Title IV of the Higher Education Act and its implementing regulations draw a critical distinction between “distance education” and “correspondence education.” While both categories involve educating at a distance, including online education, typically only courses/programs that meet the distance education definition are eligible for Title IV student aid funding. The key difference between the two (and between Title IV eligibility and ineligibility in many cases) is that distance education supports “regular and substantive interaction between the students and the instructor” (i.e., “RSI” as it’s commonly referred to) whereas correspondence education does not. This is not to say distance education courses must have synchronous components, however, as interaction opportunities can be fully asynchronous as well.

In Practice

The RSI rule requires that instructors offer frequent and predictable opportunities for students to interact with them on topics relevant to the course through instruction, assessment, and discussion among other activities approved by the institution’s accrediting agency. At least two different forms of engagement must be present in the course. Additionally, the rule requires that instructors monitor students’ progress and initiate dialogue with students as needed or at the students’ request.

Following best practices in online teaching and course design is often the best approach for compliance with the RSI rule. It may still prove helpful, however, to ensure specific components or activities that would qualify as RSI opportunities do appear in the syllabus/course materials. Not only would this transparency benefit students but having documentation to demonstrate RSI was scheduled in advance may also be valuable in the event of an audit. While learning can obviously still occur through ad hoc and student-initiated interaction, and such interaction should be encouraged, for opportunities to be considered RSI, they must be initiated by the instructor, not the students.

There is significant crossover between activities that would qualify as RSI opportunities and those that would qualify as opportunities for “academic engagement,” which must be made available weekly throughout the course for financial aid purposes. It may be helpful to consider this overlap when planning RSI opportunities, such as by taking an otherwise student initiated/completed weekly academic engagement opportunity and having an instructor provide feedback, address questions or ask follow up questions, respond to discussion posts, etc. there is no requirement for how often RSI opportunities must be provided; however, an approximately once-per-week cadence may serve as a good marker for the typical 3-credit, traditional term course.

FAQs

The responses below offer practical suggestions for demonstrating compliance with federal rules and should not be considered legal advice. It is possible that enforcement agencies may have different interpretations of these rules and whether the suggestions provided below satisfy minimum expectations. The Center for Academic Innovation (CAI) will continue to update this FAQ section with new questions and answers as additional guidance becomes available.

What are some ways to demonstrate that opportunities for RSI are “scheduled and predictable?”

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.

How should I communicate to my students about their expected participation in the class?

Participation in class should be encouraged for successful completion of the course regardless of what federal rules require; however, RSI rules require only that students are given “opportunities” to engage in RSI, not that students take those opportunities. 

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.”

Is there anything in particular that we should be thinking about for mini-courses (7-week courses)? Do the requirements change at all?

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).

 

Do the rules distinguish between synchronous and asynchronous activities? If so, do they have any requirements for synchronous activities?

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 applies to synchronous instruction only. Therefore, we would strongly recommend ensuring that some opportunity for active participation beyond attendance/passive engagement is made available to the student whenever relying on asynchronous activities to meet RSI or academic engagement requirements.

Does autograding or computer-generated feedback count toward RSI? What about GenAI grading and feedback?

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). The same could be said about uses of GenAI grating and feedback tools or use cases. These can be used (though see the GenAI page for a discussion of ethical and legal issues that should first be considered) but RSI requirements will still need to be satisfied through other means.

For the “at least two” types of substantive interaction requirement, how often do at least two need to be demonstrated?

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.

What does student progress monitoring look like?

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.
Who is/should be responsible for student progress monitoring?

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 occurring 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.

Do we need a school/program level monitoring system to create an official record or do the faculty just need to ensure that they are meeting these guidelines?

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.

How does this regulation (if at all) relate to “last date of attendance” in a course for bursar/registrar/financial aid functions?

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.” More information about which activities qualify as academic engagement can be found on the Academic Engagement and Attendance page.

Is there any difference in the Department’s RSI expectations for graduate versus undergraduate courses?

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.

1 There are exceptions, such as when student schedules feature only a limited amount of correspondence course credits as part of an otherwise eligible distance-education program