Regular & Substantive Interaction

Although the US Department of Education (US DOE) recently provided updated clarity to the definition of “Distance Education,” there is still confusion around how distance education is evaluated depending on the regulatory purpose or institution. However, it seems clear that the use of regular and substantive interaction (RSI) will provide the appropriate foundation for distance education regardless of the regulatory review.

CGCC’s online courses fall under the definition of “Distance Education” and without regular and substantive interaction (RSI) would be classified as Correspondence Courses which are not an accredited format at CGCC, nor are eligible for financial aid.

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 --

The Internet;
One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber options, satellite, or wireless communications devices;
Audio conferencing; or
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 CGCC 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 July 2, 2021:

Substantive Interaction

Substantive interaction is engaging students in teaching, learning, and assessment, consistent with the content under discussion, and includes at least two of the following:

Providing direct instruction; NOTE: instructor-recorded videos in an asynchronous course do NOT meet the definition of direct instruction.
Assessing or providing feedback on a student’s coursework;
Providing information or responding to questions about the content of a course 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.

NOTE: The institution’s accrediting agency has not 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:

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
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: CGCC is addressing this portion of the definition through the use of Dropout Detective.

RSI Dashboard Illustration taken from SUNY Online RSI Webpage.

What Does Regular and Substantive Interaction Look Like in Canvas?

The following information was compiled by members of the CGCC Online Learning Advisory Council.

NOTE: RSI indicators should be completed in Canvas as it is the institution's official online learning management system. RSI conducted in other 3rd party platforms that would not be accessible by a regulatory official during a review would not meet the requirements.

Assessing or Providing Feedback on a Student's Coursework

RSI Strategies	Recommended Practices
Grade assignments in a timely manner AND provide substantive, individualized feedback in one or all of the following: Comments box in Speedgrader Comments box in the grading rubric These are available in the score column for each criterion OR use freeform comments Provide annotations directly on the student’s submission Mark up their document and provide feedback just as you would by hand	Frequent feedback from the instructor increases learners' sense of engagement in a course. Learners are better able to manage their learning activities when they know upfront when to expect feedback from the instructor. Provide and use grading rubrics for all assignments. Give detailed criterion and rating explanations OR use freeform comments. OR use freeform comments NOTE: Grading rubrics alone would not be considered RSI unless you are entering freeform comments.
Discussion boards Discussions about course content provide an opportunity for instructor feedback during the discussion.	Participate in discussion boards to provide feedback and additional direction during the discussion
FeedbackAnnouncements or pages in the module. The key is that you are obviously engaging with students in a regular and substantive way.	Post regular announcements recapping the module content and providing generalized feedback specific to that course’s students. Add a feedback page recapping the module content and providing generalized feedback specific to that course’s students.
Quiz (formative assessment) Review each student’s submission and provide personalized feedback. Review the quiz statistics to see what questions were missed by several students and address those in generalized	Post regular announcements recapping the module content and providing generalized feedback specific to that course’s students. Add a feedback page recapping the module content and providing generalized feedback specific to that course’s students.
Incorporate student review of instructor feedback into the interaction and grading structure Require the student to review and respond to feedback provided by the instructor on each assignment

Providing Information or Responding to Questions about the Content of a Course or Competency

Examples of this in Canvas

RSI Strategies	Recommended Practices
Post regular announcements introducing module lessons and assignments Be sure to point out any nuances that you want students to pay particular attention to. Incorporate ways for students to indicate they are reading the announcements, such as using the “like” feature or having them email you with specific information.	Content must substantively cover course content; reminders and to-do’s don’t count. There should be opportunities for students to respond or ask questions
Send and respond to content-related emails or Inbox messages from individual students Provide the response via email or announcement to all students when appropriate.	Content must substantively cover course content; reminders and to-do’s don’t count.
Discussion boards Q & A or Water Cooler discussion boards	Providing a space for students to post questions for instructor response.
Provide a detailed syllabus with a Communication Statement indicating how you will interact with students.	Provide all contact-related information including virtual office hours.
Develop an FAQ section related to YOUR course design, expectations, content, and assessments This should complement and provide depth to the information provided in your syllabus
Use automated feedback for formative quiz questions to let students immediately know more about correct and incorrect answers	Providing this immediate feedback for formative assessments meets students where they are. Your follow-up feedback qualifies this as RSI.
Delivery of content (does not count as direct instruction but does count as regular communication if you do it regularly) Post videos, pictures, and audio recordings to supplement content built into the course template	Level up this strategy by having students respond to guided questions while watching a recorded lecture, completing a workbook or online exercise, choosing content from a number of provided aligned options, concept mapping or graphic organizing, etc.

Facilitating a Group Discussion Regarding the Content of a Course or Competency

Examples of this in Canvas:

RSI Strategies	Recommended Practices
Use regular, structured discussion prompts designed to engage students with one another Active instructor participation is what qualifies this as interaction in RSI; provide further question prompts to advance the discussion	Where appropriate, consider making the first response as an example for students In some discussion boards, it is appropriate to respond to each student individually. In some discussion boards, it is appropriate to summarize and post follow-up questions or redirect the discussion. For other discussion boards, it may be most appropriate to provide feedback through Speedgrader while grading the assignment.
Offering regular, scheduled synchronous opportunities for live (virtual) content discussions as a group (Webex)	Even optional synchronous meetings qualify as RSI.
Offering regular, scheduled synchronous office hours for individual students (Webex Office Hours)	Drop-in office hours are even better!

The following are examples of activities that are not considered RSI:

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 without substantive feedback.
A student submits work/assignments/quizzes that are automatically graded by a learning management system or artificial intelligence application.
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.

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.
A clear plan for instructor-learner interaction helps promote substantive interaction between instructors and learners during the course. The plan includes details regarding:
- When learners can expect the instructor's responses to questions.
- At what intervals learners will receive substantive instructor feedback on assignments.
- How the instructor has designed other regular feedback and communication opportunities into the course.

Each semester, online faculty are asked to review their online courses and develop communication plans for implementing Regular and Substantive Interaction (RSI) using the tools provided below. These tools will assist faculty in determining which RSI practices to add to their courses. Please complete the Communication Plan and the Communication Statement within the first two weeks of each semester.

Complete the Self-Review Course Evaluation Checklist (optional).
Complete the RSI Communication Plan (faculty-facing plan).
Complete the RSI Communication Statement in the Concourse Syllabus (student-facing).

When completed, the communication plan can be uploaded via the RSI Plan Form.

Your course may be reviewed as part of the Mock HLC randomly selected audit process taking place each semester. If your course is selected, you will be contacted and invited to collaboratively participate with your ID Fellow.