Policy Brief · Distance Education
A Menu, Not a Mandate: What the RSI Rule Actually Asks of Online Courses
Executive summary
Problem. The two-hour weekly synchronous lecture mandate compresses a deliberately flexible federal rule into a single format, and a format many online students cannot regularly attend.
Rule. 34 C.F.R. § 600.2 defines regular and substantive interaction (RSI) as a menu: five substantive activities, any two sufficient, delivered "either synchronously or asynchronously." The Department of Education expressly declined to prescribe any timeframe, frequency, or duration for RSI, and framed the requirement as a scheduled opportunity for interaction, not a compelled event.
Proposal. A defined menu of RSI-satisfying activities (individualized feedback, engagement monitoring with outreach, discussion, cohort posts, one-on-one conferences, scheduled office hours, optional live sessions), documented per term in the LMS.
Ask. Adopt the menu as the institutional RSI standard; Program Directors determine whether each course under their purview meets RSI based on adherence to it.
01 Context
One format, drawn from a rule that offers many
Current policy requires every online course to hold a two-hour weekly synchronous lecture. The intent behind the policy, protecting the institution's Title IV eligibility and accreditation standing through documented "regular and substantive interaction" (RSI), is correct, and nothing here argues against that goal. The instrument is the issue. The governing regulation defines RSI as a set of options and leaves the choice of format to the institution; the mandate selects one option, fixes its length, and applies it to every course regardless of fit.
Fit varies: a live session can serve a lecture-driven course well, while in small cohorts built on individualized project work the interaction that matters already happens person-to-person; the proposal below serves both kinds of courses without forcing either into the other's format.
02 The rule
The federal rule is a menu by design
The regulation behind RSI, 34 C.F.R. § 600.2, defines distance education as education that uses approved technologies "to support regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously." Asynchronous delivery is not a workaround; it is in the definition.
Substantive interaction must include at least two of five enumerated activities: direct instruction; feedback on coursework; providing information or answering content questions; facilitating group discussion; or other activities approved by the program's accrediting agency. Regular interaction means offering those interactions on a "predictable and scheduled basis commensurate with" the length and content of the course, and monitoring each student's engagement, with prompt, proactive outreach when monitoring (or a student's own request) calls for it.
Notice the shape of the definition: it is a menu. Five activity types, any two sufficient, in either modality, with regularity measured against the course rather than the clock. That shape is deliberate. The rulemaking that produced it is titled Distance Education and Innovation, and the Department's published commentary makes the intent explicit:
- No prescribed timeframe, no time accounting"Given the variety of distance education programs, coursework, instructional modalities, and course schedules, we do not believe it is practical to offer a specific timeframe for regular interaction" (85 Fed. Reg. at 54757), and the Department "does not expect an institution to measure or document the exact amount of time" spent on any substantive interaction (at 54758).
- An opportunity, not a compelled eventThe requirement was deliberately framed "as an 'opportunity' for interaction rather than a required interaction," so that institutions can "demonstrate compliance with the requirements at the program design level" (at 54757).
No minimum duration attaches to the RSI requirement itself (the rule's clock and credit hour measures size the course as a whole); the two-hour figure comes from policy, not from regulation.
03 The students
The students the flexibility was written for
The Department also explained who the flexibility is for: "Asynchronous learning allows students to design their own learning schedules around the demands of work and family that often interfere with class activities offered only at prescribed times" (85 Fed. Reg. at 54752). The stated ambition is educational models "that place the student, rather than the instructor or the institution, at the center of the learning exercise" (at 54761).
That is a description of online enrollment as it actually exists. Students choose online programs because work shifts, caregiving, and full lives rule out being in a particular room, or on a particular call, at a fixed hour each week, and they expect the asynchronicity they enrolled for. Scheduled asynchronous interaction (weekly individualized feedback, moderated discussion, instructor posts to the current cohort, proactive outreach) reaches every enrolled student, on a predictable schedule, on the student's own clock. A fixed two-hour live block reliably reaches only the students free at that hour, and the students it misses are disproportionately the working adults online education exists to serve. None of this argues for less interaction: every option below is instructor-led, scheduled, and documented; the argument is about format, not amount.
