INTRODCUTION
The following FAQ was generated at SBCC by Matthew Mooney, the Faculty Distance Education Coordinator. It was compiled by Professor Mooney to help faculty prepare their online courses for ACCJC accreditation. Be sure to watch the video he has prepared below.
GENERAL FREQUENTLY ASKED QUESTIONS
Regular Substantive Interaction (RSI)? Why do we have to bother with this?
“Given the impact of distance education on our students and greater participation, federal financial aid is being matched for those students enrolled online. This makes it high stakes with serious consequences for noncompliance: colleges could lose federal funding or be asked to repay funds. Your Financial Aid departments are familiar with audits around federal financial aid” (ACCJC May 2025 Distance Education RSI Webinar transcript)
When will our online courses be evaluated by ACCJC?
“All sections in the sample should be from the semester, quarter, or term immediately preceding the date of the review. For example: if the review is in fall 2026, the sample courses must be from spring 2026.” (ACCJC Protocol for Distance Education Review).
How many of our courses will be evaluated by ACCJC?
“…5% of the total number of distance education sections offered in the sample semester” (a minimum of 15 sections and a maximum of 50 sections). (ACCJC Protocol for Distance Education Review)
Which courses will be chosen for review?
“The sample should be randomly selected from all course sections offered at the institution that qualify as Distance Education” (ACCJC Distance Education Review – Frequently Asked Questions).
Will noncredit (formerly referred to as Adult Education) distance education courses offered through our School of Extended Learning be included in the RSI review as part of the accreditation process?
No. “The peer review team will only be looking at fully online, credit-bearing distance education courses” (https://accjc.org/wp-content/uploads/DE-Protocol-November-2024)
I’m not really comfortable providing outside evaluators access to my online courses. What about FERPA?
“According to the Department of Education, an educational institution is permitted to disclose student records to accrediting organizations to carry out their accrediting function” (ACCJC Distance Education Review – Frequently Asked Questions (November 2024)
“Institutions should expect peer review team members to maintain confidentiality of student and instructor information…” (ACCJC Protocol for Distance Education Review)
How many of the courses in the sample must demonstrate regular and substantive interaction in order for SBCC to pass RSI review?
85% (ACCJC Protocol for Distance Education Review). See also (ACCJC Addendum to the Protocol for Distance Education Review)
How much of our course will the evaluators have access to?
“Reviewers should have a level of access to the LMS (typically ‘instructor’ level) that allows them to observe activities where this interaction takes place, such as on discussion boards, other postings, and communications regarding learning content, feedback on assignments, etc. It is the institution’s responsibility to provide any additional access to relevant documentation to verify regular and substantive interaction…(ACCJC Protocol for Distance Education Review)
“Colleges need to discuss how they ensure substantive and regular interaction and what documentation should/could be made readily available for monitoring/evaluation purposes in the context of their institutional policies” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
The Canvas Inbox, particularly, is a common place for the type of RSI….How can we provide evidence to the visiting team to make this form of RSI visible beyond access to the course?
“During the review process, colleges provide maximum access allowable to demonstrate expectations are being met; this often includes access to Canvas Inbox..Note: in order to see Inbox conversations, the user would have to have ‘Act as’ permission added to their role in Canvas” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
“…usually the Accreditation Liaison Officer (ALO) makes that access available for the peer review team working with the technology department” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
What about third-party tools (such as Perusall, ALEKS, or Labster)? How will ACCJC evaluators be able to evaluate my use of these tools for RSI purposes?
“It is the institution’s responsibility to provide any additional access to relevant documentation to verify regular and substantive interaction. The institution must have methods to ensure that the instructor’s interaction with students is substantive and regular” (ACCJC Distance Education Review – Frequently Asked Questions).
“The responsibility is on the institution to demonstrate RSI. If communications happen elsewhere, you need to provide that documentation in the review process. It’s a common concern – if it’s not within the LMS, it’s hard to find – so institutions decide how to tackle that, but you still must demonstrate it” (ACCJC May 2025 Distance Education RSI Webinar transcript)
Are hybrid classes included in the RSI review?
“When in-person instruction takes place in a course, ACCJC does not include that course (what you call hybrid) in the DE review process” (ACCJC May 2025 Distance Education RSI Webinar transcript)
“If there are instructional components taking place physically in person, then the course would not be included in the random sample of courses for review since it is not fully online per federal regulations” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
What about totally live, synchronous online courses? Are they included in the RSI review?
‘“Synchronous courses are considered still as DE per federal regulations and need to have the required substantive and regular interaction methods per the definitions/rubric…Yes, synchronous courses are still considered distance education and reviewed for substantive and regular interaction per the definitions and rubric (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
What if all of the instruction is online, but we do our exams in person?
“Courses in the sample should be 100% online, that is, ALL of their instructional portions can be completed by distance education (i.e., exclude hybrid sections). Non-instructional in-person requirements (e.g., orientation and testing) do not exclude a course or program from being classified as exclusively distance education.” (ACCJC Protocol for Distance Education Review)
“…the only courses that qualify for ACCJC’s monitoring purposes as Distance Education are when 100% of the course is offered in DE modality (including synchronous). If students and instructors are meeting physically in person for instructional components of the course, then the course does not get reviewed for RSI per ACCJC’s policies” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
“If the course is Hybrid with some instruction taking place in-person/F2F, then the course is not to be included for RSI evaluation by the ACCJC for accreditation review purposes” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
“ACCJC’s definition for distance education is based on federal regulations and it only reviews 100% fully online courses (synchronous/asynchronous)…” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
SUBSTANTIVE INTERACTION QUESTIONS
Does my course need to meet all four substantive interaction categories to pass an RSI review?
