What is RSI and Why Do We Care?

The Department of Education requires Regular and Substantive Interactions (RSI) as a distinguishing feature between distance education courses and correspondence courses. If a higher education institutions is receiving Title IV federal financial aid, they need to follow federal guidelines so that their courses are classified as "distance education" in order to maintain the eligibility.

Want to learn more? Columbia Basin College has a three part video series (6 minutes each) about RSI regulations, Substantive Interaction, and Regular Interaction that gets deeper into the regulations and some examples of how faculty can build these elements into courses.

Definitions

Regular

Interactions occur at predictable and consistent intervals

Substantive

Interactions are instructor initiated and academic in nature

RSI in Practice

The good news is that implementing RSI principles in your course does not need to be complex, and there are many tools in Canvas that will help you. Take a look at the graphic and suggestions below. More than likely you are already practicing RSI!

Examples of how different teaching strategies are indicative of correspondence education (such as auto graded quizzes, video lectures, pre-set information sharing announcements) and distance education (feedback on assignments, discussions, office hours.)

Image: Sunny Empire State College

Remember: RSI Matters to Students!

Students learn more when engaged in a course. Engagement requires meaningful interaction and students also need to know that there is a knowledgeable person helping to guide them through the learning process who actually cares about their learning.

Faculty Engagement is equally important to Student Engagement!

Important details

What makes a course "distance education?"

RSI applies to any delivery format when you deliver instruction to students who are separated from the instructor in a synchronous or asynchronous course environment. Currently COCC offers several formats of course delivery and most of them include the element of distance education. With the exception of In-person, all formats could meet the definition of "distance education."

Our delivery methods are included on the Class Schedule page of the COCC website.

In-Person - Synchronous class. You will attend class at a specified location at specified times.
Online - Asynchronous class. You will receive course instruction virtually (usually via Canvas) with no requirements for you to attend class at a specified time.
Hybrid - A mix of synchronous and asynchronous. You will attend class in-person or virtually (usually via Zoom) at specific times AND have additional instruction delivered virtually. Hybrid can take many forms and expectations should be clearly communicated to students both in the class schedule and in Canvas.

What is the longer legal definition of RSI?

In 2020, the Department of Education released new regulatory language around distance education that was to go into effect on July 1, 2021. This new language included, for the first time, clarification of regular and substantive interaction.

The Regulatory Definition of "Distance Education," Including Regular and Substantive Interaction, 34 C.F.R. 600.2Links to an external site.

The new language finally provides us some clarifications we have been looking for:

(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 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 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.

What happens if COCC doesn't ensure there is RSI in its distance education courses?

The Office of Inspector General (OIG) is an independent entity within the U.S. Department of Education that is responsible for identifying fraud, waste, abuse, and criminal activity involving Department of Education funds, programs, and operations. The OIG conducts independent audits and other reviews and criminal and civil investigations.

The implications of institutions not meeting RSI guidelines will include losing access to federal student financial aid and repayment of the financial aid money they have received.

A notable case was the September 2017 audit of Western Governors University (WGU), the largest competency-based online education provider in the country. WGU advertises their programs with the claim that students can graduate faster with about half of the cost of other online universities.

As a result of the audit, the Department of Education identified that the most of the Western Governors courses should actually be classified as "correspondence" courses, and Western Governors University was told to pay back $713 million in federal aid due to out of RSI compliance.