Regular & Substantive Interaction
What it means for distance education compliance.
In September 2020, the U.S. Department of Education established new requirements that fundamentally changed distance education standards. Any course where students utilize Title IV funds—federal financial aid—must now demonstrate Regular and Substantive Interaction (RSI) between students and faculty.
This requirement affects millions of students across thousands of institutions nationwide, making RSI compliance a critical priority for higher education administrators.
What is "Distance Education"?
Distance Education is defined as:
Education that uses one or more of the technologies listed below to deliver instruction to students who are separated from the instructor or instructors and to support regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously. The technologies that may be used to offer distance education include:
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The internet;
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One-way and two-way transmissions through open broadcast, closed circuit, cable microwave, broadband, fiber optic, satellite, or wireless communication devices;
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Audio conference;
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Other media used in a course in conjunction with any of the technologies listed in this definition.
For the purposes of this definition, substantive interaction is engaging students in teaching, learning, and assessment, consistent with the content under discussion, and also included at least two of the following:
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Providing direct instruction;
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Assessing or providing feedback on a student's coursework;
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Providing information or responding to questions about the content of a course or competency; or
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Facilitating a group discussion regarding the content of a course or competency; or
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Other instructional activities approved by the institution's or program's accrediting agency.
(Distance education definition adopted from Code of Federal Regulations 34 CFR § 600.2)
Regular Substantive Interaction (RSI) represents a fundamental shift in how we approach distance education. It ensures that online courses provide meaningful, consistent engagement between students and instructors—moving beyond passive content consumption to active, participatory learning experiences.
This isn't just pedagogical best practice; it's a federal requirement that shapes how institutions design and deliver online education.
This definition helps clarify what falls short of RSI requirements. In correspondence courses, students work independently through materials with minimal instructor involvement. The instructor responds only when contacted, rather than proactively engaging students.
Online courses that rely solely on pre-recorded content without regular instructor engagement risk being reclassified as correspondence courses, potentially affecting financial aid eligibility.
Five Core Requirements of RSI
Instructor-Led
All interactions must be with a qualified instructor, not solely with peers or automated systems.
Instructor-Initiated
The instructor must proactively initiate engagement, not wait for students to reach out.
Scheduled & Predictable
Interactions occur on a consistent, planned basis that students can anticipate.
Academic in Nature
All interactions must be directly relevant to course content and learning objectives.
Direct Interaction
Assumes genuine engagement between the learner and instructor, not passive content delivery.
The Department of Education provides specific examples of activities that meet RSI requirements. These span synchronous and asynchronous modalities:
Contextualized ContentProviding pre-recorded lectures and videos that contextualize course material and connect learning objectives. |
Discussion FacilitationActively facilitating group discussions about course content or competencies, not just monitoring forums. |
Live SessionsHosting synchronous class sessions where real-time interaction and instruction occur. |
Curated ActivitiesEngaging students with interactive learning activities specifically designed by the instructor. |
Guided ProjectsFacilitating collaborative group projects with active instructor guidance throughout the process. |
Individual MeetingsScheduling one-on-one virtual meetings to address individual student needs and progress. |
Assessment and Feedback Matter
Critical RSI Components
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Assessing student coursework with meaningful evaluation criteria
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Providing timely, constructive feedback that advances learning
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Responding to questions about course content promptly and thoroughly
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Clarifying concepts when students demonstrate confusion or misconceptions
These activities represent the substantive, direct interaction at the heart of RSI requirements.
Moving Forward with RSI Compliance
Key Takeaways
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RSI is a federal mandate, not optional best practice
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Requires intentional course design from the outset
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Instructors must be proactive, not reactive
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Documentation of RSI activities is essential for compliance
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Both substantive content and regular scheduling matter
Institutions must audit existing online courses and establish clear RSI policies to ensure compliance while enhancing educational quality.
Resource: CSU QLT Section 4
The CSU Quality Learning and Teaching (QLT) Tool Section 4 focuses on Student Interaction and Community, providing specific objectives that align with RSI requirements.
Updated: October 30, 2025