instructional technology and distance education services

The U.S. Department of Education (ED) has issued Regular and Substantive Interaction: Background, Concerns, and Guiding Principles which go into effect on July 1, 2021. Under the new regulations, the U.S. Department of Education requires that all online courses and programs for which students may use Title IV funds (federal financial aid) include regular and substantive interaction between students and their instructors. This ruling applies to both synchronous and asynchronous courses, with the primary focus being asynchronous courses. The Department of Education has the authority to audit courses and programs at institutions, like Texas A&M International University, with online offerings.

The Department of Education defines “substantive interaction” as engaging students in teaching, learning and assessment, that is consistent with the course content under discussion and includes at least two of the following activities totaling at least 50-60 minutes every week for a 3 credit-hour course in a long fall/spring semester, or a scaled number of minutes for a course with a different number of credit-hours and a shorter or longer semester:

• Attending a synchronous class, lecture, recitation, or field or laboratory activity, physically or online, where there is an opportunity for interaction between the instructor and students;
• Submitting an academic assignment;
• Taking an assessment or an exam;
• Participating in an interactive tutorial, webinar, or other interactive computer-assisted instruction;
• Participating in a study group, group project, or an online discussion that is assigned or led by the instructor;
• Interacting with an instructor about academic matters; and
• Required discussion forum activity associated with the course material.

Instructor Responsibilities

"Regular and Substantive Interaction" 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
• ensure that instructors are promptly and proactively engaging students in substantive interaction
• include at least TWO of the following methods for substantive interaction:
  • direct instruction (i.e., discussion participation, instructor feedback, synchronous lectures, etc.)
  • providing information or responding to questions about course content
  • coursework assessment or feedback
  • facilitating group discussion of the course content
  • other instructional methods to be approved by accreditor
  • Instructors must be able to show evidence of at least TWO of the above methods in their course.
• Examples of RSI include but are not limited to:
  • Participation in regularly scheduled learning sessions (where there is an opportunity for direct interaction between the student and the qualified instructor).
  • Provide personalized comments (in any medium) for an individual student’s assignment or exam.
  • An instructor-moderated online discussion forum.
  • Instructor posts announcements, email, or social media check-ins about academic aspects of the class.
  • Regularly set office hours initiated by the instructor are considered substantive interaction, even if students do not take advantage.
  • 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 of small working/study groups that are moderated by the instructor.

What does not constitute RSI?

• Pre-recorded video lectures available for students to watch at their own pace not associated with an assignment, discussion, quiz, etc.
• Only student-solicited office hours offered.
• A student logging into a live webinar with no opportunity for interaction.
• Asynchronous courses without at least two of the methods listed for substantive interaction.
• Assignment of recorded webinars, videos, and reading materials if the course design does not require the students to review the assigned material and then interact with the instructor
• Contact with instructors not related to the course subject matter.
• Adding numeric grades to the course gradebook.
• A student submits a quiz that is automatically graded.
• Sending a welcome message during the first week of class and another around mid-semester.
• Encouraging students to participate in an optional, one-time online review session before the final exam.
• Reminding students of the course attendance policy.
• Posting an announcement about an upcoming assignment deadline.
• Providing an open-ended online forum that is not moderated by the instructor.

Design Strategies for Including RSI in Your Courses

Course syllabus includes instructors virtual office hours.

Syllabus includes 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 must be identified in the syllabus detailing the preferred method of communication. Participation expectations for students should be included as well.

Course includes easily accessible instructor contact information with instructor name, email, and preferred phone number.

Course includes Announcements that offer one-way, public communication from instructor to students. Course can include recommended announcements written by the course developer to provide additional guidelines for instructors teaching the course for the first time.

“Ask a Question” discussion forum is included in the course for students to openly ask questions about the weekly course material to be answered by the instructor and/or other students.

Instructor encourages students to use the “Ask a Question” discussion forum and regularly checks for questions.

Course includes 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 (I.e., Icebreaker discussion area where students introduce themselves, the first synchronous session where students introduce themselves, etc.).

Instructor-facilitated discussion forums are included throughout the course if 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.

Instructor regularly posts to course discussion forums to pose guiding questions related to the course subject, propose counter points of view students may not be considering, establish connections among student’s ideas, and provide encouragement. Consider different discussion response techniques such as individual responses, summary responses or posting an announcement with the favorite ideas, most common misconceptions, counter points.

Learning activities/assessments that require timely instructor feedback via detailed rubrics and written comments.

Instructor utilizes course rubrics and gradebook written comment areas to provide timely feedback on learning activities/assessments. Feedback should communicate to students both their accomplishments and areas they may need to improve as well as concrete suggestions for actions students can take in the future to make progress in their learning.

Course includes a survey midway through the course that provides instructor with feedback as to the content of the course, issues with concepts or assignments, need for additional resources, etc.

Instructor reviews midterm student surveys to make adjustments to the instruction and conduct edits as deemed necessary.

Course includes recorded lectures that are accompanied by the discussion forums or wikis or other activities allowing students to engage with the instructor about the content of the videos.

Instructor participates in the learning activities that accompany recorded lectures to provide additional instruction and clear up misconceptions.

Course utilizes online tools and environments that make interactions easy to use and easy to document. External platforms are reviewed and scrutinized to ensure the communication and feedback given to students can be accessed after a course concluded.

Instructor utilizes the university approved and supported technology and tools built within the course to ensure that all the instructor-student and student-student interactions are easy to use and easy to document.

Additional Resources:

Negotiated rulemaking for higher education 2018-19. (2020, November 6). U.S. Department of Education. https://www2.ed.gov/policy/highered/reg/hearulemaking/2018/index.html

Poulin, R., & Davis, V. (2019, April 23). Interpreting what is required for “Regular and substantive interaction”. WCET Frontiers. https://wcetfrontiers.org/2016/09/30/interpreting-regular-and-substantive-interaction/

Regular and substantive Interaction: An overview for instructors of online courses at Everett Community College. (n.d.). Everett Community College. https://www.everettcc.edu/files/programs/elearning/Regular_and_Substantive_Interaction_Primer.pdf

Regular and substantive interaction: Background, concerns, and guiding principle. (2018, November 30). https://eric.ed.gov/?id=ED593878

U.S. Department of Education issues final rules on distance education and innovation | NC-SARA. (2020, October 1). NC-SARANC-SARA. https://nc-sara.org/news-events/us-department-education-issues-final-rules-distance-education-and-innovation

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