What is Regular and Substantive Interaction (RSI)?.

April 28, 2022

By: Megan Larkin

Reading Time: 4.1

After a 2012 US Department of Education (DoE) Office of Inspector General (OIG) audit, Saint Mary-of-the-Wood College found itself on the hook for repayment of $42 million worth of federal financial aid funds. A similar audit in 2017 left Western Governor’s University responsible for repaying at least $713 million (you read that right) of federal financial aid funds. Why? In both cases, the DoE OIG found what it deemed to be insufficient levels of Regular and Substantive Interaction (RSI) in the institutions’ eLearning programs. This is a situation you do not want to find your educational institution facing. So what exactly is RSI? And how can you ensure that the DoE OIG knows you’re doing it? We’ll touch on both topics here.

What is RSI

RSI refers to “regular and substantive interaction” between instructors and students in distance education eLearning courses. RSI is key to facilitating high-quality learning and verifying that high-quality learning is happening at your educational institution as well as a way for the U.S. Department of Education to differentiate “distance education” from “correspondence education.” Implementing and documenting RSI has an enormous impact on your institution’s eligibility to receive federal financial aid dollars. Here’s how it breaks down:

  • Correspondence courses are not eligible for federal financial aid
  • If 50% of courses at an institution are classified as correspondence courses, the institution as a whole is not eligible for financial aid.
  • Distance education, which is eligible for financial aid, is differentiated from correspondence education as having “regular and substantive interaction” (RSI) between instructors and students.
  • Failure to demonstrate RSI can result in online courses being counted as correspondence courses, thus jeopardizing your institution’s eligibility for federal financial aid dollars.

In 2012, it became evident that the DoE OIG was prepared to back up that last bullet point with substantial penalties. That’s when Saint-Mary-of-the-Wood College – and, 5 years later, Western Governor’s University – failed their DoE OIG audits and were faced with tens of millions of dollars in federal aid repayment. In 2019, the DoE found that neither Saint Mary-of-the-Wood nor WGU had to pay back the aid because of the ambiguity of the law and regulations at the time of the audit period. Still, both institutions had to spend hundreds of thousands of dollars in legal fees during the dispute.

How IntelliBoard Can Help

You definitely don’t want to find yourself in Saint Mary-of-the-Wood or WGU’s shoes. So how can you go about documenting RSI at your institution? The IntelliBoard Learning Analytics Platform allows for institution-level monitoring and documenting of instructors’ interactions with their courses and students through engagement and course content utilization statistics.

Bolded text represents language from taken directly from the definition of RSI in Title 34 Part 600 Subpart A. IntelliBoard can facilitate Regular and Substantive Interaction by:

Monitoring, organizing, and analyzing learner performance to aid the instructor in assessing or providing feedback.

Providing instructors with an opportunity to monitor their own course activities as well as their students’ through the Instructor Dashboard. The instructor can keep track of when and how often they are engaging with their students both collectively and individually to make sure they are “providing the opportunity for substantive interactions with the student on a predictable and scheduled basis.”

Alerting the learner, instructor, and institution when a student exhibits symptoms of being at-risk so that the instructor can then promptly and substantively engage with that student so that they are “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.”

Compiling reports with descriptive, predictive, and prescriptive learning analytics that not only help instructors and institutions improve their courses, but also aid in the documentation of RSI for the respective state and federal level Departments of Education.

Regular and Substantive Interaction has a significant impact on your institution’s eligibility to receive federal financial aid dollars. Failing a DoE OIG audit is not an option. As such, demonstrating and documenting RSI is vital for any higher education institution in the US.

The bottom line?

Institutions that want to receive federal financial aid need to ensure that they are not only implementing solid RSI in their eLearning courses, but that they have the documentation and reporting to back it up. Let IntelliBoard’s Learning Analytics Platform save you tens of thousands of dollars and hundreds of hours by assisting with facilitating and documenting RSI.

Interested in learning more about RSI and how your institution can make sure it’s prepared for a DoE OIG audit? Check out our eLearning experts’ deep dive into RSI.

Do you need help streamlining the implementation and documentation of RSI at your educational institution? Let us help you. Schedule a meeting with us or take advantage of our webinars. We’d love to help you harness the power of your data.

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Megan Larkin

Megan Larkin is an advocate and writer with a Master’s degree in Educational Leadership and Policy Studies and has extensive experience in the public education ecosystem. Her mission in life is creating tools so that all kids have access to high quality, easy to use EdTech and digital learning.


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