologies listed in paragraphs (1)(i) through (1)(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 the 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—
    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.
  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—
    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.

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. 

  1. “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. 
  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.”

(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.

Resources

WCET Resources

Resources from Other Institutions