Regular and Substantive Interaction (RSI) in Distance Education
Regular and Substantive Interaction (RSI) in Distance Education
This article provides a comparative overview of how other institutions interpret and implement U.S. Department of Education regulations regarding Regular and Substantive Interaction (RSI) in distance education. RSI is a federal requirement to ensure quality in online learning and is essential for financial aid eligibility and accreditation compliance.
Executive Summary
Key Requirements Identified:
- Regular Interaction – Most institutions, including the University of Illinois Urbana-Champaign, University of Wisconsin–Madison, University of Texas Rio Grande Valley, and University of Minnesota, consistently cite two regulatory requirements:
- Substantive interaction must occur on a predictable and scheduled basis.
- Instructors must monitor student engagement and initiate interaction when needed.
- Substantive Interaction – At least two of the following five activities must be evident in each course:
- Providing direct instruction
- Assessing or giving feedback on coursework
- Answering questions about course content
- Facilitating group discussions
- Engaging in other instructor-led educational activities approved by accreditors
While many institutions acknowledge these five categories, few elaborate on implementation strategies, with some ambiguity remaining about frequency and instructor-initiated versus technology-facilitated interaction.
Institutional Practices and Guidance:
- Some institutions (e.g., Northern Illinois, UIUC, UTRGV) provide detailed RSI definitions and best practices.
- Others (e.g., Purdue, Penn State, University of Arizona) embed interaction expectations into broader course design standards but do not explicitly reference RSI.
- WCET (WICHE Cooperative for Educational Technologies) is frequently cited as a thought leader clarifying evolving interpretations of RSI, especially in relation to adaptive technologies.
Key Takeaways:
- There is strong alignment across institutions on the federal baseline for RSI, particularly the two rules for “regular” interaction and the five recognized forms of “substantive” interaction.
- However, variation exists in the depth of implementation, terminology used, and course design support provided.
- Institutions are encouraged to clearly communicate RSI expectations in syllabi and design processes and to monitor for compliance through instructional design and quality assurance efforts.
This executive summary underscores the importance of aligning institutional policies and course design practices with federal RSI requirements while advocating for clearer guidance from the Department of Education and accrediting bodies.
Regular and Substantive Interaction (RSI) Report
Question: How many rules are required for Regular and Substantive Interaction regarding distance education among different institutions?
Regular Interaction
Many institutions mentioned two rules that are required for regular interaction: University of Illinois Urbana-Champaign, University of Wisconsin – Madison, The University of Texas Rio Grande Valley, University of Minnesota.
The rules are:
- Providing the opportunity for substantive interactions with the student on a predictable and scheduled basis;
- 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.
Substantive Interaction
Many institutions mentioned that “at least two” requirements are needed for the Substantive interaction. These institutions are Northern Illinois University, University of Illinois Urbana-Champaign, University of Michigan, University of Wisconsin-Madison, The University of Texas Rio Grande Valley, University of Minnesota. However, they do not specify or provide further explanation on what actions are expected to meet “at least two” requirements.
The requirements are:
- Providing 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.
There’s an organization called WCET, quoted by University of Illinois Urbana-Champaign, which provides some explanation on the Department of Education’s definition of “distance education” in 2021. Based on their explanation, “the new definition provides more specifics, but questions remain regarding the interpretation and expected actions that an institution should take to meet the requirements”. WCET’s report on RSI, “Regular and Substantive Interaction: Background, Concerns, and Guiding Principles” is also cited by University of Minnesota. The report indicated the unclear “definition of substantive interaction” as one of the remaining concerns.
It is suggested:
As institutions begin to deploy new technologies, especially adaptive learning technologies, the issue of whether or not students can receive substantive interaction that is not instructor-initiated must be discussed. If the Department does decide to address this issue, it will need to determine if the definition of substantive interaction should be changed to allow for technologies such as adaptive learning that might provide interactions that are not necessarily instructor initiated but built into the program delivery model and have instructor-validated learning technologies.
Some other institutions do not specifically use the term “Regular Substantive Interaction” for distance learning, but they provide some relevant expectations or requirements for the course design process. These institutions are Purdue University, Penn State University, and University of Arizona. Their standards on how to maintain student-instructor interaction in distance classes vary from one institution to another.
The websites for the following institutions were searched for published information on RSI and the results are below.
Substantive interaction is engaging students in teaching, learning, and assessment, consistent with the content under discussion, and also includes at least two (2) of the following:
- Providing 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.
Recommendations for promoting regular and substantive interaction (RSI) in online courses:
- Set clear expectations for interaction in the syllabus
- Send course announcements or other messages at regular intervals throughout the semester
- Provide timely, individualized, and in-depth feedback on student work
- Actively facilitate online discussions and chats
- Conduct regularly scheduled online review sessions, tutorials, office hours, or individual appointments
- Choose online tools and learning environments that make interactions east-and easy to document
- Collect mid-semester feedback from students
- Ask for feedback from trusted colleagues
HLC (Higher Learning Commission) RSI Definition:
Institutions are expected to ensure regular and substantive interaction between students and instructors in their distance education and competency-based education offerings. 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.
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:
- Providing 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 HLC or the program’s accrediting agency.
According to WCET, “in 2021, the Department (of Education) enacted “distance education” definition, including:
- The instructor (or instructors) meets the “qualifications for instruction established by the institution’s accrediting agency.”
- Substantive interaction includes at least two of the following:
- Providing 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.