04 The proposal
A defined menu of approved RSI options
Rather than mandate one method, define a menu of interaction types that satisfy RSI, require every online course to meet a documented minimum, and let instructors choose the methods that fit their course. This keeps the institution provably compliant at a site visit while freeing instructors to teach in the way their course actually needs.
05 Compliance
Compliance turns on interaction, not lecture hours
The accreditor is aligned with the federal rule. ACCSC's standards ask programs to "provide for timely and meaningful interaction between students and faculty, and among students" (Standards of Accreditation, July 1, 2026, § IX.D.4). Section IX contains no synchronous-session requirement and no quantum of live minutes; its glossary recognizes fully asynchronous courses as an accepted form of distance education, and its distance-education obligation is course-level comparability to the residential version (§ IX.D.2).
06 The decisive point
The credit attaches to the offer, not the hour count
The Department addressed this directly. The regular-interaction requirement "could be met if instructors made themselves available at a specific scheduled time and through a specific modality ... regardless of whether the students chose to make use of this opportunity" (85 Fed. Reg. at 54760). The credit attaches to offering scheduled, instructor-initiated, responsive interaction commensurate with the course. It does not attach to a two-hour length, to the lecture format, or to the recording a session leaves behind. A brief scheduled session held on those terms earns the same compliance credit as a two-hour lecture. What the rule refuses to credit is the opposite arrangement: a course that relies solely on students to initiate contact.
If a short, scheduled interaction satisfies the rule, what is the two-hour lecture for?
In courses run on the menu, the answer is already in the record: the regular and substantive interaction lives in the weekly feedback and proactive outreach, documented term by term in the LMS.
07 Precedent
How peer institutions interpret and enact it
Across higher education, institutions implement RSI through published policies that list multiple qualifying activities and treat fully asynchronous courses as compliant. Ohio State's Office of Distance Education, the University of Houston, and SUNY's OSCQR course-quality framework each define RSI as instructor-initiated, scheduled, academically substantive contact; none requires a synchronous lecture (Ohio State University, n.d.; University of Houston, n.d.; State University of New York, n.d.). Fully asynchronous courses are understood to satisfy RSI through feedback, discussion, content posts, and proactive outreach (WICHE Cooperative for Educational Technologies, 2021). Implementations differ in detail, but on the points that matter here the field is uniform: no peer policy requires a synchronous lecture, and documented asynchronous interaction complies. Measured against this field, a fixed two-hour synchronous mandate is stricter than the rule and out of step with common practice.
08 Recommendation
Adopt the menu; let Program Directors verify adherence
Adopt the menu of approved RSI options and the per-term LMS documentation standard as the institutional RSI standard for online courses. Oversight then sits where course knowledge sits: Program Directors determine whether each course under their purview meets RSI based on its adherence to the menu, using the per-term LMS record as the evidence. A course that documents the baseline activities plus a selected option is compliant; one that does not is flagged and corrected through the same record. The synchronous session stays on the menu as one option among several, chosen by the instructor, with no fixed duration. The menu, the documentation standard, and a mapping to the federal activity types can be codified into a short standards document so any site visit begins with the evidence already organized.
References
Distance education, 34 C.F.R. § 600.2 (2025). law.cornell.edu/cfr/text/34/600.2
Distance Education and Innovation, 85 Fed. Reg. 54742 (Sept. 2, 2020). federalregister.gov
Accrediting Commission of Career Schools and Colleges. (2026). Standards of accreditation and bylaws. accsc.org
Ohio State University, ASC Office of Distance Education. (n.d.). Regular substantive interaction (RSI) guidance. ascode.osu.edu
State University of New York. (n.d.). Regular & substantive interaction. OSCQR, SUNY Online Course Quality Review Rubric. oscqr.suny.edu/rsi
University of Houston. (n.d.). New rules in online learning: Regular and substantive interaction. uh.edu/power-on/rsi
WICHE Cooperative for Educational Technologies. (2021, August 26). RSI refresh: Reviewing & sharing our best interpretation of current guidance and requirements. WCET Frontiers. wcet.wiche.edu
Additional RSI policy documents reviewed: College for Creative Studies; Texas A&M International University; University of Alaska Fairbanks; University of Nebraska Omaha; West Valley College.