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Regular and Substantive Interaction

What is RSI?

RSI stands for Regular and Substantive Interaction. It is part of the new definition of distance education from the US Department of Education and is the difference between online courses (distance education) and correspondence courses. While this new definition was released in July 2021 (34 CFR 600.2), the higher education community asked questions and requested guidance in the past year. In October 2022, the US Department of Education responded and provided clarity on this topic as well as what higher education institutions would need to do to be compliant. A critical aspect of this issue is that students can use Federal Financial Aid (Title IV) for distance education courses that include “regular and substantive interaction” but can not for correspondence courses.  

What is the final definition of distance education in 34 CFR 600.2?

  1. Education that uses one or more of the technologies listed in paragraphs (2)(i) through (2)(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 —
    1. The internet;
    2. One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices;
    3. Audio conferencing; or
    4. Other media used in a course in conjunction with any of the technologies listed in paragraphs (1)(i) through (1)(iii) of this definition.

  1. For purposes of this definition, an instructor is an individual responsible for delivering course content and who meets the qualifications for instruction established by the institution’s accrediting agency.

  2. 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;
    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.

  1. An institution ensures regular interaction between a student and an instructor or instructors, 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.

 

RSI Guidance for Faculty