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The RSI syllabus statement should be included on the syllabus for any course with distance students, which includes hybrid and hyflex courses.

The statement should be personalized to indicate which substantive practices are planned to be utilized in the given course. Federal regulations and accreditation requirements state that a minimum of two substantive practices should be used in all distance courses.

Faculty are required to implement the following language in course syllabi:

To be compliant with federal law and Northwest Commission on Colleges and Universities (NWCCU)
accreditation requirements, ������Ƶ faculty must ensure that all courses where faculty and students are not
physically located in the same space for which students use federal financial aid have regular and
substantive interaction (RSI) between students and instructors. Regular refers to interactions that are
scheduled and predictable. Substantive refers to engaging students in teaching, learning, and assessment,
consistent with course content. As your faculty member, I have included the following actions in the
course to meet RSI requirements: (select a minimum of two below):

• Providing direct instruction
• Providing feedback on student coursework
• Providing course-related information or answering questions
• Facilitating group discussions about content or competencies
• Other instructional activities (please describe)

In the RSI Student Survey, students are asked to self-identify the substantive interactions available to them in their course, whether they have engaged in those activities or not.

Students will receive an email with the link to complete the survey for each of their distance courses with a length of 8 days or longer, with regular reminders sent via email until the survey closes. Surveys are administered using Explorance Blue, the same platform used to administer course evaluations each semester. Survey administration will happen automatically, and instructors will not need to provide the survey to their students themselves.

Students' responses are not anonymous.

Information for Instructors:

• Please remind your students to complete the student survey!
• It is up to your discretion to determine if you would like to offer extra credit to your students or not, but it is encouraged to help incentivize students and improve overall response rates.
• Use the feedback you receive from students to make adjustments to the substantive practices being used in your course and to inform outreach and support to the students enrolled in your course.
• The surveys are administered mid-term to provide information on how your students are progressing in and interacting with your course. This can be a tool for you to improve your course and student outcomes!

Timeline:

• Surveys will open at the 25% point of the course; exact dates may vary depending on the length of the course.
• Surveys will close at the 50% point of the course; exact dates may vary depending on the length of the course or if instructors choose to close the survey for their course early.
• Instructors will be able to view the response reports one day after the survey is closed.

The survey will be presented as a checklist where students are asked to check a box for each of the listed activities they have observed or engaged with in their course.

Student Survey Questions:

1. I have been offered opportunities to meet with my instructor outside of class-time (in-person or online) to discuss the course. This includes your instructor offering by-appointment or drop-in office hours.
2. I receive announcements from my instructor regularly with information such as general course instructions, reminders about upcoming assignments/exams, and/or changes in the course content.
3. My instructor has given me feedback on the work I have submitted that was meaningful and/or helped me understand the grade I received.
4. My instructor has graded my assignments and answered my emails in a timely manner.
5. My instructor has checked in with me (via message or email) or met with me (in-person or online) to talk about how I am doing in this course.
6. My instructor has shared supplementary resources related to the course material that are not listed in the course syllabus. For example, my instructor has shared a news article that relates to class discussions.
7. My instructor responds to discussion board posts with meaningful and thoughtful comments or feedback.
8. I have had a conversation with my instructor about the content of this course through messaging (live chat, email, Canvas) or through video (Zoom, Google Meet) either in class or outside class-time.
9. I was offered an opportunity to attend a learning activity supervised by my instructor and held outside of class-time, such as a study session or a field trip (either in-person or online).

Instructors will receive an email with a link to complete the reflection checklist for every distance course they taught in the given semester. These will be sent through Explorance Blue as well, so they will go out automatically and no other action needs to be taken by instructors, deans, or unit administrators.

Timeline:

• Reflection will be sent out on the last day of term; this is typically on a Friday.
• Reflection will close after 10 days.
• Blue Supervisors (typically deans and unit admins) will be able to view response reports for their unit one day after the reflection closes.

The survey will be presented as a checklist where instructors are asked to indicate which substantive practices they implemented in their course, including anything added or changed in response to the student survey. Additionally, instructors will have an "other" space to add their own responses.

Faculty Reflection Checklist Questions:

1. I have offered opportunities to meet with students outside of class-time to discuss the course, such as holding by-appointment or drop-in office hours. (RSI actions 1, 2,& 3)
2. I have made announcements to the class that include information such as general course instructions, reminders about upcoming assignments/exams, and/or changes in the course content. (RSI action 3)
3. I have given meaningful feedback to students about their submitted assignments that helps the student understand the grade they received. (RSI action 2)
4. I grade assignments and answer emails in a timely manner.  (RSI actions 2&3)
5. I checked in with students (via message or email) or met with students (in-person or online) to talk about how they are doing in the course. (RSI actions 1, 2,& 3)
6. I have shared supplementary resources to the class related to the course material that are not listed in the course syllabus. For example, I shared a news article that relates to class discussions. (RSI action 3)
7. I respond to discussion board posts with meaningful and thoughtful comments or feedback. (RSI action 4)
8. I have had conversations with students about the content of this course through messaging (live chat, email, Canvas), or through video (Zoom, Google Meet) either in-class or outside of class-time. (RSI action 4)
9.  “Other” space for personal entries regarding additional RSI activities implemented in the class.

