Regular Substantive Interaction | Center for Excellence in Teaching and Learning

What is Distance Education?

To paraphrase from the US Department of Education, Distance Education is education that uses specific technologies to deliver instruction to students who are separated from the instructor(s) and to support regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously.

This definition was updated effective July 1, 2021 to distinguish Distance Education from correspondence courses. Distance Education, unlike correspondence courses, includes "regular and substantive interaction." GHC is not authorized to provide correspondence courses. Doing so may jeopardize its access to federal financial aid such as Pell Grants.

Do hybrid courses count as distance education?

What is Regular Interaction?

The Department of Education's definition in Chapter 34, §600.2 continues: "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" meeting both of the following requirements:

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

Examples

Instructor Communication Policy
- addresses how to contact instructor (e.g., D2L or highlands email; phone; office location)
- specifies response time to student questions (24-48 hours M-F; specify weekend policy)
- specifies what level of feedback students can expect on various assignments, including a timeline of when to expect feedback
Modeling Communication Practices
- instructor clarifies and models appropriate online communication practices
- instructor posts etiquette policy and clear expectations regarding how students should adhere to it
- instructor consistently communicates respectfully and acknowledges the broad range of perspectives found in the class
Expectations for Student Participation
- general statement of nature and frequency of student participation
- specific guidelines and evaluation criteria anywhere students expected to actively participate
Instructor Presence
- instructor writes in first-person where appropriate to establish their voice in course materials
- students see evidence of instructor activity at multiple points each week such as:
  - posting regular announcements specific to each section of a class, beyond calendar reminders
  - adding materials
  - guiding discussions with follow-up questions and responses to questions
  - providing personalized and constructive feedback on assignments, discussions, etc. that guides students to further knowledge and/or skills, identifying what has been done correctly or what may need improvement
  - offering online meetings or chats focusing on course material and/or addressing student questions

How much interaction is required?

According to a March 2022 letter from the Department of Education, this must be determined by institutions on a "case-by-case basis depending on the specific circumstances of the situation" (pg. 3). At GHC these determinations will be made by each school and/or department. Contact your Chair or Dean for the standards for your discipline.

Can office hours fulfill part of the requirement for regular interaction?

Yes. In the preamble to the September 2, 2020 final regulations, the Department of Education stated that an institution could meet the requirement to provide the opportunity for substantive interactions "if instructors made themselves available at a specific scheduled time and through a specific modality (e.g., an online chat or videoconference) for students to interact about the course material, regardless of whether the students chose to make use of this opportunity or interact with the instructor at the scheduled time” [85 FR 54760]. A March 2022 letter from the Department of Education clarified that because "office hours" fall into this category, they "could fulfill part of the requirement for regular interaction between instructors and students."

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."

Examples

Monitoring Student Interactions
- instructor intervenes immediately if inappropriate communication occurs
- instructor appropriately redirects or counsels students
Guidance of Student-Student Interactions
- instructors take a strategic role in guiding, focusing, and encouraging student-to-student interactions to deepen understanding of course materials
- student roles in collaborative projects are clearly defined
Time Management Tools
- instructor gives clear directions on where to find current due dates
- course calendars, checklists, or instructor reminders provide students with a way to keep track of time-sensitive tasks
- course schedules organized by week that include topics, assignments, and due dates
- weekly announcements with reminders of upcoming deadlines keep students updated and on task
  - Note: Such weekly time management announcements by themselves are not sufficient to demonstrate instructor presence. Announcements should include content unique to each section and term.

What is Substantive Interaction?

Chapter 34, §600.2 continues: "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

What is direct instruction?

A March 2022 letter from the Department of Education clarified that direct instruction "means live, synchronous instruction where both the instructor and the student are online and in communication at the same time" (pg. 5). This definition does not prohibit the use of asynchronous video lectures in online courses. Asynchronous videos can still add value to online courses. However, they cannot be used meet RSI requirements.

