Regular and Substantive Interaction (RSI) Compliance Statement

INTRODUCTION

The U.S. Department of Education mandates that all online courses eligible for Title IV federal financial aid ensure Regular and Substantive Interaction (RSI) between students and faculty. This requirement applies to all institutions receiving federal funds, and the Department retains the authority to review distance education offerings to verify compliance. To maintain accreditation and federal funding, John Wood Community College (JWCC) instructors must engage in regular and substantive interaction with students in online courses. JWCC is fully committed to adhering to all federal regulations regarding RSI and affirms its responsibility to provide high-quality distance education in full compliance with these standards.

For historical context, federal RSI regulations were developed to address concerns related to consumer protection, academic quality, and the potential for fraud in correspondence education, especially as distance learning expanded.  As distance learning became more prevalent, Congress established regulatory definitions to differentiate between ‘distance education’ and ‘correspondence education’ for purposes of federal financial aid eligibility. The key difference lies in the presence of RSI: distance education includes regular and substantive interaction between students and instructors, while correspondence education does not.

According to the U.S. Code of Federal Regulations (34 CFR § 600.2), a correspondence course is defined as one in which “Interaction between instructors and students in a correspondence course is limited, is not regular and substantive, and is primarily initiated by the student.” From this definition, it is clear JWCC does not offer correspondence courses.

John Wood Community College delivers online courses exclusively through distance education and not through correspondence education.  To ensure the continued eligibility of its programs for federal financial aid, JWCC instructors are expected to initiate and maintain regular and substantive interaction with students. All courses are designed to ensure there is regular and substantive interaction between students and instructors, and the college has implemented policies, procedures, and expectations to ensure compliance with federal regulations governing regular and substantive interaction.

REGULATION LANGUAGE

U.S. Department of Education Regulation related to RSI

The final definition of distance education in 34 CFR 600.2 (Department of Education, 2019 Distance Education and Innovation Regulations, Chapter 42, section 600.2) in its entirety is as follows (emphasis added):

  1. Education that uses one or more of the technologies listed in paragraphs (1)(i) through (1)(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 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.

INSTITUTIONAL ASSURANCE AND COMMITMENT

JWCC affirms its commitment to full compliance with federal expectations regarding Regular and Substantive Interaction (RSI) and the following outlines JWCC’s adherence to the five core factors associated with RSI compliance:

  • Appropriate form of media used. The institution’s online instruction is delivered through an appropriate form of media; at JWCC that is the Canvas Learning Management System (LMS).
  • Instructors must meet accreditation requirements. The instructors with whom students regularly and substantively interact meet the requirements of the institution’s accrediting agency for instruction in the subject matter. JWCC ensures compliance with standards established by the Higher Learning Commission (HLC), the Illinois Community College Board (ICCB), and relevant programmatic accrediting agencies.
  • At least 2 of 5 “substantive” activities are used. Instructors engage in at least two forms of substantive interaction meeting the regulatory requirements for the course or competency.

NOTE: ‘Direct instruction’ means “live, synchronous instruction where both the instructor and the student are online and in communication at the same time.” (Weisman, Annmarie, “Dept. of Education Response on RSI”  Letter to Kathryn Kerensky, 10 March 2022.)  Online courses where content is delivered using pre-recorded video lectures do not qualify as direct instruction, but quality online courses can easily meet the substantive interaction standards with the other practices.

  • There are scheduled and predictable interaction opportunities. The institution has established scheduled and predictable opportunities for substantive interaction between students and instructors and created expectations for instructors to monitor each student’s engagement and substantively engage with students on the basis of that monitoring. At JWCC, college engagement procedure establishes students must be actively engaged and earning points at a minimum of once every two weeks in a standard 16-week course in order to not be withdrawn from a course.  Instructors are required to provide grading assessment and feedback within enough instructional days of an assignment’s due date to ensure students are earning points and have enough time to be alerted and rectify behavior within that timespan. For courses of differing lengths, these expectations are adjusted proportionally to maintain the same level of instructional engagement that is regular and substantive.


 NOTES:

  1. Scheduled open ‘office hours’ that are regularly and predictably offered may potentially fulfill part of the requirement for regular interaction between instructors and students (Weisman) and would be substantive if faculty-initiated interaction occurs. However, interaction that is wholly optional or initiated primarily by the student does not constitute regular and substantive interaction (Mahaffie, Lynn. “Dept. of Education on Competency-Based Education Programs.”  Dear Colleague Letter, 19 December 2014.).  Interaction that occurs only upon the request of the student (either electronically or otherwise) is not considered regular and substantive interaction as that is not proactive engagement on the part of the instructor. ‘Office hours’ that require a student to preemptively request or reserve a meeting in order for an instructor to hold them do not qualify as regular or substantive interaction.
  2. Grading, feedback, assessment, or instruction provided by 3rd party tools (e.g. textbook homework systems), rather than directly from the instructor, do not qualify as substantive interactions. As“merely grading a test or paper would not be substantive interaction” (Mahaffie) feedback must be regularly given that is led by the instructor.
  • Instructor responsive to student requests. Instructors are responsive to students’ requests for instructional support. At JWCC, instructors are required to reply to student emails within twenty-four (24) business hours to respond to student requests.

Definition of Online Learning at JWCC

The Higher Learning Commission (HLC) defines online courses as those in which all or the majority (75% or more) of the instruction and interaction occurs via electronic communication or equivalent mechanisms, with the faculty and students physically separated from each other. JWCC further defines online learning as sections delivered online and asynchronously which covers both hybrid (blended), hyflex, and fully online modalities.