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Title IV Compliance in Online Courses

A guide for finding Title IV resources and information

What is regular and substantive interaction?

Four Elements of Regular and Substantive Interaction

Auditors review interactions between instructors and students based on the following four elements. Interactions must have all four elements to be considered "regular and substantive" interactions. 

1. Initiated by Instructor

This requirement is not explicitly cited in the regulations, but it has shown up in audit findings for other universities. For example, in the St. Mary-of-the-Woods report, the auditors 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."

This element comes from distinguishing between correspondence courses and online coursework. Correspondence courses are expected to have limited interaction with an instructor. Additionally, students initiate most of the "interaction" by turning in assignments, exams, and papers.

In an online course, it is expected that students have regular interaction with the instructor throughout the course and that the instructor initiates some interaction. In face-to-face classes, instructor initiated interaction occurs in the classroom through the lecture or in-class activities. Online, this could be an instructor posting a weekly announcement with a mini-lecture, the instructor interacting on the weekly discussion board, or in-depth feedback on student's assignments.

2. Regular Interaction

Merriam-Webster's simple definition of "regular" is:

  • Happening over and over again at the same time or the same way; occurring ever day, week, month, etc.
  • Happening at times that are equally separated
  • Happening or done very often

Overall, the intent is that online instructors would be in regular contact with students throughout the course. Findings from other institutions indicated that interaction from instructors should not be on an "as needed" basis (i.e., instructor initiated interaction when they notice a student is struggling) and interactions should be frequent.

In an online course, instructors should consider the frequency and type of regular interaction they have with students.

3. Substantive Interaction

The Department of Education (DOE) would like the frequent, instructor initiated interactions to be substantive or of an academic nature. All online courses include content that is "of an academic nature" so it is important to consider the nature of instructor's communication throughout the course.

Examples of Interactions that are Substantive

  • Regularly schedule synchronous activities or study group - Host a live BlueJeans session or use Conferences in Canvas. Instructors can record the session for students who cannot join live.
  • Actively participate in an online discussion board - Instructors can respond to student posts or provide content feedback privately to each student in SpeedGrader.
  • Send weekly announcements - Announcements could include week's content and provide additional guidance than what already exists in the course. In Canvas, instructors can schedule announcements to be sent each week ahead of time.

Examples that are Not Substantive

  • A student turns in an assignment, quiz, exam, or paper (not instructor initiated)
  • An announcement that informs students about an error in Canvas or a change in due date (not of an academic nature)
  • Student-led study groups (not an interaction with the instructor)

4. Interaction from Instructor that Meets Accrediting Agency Standards

To be considered "regular and substantive," instructor initiated interaction must come from an instructor who meets accrediting agency standards. The purpose of this regulation is to ensure students received instruction from a qualified individual. The DOE leaves the definition of "qualified" up to the discretion of the institution's accrediting body.

Northwest Nazarene University is accredited by the Northwest Council of Colleges and Universities (NWCCU). According to the NWCCU, a qualified instructor is someone who ____. An instructor's qualifications are screened in the hiring process. If an instructor is a full-time teaching faculty member, an approved adjunct, or an approved clinical supervisor, it is likely they meet the accrediting agency standards. Teaching assistants would not typically meet accrediting agency standards unless they were also a full-time faculty member or approved adjunct or clinical supervisor.

 

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