2. Assessing or providing feedback on a student's coursework

Examples

Personalized, Specific Feedback
- provides information students can use to understand where they are succeeding and where they need to improve
- assessment instruments (e.g., rubrics) are supplemented with feedback about key elements of an individual student’s work
- may include:
  - participation in discussion boards
  - recorded tutorials in response to student questions
  - D2L personal chat to groups of students offering further study guidance for topics with which they are struggling
  - comments on essays, tests, assignments, etc.
  - study guides or review sheets created in response to student questions
Frequent and Timely Feedback
- individually focused and provided at least once a week during the course, starting in week 1
- early enough and with sufficient frequency for students to correct misunderstandings and deepen comprehension while the course is in progress
- instructor consistently responds to student questions within the timeframe stated in their communication policy, or alerts students ahead of time if they will not be able to uphold their policy
- instructor makes a special effort to communicate with struggling students as they are likely to benefit from early intervention
- course gradebook is accurate and up-to-date to help students self-assess their learning progress and possible need for guidance outside the course activities

Does automated grading count as feedback?

No. According to a March 2022 letter from the Department of Education, "The Department does not consider a grade on an assignment to be 'substantive interaction' unless the instructor evaluates the student’s work and provides specific feedback to the student about that work. An automated grading system that provides feedback based on a programmed response to input does not count as 'substantive' because it is interaction with a computer, not an instructor" (pg. 5).

3. Providing information or responding to questions about the content of a course or competency;

Examples

Course Welcome Message or Video
- available when the course opens
- sets a warm, welcoming tone by using the instructor's voice and/or image
- addresses course content, what students can expect, tips for being successful in the course, etc.
- unique to each course in a term or session
Week 1 Instructor Activity
- instructor accesses the course to respond to student questions in D2L discussion at least three times in the first week
- first access no later than first day
Weekly Announcements
- regarding course content, expectations of students, tips for success, etc.
Public Forum for Student Questions
- D2L discussion forum for students to post course-related questions
- available to all students in the course so all may benefit from instructor responses
- instructor answers questions in a timely fashion, according to communication policy
- instructor posts clear guidelines for forum usage, including policy for messages of a personal nature
Instructor Responses
- guiding discussions with follow-up questions and responses to questions
- providing personalized and constructive feedback on assignments, discussions, etc. that guides students to further knowledge and/or skills, identifying what has been done correctly or what may need improvement
- offering online meetings or chats focusing on course material and/or addressing student questions

4. Facilitating a group discussion regarding the content of a course or competency; or

Examples

Asking follow-up questions to students’ posts about course content on a discussion board
Course materials (document, audio, or video) that facilitate interactions between student(s) and instructor(s) and require students to contact the instructor or participate in an online discussion moderated by the instructor
Online meetings or chats focusing on course material and/or addressing student questions

How active must discussion facilitation be?

Each school and/or department has specific guidelines for instructors to follow. Contact your Chair or Dean to see what the standards are for your discipline.

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

What counts as approval of "other instructional activities" at GHC?

According to a March 2022 letter from the Department of Education: "A letter from an accrediting agency that approves one or more activities for purposes of the definition of 'substantive interaction' would be sufficient to demonstrate that the accrediting agency had approved those practices. If an accrediting agency is unwilling to provide specific documentation of its approval of institutional practices, then the 'approved practices' would only be those that the accrediting agency had included in its general published policies" (pg. 6). Our accrediting agency is SACSCOC. If GHC were to receive SACSCOC approval for additional instructional activities that would qualify for substantive interaction, the Chief Academic Officer at GHC and all Deans would make this approval known and incorporate it into our RSI policies.

RSI Dashboard

The State University of New York: Regular and Substantive Interaction

Resources

Examples above adapted from Blue Mountain Christian University and Georgia State University. These examples do not constitute policy for Georgia Highlands College. The information is provided to help online faculty consider how they might address regular and substantive interaction in their classrooms. Many of the checklist items are well-established as best practice for online course design and delivery.