RSI Plan & Position: Game UX Courses

01 Position

Compliant by design, without a live lecture

These courses meet RSI through instructor-initiated, scheduled, substantive interaction delivered asynchronously, primarily weekly individualized feedback, supported by monitoring and proactive engagement. Synchronous live lecture is not used and not required, and its absence does not affect compliance.

02 The rule

What RSI actually requires, and what it does not

RSI has two tests:

• Substantive: the course engages students in teaching, learning, and assessment via at least two of five activity types (direct instruction; feedback on coursework; providing information or answering content questions; facilitated discussion; other accreditor-approved activity).
• Regular: the instructor provides the opportunity for substantive interaction on a predictable, scheduled, instructor-initiated basis, and monitors engagement and proactively engages when needed.

What the rule does not require, confirmed against 34 CFR 600.2:

• No live or synchronous lecture. Interaction may be "synchronously or asynchronously." Asynchronous delivery is explicitly sufficient.
• No minimum lecture time. There is no mandated number of lecture minutes or hours; there is no lecture clock at all.
• No minimum length for posts or messages. "Substantive" is judged by whether the interaction teaches, not by word count or duration. A brief instructional message qualifies; a long administrative one does not.
• "Opportunity" alone is not enough. The 2021 rule eliminated the old "available on request" model. Actual substantive interaction must be delivered and engagement must be monitored. This plan delivers real interaction (feedback), so it clears the bar that mere availability would fail.

03 The verbatim basis

Time and length requirements, quoted directly

This is the crux of the no-live-lecture position, so the supporting text is quoted directly.

Asynchronous is expressly permitted; no live session is mandated

34 CFR 600.2 defines distance education as education delivered through technology that supports

"regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously."

34 CFR § 600.2, "Distance education," para. (2)

No synchronous or live component is required anywhere in the definition.

RSI specifies no fixed duration; it scales to the course

The "regular interaction" prong requires only:

"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."

34 CFR § 600.2, "Distance education," "Regular interaction," (i)

The operative words are "predictable and scheduled" and "commensurate," not a count of minutes or hours. There is no minimum lecture time and no minimum message or post length stated.

"Substantive" is a quality test, not a length test

"Engaging students in teaching, learning, and assessment, consistent with the content under discussion, and also includes at least two of the following: (i) Providing direct instruction; (ii) Assessing or providing feedback on a student's coursework; (iii) Providing information or responding to questions about the content of a course or competency; (iv) Facilitating a group discussion regarding the content of a course or competency; or (v) Other instructional activities approved by the institution's or program's accrediting agency."

34 CFR § 600.2, "Distance education," "Substantive interaction"

Nothing here imposes a duration or word count. A short message that does one of these things is substantive; a long administrative one is not.

The only time-based rules measure the course, not live lecture

ACCSC's hour definitions size the whole course, not synchronous lecture:

"A clock hour is defined as 50 minutes of instruction in a 60-minute period of time."

ACCSC Standards of Accreditation, July 1 2025, § II.A.3.e.i, p. 86

"One semester credit hour equals 45 units ... One clock hour in a didactic learning environment = 2 units ... One hour of out-of-class work and/or preparation for the didactic learning environment ... = 0.5 unit."

ACCSC Standards of Accreditation, July 1 2025, Appendix III, Definition of a Credit Hour

These measure total didactic plus out-of-class effort across the term. They do not prescribe synchronous lecture, and for distance education the obligation is course-level equivalence, justified by the school, not a quota of live minutes:

"The school must demonstrate that the content and length of a distance education program or course of study are comparable to residential programs. The school must justify and provide validation for any deviation from established clock-to-credit hour conversions, if applicable."

ACCSC Standards of Accreditation, July 1 2025, § IX.D.2, p. 118

04 The plan

How these courses satisfy RSI

05 Fit

Why no live lecture is the right call here

• Small cohorts (typically under 10). Interaction happens at the individual level through quality personal feedback, which is the strongest, most personalized form of RSI. A one-to-many lecture has questionable value, especially on project work. This is proven by the ongoing low or no attendance. We spend a lot of effort to give the students something they don't want, and that is not required.
• Highly individualized, divergent projects. Each student invents and designs their own game and takes a different path to the same end goal; concept, direction, and design decisions diverge sharply from one student to the next. A generalized synchronous lecture has little to offer a room where everyone is solving a different problem; the teaching that matters is per-student feedback on their project. Anything general enough to lecture is already captured in the course content, which students work through asynchronously, so a live session would only re-deliver what they already have.
• It is the modality students chose, and what they pay for. People enroll online precisely because jobs, families, and other obligations rule out attending sessions during business hours. Online learning is asynchronous by expectation when it is not fully self-paced, and learners increasingly expect the full body of content available from day one, the norm set by modern learning portals. What students pay for is access to the content and access to the instructor; embedding the content from the start, plus responsive individualized interaction, serves both better than a synchronous lecture many cannot attend (and attendance is never the compliance burden anyway). A live session works against the very flexibility they enrolled for.

06 Evidence

Proving it: the documentation record

The compliance burden is to show monitoring and delivered interaction, not to show outreach to students who do not need it.

• Feedback records in FSO (timestamped, per student, weekly) prove both substantive interaction and that each student was monitored. This is the core evidence.
• LMS engagement data (submissions, logins, gradebook) and participation in any institutional early-alert system show roster-wide monitoring.
• Outreach messages, kept in FSO, show the "engage when needed" trigger fires when warranted. A handful across a term demonstrates the mechanism; thriving students requiring no outreach is the expected, compliant case.

All teaching messages and outreach stay inside FSO so they are automatically logged.

07 Caveats

Scope and verification

• Institutional RSI policy and any ACCSC-approved list of activities (activity type five) control over this plan.
• Federal text verified. The 34 CFR 600.2 quotations above were checked verbatim against the published regulation on May 29, 2026 and match the current text (most recent amendment citation: 90 FR 503, Jan. 3, 2025). Re-verify only if a later rulemaking amends the distance-education definition.
• Prepared with public-facing guidance only.