Regular & Substantive Interaction

Distance Education Definition Clarification

Note: Sharing from our friends at Mesa Community College’s Center for Learning. Thank you MCC!

The US Department of Education (US DOE) provided much needed clarity to the definition for “Distance Education.” MCC’s online courses [same with GCC, including Live Online] fall under the definition of “Distance Education” and without regular and substantive interaction (RSI) would be classified as Correspondence Courses which are not an approved format at MCC [or at GCC], nor eligible for financial aid.

The Definition

Distance education means education that uses one or more of the technologies listed in paragraphs (1) through (4) of this definition to deliver instruction to students who are separated from the instructor and to support regular and substantive interaction between the students and the instructor, either synchronously or asynchronously.

The technologies may include —

1. The Internet;
2. One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber options, satellite, or wireless communications devices;
3. Audio conferencing; or
4. Video cassettes, DVDs, and CD-ROMS, if the cassettes, DVDs, or CD-ROMS are used in a course in conjunction with any of the technologies listed in paragraphs (1) through (3) of this definition.

Note: At MCC [same for GCC] we use the internet as our method to deliver “Distance Education”

The Clarification

Until now, the US DOE provided no clarification for the “regular and substantive interaction…” portion of the definition. The following clarifications from the US DOE went into effect on Jul 2, 2021:

Substantive Interaction

Substantive interaction is engaging students in teaching, learning, and assessment, consistent with the content under discussion, and include 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.

Note: The institution’s accrediting agency has not currently issued any additional approved activities.

Regular Interaction

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.

Importance of Regular and Substantive Interaction

Understanding what constitutes regular and substantive student-instructor interaction is important for several reasons, including:

1. MCC [and GCC] is not accredited to offer correspondence courses. The core feature that distinguishes a distance course from a correspondence course is the presence of regular and substantive student-instructor interaction. If the college is found to have offered correspondence courses, sanctions may be imposed including substantial fines and a requirement to repay millions in federal financial aid dollars.
2. Interaction with faculty and instructional staff is key to establishing a sense of belonging for students at MCC [and GCC or anywhere] and can improve student success.

How To Implement Regular and Substantive Interaction

Regular and Substantive Interaction

• 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.
• Actively facilitate an online discussion.
• Instructor posts announcements, email, or social media check-ins about academic aspects of the class.
• 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 is Not Considered Regular and 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 work/assignments/quizzes that are automatically graded by a learning management system.
• 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.

SUNY Online visual for RSI

Strategies and Ideas

Instructors can use the following strategies and ideas to incorporate regular and substantive interaction:

• Design your course from the ground up to integrate strategic points for instructor interaction.
  • Regardless of modality, have a course schedule that includes written assignment due dates, exam dates, readings, and other assignments as relevant. Ensure that there are predictable opportunities for feedback throughout the semester.
• Develop a communication plan to help guide and manage your interactions.
  • This can be done in your syllabus by setting expectations for instructor response time, grade turnaround time, student participation, and instructor participation.
• Regular and substantive interaction must occur between students and the qualified instructor(s). This may be supplemented, but not replaced, by interaction between students and teaching assistants or other program staff.
  • This can be done with regular substantive academic feedback to all students on all assignments. For example, tell a student why he got a B and what he can do to get an A. Also, use rubrics for grading. Academic feedback does not include reminders about deadlines or other logistical matters. The feedback must go beyond perfunctory comments such as “good job” or “great work.”
  • Regular instructor participation in discussions that deal with academic content. You should constantly provide substantive feedback and facilitate all of the discussions.
  • Regular announcements that offer feedback that are academic in nature.

Note: Do not put interactions in third-party sites, such as MyMathLab or your personal emails; auditors and accreditors will only look inside your course for evidence. Additionally, they do not consider posting lecture videos as interaction.