Regular and Substantive Interaction Unit Rule for Oregon State University

The U.S. Department of Education provides regulations guiding online education. To be eligible for federal financial aid, the U.S. Department of Education requires that distance education courses provide students with regular and substantive interaction (RSI). “Distance education courses” at OSU are those that are delivered in online or hybrid format via Ecampus.

RSI is what distinguishes distance education from correspondence courses. RSI is critical for providing a high-quality educational experience and supporting student success. Over the years, the Department of Education has defined the RSI requirement to include three criteria: regular, substantive, and instructor-led, which are described below.

For purposes of fulfilling RSI requirements, “Instructor” is defined as a qualified faculty member, which may include graduate teaching assistants. Undergraduate learning assistants or peer tutors are not considered qualified faculty members for the purpose of meeting RSI requirements.

RSI Defined

Under RSI, interaction between instructional faculty and students must be regular, substantive, and instructor-led interaction. That is, interaction with students must:

• Be predictable and scheduled: in OSU's quarter system format, regular interaction must happen weekly and throughout the term;
• Be substantive: to be engaged in “substantive” interaction, the online course instructor must do at least two of the following three actions:
  1. Assess or provide feedback on student work (does not include auto-grading or grading completed by artificial intelligence);
  2. Provide information or respond to questions about course content (e.g., responding to student questions in discussion forums, holding regularly scheduled office hours);
  3. Facilitate group discussions regarding course content;

• Be initiated by the instructor (e.g., it is not sufficient to only state the instructor is available if students have questions without other regular, instructor-led, and substantive interactions.); and
• Include monitoring of students’ academic engagement and success, including proactively engaging in substantive interaction when that monitoring suggests a need for additional support (e.g., reaching out to a student who is not participating or whose work quality is below a satisfactory level).

At OSU, online courses and programs are delivered asynchronously. The lists below demonstrate the kinds of activities that would and would not count as RSI in an asynchronous learning environment.

Examples of Regular, Substantive, and Instructor-led (RSI) Interaction

• Posting weekly announcements discussing course concepts.
• Posting weekly announcements addressing common errors or misconceptions noticed in the grading of course assignments.
• Facilitating online group discussions pertaining to course content.
• Responding to student questions about course concepts or learning activities.
• Dedicating a special discussion forum for student questions, monitoring for questions and responding promptly.
• Providing prompt, constructive, and personalized feedback on student assignments.
• Holding regularly scheduled virtual office hours to allow students the opportunity to ask questions live.
• For hybrid courses, instructor-led interactions during synchronous class meetings.

Examples that are insufficient and do not meet RSI requirements

• Courses in which all interaction with the instructor is wholly optional or only initiated by the student.
• Interaction initiated primarily by the student or occurring only upon the request of the student.
• Activities such as merely logging into an online class or tutorial (not created/managed by the instructor) without further participation or participating in academic counseling or advisement.
• Posting an announcement about an assignment due date or any topic that doesn’t allow for interaction.
• Recorded lectures that do not allow for interaction.
• Office hours by appointment (because this requires initiation by the student). Note: Instructors may offer office hours by appointment, but RSI must be met in other ways.

Activities listed that do not meet RSI requirements may still be worthwhile but would need to be in addition to activities that do meet RSI requirements.

Support for Faculty

OSU provides faculty support and training and monitors distance education courses to ensure that RSI requirements are being met. Ensuring that RSI requirements are met is a shared responsibility at OSU.

• The Division of Educational Ventures (DEV) provides training for faculty developing and teaching online courses to ensure that online and hybrid courses are designed to promote regular and substantive instructor-led interaction and that faculty are prepared to facilitate courses in ways that meet or exceed RSI requirements. DEV provides information in their regular announcements about RSI to faculty teaching Ecampus courses, including links to OSU’s RSI unit rule, relevant Ecampus trainings, and contacts for support/questions about RSI. The Ecampus Online Teaching Principles have been designed to help faculty meet or exceed RSI requirements and teach effectively in both the online and asynchronous format.
• Faculty teaching distance education courses are expected to meet or exceed RSI requirements in the delivery of online and hybrid courses. Faculty learn about RSI requirements through required and optional Ecampus trainings. At that time, faculty are provided with an Ecampus RSI Quick Reference Guide to review and demonstrate compliance during regular conversations with their supervisor.

• Academic units are expected to monitor distance education courses and evaluate faculty who teach distance courses based on RSI criteria. School heads monitor and enforce RSI compliance through a combination of 1) review during the term, and 2) during regular conversations with their academic faculty employee. Review during the term includes monitoring through reports, with supervisors reaching out to faculty who have not been regularly, substantively, and interactive with students in their Canvas course.

Additional Resources

• Ecampus Quick Reference Guide for Regular and Substantive Interaction includes checklists to help faculty establish and sustain RSI
• WCET Policy Brief on Regular and Substantive Interaction (2023)
• New Guidance on "Regular and Substantive" (Inside Higher Ed, 2022)
• WCET Policy Analysis of Regular and Substantive Guidelines (2021)
• Department of Education Final Rulemaking (2020)
• Ecampus Essentials, OSU's online course design standards
• Ecampus Online Teaching Principles, OSU's guidelines for effective facilitation of online and hybrid courses