Regular and Substantive Requirements in Distance Education

For courses and programs offered via distance education in which students may be eligible to use Title IV funds (federal financial aid), the Department of Education (ED) requires that institutions like the Metropolitan State University of Denver are able to confirm and document that there is regular and substantive interaction between students and their instructors.

This page aims to help faculty and staff understand this requirement and associated regulations, apprise them of the difference between distance and correspondence education, and offer guidance and suggestions for creating and offering opportunities for regular and substantive interaction in the digital classroom.

Distance Education

Distance education is, according to the ED, education that uses one or more technologies to deliver instruction to students who are physically separated from the instructor and to support regular and substantive interaction between the students and the instructor, either synchronously or asynchronously.

Not all education that takes place in a digital environment (e.g., online) is considered distance education—the level of interaction and who initiates the interaction matter greatly. An important distinction is, according to the ED, that a course or program that can be described as “self-paced” is considered to be correspondence education, regardless of the technology used.

For the university and our students, it is important to know the difference between “distance” and “correspondence” modalities when creating or delivering courses and programs. The core feature that distinguishes a distance course from a correspondence course is the presence of regular and substantive interaction.

MSU Denver is recognized by our accreditor as an institution that offers/delivers correspondence courses and programs. MSU Denver also has approval to offer Title IX aid for these courses/programs.

What is Regular and Substantive Interaction?

Regular Substantive Interaction (RSI) in distance education refers to meaningful and consistent engagement between students and their instructors or the educational content. It’s about ensuring that students aren’t solely asked to passively absorb information but are expected to actively participate in the learning process.

The U.S. Department of Education now requires that all online courses for which students may use Title IV funds (federal financial aid) “ensure that there is regular and substantive interaction between students and faculty.” In online teaching and learning environments of any kind, (asynchronous, synchronous, blended/hybrid), regular and substantive interactions should:

  • Be with an instructor
  • Be initiated by the instructor.
  • Be scheduled and predictable.
  • Be academic in nature and relevant to the course.
  • Substantive interaction assumes direct interaction between the learner and the instructor including:
    • Providing pre-recorded lectures and videos contextualizing course content
    • Facilitating a group discussion regarding the content of a course or competency
    • Hosting live class sessions
    • Engaging students with interactive activities curated by the instructor
    • Facilitating collaborative group projects with instructor guidance
    • Scheduling one-on-one virtual meetings between students and instructor
    • Assessing or providing feedback on a student’s coursework
    • Providing information or responding to questions about the content of a course

RSI is essential because it keeps students engaged, helps clarify uncertainties, promotes deeper understanding of the material, and allows instructors to gauge student progress and provide necessary support. RSI encompasses a wide range of evolving practices for creating active learning communities in a digital space.

According to the MSU Denver catalog, these requirements apply to all of the online course modalities which include Asynchronous, Synchronous, Dual Mode Online, and Hybrid Online.

Regular and Substantive Interactions Defined

Regular Interactions

We are able to ensure regular interaction between a student and an instructor, prior to the student’s completion of a course or competency, by:

  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.

The requirement for the “regularity” of the interactions stops short of being overly prescriptive and allows for the various pedagogical techniques employed by the instructor(s) or required by the course. For this reason, course syllabi should clearly delineate expectations, instructional activities, regular meeting patterns, or opportunities for meetings per university guidelines.

Substantive Interactions

Substantive interactions are interactions where the instructor actively engages students in teaching, learning, and assessment, consistent with the content under discussion and

Substantive interactions are interactions where the instructor actively engages students in teaching, learning, and assessment, consistent with the content under discussion and must include 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.
  5. Other instructional activities approved by the institution’s accrediting agency.

The language used by the Department of Education to clarify substantive interactions addresses the expectation that those involved in delivering distance education have the flexibility to be innovative in their approaches in education. That is, what is considered “substantive” for one course or program may not be for another.

 

Examples of Interactions

Examples of regular and substantive interactions include, but are not limited to the following:

  • Regularly scheduled learning sessions where there is an opportunity for direct interaction between the student and the instructor.
  • Regular, timely, personalized, and constructive feedback on assignments, discussions, etc., that guides students to further knowledge and/or skills, identifying what has been done correctly or what may need improvement.
  • An instructor-moderated or facilitated online discussion, including follow-up questions and additional information.
  • Instructor posts announcements, email, or other check-ins about academic aspects of the class.
  • Regularly set office hours initiated by the instructor.
  • An overview video, provided by the instructor, to accompany lectures.
  • Additional interaction opportunities for students whom the instructor has identified (through observation of discussion activity, assessment completion, or user activity) as possibly struggling to reach mastery of the course. Use of small working or study groups that are moderated by the instructor.
  • Instructor announcements at strategic points in the course concerning course assignments and offering additional guidance.
  • Course materials that facilitate interactions between student(s) and instructor and require the student to contact the instructor or participate in an online discussion moderated by the instructor.
  • Online meetings and chats focusing on course material and/or addressing student questions.

What does not constitute interactions?

  • Assignment of pre-recorded lectures, webinars, videos, and reading materials if the course design does not require the students to review the assigned material and then interact directly with the instructor.
  • Only student-solicited office hours offered.
  • A student logging into a live webinar with no opportunity for interaction.
  • Courses without at least two of the methods listed (above) for substantive interaction.
  • 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.
  • Use of AI-generated content or tools used in place of instructor-initiated communication, feedback, grading and/or guidance.