Context

In order to deliver online education, institutions have always been held to a standard that impacts the ability to distribute federal financial aid to qualifying students. Congress and the U.S. Department of Education (ED) shared regulatory and statutory concerns as more and more students accessed education outside of the traditional brick and mortar classroom. 

Fraudulent use of Title IV funds and concerns over quality led to the development of the 50 percent rule found in the to the – a regulation that disallowed students from receiving federal financial aid if more than half the student population at an institution were enrolled in correspondence courses. The original act was modified over time as technology enhanced the possibilities of distance education. 

Congress differentiated between correspondence courses and distance courses with the distinction of regular and substantive interaction correspondence courses being:

Consequences

Institutional compliance is required and non-compliance can have a variety of consequences, including:

• University fines
• Individual disciplinary action for faculty and or staff
• Loss of the ability to award federal financial aid to students
• Ability to serve U.S. military, veteran, or dependent students
• Ability to offer online education
• Ability to approve new courses and or programs

These are not empty or idle threats.

In September 2020, ED issued a new regulatory action on Distance Education and Innovation that amended the establishing, maintaining, and losing eligibility section of the Institutional Eligibility regulations of the HEA as it relates to distance education and innovation. The rule became effective on July 1, 2021.

The most significant change in this action was clarifying the definitions of distance education and correspondence courses. Distance education supports regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously.

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, based onsuch monitoringor upon request by the student.

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–

• 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.
• Providing direct instruction;
• Assessing or providing feedback on a student’s coursework;
• Providing information or responding to questions about the course or competency; 

At the University of ������Ƶ Fairbanks, RSI with the instructor is essential to differentiate between correspondence courses and interactive distance education courses (online synchronous, asynchronous, and hybrid modalities). This is necessary to comply with federal regulations for financial aid disbursement and .

To address requests for guidance on the Distance Education and Innovation regulations, ED published a in March of 2022 with the following select points of clarification on RSI:

• “Direct instruction” refers to live, synchronous instruction only
• Auto-graded responses do not count as substantive interaction; however providing personalized feedback to students does
• Holding office hours meets the requirement for regular interaction by offering students the opportunity for substantive interaction about a course or competency even if students choose not to participate in the opportunity

Important note about regular interaction: to be fully compliant, interaction must go beyond scheduled and predictable. The regulation highlights monitoring the academic success and engagement levels of students and interacting with themwhen neededas a result of that monitoring. The intent is not to add daily monitoring of each individual student’s activity within an online course on top of normal teaching activities. Rather, to ensure that instructors are aware of whether or not a student is engaged and actively participating in an online course and to take appropriate action to interact with that student as needed.

Examples of this type of monitoring might include:

• Utilizing the “ ” tool in the Canvas Gradebook to reach out to students who meet certain criteria (such as a missing assignment or low grade).
• Encourage participation in campus tutoring services as appropriate
• Review Canvas “ ” on a regular basis
• Issue a alert
• Note any changes to the quality of a student’s assignment submissions
• Evaluate a student’s level of mastery of a concept and provide additional resources

Important notes about substantive interaction: while direct instruction refers to synchronous instruction, online asynchronous courses can still be filled with RSI. Additionally, the regulation requires at least two criteria be used to demonstrate substantive interaction; however the intent is not to have instructors, programs, or even institutions document each and every interaction that occurs in every course. ED clarified in the March 2022 response letter that the expectation is for institutions to establish policies and procedures for RSI that includes regular compliance evaluation in distance education courses.

The ������Ƶ Chancellor’s Policy for RSI is currently being developed and reviewed by governance bodies. Opportunity for feedback will be available through shared governance and specific questions can be directed to CTL executive director, Jenn Pedersen.

ED sought after an audit report determined their courses did not meet the criteria (regular and substantive interaction) to be labeled distance education.

ED determined in a federal audit that to students who were enrolled in similarly mislabeled distance education courses and the college was required to return the full amount.

Accreditation agencies also get involved. Scottsdale Community College’s request for 48 new online programs was due in large part to inconsistent standards in the proposed courses and programs and by a marked lack of faculty training for online instruction.

. (PDF)
OLC. UPCEA. WCET
This in-depth article from three of the major online learning organizations in higher education covers three things:

1. The history of how the HEA has regulated distance education over the past thirty years.
2. Concerns and questions about the new rules from a statutory and regulatory standpoint
3. Principles that guide the advocacy efforts of these organizations.

(PDF)
A straight-forward list that clarifies what type of interactions do and do not qualify as RSI.

Sara Nafzgar and Carrie Patterson at Moreno Valley College share the ways they worked with faculty to ensure accreditation, and how humor and straightforwardness was key to their success.