Regular and Substantive Interaction

Whether you are teaching a fully online class—synchronously and/or asynchronously—a hybrid class or a HyFlex class, online instruction has to be accompanied by human interaction. Primarily, this interaction has to be between the instructor and the students and mostly initiated by the instructor. 

These mandates are spelled out in federal and state regulations.

Federal Regulations

Definition of Distance Education (34 C.F.R. §600.2.)

Distance Education means:

1. Education that uses one or more of the technologies listed in paragraphs 2(a) through (d) to deliver instruction to students who are separated from the instructor(s) and to support regular and substantive interaction between the students and the instructor(s), either synchronously or asynchronously.
2. The technologies may 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. audioconferencing; or
   4. other media used in a course in conjunction with any of the technologies listed in paragraphs (a) through (c).
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
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 regular 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.

Definition of Correspondence Education (34 C.F.R. § 602.3.)

Correspondence education means:

1. education provided through one or more courses 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
2. interaction between the instructor(s) and the student is limited, is not regular and substantive, and is primarily initiated by the
3. If a course is part correspondence and part residential training, the Secretary considers the course to be a correspondence
4. correspondence education is not distance

State Regulations

The only notable difference between the above federal regulations and state Title 5 regulations on interaction in DE courses comes in subsection (a) under Instructor Contact (§ 55204):

1. Any portion of a course conducted through distance education includes regular and substantive interaction between the instructor(s) and students (and among students if described in the course outline of record or distance education addendum), either synchronously or asynchronously, through group or individual meetings, orientation and review sessions, supplemental seminar or study sessions, field trips, library workshops, telephone contact, voice mail, e-mail, or other activities.

LPC Resources

The LPC Distance Education Interaction Guidelines provide examples of how to meet the interaction regulations. They also contain examples of what does not meet the regulations.

View the LPC Distance Education Interaction Guidelines.

Here are other resources that instructors should find helpful:

• Example interaction assignments by LPC instructors
• CVC-OEI's Student-Student Interaction Guide (contains examples)

Consequences of no Interaction

There are two ways your course can be scrutinized for evidence of RSI: through an audit and through accreditation. Audits are performed by the U.S. Department of Education, and our regional accreditor, the Accrediting Commission for Community and Junior Colleges, (ACCJC) is part of the Western Association of Schools and Colleges (WASC), which is under the federal DOE.

It is possible that if auditors or accreditors find many LPC Distance Education courses without evidence of RSI, they can classify those as Correspondence Courses, which might jeopardize federal financial aid flowing to the college. Students in Distance Ed courses are eligible for financial aid, but students in Correspondence courses are not.

Do not put interactions in third-party sites, such as MyMathLab or your personal emails; auditors and accreditors will only look inside your course for evidence.