This content was published: November 20, 2017. Phone numbers, email addresses, and other information may have changed.
Regular and substantive interaction
Posted by Andy Freed
There’s been a lot of noise lately about a recommendation from the Office of the Inspector General (OIG) at the Department of Education whereby the OIG stated that they believe that Western Governors University should repay over $700 million in Title IV financial aid funding. The OIG states that Western Governors classes (because of their unique competency based education model and more) are correspondence courses, not distance learning courses, and thus not eligible for Title IV funds.
Huh? Why should I care? Because of Regular and Substantive Interaction!
According to the Federal Financial Aid handbook, there’s a clear difference between distance learning and correspondence courses. Distance learning is defined as:
And a correspondence course is defined as:
A correspondence course is a home-study course for which the school provides instructional materials, including examinations on the materials, to students who are not physically attending classes at the school. Interaction between the instructor and student is limited, not regular and substantive, and primarily initiated by the student.
Correspondence courses are typically self-paced. When a student completes a portion of the instructional materials, the student takes the examinations that relate to that portion of the materials and returns the examinations to the school for grading.
Western Governors got in trouble for a couple reasons, but underlying the mess is the OIG’s reading of the regulations and stating that:
But what is regular and substantive interaction? That’s a difficult question to answer. The good news is that if you use our amazing What Works Well in Online Teaching at PCC handbook, you’re already on solid ground. The recommendations in there aren’t a coincidence.
But if you’re looking for more specific guidance from the Department, try this list of what was recommended in a 2014 Dear Colleague letter. The letter refers to distance CBE courses and focuses on what counts as attendance, but is relevant for all distance learning courses:
- Participating in regularly scheduled learning sessions (where there is an opportunity for direct interaction between the student and the faculty member);
- Submitting an academic assignment;
- Taking an exam, an interactive tutorial, or computer-assisted instruction;
- Attending a study group that is assigned by the institution;
- Participating in an online discussion about academic matters;
- Consultations with a faculty mentor to discuss academic course content;
And it’s worth noting that “merely grading a test or paper would not be substantive interaction.” That would be more helpful if there was a better definition of timing and frequency. Here’s some further guidance:
- Faculty should provide substantive feedback and guidance to students on multiple assignments over the full length of the term.
- Feedback and guidance must be related to the academic content of the course (i.e. not limited to reminders about deadlines or other logistical matters) and must go beyond limited comments such as “good job” or “great work.”
- Regular and substantive interaction must occur between students and faculty members. This may be supplemented, but not replaced, by interaction between students and teaching assistants or other program staff.
So hopefully that helps fill in the “policy” part of the regular and substantive interaction puzzle. But that’s just as it relates to whether or not the college is able to provide Title IV funds. Yes, we do wish to continue to make financial aid available. But should we continue to focus on minimums? No! Let’s focus on What Works Well in Teaching Online at PCC.