Recently my colleague Tony Pina and I presented at the AECT convention about regular and substantive interaction in online courses. Below are notes from our presentation.

Regular and Substantive Interaction in Online Courses is Crucial: What to Do About It

Anthony Piña, Illinois State University

Trey Martindale, Middle Tennessee State University

Definitions matter

• Correspondence education
  • A course providing instructional materials, by mail or electronic transmission, to students who are separated from the instructors.
  • Interaction between instructors and students in a correspondence course is limited, is not regular and substantive, and is primarily initiated by the student. (Code of Federal Regulations, 2022)
• Correspondence education program
  • Academic program in which 50% or more of the required courses may be taken as correspondence education courses
  • Even if students opt not to take any of the courses via correspondence, they are still in a correspondence education program
• Distance education
  • Education that uses technology 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. (Code of Federal Regulations, 2022)

What is the difference?

• Distance education includes regular and substantive interaction between instructors and learners, while correspondence education does not.

Why are these distinctions important?

• Students in distance education courses and programs are eligible for federal financial aid
• Students in correspondence education courses and programs are NOT eligible for federal financial aid
• Audits by the US. DOE OIG of St. Mary of the Woods College and Western Governor’s University, deemed their programs to be correspondence
  • Recommended that St. Mary of the Woods return $42 million in Title IV funds
  • Recommended that Western Governors return $713 million in Title IV funds

Regular Interaction

• Interaction between a student and an instructor or instructors
• Providing the opportunity to interact with the student on a predictable and scheduled basis, according to course length and the amount of content
• Monitoring the student’s academic engagement and success
  • Ensuring that an instructor promptly engages in interaction when needed  or upon request.

Substantive Interaction

• Engaging students in teaching, learning, and assessment. Includes at least two of the following
  • Providing direct instruction (synchronous)
  • Assessing or providing feedback on a student’s coursework
  • Providing information or responding to questions about course content
  • Facilitating a group discussion regarding the content of a course
  • Other instructional activities approved by the accrediting agency

Who provides the interaction?

• An “instructor” is defined as an individual responsible for delivering course content and who meets the qualifications for instruction established by an institution’s accrediting agency.

Example RSI activities

These are not RSI

• Posting announcements with no mechanism for students to respond directly.
• Providing asynchronous video (either form the instructor or via YouTube, Vimeo, etc.) with no mechanism for students to respond or interact directly.
• Providing auto-graded tests or assignments with no instructor-supplied feedback.
• Having all instruction or assessments delivered by a 3rd-party vendor system without the instructor engaging in any of the substantive interaction activities.

What if we offer no fully online programs?

• Since Jan. 2021, programs that offer at least one DE course, are considered DE programs
  • Even if most students opt not to take the distance education course(s)
• Program must adhere to DE rules and regulations
  • Online courses must include RSI

Why do I need to be concerned?

• Mary of the Woods and Western Governors were able to avoid the huge fines because the DoE had not sufficiently defined RSI
• This is no longer the case
• 5/11/23: President Biden declared the COVID-19 emergency over
  • Federal COVID “flexibilities” for financial aid set to end in at the end of summer
  • Waivers for distance education may end at the same time