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INDEX
PURPOSE
REASON FOR POLICY
ENTITIES AFFECTED
DEFINITIONS
POLICY STATEMENT
ROLES AND RESPONSIBILITIES
COMPLIANCE AND TRAINING REQUIREMENTS
EXCEPTIONS
APPROVALS
RELATED DOCUMENTS
REVIEW AND REVISION HISTORY
This policy clarifies the federal requirement for Regular and Substantive Interaction (RSI) in distance education courses, as mandated by the U.S. Department of Education. While federal regulations require RSI to distinguish distance education from correspondence education, the definitions provided are often vague. This policy offers clear, actionable guidance to faculty and instructional designers, ensuring compliance and promoting consistent interpretation across the Kentucky Community and Technical College System (KCTCS). It also supports institutional accreditation by providing a documented, transparent approach to implementing RSI standards. This policy is required to ensure institutional compliance with federal regulations set forth by the U.S. Department of Education (ED). As part of the Distance Education and Innovation rule, effective July 1, 2021, the ED mandates that distance education courses must demonstrate Regular and Substantive Interaction (RSI) between students and instructors. Failure to meet RSI requirements may result in the reclassification of courses as correspondence education, making them ineligible for Title IV federal financial aid.
This policy helps KCTCS meet the following mandates: - 34 CFR § 600.2 – Definition of Distance Education
- 34 CFR § 668.2 – Student Eligibility and Program Integrity
- Title IV of the Higher Education Act of 1965
Additionally, this policy supports institutional accreditation standards that require the delivery of high-quality and verifiable educational experiences in all formats, including online. The following groups are directly affected by this policy: - Faculty who teach online courses and are responsible for meeting RSI expectations
- Instructional designers and distance learning staff who support course development and ensure alignment with RSI standards
- Academic deans and program coordinators who oversee course quality and instructional compliance
- Compliance and accreditation officers who must verify RSI practices during internal and external reviews
- Financial aid and academic affairs administrators responsible for ensuring institutional eligibility under Title IV guidelines
- Students benefit from this policy.
Distance Education: KCTCS defines distance education as those courses where instruction is delivered to students who are not in the same physical location as the instructor or instructors. Distance learning requires regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously. Instructor: An instructor is an individual responsible for delivering course content and who meets the qualifications for instruction established by an institution’s accrediting agency. Substantive Interaction: Substantive interaction is engaging students in teaching, learning, and assessment, consistent with the course content. It must also include at least two of the following: - Providing direct instruction;
- Assessing or providing feedback on a student’s coursework;
- Providing information or responding to questions about the content of a course or competency;
- Facilitating a group discussion regarding the content of a course or competency; or
- Other instructional activities approved by the institution’s or program’s accrediting agency.
Regular Interaction: Regular is defined as frequent and predictable. Prior to the student’s completion of a course or competency, an institution ensures regular interaction between a student and an instructor or instructors by: - Providing the opportunity for substantive interactions with the student on a predictable and scheduled basis commensurate with the length of time and the amount of content in the course or competency; and
- 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.
Direct Instruction: Direct instruction is defined as faculty-initiated interactions. There are several activities that could be used to meet a requirement. For example, a recorded video is not direct instruction, but a recorded video used as part of an engaging online discussion where the instructor interacts with students would be. Feedback: Feedback is characterized by providing substantial, useful, and timely responses to students regarding the quality of their performance. Feedback should also offer suggestions for improved future performance. KCTCS is committed to complying with all requirements regarding the operation of online education. This policy addresses the U.S. ED regulations concerning RSI which consist of three components: (1) instructor-initiated interactions, (2) frequent and timely interactions, and (3) substantive interactions.
The ED has determined that interactions between faculty and students in distance courses must - Occur frequently and predictably (see the definition of Regular) and;
- Engage students in teaching, learning, and assessment activities, in alignment with course competencies, plus two additional demonstrable interactions (see the definition of Substantive)
Institutions within KCTCS are responsible for ensuring compliance with the ED standards for RSI and may be more prescriptive with requirements for meeting RSI within their courses. - Instructors are responsible for initiating regular and substantive interactions with students and ensuring that engagement aligns with course learning outcomes.
- Instructional Designers assist instructors in designing compliant course materials and interactions, ensuring alignment with RSI expectations.
- Academic Leadership (Deans, Chairs, Program Coordinators) oversee course quality and are responsible for verifying that courses meet RSI standards.
- Online Learning Units provide training, resources, and ongoing support to faculty and staff on how to integrate RSI effectively.
- Compliance and Accreditation Staff monitor institutional adherence, collect documentation, and coordinate with federal and accrediting bodies as needed.
To comply with federal regulations and ensure high-quality online education, KCTCS requires all online faculty new to teaching in the System to complete the KCTCS Online Faculty Orientation, available via the KCTCS Online SharePoint site. This training includes targeted modules that address federal RSI regulations (Module 7), strategies for establishing faculty presence (Module 4), and techniques for facilitating faculty-student interaction (Module 5). Completion of this orientation is required prior to teaching any online course and is tracked at the college level. Colleges may offer a locally developed version of this training, provided it fully aligns with all required learning outcomes and content topics and does not omit any required components.
In addition, all online courses must undergo a formal internal review in accordance with the KCTCS Online Learning Assessment (KOLA) plan. These quality assurance reviews, led by college teams, include feedback to faculty for suggested improvements. Courses found to lack required levels of interaction should receive a note for suggested improvements.
Responsibility for monitoring training rests with college Online Learning teams and academic leadership. Compliance will be documented through training completion records and quality assurance review logs. There are no exceptions to this policy. All courses offered for academic credit through distance education must comply with federal regulations requiring Regular and Substantive Interaction (RSI). Compliance is mandatory and non-negotiable under U.S. Department of Education rules. Approved by KCTCS President, Dr. Ryan Quarles on February 25th, 2026. A.P. 4.14 – Policy relating to implementation of online learning instructional support Initial Approval of the Policy: February 25th, 2026
Next Scheduled Review, on or before February 25th, 2029
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