RSI - Why These Three Letters Should Matter to You

Dr. Anthony A. Piña, Chief Online Learning Officer, Illinois State University

Dr. Anthony A. Piña, Chief Online Learning Officer, Illinois State University

If your institution offers online courses and the words ‘regular and substantive interaction’ do not ring a bell or cause you concern—they should. Regular and substantive interaction (RSI for short) determines whether the tuition for online courses is allowed to be paid for by federal financial aid. An online course without evidence of RSI is liable to be classified as a correspondence course, and any federal funding received for that course will have to be returned to the U.S. Department of Education (USDOE).

The U.S. Federal Government defines 'distance education’ and ‘correspondence education’ as instruction delivered between students and instructors who are physically separated. However, in correspondence education, the interaction between instructors and students is limited, is not regular and substantive, and is primarily initiated by the student. Distance education courses support regular and substantive interaction between the students and their instructors, either synchronously or asynchronously. Distance education can be federally funded, while correspondence education cannot. That is why those three letters (RSI) are so important.

If RSI is so important, why haven’t I heard of it?

When the COVID-19 pandemic hit in March 2020, the federal government declared a national health emergency and issued exemptions from federal regulations and requirements for distance and correspondence education. For the next few years, the amount of emergency remote teaching and the number of students logging in (rather than walking in) to their courses skyrocketed. With an existential crisis that threatened to shut down colleges and universities nationwide, the USDOE stopped enforcing its definitions and regulations for distance and correspondence education.

In 2023, President Biden declared the national COVID-19 emergency to be ended—along with the exemptions and flexibilities. Federal regulations are now beginning to be enforced again, and audits from the USDOE and accrediting agencies are now including RSI.

How are ‘regular’ and ‘substantive’ defined?

Audits conducted by the Department of Education’s Office of Inspector General (OIG) in 2012 and 2016 determined that online courses offered by St. Mary of the Woods College and Western Governors University should have been classified as correspondence courses. The OIG recommended that the institution be required to return $42 million and just under $713 million, respectively, to the USDOE in ‘overpaid’ financial aid monies used for these courses. Fortunately for the two institutions, they argued successfully that the definitions and directions provided insufficient guidance to determine whether RSI was sufficiently implemented. In 2018-19, the USDOE provided clearer definitions and guidance regarding RSI.

Regular Interaction

For distance education courses, regular means interaction that is predictable and scheduled, originating primarily from the instructor. This requirement can be met if instructors make themselves available at a specific scheduled time and through a specific modality. For example, instructors teaching online can have regularly scheduled instructional sessions or office hours in which the dates and times are publicized in advance to their students. These can be done in person, via videoconference, live chat, or other modalities.

Substantive Interaction

Substantive interaction is defined as interaction between instructors and their students in teaching, learning, and assessment activities. Substantive interaction in online courses must include evidence of at least two of the following five activities occurring on a regular basis:

• Providing direct instruction means instruction is delivered synchronously. This may include instruction delivered via Zoom, Microsoft Teams, or another live videoconference technology.

"Regular and substantive interaction (RSI for short) determines whether the tuition for online courses is allowed to be paid for by federal financial aid"

• Assessing or providing feedback on a student’s coursework. This would include feedback from the instructor beyond merely assigning a grade. It also would not include exams/tests/quizzes that were automatically graded or assigned feedback from a system. The feedback must come from the instructor and can be text, audio, or video-based.

• Facilitating a group discussion regarding the content of a course or competency. Discussions in which all posts were generated by students would not be considered RSI. Instructors do not have to post replies to every individual student but must demonstrate active involvement and facilitation, such as summarizing student responses, providing new insights, asking leading questions, etc.

• Providing information or responding to questions about the content of a course or competency. An example of this may be providing an "Ask the Instructor” discussion forum.

• Other instructional activities approved by the institutions or program’s accrediting agency.

What if students do not take advantage of my office hours or feedback?

Instructors are required to only provide opportunities for regular and substantive interaction but are not expected to force students to take advantage of these opportunities.

Is RSI required if the program only offers online courses, not degrees?

Yes, even if a program only offers individual online courses rather than fully online degrees, each of the courses must include evidence of meeting the requirements of RSI.

Does recording or using a video for my class constitute RSI?

Not by itself. Recording a video announcement or lesson, recording a live Zoom session for later viewing, or embedding a YouTube video are all great things to do. However, these are one-way interactions, so they are not RSI. However, many LMSs allow you to enable students to post comments on videos, embed test questions into videos, and allow you to post videos into discussion boards and tests—all of which turn one-way interactions into two-way interactions. RSI entails two-way interactions between you and your students.

Conclusion

For faculty and administrators alike, regular and substantive interaction is not just about meeting federal requirements for financial aid. It is about an important part of the online learning experience—the interaction between instructors and their students. For all those who care about students, the three letters R-S-I should be a priority.