2026 Annual Review · Filed Document
Regular & Substantive Interaction: Instructor Reference
01 The rule in one sentence
A qualified instructor, on a predictable schedule, does at least two kinds of real teaching with students, and keeps an eye on engagement and reaches out when needed.
02 The two tests
Substantive, and regular
03 Key principles
The five that resolve most questions
- You provide and monitor; you don't have to force engagement. If you offer the interaction on schedule and a student ignores it, you have still met RSI. Noticing the non-engagement and reaching out is the compliance.
- No live lecture required. RSI can be fully asynchronous. Synchronous sessions are optional, and student attendance is never the compliance burden.
- Instructor-initiated beats reactive. Anything that only happens if the student starts it (questions, office-hours drop-ins) is supporting evidence, not a foundation.
- Substantive means teaching, not logistics. Content, skills, and feedback count. "Assignment due Friday" and schedule reminders do not.
- Content is not interaction. Pre-built materials (including embedded videos) are course content, not RSI, no matter how good.
04 The weight table
What counts, and how much to lean on it
| Activity | RSI weight | Why |
|---|---|---|
| Weekly personal feedback on assignments | Primary pillar | Instructor-initiated, scheduled, per-student. Teaching-rich feedback covers both assessment/feedback and direct instruction in one act, so it can carry the two-type bar on its own, and it doubles as the monitoring record. |
| Proactive, observation-driven engagement | Second pillar | A content-specific message sent when your review surfaces a pattern or an at-risk student ("several of you missed X, here is the fix"). Instructor-initiated and current; near-zero extra effort since you are already reviewing the work. |
| Weekly teaching post to the class | Supporting | Counts only with a current-cohort hook ("what I am seeing this week"). A reused-identical post is content, not interaction, so treat it as a delivery vehicle for proactive engagement, not a standalone pillar. |
| Start / mid / end check-ins + outreach when someone goes quiet | Required prong | This is the monitoring plus proactive-engagement half of "regular." |
| Online office hours | Bonus | Substantive when attended, but student-initiated, so not a standalone pillar. Stronger when you proactively send a specific student to a session. |
| Answering questions (FSO messaging) | Bonus | Counts when it happens, but reactive. Cannot anchor RSI; if no one asks, nothing occurred. |
| Embedded / evergreen course videos | Not RSI | Instructional content (governed by the materials standard), not interaction. "Sending" a build-once video does not change this. |
| Live lectures | Not required | Optional; attendance irrelevant; skip if it is a time-sink. |
A video only edges toward counting if it is cohort-current and timely, e.g., a recap recorded this term addressing this class's common errors, posted that week. Freshness and responsiveness to where students are is what would flip it from content to interaction.
05 Recommended setup
Low time-sink, fully asynchronous
06 Documentation
What an audit wants to see
In an audit, the school must be able to show RSI happened. The LMS (FSO) interaction and feedback records, plus posted weekly announcements and check-in messages, are the evidence. Keep the teaching posts and outreach inside the LMS so they are logged.
07 Caveats
Scope
- Institutional policy governs. If Full Sail has an RSI policy or an ACCSC-approved list of "other instructional activities," that controls over this summary.
- Verify against the current rule before relying on any edge case; federal guidance is periodically refreshed.
- A practitioner summary, not legal advice.
Sources
34 CFR § 600.2, Definitions (distance education, instructor, regular, substantive). law.cornell.edu/cfr/text/34/600.2
WCET, RSI Refresh: Reviewing & Sharing Our Best Interpretation of Current Guidance and Requirements. wcet.wiche.edu
ACCSC Standards of Accreditation, July 1 2025, Section IX (Distance Education), D.4 and G.4.