As far back as 2005, the federal government began differentiating correspondence courses, which are ineligible for Title IV financial aid, from aid-eligible distance education courses using the term “regular and substantive interaction” (RSI).
In brief, distance education courses have RSI and correspondence courses don’t. And this is important! If your intuition’s courses are found to be lacking in terms of RSI, you may have to pay back millions of dollars in financial aid money received.
Although RSI has been required for many years, it was poorly defined. New RSI regulations were published in the Code of Federal Regulations, Title 34, and became effective on July 1, 2021. They were not intended to actually change the requirement for Regular and Substantive Interaction, but to clarify what RSI was and how to recognize it. Instead of saying that auditors will “know it when they see it,” the new regulations are much more descriptive, without being entirely prescriptive. Anyone involved in financial aid should be aware of the changes, which were widely publicized.
Why academics should care
Honestly, though, I’d prefer to look at this issue from an academic lens rather than a financial one. It may seem unrealistic to think that Title IV regulations, which tend to apply only to student financial assistance programs, can be a powerful tool to improve teaching and learning. However, that’s just what I’m suggesting.
In a “Quick Poll” from April 2021 by the Instructional Technology Council (ITC), an affiliate council of the American Associated of Community Colleges, about 55% of those who responded said that they either were not aware of the recent updates to RSI rules or needed more guidance. ITC’s members are predominantly academic administrators, faculty and instructional designers, not financial aid officials. Here are a couple of reasons why academics also needed to know about RSI rules.
The first is that, although these rules apply to financial aid, the evidence that they are being followed comes from the online classroom. Many institutions are probably already in compliance because the RSI regulations mimic good practice for faculty presence and student engagement in online courses. However, some schools may not be, or some courses at mostly compliant institutions may not be. Academics would certainly not want their institutions to fail an audit because faculty weren’t following rules they didn’t even know about when they designed and taught online courses.
The second is that, if someone isn’t following good practice, Title IV regulations give the institution real “teeth” to encourage the adoption of those practices. So, in those rare cases where there might be push-back against RSI, administrators can shift the dialogue from “you should” to “you must” because of the very real and possibly quite substantial financial penalties for non-compliance.
RSI in action
What could this look like in practice? Well, giving a test and providing detailed feedback on what the student got right and what they got wrong and how to improve meets part of the definition of substantive interaction. So does facilitating a group discussion or answering student questions about the course topic. And so does providing direct instruction or other educational activities approved by the institution’s or program’s accrediting agency.
To be in compliance, two or more of the above would need to be evident in every distance education course. And to qualify as regular interaction, the above must be done on a predictable and scheduled basis.
Does your institution have documented course design standards that could be shown to an accreditor or auditor? Perhaps included in some sort of mandatory training or a best practices document? Are there explicit expectations by the institution for faculty to have established regularly scheduled assessments/assignments and/or graded discussions/journals/blogs in their online courses?
Accreditors generally like to see “documented policies and procedures” while auditors may actually ask for course access to see that what is documented in policy is actually taking place in practice. Are you ready?