The Federal Government (and ADHE through the agreement with NC-SARA) requires Regular and Substantive Interaction in online (distance) courses and delineates federal financial aid eligibility (Title IV funds) based on the use of Regular and Substantive Interaction to distinguish between online (distance) and correspondence (self-paced) courses.

“Failure to comply with regular and substantive interaction requirements jeopardizes an institution’s access to federal financial aid if more than 50 percent of their courses are classified as correspondence courses…” (WCET). While it’s unlikely that 50% of our online courses would be classified as such, this could get murky when we begin supporting alternate delivery methods. So, we must maintain the regular and substantive interactions in our online courses lest they have a chance to be reclassified as correspondence.

In the definition of distance education, regular interaction and substantive interaction are separate concepts and can be met through different means.

Definition of Regular Interaction

Contained in the Dept. of Ed’s definition of distance education, “regular interaction” is defined in part 5 (see below in Definitions). Evidence of both sub-points listed below is required.

Excerpt:

“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.”

Discussion of Regular Interaction (the sub-points) 

i. Instructors are expected to interact with students on a fairly set schedule (routinely) with those communications not too far apart (in time). Student-initiated interactions do count, but alone do not suffice without additional instructor-initiated and regular interactions. (Paraphrased from Source WCET Aug 26th 2021 article)

Examples: Reminder announcements/emails to class once or twice a week stating topics, readings, upcoming assignments, etc.; Announcement/email notices of posted grades and reminders to review feedback; Regularly/weekly scheduled virtual office hours.

ii. It is not expected for instructors to keep track of all interactions with students (ultimately, this would not be a bad idea – some do already). However, it is expected that instructors take a proactive approach to determining whether students need assistance. “Promptly and proactively engaging” implies that specific information in a course syllabus or other similar document shared with students that illustrates how quickly students can expect responses from their instructors may suffice to meet this requirement. (Paraphrased from Source WCET Aug 26th 2021 article)

Examples: These are ways for an instructor to be proactive about monitoring student engagement: (using LMS tools, traditional instructor-to-student evaluations, using tests or quizzes, and evaluating each student’s performance through regular assignments and formative assignments that build throughout the course).

Timely “expected responses” are the ‘contact policy’ that we ask instructors to add to their syllabus to be in accordance with QM.

Definition of Substantive Interaction 

Contained in the Dept. of Ed’s definition of distance education, substantive interaction is defined in part 4 (see below in Definitions).

Excerpt:

“4. 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—

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.”

Discussion of Substantive Interaction (the sub-points) 

i. A real-time, synchronous video lecture would count as direct instruction. Even though direct instruction is not defined in the regulation by the Dept. of Ed., based on the Dept of Ed’s April 2021 webcast, a recorded lecture would likely not count as direct instruction. Direct instruction is the only option in the list of five options for substantive interaction that cannot be met by asynchronous online courses. Two of the other options must be met for direct instruction to be fulfilled. (Edited – Source WCET Aug 26th 2021 article) 

ii. Assessments where feedback is given (e.g., papers and projects) qualifies. However, auto graded assessments do not qualify. Dept of Ed says, ‘that interactions with artificial intelligence, adaptive learning systems, or other forms of interactive computer-assisted instructional tools will not meet the statutory requirements for regular and substantive interaction.’ (Paraphrased from Source WCET Aug 26th 2021 article)

Remind instructors that for an online 3hr credit class they can use the 3hrs each week that they are not in-class lecturing for interacting with students and giving detailed feedback.

Examples: Detailed feedback on discussions, blogs, journals, papers, projects, group projects, eportfolios, etc.  Note: Automated feedback (such as available on right/wrong answers in Blackboard exams) does not count.

iii. It is important to interact with students not only for students to know that the instructor is present in the course, but to distinguish distance from correspondence courses.

Examples: Assessment instructions, individual/course emails, announcements, and participating in discussion boards. 

iv. This is not necessarily the Discussion Board tool in Bb, however it can foster interactions between students and instructors.

