1.0 Purpose


To establish College policy for substantive interaction in distance education courses and to comply with Department of Education regulations.


Effective July 1, 2021, the Department of Education defines distance education under 34 §C.F.R. 600.21 as education that includes the following:

  1. 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 and to support regular and substantive interaction between the students and the instructor, either synchronously or asynchronously.
  2. The technologies that may be used to offer distance education include (i) The internet; (ii) One- way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber options, satellite, or wireless communications devices; (iii) Audio conference; or (iv) Other media used in a course in conjunction with any of the technologies listed in paragraph (2) (i) through (iii) of this definition.
  3. For the 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.
  4. For the purposes of this definition, substantive interaction is engaging students in teaching, learning, and assessment, consistent with the content under discussion, and also include at least two of the following: (i) Providing direct instruction; (ii) Assessing or providing feedback on a student’s coursework; (iii) Providing information or responding to questions about the content of a course or competency; (iv) Facilitating a group discussion regarding the content of a course or competency; or (v) Other instructional activities approved by the institution’s or program’s accrediting agency.
  5. 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: (i) 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 (ii) 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.

Why Regular and Substantive Interaction Matters

  1. Regular and substantive interaction is more than a federal requirement; it is the foundation of effective online teaching and learning.
  2. Positive impact on students, including student success, engagement, retention, and advancement.
  3. Regular and substantive interaction separates distance learning courses and correspondence courses, which directly impact federal financial aid and funding, including Title IV funding and other federal sources of funding.

2.0 Policy

The College expects these minimum standards in distance learning courses:

The instructor will engage students in teaching, learning, and assessment consistent with the content of the course. In addition, the instructor will include at least two of the following:

a. Provide direct instruction (required for all synchronous, hybrid, hyflex courses)
b. Provide substantive feedback on a student’s coursework
c. Provide information or respond to questions about the course content
d. Facilitate and participate in interactive discussions regarding the content of the course (required for all asynchronous courses)

The instructor will provide opportunities for substantive interactions with the student on a predictable and scheduled basis, including at minimum:

a. Post a welcome announcement on the first day of the session and at least one substantive announcement per week in all asynchronous courses
b. Regularly scheduled availability for office hours weekly, either virtual or in-person
c. The course syllabus should be easily located in the online course and in the format approved by the college
d. The course syllabus includes the instructor’s communication plan, which includes the specific time frame students can expect interaction from the instructor, including feedback for assignments and turn around for communication. The time frame for feedback should not be more than seven days and communication should normally be returned within 24-48 hours.
e. The syllabus should include information on how students can interact with instructors, which include institutional email and appropriate office hours and location.

The instructor will monitor the student’s academic engagement and success and will attempt to engage all students who were considered absent per relevant attendance policies without prior notification of illness, family emergency, etc. The instructor will maintain a record of such efforts through established protocols approved by the institution (e.g. RSI Committee).

3.0 Procedures

To support this policy, the RSI Committee will be formed.


The RSI committee will work with department chairs, faculty, and the IIT department to facilitate and document RSI compliance.

Committee Charges

  • Communicate with faculty members about the importance of RSI documentation and the process at the beginning of each term. Faculty are responsible for submitting their documentation for their course(s) within two weeks following the last day to withdraw without academic penalty for a given session.
  • Ensure documentation of RSI compliance through a scheduled, rotational cycle of departments, representing 10% of all online asynchronous courses
  • Oversee and review completed RSI Self-Reflection submissions using established rubric
  • Contact department chairs regarding mentoring that may be needed for faculty who do not meet standards
  • Develop a semester and annual report
  • Review and revise the process annually as needed


The RSI Committee is composed of 6 faculty members (2 from Nursing and Health Technology, 3 from Arts and Science, 1 from Professional and Technical Studies). The length of each term is 2 years. Terms will be staggered so that three new members will join the committee every year. At the beginning of every academic year, one of the members who is in the second year of their term will be appointed as chairperson.

4.0 Definitions

Substantive Interaction – important, meaningful, or considerable information or feedback of an academic nature that is initiated by the instructor. These substantive interactions can include but are not limited to:

  • Provide direct instruction, which includes synchronous meetings, asynchronous video coupled with interactive discussion, or any opportunity for student interaction with the instructor during instruction.
  • Provide substantive feedback on a student’s coursework, which includes content or competency-related feedback regarding student performance and opportunities for future success
  • Provide information on or respond to questions about the course content, which includes email, announcements, or other course-wide or individual communication
  • Facilitate and participate in interactive discussions regarding the content of the course, which can occur synchronously or asynchronously in discussion forums

Direct Instruction – real-time, synchronous video lecture or demonstration; instructor participation in and/or facilitation of class discussions, providing feedback to students, and office hour interactions with students focused on the subject of the class. Pre-recorded, publisher content, or written lecture materials alone would likely not meet the Federal regulation for distance learning and should not be considered as meeting one of the minimum standards for RSI.

Assessing Student Work – providing assignments and substantive feedback on assignments. The creation of assessments alone, without substantive feedback, is not enough to satisfy the RSI definition.

Predictable and Scheduled Interactions – weekly announcements, scheduled test-prep sessions, office hours, and other regularly scheduled instructor-initiated interactions. A series of videos or other materials that are available for students to view at any time (considered self-paced), for example, would not meet the requirements for RSI. It is important to note the regulation may be met by instructors making themselves “available at a specific time and through a specific modality…regardless of whether the students choose to make use of this opportunity or interact with the instructor.”

Academic Engagement – defined by the Department of Education as the “active participation by a student in an instructional activity related to the student’s course of study.” Activities include, but are not limited to, attending a synchronous academic activity where there is opportunity to interact with the instructor; submitting an academic assignment; taking an assessment; participating in interactive computer-assisted instruction; participating in a study group, group project, or online discussion; or interacting with an instructor about academic matters.

6.0 Point of Contact

Instructional Designer

7.0 Approval and Revision Dates

Cabinet: February 10, 2022
Faculty Senate: May 20, 2022
Department Charis: May 06, 2022
College Council: N/A
Leadership Council: September 29, 2022

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