Meeting Regular and Substantive Interaction (RSI) Requirements

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Last revised: 2/5/2025 by ess

Overview

This article provides examples for meeting the federal requirement for online or distance learning courses to “support regular and substantive interaction (RSI) between the students and the instructor, synchronously or asynchronously” (Downs, 2021).

Regular and Substantive Interaction (RSI) Background

In order for online students to receive financial aid, they must be enrolled in distance education courses, not correspondence courses. The Higher Education Opportunity Act (HEOA) of 2008 600.2 differentiates distance education from correspondence courses by stating distance education is “education that uses one or more technologies to deliver instruction to students who are separated from the instructor and that supports ‘regular and substantive interaction’ between the students and the instructor, synchronously or asynchronously” (HEOA, 2008). For years higher education institutions struggled defining regular and substantive interaction (RSI) because federal requirements and expectations surrounding RSI were somewhat unclear. On August 24, 2020 the Department of Education issued Final Rules on Distance Education and Innovation to help clarify the Regular and Substantive Interaction (RSI) requirements. The NC Sara organization posted the following announcement of the U.S. Department of Education Issues Final Rules on Distance Education and Innovation.

What is RSI?

While there is still room for interpretation, the final rules issued by the Department of Education help shape the definitions of “regular and substantive interaction.” Let’s review how the US Department of Labor defines RSI by breaking it down into the following two parts (U.S. Dept of Ed, RSI Regulation):

Regular Interaction:

An institution ensures regular interaction between a student and an instructor (or instructors) by:

  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 before the student completes the course or competency.
  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.

Substantive Interaction:

For the purposes of this definition, substantive interaction is:

  1. Faculty providing an engaging learning environment, with the teaching, learning, and assessment consistent with the content presented in the course, and
  2. At least two of the following:
    1. Providing direct instruction;
    2. Assessing or providing personalized feedback on a student’s coursework (not auto-generated);
    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. [Note: UConn’s accreditor is the New England Commission of Higher Education (NECHE).]

Ways to Meet RSI

The following examples outline some of the types of interactions that would help faculty meet the RSI requirement (Empire State University, n.d.).

  • weekly course announcements tailored to the course;
  • weekly summaries or highlights of discussion threads;
  • regularly scheduled office hours and/or online review/help sessions;
  • regular announcements and/or emails previewing or reviewing difficult content;
  • listing out questions for students to ponder when interacting with the assigned materials each week;
  • instructor-facilitated discussions illustrating real life applications of course concepts;
  • personalized, specific, and detailed feedback to individual students.

(Note: At least two types of interactions are required to meet RSI)

SUNY Empire created the following creative commons RSI dashboard image (shown below) to help faculty visualize the RSI regulations in terms of a scale. Activities aligning more closely with “correspondence education” are on the left and “distance education” are on the right in this RSI dashboard image.

RSI gauge showing lower RSI activities on the left of the gauge to higher RSI activities to the right.

Image credit: “RSI Scale” by Empire State University is licensed under CC BY-NC-SA 4.0.

Additional Resources

Related Resources

References

  1. Downs, L. (2021, August 26). Regular and Substantive Interaction Refresh: Reviewing & Sharing Our Best Interpretation of Current Guidance and Requirements. Western Cooperative for Educational Telecommunications (WCET).
  2. Higher Education Opportunity Act (HEOA)- Public Law 110-315. (August 14, 2008). Sec. 102, Definition of institution of higher education for purposes of title IV programs.
  3. Empire State University. (n.d.). Background: Definitions of distance education and correspondence courses.
  4. U.S. Department of Education Negotiated Rulemaking for Higher Education. RSI regulation – see pp. 339-341. Found in the Department of Education, Office of Postsecondary Education, Distance Education and Innovation.
  5. Harding, B. (2024, November 14). Identifying imposters: Recognizing the differences between correspondence course interaction and distance education course interaction [Webinar]. Anthology DTS24.