Examples: Instructor participation in occasional (whole class or small group) discussion boards on course content.  Discussions also facilitates student-to-student interaction which is important for active learning (per QM), Examples other than Blackboard’s built-in discussion board are: Packback, or video-based discussion tools  such as VoiceThread or Flip (formerly Flipgrid), etc.   

v. This would be on a case-by-case basis.

Examples: Internships or Clinicals 

The 5 Broad Factors that the Dept. of Ed Considers When It Reviews Cases 

Quoted from the WCET website (the website has far more detail and discussion):

“However, when it comes to oversight of the requirements for regular and substantive interaction and distinguishing distance education from correspondence education, the Department outlined the five factors on which it will focus in the preamble to the final regulations:

  1. The institution’s online instruction is delivered through an appropriate form of media;
  2. The instructors with whom students regularly and substantively interact meet the requirements of the institution’s accrediting agency for instruction in the subject matter;
  3. Instructors engage in at least two forms of substantive interaction meeting the regulatory requirements for the course or competency;
  4. The institution has established scheduled and predictable opportunities for substantive interaction between students and instructors and create expectations for instructors to monitor each student’s engagement and substantively engage with students on the basis of that monitoring; and
  5. Instructors are responsive to students’ requests for instructional support.”

 

Discussion of the 5 Broad Factors that the Dept. of Ed Considers When It Reviews Cases 

As instructors, you should take every opportunity to incorporate aspects of numbers 3-5.

  1. Blackboard is modern and appropriate.
  2. Your department makes sure you are qualified instructors.
  3. Examples from above: Detailed feedback (on discussions, blogs, journals, papers, projects, group projects, eportfolios), detailed assessment instructions (and/or rubrics), individual/course emails, announcements, instructor participation in discussion boards, occasional (whole class or small group) student discussion boards, Packback, or video-based discussion tools (VoiceThread, Flip [formerly Flipgrid]), peer reviews, collaborative documents, etc.
  4. The institution doesn’t really schedule the interaction but provides the mediums for you to interact (both through the LMS and external to LMS): email, chat, virtual meetings, etc.
  5. Responsiveness and communication are key when teaching at a distance.

Definitions 

For clarity the following relevant definitions listed are from the Code of Federal Regulations: Title 34 / Subtitle B / Chapter VI / Part 600 / Subpart A / § 600.2

Academic engagement: 

Active participation by a student in an instructional activity related to the student’s course of study that

  1. Is defined by the institution in accordance with any applicable requirements of its State or accrediting agency;
  2. Includes, but is not limited to –
  3. 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;
    1. Submitting an academic assignment;
    2. Taking an assessment or an exam;
    3. Participating in an interactive tutorial, webinar, or other interactive computer-assisted instruction;
    4. Participating in a study group, group project, or an online discussion that is assigned by the institution; or
    5. Interacting with an instructor about academic matters; and
  4. Does not include, for example –
    1. Living in institutional housing;
    2. Participating in the institution’s meal plan;
    3. Logging into an online class or tutorial without any further participation; or
    4. Participating in academic counseling or advisement.

Correspondence course: 

  1. A course provided by an institution under which the institution provides instructional materials, by mail or electronic transmission, including examinations on the materials, to students who are separated from the instructors. Interaction between instructors and students in a correspondence course is limited, is not regular and substantive, and is primarily initiated by the student.
  2. If a course is part correspondence and part residential training, the (Dept. of Ed.) Secretary considers the course to be a correspondence course.
  3. A correspondence course is not distance education.

Distance education:

  1. Education that uses one or more of the technologies listed in paragraphs (1)(i) through (1)(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.
  2. The technologies that may be used to offer distance education include —
    1. The internet;
    2. One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices;
    3. Audio conferencing; or
    4. Other media used in a course in conjunction with any of the technologies listed in paragraphs (1)(i) through (1)(iii) of this definition.
  3. For purposes of this definition, an instructor is an individual responsible for delivering course content and who meets the qualifications for instruction established by the institution’s accrediting agency.
  4. 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—
    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; or,
    5. 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—
    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.