Regular & Substantive Interaction

Listing out dates/cadences for RSI opportunities on a syllabus may be the most effective way to demonstrate compliance with this requirement (e.g., “There will be short assignments due each Friday. The instructor will provide feedback on these assignments during the following week.”). Other ways to demonstrate compliance could include designating times for office hours that are announced to students in advance or added to a course calendar, scheduling windows for asynchronous Q&A about specific topics or assignments, or alerting students to specific dates where students can expect written instructor feedback on major assignments, assessments, or drafts.

While participation should be encouraged regardless of what federal rules require, the new RSI rules require only that students are given “opportunities” to engage in RSI. Though, the new RSI rules do also separately require instructors to intervene when students are found to be struggling on the basis of academic engagement monitoring, which may not be possible to demonstrate without student participation occuring. Being able to document instances of active engagement may prove helpful in other areas as well, such as when evidencing the last date of attendance for Return of Title IV Funds (R2T4) purposes. It would therefore be advisable to communicate in one’s syllabus or courses description materials both (i) the schedule of RSI opportunities and other forms of academic engagement and (ii) descriptions for how students and instructors will be engaging with one another during and after these opportunities take place. For example, if a course uses discussion boards, a syllabus might include language similar to the following: “Student participation in weekly discussions is critical in informing the instructor of how well students are progressing through the course. The instructor will facilitate these discussions, and may also follow up directly with individual students to continue these conversations and further promote learning.”

Please consult with the U-M Registrar’s Office before designing courses with unique term lengths as condensing a course can have implications for financial aid, add/drop, and withdrawal procedures. The Operations Section of the OHP Playbook contains additional information on this topic.

Regarding the application of these recent rule changes, interaction must still be predictable and scheduled and must also occur as needed based on assessment of student progress and success or when requested by the student—all to be considered “regular.” Specifically, the frequency/amount of instructor-student interaction opportunities must be “commensurate with the length of time and the amount of content in the course or competency.” Because shorter courses are expected to have a similar total number of interaction opportunities as longer courses awarding the same number of credits, the frequency of RSI opportunities would likely need to be greater within that condensed period (e.g., if a 3-credit, 14-week course has approximately one RSI opportunity per week, the same course condensed into 7 weeks could be expected to feature approximately two RSI opportunities per week instead).

 

Both academic engagement and RSI can be either synchronous or asynchronous. While synchronous options are often listed without other conditions (i.e., the student simply showing up might suffice), asynchronous options are often conditioned on the presence of “interactive” elements.

Regarding RSI, specifically, one of the substantive interaction examples provided is “direct instruction,” which we believe applies to synchronous instruction of any kind but likely would not be interpreted as inclusive of asynchronous direction instruction unless instructor interactive elements are also present. Additional guidance from the Department on this issue would be appreciated. In the meantime, we would strongly recommend ensuring that some opportunity for active participation beyond attendance/passive completion is made available to the student whenever relying on asynchronous activities to meet RSI or academic engagement requirements.

The Department still considers autograding to lack the presence of an “instructor,” even when an instructor has written specific feedback scenarios. This does not mean autograders should not be used, and indeed autograded assignments are still helpful for demonstrating “academic engagement” and can be used as part of monitoring efforts. However, “human” feedback would still be needed, perhaps directly alongside the autograded feedback, for such feedback to count as RSI (e.g., multiple choice mixed with short answers reviewed by the instructor and/or accompanied by substantive feedback from the instructor about why certain answers are right or wrong or perhaps suggestions for where to look for additional information).

Two or more types of substantive interaction can be featured at any point during the course (as long as at least one type satisfies the “regular” requirement). Specifically, the Department has stated that:

The definition requires an institution to perform at least two of those activities, and since we apply the regulation at the course or competency level, we also require an institution to perform at least two of those activities over the period of time that the student completes the course or competency. We believe that requiring a specific timeframe, sequence, or frequency that the activities need to occur within that timeframe would be impractical and would extend beyond our purview under the Department of Education Organization Act. 85 FR 54758-59, Preamble.

Instructors are not required to personally monitor each student’s engagement throughout each class session while also instructing, facilitating discussion, or responding to questions from students, etc. Instead, the Department is asking that instructors are able to generally determine when a student is “engaged and successful throughout a given course or competency,” which can be achieved through a number of means, including:

• evaluating a student’s level of participation in synchronous class sessions;
• monitoring the student’s activity on course websites or materials;
• considering the quality of the student’s assignments or responses to questions about course materials;
• or evaluating the level of the student’s understanding of course materials during conversations with instructors or performance on exams.

85 FR 54757, Preamble.

While the rules themselves specify only that the “institution” is responsible for monitoring academic engagement, it is worth noting that “instructors” are ultimately responsible for providing substantive interaction where needed on the basis of such monitoring and instructors would serve as the last line of defense where no monitoring is occuring at the departmental or institutional level. As U-M does not have a university-wide policy addressing this requirement, individual academic units would have flexibility in setting their own procedures as desired. Where specific technologies or academic support staff would be leveraged as a means of meeting the monitoring requirement, there may be benefits in coordinating an approach at the department level as well.

There is no requirement to create a school/program level monitoring system. However, having such a system could prove helpful in documenting compliance efforts and, depending on its use, could potentially be used to remove burden from individual instructors. Departments are encouraged to engage their faculty in conversations around whether centralized monitoring solutions or the adoption of department-wide monitoring practices may be desirable.

Yes, instructors are still responsible for initiating RSI but must now only provide for the “opportunity” for RSI regardless of whether individual students take advantage of those opportunities. However, with the new monitoring and intervention requirements, struggling students who reach out to instructors can also, in effect, initiate RSI. While instructors must respond to students who are seeking additional support, this requirement should not be viewed as replacing any other instructor-initiated RSI obligation.

While the updates to RSI do not impact attendance, the Department also moved certain concepts associated with Return of Title IV Funds (R2T4) provisions into a new definition for “academic engagement” as part of this same rulemaking process, which does have an impact on attendance. Unless an academic unit has its own policy addressing this issue, taking attendance is not specifically required at U-M. However, when R2T4 issues arise, the determination of a student’s last date of attendance would need to be based on the last recorded date of “academic engagement.”

Academic engagement is any “active participation by a student in an instructional activity related to the student’s course,” which can include but is not limited to attending classes where there is an opportunity for interaction, submitting an academic assignment, taking an assessments, participating in an interactive tutorial, webinar, etc., participating in study groups or online discussions assigned by the institution, or interacting with an instructor about academic matters. Academic engagement does not include logging into an online class without further participation or participating in academic counseling or other opportunities that are not specific to the course itself. 85 FR 54808.

There are no stated differences in expectations based on the level course level. However, the Department is likely to defer to the institution’s accreditor in making determinations about what difference may be appropriate across degree levels.

The Center for Academic Innovation maintains this Collection of Additional Resources.