- Regular interaction includes both:
- Providing the opportunity for substantive interactions with the student on a predictable and scheduled basis, 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.
While the new 2021 definition provides more specifics than in previous versions of the regulation, some questions remain regarding the interpretation and expected actions that an institution should take to meet the requirements. WCET will continue to follow this topic and seek guidance for its members.
See resources below for the latest from WCET.
FAQs session:
Substantive interaction: for the “at least two” types of substantive interaction requirement, how often do at least two need to be demonstrated?
- Two or more types of substantive interaction can be featured at any point during the course (as long as at least one type satisfies the “regular” requirement).
Specifically, the Department has stated that:
- The definition requires an institution to perform at least two of those activities, and since we apply the regulation at the course or competency level, we also require an institution to perform at least two of those activities over the period of time that the student completes the course or competency. We believe that requiring a specific timeframe, sequence, or frequency that the activities need to occur within that timeframe would be impractical and would extend beyond our purview under the Department of Education Organization Act. 85 FR 54758-59, Preamble.
RSI is not mentioned, but course design process and evaluation rubrics are provided.
- In a document called QM-correlated Course Design Evaluation Rubric with Learning Management System (LMS) Recommendations provided on the website, following standards about “Interaction and Communication” need to be met for the course design:
- Expectations for learner interaction are clearly communicated. This includes how synchronous and asynchronous communication methods will be utilized, and the instructor’s plan for interacting with learners during the course is clearly stated.
- Learners are provided with regular and substantial opportunities initiated by the instructor(s) or by themselves to build community through the promotion of instructor-to-learner and learner-to-learner interaction and dialogue. Communication tools are utilized when appropriate.
- Learning activities provide opportunities for interaction of a meaningful or academic nature that support active learning and advance the achievement of the learning outcomes and objectives.
- Instructor response time and feedback to learner-initiated communications are clearly stated at the start of the course. Reminder: During course delivery, the instructor should initiate regular, substantial, and frequent interaction of a meaningful academic nature.
- Instructor mechanisms for assignment and assessment feedback align with assignment/activity instructions and aim to help learners achieve course and module/unit/lesson objectives. Specific and descriptive criteria are provided for the evaluation of learner work and participation, and exemplars may be provided. These are tied to the course grading policy.
- Learners' self-assessments and/or peer feedback opportunities exist in the course to allow learners to reflect and assess their own performance/knowledge prior to formal assessment (i.e., major exams, projects, etc.).
Course Design Recommendations:
Clearly state expectations for learner interactions with content, peers, and instructor including when and how.
Provide a discussion post for learners to interact with each other and you. (This can be used for asking clarifying questions and community-building.)
Label required content, differentiating required items from additional resources for deeper understanding.
State how to reach instructors for assistance, as well as turnaround time for both grading and communications.
Provide descriptive feedback for all assessments.
Penn State University
Specific information on RSI was not found on the Penn State website, or for asynchronously delivered courses. But their Registrar's website does include information in a flowchart document regarding RSI and synchronously deliver courses. The flowchart document is available here on their Registrar's website.
University of Wisconsin – Madison
Below is the only information found on the University of Wisconsin website regarding RSI.
- Education that uses one or more of the technologies listed in paragraphs (2)(i) through (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.
- The technologies that may be used to offer distance education include
- the internet;
- One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices;
- Audio conference; or
- Other media used in a course in conjunction with any of the technologies listed in paragraphs (2)(i) through (iii) of this definition.
- For purposes of this definition, an instructor is an individual responsible for delivering course content and who meets the qualifications for instruction established by an institution's accrediting agency.
- 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
- Providing 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.
- 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.
Regular interaction requires an institution to ensure, “before the student completes a course or competency,” that there is “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.” The institution also is responsible for 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 on such monitoring or upon request by the student.
Substantive interaction is engaging students in teaching, learning, and assessment, consistent with the content under discussion. It must include at least two of five components:
- Providing direct instruction. This does not include micro-lectures or recorded webinars.
- Assessing or providing feedback on a student’s coursework. Limited feedback such as posting “good job” or just entering a numerical grade dose not qualify as substantive. Feedback should be meaningful, both when a student is doing well and in areas where they could improve
- 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
- Other instructional activities are approved by the institutions or program’s accrediting agency
Instructors are expected to design and deliver all classes with “regular and substantive interaction” (RSI) between themselves and students. The ways in which an instructor provides RSI should be evident on the class syllabus.
- Regular interaction includes both:
- 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 class; 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.
- Substantive interaction refers to engaging students in teaching, learning and assessment, consistent with the content under discussion. Substantive interaction includes at least two of the following:
- Providing 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
- Other instructional activities approved by HLC or the program's accrediting agency (only for classes scheduled as asynchronous online)
- Characteristics of RSI include:
- Initiated by the instructor;
- Scheduled and predictable;
- Frequent and consistent;
- Academic in nature and relevant to the course.
University of Arizona
RSI is not clearly mentioned. Requirements specifically about distance education or online teaching are not mentioned. The university center for assessment, teaching & technology provides resources on course design where they indicate “Quality Matters”. In the form QM Rubric Standards Overview, specific review standards for “Learning activities and learner interaction” are:
- The learning activities help learners achieve the stated objectives.
- Learning activities provide opportunities for interactions that support active learning.
- The instructor’s plan for regular interaction with learners in substantive ways during the course is clearly stated.
- The requirements for learner interaction are clearly stated.
The third standard asks for “regular interaction in substantive ways” without further explanation on specific expectations.
