Regular & Substantive Interaction
Regular and Substantive Interaction (RSI) differentiates distance education from correspondence education. Clarity with understanding RSI is critical since it can impact federal financial aid eligibility for courses and competencies in the United States.
The Final Rules on Distance Education and Innovation were issued by the U.S. Department of Education on September 2, 2020 and went into effect July 1, 2021.
NC SARA (2020) highlights five critical factors that distinguish distance education and correspondence education. Additionally, NC Sara provides a break down of how the US Department of Education defines both "regular" and "substantive."
"Distance education and correspondence education are more clearly distinguishable through five critical factors:"
Distance education should be delivered through an “appropriate” form of online media.
Distance education must use instructors that meet accreditor requirements for instruction in the subject matter.
There should be at least two forms of substantive interaction (see below).
There must be “scheduled and predictable” opportunities for instructor/student interaction (see below).
Instructors must be responsive to students’ requests for support. (NC SARA, para. 7)
“Regular and Substantive Interaction” in distance education such that “regular” is defined as taking place on a “predictable and scheduled basis” and “substantive” means students are engaged through teaching, learning, and assessment as well as at least two of these five activities:
providing direct instruction;
assessing or providing feedback on a student’s course work;
providing information or responding to questions about the course content 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. (NC SARA, para. 3)
The definition for distance education, which includes regular and substantive interaction, was published on the Federal Register on September 2, 2020 and went into effect July 1, 2021.
(1) Education that uses one or more of the technologies listed in paragraphs (2)(i) through (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—
(i) The internet;
(ii) One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices;
(iii) Audio conference; or
(iv) Other media used in a course in conjunction with any of the technologies listed in paragraphs (2)(i) through (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 an 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—
(i) Providing direct instruction;
(ii) Assessing or providing feedback on a student's coursework;
(iii) Providing information or responding to questions about the content of a course or competency;
(iv) Facilitating a group discussion regarding the content of a course or competency; or
(v) 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—
(i) 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
(ii) 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.
Note: Negotiated Rulemaking for Higher Education 2018-19 with links to public hearing, meetings, and sessions.