Regular and Substantive Interaction - University of Houston
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New Rules in Online Learning: Regular and Substantive Interaction

The U.S. Department of Education (ED) has issued Final Rules on Distance Education and Innovation which go into effect on July 1, 2021. Under the new regulations, the U.S. Department of Education requires that all online courses and programs for which students may use Title IV funds (federal financial aid) include regular and substantive interaction between students and their instructors. This ruling applies to both synchronous and asynchronous courses, with the primary focus being asynchronous courses. The Department of Education has the authority to audit courses and programs at institutions, like the University of Houston, with online offerings.

Read the Definition of Online Learning

Elements of Regular and Substantive Interaction

The ED defines “substantive interaction” as engaging students in teaching, learning and assessment, that is consistent with the course content under discussion and includes at least two of the following activities totaling at least 50-60 minutes every week for a 3 credit-hour course in a long fall/spring semester, or a scaled number of minutes for a course with a different number of credit-hours and a shorter or longer semester:

(i) Attending a synchronous class, lecture, recitation, or field or laboratory activity, physically or online, where there is an opportunity for interaction between the instructor and students;

(ii) Submitting an academic assignment;

(iii) Taking an assessment or an exam;

(iv) Participating in an interactive tutorial, webinar, or other interactive computer-assisted instruction;

(v) Participating in a study group, group project, or an online discussion that is assigned or led by the instructor;

(vi) Interacting with an instructor about academic matters; and

(vii) Required discussion forum activity associated with the course material.

Instructor Responsibilities

"Regular and Substantive Interaction" must:

  • be with an instructor as defined by the institution's accreditor
  • be initiated by the instructor
  • be scheduled and predictable
  • be academic in nature and relevant to the course
  • ensure that instructors are promptly and proactively engaging students in substantive interaction
  • include at least TWO of the following methods for substantive interaction:
    • direct instruction (i.e., discussion participation, instructor feedback, synchronous lectures, etc.)
    • providing information or responding to questions about course content
    • coursework assessment or feedback
    • facilitating group discussion of the course content
    • other instructional methods to be approved by accreditor 
    • Instructors must be able to show evidence of at least TWO of the above methods in their course.

      Examples of RSI include but are not limited to:

    • Participation in regularly scheduled learning sessions (where there is an opportunity for direct interaction between the student and the qualified instructor).
    • Provide personalized comments (in any medium) for an individual student’s assignment or exam.
    • An instructor-moderated online discussion forum.
    • Instructor posts announcements, email, or social media check-ins about academic aspects of the class.
    • Regularly set office hours initiated by the instructor are considered substantive interaction, even if students do not take advantage.
    • Provide an overview video to accompany recorded lectures.
    • Identify students struggling to reach mastery through observation of discussion activity, assessment completion, or even user activity and offer additional opportunities for interaction.
    • Use of small working/study groups that are moderated by the instructor

What does not constitute RSI?

  • Pre-recorded video lectures available for students to watch at their own pace not associated with an assignment, discussion, quiz, etc.
  • Only student-solicited office hours offered.
  • A student logging into a live webinar with no opportunity for interaction.
  • Asynchronous courses without at least two of the methods listed for substantive interaction.
  • Assignment of recorded webinars, videos, and reading materials if the course design does not require the students to review the assigned material and then interact with the instructor
  • Contact with instructors not related to the course subject matter.
  • Adding numeric grades to the course gradebook.
  • A student submits a quiz that is automatically graded.
  • Sending a welcome message during the first week of class and another around mid-semester.
  • Encouraging students to participate in an optional, one-time online review session before the final exam.
  • Reminding students of the course attendance policy.
  • Posting an announcement about an upcoming assignment deadline.
  • Providing an open-ended online forum that is not moderated by the instructor.

New Checklist for Your Asynchronous Course

Learn More

Meet with your Instructional Designer or watch the past training presentation.  FDIS will offer periodic online trainings as well.