Using OSCQR to address RSI
The SUNY Online course quality rubric – OSCQR, can assist you in understanding RSI and how to address it.
The first thing to keep in mind is that RSI is NOT about quality. It is the way that the DoE uses to distinguish Distance Education from Correspondence Courses for the purposes of financial aid. It is a US DoE regulation and compliance and accountability are at the institutional, online course design, and faculty levels.That said, to count as RSI, the regular and substantive interactions must:
- Be with an instructor as defined by the institution’s accreditor.
- Be initiated by the instructor.
- Be scheduled and predictable.
- Be academic in nature and relevant to the course.
Substantive interaction means:
- Assessing or providing feedback on a student’s coursework.
- Providing information or responding to questions about the content of a course.
- Facilitating a group discussion regarding the content of a course or competency.
- Any synchronous interaction like f2f or synchronous office hours
- Other instructional activities approved by the institution’s or program’s accrediting agency.
One of the easiest things to do to ensure compliance in part is to have a statement in the course syllabus that uses the RSI language. I have created a syllabus template that you can use as a model with an example of an RSI statement. To make sure you fully comply, in addition to having it stated in the syllabus, you have to make sure it is actually in the course design – i.e., stated in the online course information areas of the course and explicitly reinforced in the expectations communicated to the online learners in addition to via the syllabus. It also must be actually implemented by the instructor teaching the course. Since you are designing a program, the best thing would be to have consider addressing consistency across all the courses in the program in how RSI is addressed– e.g., ensure that all the courses in the program provide an RSI statement in the syllabus.
Another thing you could do that is fairly easy to do consistently across all courses in the program would be to leverage “office hours” for RSI to provide help to learners before or after assessed activities. To count as RSI, you would have to make sure to have it consistently documented in the course/syllabus, and the instructor must explicitly communicate the expectation in course materials, announcements, and assignment/assessment instructions and follow up, and create a mechanisms for that interaction (synch/asynch/f2f) related to specific assessments.
In addition, you should have a couple of other things that you can document to demonstrate compliance at the course and program levels. OSCQR standards 2, 3, 29, 38, 39, 41, 43, specifically address RSI and OSCQR Standards 1, 6, 9, 10, 19, 30, 31, 40, 44-47, can be leveraged to support and articulate RSI.
It is important to note that you don’t have to do all of the things listed in all the RSI OSCQR standards, and you can’t only have RSI types of interaction in an online course of high quality.
Here is a template to help you document RSI at the course and program level. If you do this for each course in your program, you will have documentation to demonstrate compliance from the institutional perspective. You don’t have to do this, but it could be adapted as an aspect of online faculty development training to build awareness and ensure that it has been considered as part of the online course design process.
There are some updates to questions for clarification from the DoE on definitions, process, and what counts as RSI. Led by WCET and other national distance education organizations on behalf of their members and all educators and institutions involved in online teaching and learning. This is an ongoing process, but WCET has documented new information based on clarifications provided by the DoE. See WCET’s Blog post: Regular and Substantive Interaction Refresh: Reviewing & Sharing Our Best Interpretation of Current Guidance and Requirements
The main questions have been around definitions and interpretations of the regulation regarding the definition of interaction, who counts as an instructor, what is meant my substantive and how is regular defined?
| PREVIOUS INTERPRETATION | CURRENT (AFTER JULY 1, 2021) | |
|---|---|---|
| INTERACTION | Only initiated by the instructor.
Previously, the DoE had stated: “We do not consider interaction that is wholly optional or initiated primarily by the student to be regular and substantive interaction between students and instructors. Interaction that occurs only upon the request of the student (either electronically or otherwise) would not be considered regular and substantive interaction.”
|
Mostly instructor initiated, some leeway.
“The new language allows for interactions “upon request of the student” for the first time. Previously, only interactions initiated by the instructor were counted. However, as discussed below, these student-initiated interactions alone will not suffice without additional instructor-scheduled opportunities for interaction.” |
| INSTRUCTOR | Meets accreditation standards.
A strict interpretation had been by some that GAs and TAs didn’t count. |
Explicit reliance on accreditor approval.
Instructional teams of OK. GAs and TAs may count. Need to check with accreditor. |
| SUBSTANTIVE | Of an academic nature.
There has been indication that direct instruction was defined as synchronous only (f2f or online). Under strict interpretation “auto-graded” assessments or “computer-generated” feedback didn’t count. |
List of activities include: instruction, assessment, tutoring, answering questions) The institution is expected to maintain policies or procedures that create expectations for faculty to substantively interact with students. it does not expect institutions to document the exact amount of time spent on any substantive interaction.“Direct instruction” would likely include asynchronous activities, such as participating in discussions, providing feedback, and office hour interactions with students focused on the subject of the class. A real-time, synchronous video lecture would count as direct instruction. A recorded lecture would likely not count as direct instruction.Online assessments qualify as substantive interaction, “assessing or providing feedback on a student’s coursework” but not sufficient, if there are no other types of interaction… assessments alone would not satisfy the requirement. Also, Interactions with artificial intelligence, adaptive learning systems, or other forms of interactive computer-assisted instructional tools will not meet the statutory requirements for regular and substantive interaction. |
| REGULAR | Regular and somewhat substantive.
Scheduled “office hours” could be used fulfill the regular interaction requirement, and would meet the requirement if instructors made themselves available at a specific time and modality, regardless of whether students chose to attend.
|
Predictable and scheduled and tracking and intervention. It is recommended that “institutions develop policies or procedures that create expectations for faculty to substantively interact with students on a predictable and scheduled basis and to monitor each student’s engagement and success and follow up with the student as needed. An example of “predictable” would be to say that a new lesson is released every Monday, Friday, or some equally predictable timeframe. An example of “scheduled” is the course syllabi in outlining when activities will happen in the course.” This requirement is an “opportunity” for interaction rather than a required interaction. It is believed that specific information in a course syllabus or other similar document shared with students that illustrates how quickly students can expect responses from their instructors may suffice to meet this requirement. The DoE has been asked to confirm. There is an expectation that instructors take a proactive approach to determining whether students need assistance. Institutions may be able to leverage data collected by their current learning management system as evidence of both interactions in online courses and of monitoring of student’s academic engagement and success. |
Summarized and quoted directly from the WCET article.
Tags: compliance, DoE, OSCQR, regular and substantive interaction, regulation, RSI
