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Note: This policy was approved by the WVC Distance Education Committee on October 21, 2025 and is currently pending WVC Academic Senate approval.

WVC Policy on Regular and Substantive Interaction (RSI) in Distance Education Courses

To comply with federal and state regulations, this policy defines how ×îÐÂÂ鶹ӰÒôÊÓƵ ensures Regular and Substantive (RSI) in distance education courses. Practical examples are included to guide implementation.  

See the full text of the federal and state RSI regulations at the end of this document. 

Substantive Interaction Must Happen on a Regular Basis 

×îÐÂÂ鶹ӰÒôÊÓƵ faculty must fulfill both the substantive and regular components of interaction as defined in this policy. The substantive interaction definition mirrors the federal definition (4a-4d). The regular interaction definition includes the federal definition (5a-5b) and then provides additional guidance on how faculty are expected to meet those requirements. 

Definition: Substantive Interaction 

Substantive interaction means engaging students in teaching, learning, and assessment that is consistent with course content. To meet requirements for substantive interaction, faculty must regularly engage students using at least two of the following methods (italicized language comes directly from the federal regulations): 

• (4a) Providing direct instruction;
• (4b) Assessing or providing feedback on a student's coursework;
• (4c) Providing information or responding to questions about the content of a course or competency; or
• (4d) Facilitating a group discussion regarding the content of a course or competency. 

Definition: Regular Interaction

To ensure substantive interactions are regular, faculty must meet both requirements (italicized language comes directly from the federal regulations):

• (5a) Predictable and scheduled opportunities:
  • In a semester-length course, faculty must engage students using at least two different methods of substantive interaction during any given two-week period.
  • In shorter-term courses, substantive interaction must occur more frequently, consistent with the accelerated schedule, to ensure equivalent total engagement. 
• (5b) Monitoring students’ academic engagement and success:
  • Faculty must promptly and proactively initiate substantive interaction with students when needed, based on this monitoring or upon a student’s request. 

Student-Student Interaction Requirements

California’s Title 5 regulations require student-to-student interaction in distance education courses as outlined in the Course Outline of Record (COR) or distance education addendum (italicized language comes directly from state regulations).  

For this reason, faculty should refer to the COR to confirm student-to-student interaction requirements for each course. 

Examples of RSI in Practice

The following are examples of how each category of substantive interaction (4a-4d) might be demonstrated regularly (as outlined in 5a-5b) in an online class. Faculty can also meet RSI requirements using other methods not listed here. 

Substantive Interaction Examples

(4a) Providing direct instruction

• Use synchronous tools, such as web conferencing, to deliver live instruction during scheduled meeting times, with opportunities for interactive activities or post-lecture discussions. 

(4b) Assessing or providing feedback on a student's coursework 

• Provide regular and timely feedback on student work that goes beyond brief comments such as "good job" or "great work." For example, explain why a student earned a particular grade and offer specific suggestions for improvement.
• Use descriptive rubrics for student grading and integrate meaningful and actionable feedback into rubric categories. 
• In your syllabus or communication plan, set expectations for instructor response time, grading turnaround time, and participation for both students and instructors.
• Incorporate alternative feedback methods—like video or audio—to deliver personalized and engaging responses to student work. 

(4c) Providing information or responding to questions about the content of a course or competency

• Post regular announcements that are academic in nature. These might address common mistakes, connect course content to current events, or highlight key insights from the past week.
• Provide overviews of upcoming modules and summaries of recently concluded modules.
• Share detailed instructions and expectations for assignments, including how and when they will be graded.
• Provide timely responses to student questions via email, LMS messaging, or Q&A discussion boards to clarify course material. 

(4d) Facilitating a group discussion regarding the content of a course or competency 

• Facilitate whole-class discussions by posing prompts and engaging student responses with critical questioning to deepen their analysis.
• Create assignments where students collaborate in small groups on course-related tasks, with the instructor providing oversight and guidance.
• Interact with students through tools like social annotation platforms, encouraging collaborative engagement with course readings or resources.  

Regular Interaction Examples

(5a) Providing the opportunity for substantive interactions with the student on a predictable and regular basis commensurate with the length of time and the amount of content in the course or competency.

• Share a communication plan with students at the start of the course, outlining how and when interactions will occur (e.g., announcements, emails, office hours).
• Hold regularly scheduled office hours and encourage students to attend.
• Provide timely responses to student questions via email, LMS messaging, or Q&A discussion boards to clarify course material.
• Make announcements, modules and assignments (including interactive assignments) available on a predictable basis throughout the semester.  

(5b) 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.

• Use course analytics, early alert, and gradebook tools to track student engagement and progress and proactively reach out to students needing additional support.
• Follow up on opportunities for self-evaluation and reflection to provide feedback and guide student learning progress.
• Following exams and assessments, encourage students needing additional support to utilize office hours, tutoring services and other student support services offered by the college. 

Meaningful Course Components That Don't Count as RSI 

While the activities listed below are valuable components of a well-designed course, they do not meet the federal and state requirements for regular and substantive interaction (RSI). RSI specifically refers to instructor-initiated engagement that supports student learning.

Activities such as student-to-student or student-to-content interactions, though important for fostering engagement, do not fulfill this requirement unless they involve direct, purposeful interaction from the instructor - such as providing personalized feedback, guiding discussions, or facilitating learning through direct communication. 

The following are examples of activities that support student learning but do not satisfy the specific criteria for RSI.

• Recorded webinars and reading materials, either created by the instructor or curated from outside resources.
• Computer-generated feedback such as in a quiz or exam
• Humanizing interactions between faculty and students that are encouraging or about matters outside of course content.
• Discussion forums without instructor participation
• Discussions designed solely to facilitate student community and connections 

Federal and State Regulations on Regular and Substantive Interaction (RSI)

Federal Regulations - Definition of Distance Education (34 C.F.R. §600.2.)

Distance Education means:  

1. Education that uses one or more of the technologies listed in paragraphs 2(a) through (d) to deliver instruction to students who are separated from the instructor(s) and to support regular and substantive interaction between the students and the instructor(s), either synchronously or asynchronously.  
2. The technologies may include:  
   1. 1. the internet;
      2. one-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices;
      3. audioconferencing; or
      4. other media used in a course in conjunction with any of the technologies listed in paragraphs (a) through (c).  
3. For purposes of this definition, an instructor is an individual responsible for delivering course content and who meets the qualifications for instruction established by an institution's accrediting agency.  
4. For purposes of this definition, substantive interaction is engaging students in teaching, learning, and assessment, consistent with the content under discussion, and includes at least two of the following:  
   1. 1. Providing direct instruction;  
      2. Assessing or providing feedback on a student's coursework; 
      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.  
5. An institution ensures regular interaction between a student and an instructor or instructors by, prior to the student's completion of a course or competency
   1. 1. Providing the opportunity for substantive interactions with the student on a predictable and regular basis commensurate with the length of time and the amount of content in the course or competency; and 
      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.

State Regulations - Title 5. § 55204 Instructor Contact

The only notable difference between the above federal regulations and state Title 5 regulations is that Title 5 includes provisions for student-to-student interaction in distance education courses, but only if such interaction is explicitly described in the course outline of record (COR) or distance education addendum. This distinction appears in subsection (a) under Instructor Contact: 

(a) Any portion of a course conducted through distance education includes regular and substantive  interaction between the instructor(s) and students (and among students if described in the course  outline of record or distance education addendum), either synchronously or asynchronously,  through group or individual meetings, orientation and review sessions, supplemental seminar or  study sessions, field trips, library workshops, telephone contact, voice mail, e-mail, or other  activities.