Regular and Substantive Interaction (RSI)


In adherence to federal financial aid criteria for students, instructors at Illinois are expected to maintain frequent and meaningful engagement with students in online courses.

Below you will find background information regarding RSI and definitions of distance education and regular and substantive interaction as outlined by the Higher Learning Commission (HLC) for establishing RSI best practices at Illinois. The Online Learning Advisory Committee (OLAC) at Illinois supports these definitions endorsed by the HLC and encourages academic programs to establish guidelines and best practices for online instruction.


For the purposes of determining institutional eligibility for federal financial aid, Congress created a delineation between the definitions of “distance education” and “correspondence education.” This resulted from a consumer protection concern, as students in the 1990’s experienced financial aid fraud related to correspondence education. Additionally, there was interest in assuring aid eligibility for those taking distance education courses, as that modality was growing.

The U.S. Department of Education (ED) issued Final Rules on Distance Education and Innovation which went into effect on July 1, 2021.

HLC Distance Education Definition

Education that uses one or more of the technologies listed below to deliver instruction to students who are separated from the instructor or instructors and to support regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously.

The technologies that may be used to offer distance education include:

  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. Audio conference; or
  4. Other media used in a course in conjunction with any of the technologies listed in items 1–3 above.

For purposes of this definition, an instructor is an individual responsible for delivering course content and who meets the qualifications for instruction established by HLC.

HLC RSI Definition

Institutions are expected to ensure regular and substantive interaction between students and instructors in their distance education and competency-based education offerings. 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. 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
  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.

Substantive interaction is engaging students in teaching, learning and assessment, consistent with the content under discussion, and also includes at least two of the following:

  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 HLC or the program’s accrediting agency.