No. A course does not need to meet all four substantive interaction categories to pass an RSI review. Only two of the four substantive categories are required (ACCJC Addendum to the Protocol for Distance Education Review).
“For substantive interaction, in a course, the instructor needs to include at least two of the following methods for it to count as substantive interaction. If you look at the levels A–D, those are four mechanisms. You can choose two of the four” (ACCJC May 2025 Distance Education RSI Webinar transcript)
Substantive Interaction A: Providing Direct Instruction
Does “direct instruction” really only mean live, synchronous online instruction?
“When the Department [of Education] uses the term ‘direct instruction,’ it means live, synchronous instruction where both the instructor and the student are online and in communication at the same time” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
Why doesn’t a pre-recorded video lecture, or a written lecture count as “direct instruction?”
“When the Department uses the term “direct instruction,” it means live, synchronous instruction where both the instructor and the student are online and in communication at the same time.” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
Do voiceover PowerPoint presentations count as direct instruction?
No, direct instruction is only a method considered by the Department of Education in live synchronous course sections (ACCJC Distance Education Review – Frequently Asked Questions)
Will I need to provide Zoom meeting recordings to verify that I conduct direct instruction?
“No, ACCJC does not require observation of recorded Zoom meetings; peer reviewers will review the syllabus to verify that the course section was synchronous, and the content covered by the instructor, in order to validate direct instruction” (ACCJC Distance Education Review – Frequently Asked Questions).
“ACCJC does not require observation of recorded Zoom meetings of synchronous courses; peer reviewers will review the syllabus to verify that the course section was synchronous and the content covered by the instructor in order to validate direct instruction” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
Can office hours count toward Substantive Interaction Category A (live, synchronous direct instruction)?
[Office hours listed] “‘As needed’ in a syllabus doesn’t count…By themselves, they aren’t substantive interaction; however, if during office hours you provide information or respond to students in ways that meet substantive criteria, that can suffice as substantive interaction” (ACCJC May 2025 Distance Education RSI Webinar transcript)
“Generally, it is better to think of office hours as one of the mechanisms for Regular Interaction per FAQ#6 and to identify the other methods (at least two) for Substantive Interaction…” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
ACCJC “Policy on Distance Education and on Correspondence Education” (June 2025) includes the following language in Section 5: “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— (a) providing the opportunity for substantive interactions with the student on a predictable and regular basis commensurate with the length of time and the amount of content in the course or competency…”
So…the keyword here is “opportunity.” The policy does not state that substantive interaction must be required. If an instructor is providing students with the opportunity to attend synchronous live meetings, then the instructor may be fulfilling RSI Category 1 (Direct Instruction).
Substantive Interaction B: Assessing or Providing Feedback
The computer automatically grades my students’ quizzes and tests. Will this count for RSI?
“No, per the Department of Education, ‘a grade on an assignment alone does not qualify as substantive interaction’ unless the instructor evaluates the student’s work and provides specific feedback to the student about that work.” (ACCJC Distance Education Review – Frequently Asked Questions)
“The Department of Education is explicit that a grade alone doesn’t qualify unless the instructor evaluates the work and provides specific feedback. Automatic grading with automated feedback doesn’t count – it’s interaction with a computer, not an instructor” (ACCJC May 2025 Distance Education RSI Webinar transcript)
What about rubrics? Can a detailed rubric count as substantive interaction, or does a rubric always need to be accompanied by a separate, individualized comment?
“The Department of Education does not consider a grade on an assignment to be ‘substantive interaction’ unless the instructor evaluates the student’s work and provides specific feedback to the student about that work” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
If I use a pre-written library of feedback comments, can that count as substantive interaction for RSI purposes, or does interaction need to be individualized in real time?
“The [RSI] rubric provides flexibility for the kinds and amount of feedback to students within a course overall. Using the rubric, focus on providing meaningful and personalized feedback to help the student attain the learning outcomes” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
What about using AI to generate feedback for students?
“The Department [of Education] specifically notes, “an automated grading system that provides feedback based on a programmed response to input does not count as ‘substantive’ because it is interaction with a computer, not an instructor” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
OK…what about, for example: we have an instructor with a course that utilizes Canvas quizzes, which provides automated feedback, but within the course, there is also a research paper where the instructor provides annotated feedback…would this count for RSI?
“The rubric provides flexibility for the kinds and amount of feedback to students within a course overall” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
Substantive Interaction C: Providing Information
I’m having trouble understanding Category C. I understand live instruction (A), feedback to students (B), and discussion facilitation (D), but what is Category C supposed to capture that isn’t already covered by those?
Category C is about noticing patterns of confusion or common questions across the class and stepping in to teach the class as a whole – through an announcement, short video, clarification post, or written explanation. Please note: this must be a direct response to student work or activity in the current course, not pre-created content prepared before the semester begins.
Substantive Interaction D: Facilitating Group Discussion
Is there an expected amount of discussion interaction? In other words, how much discussion is ‘enough’ to satisfy RSI?
“This is…best answered by local faculty at the local institution” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)
I don’t see anything in the RSI rubric about student-to-student interaction. Isn’t that required by Title 5?
“ACCJC is required to monitor quality in distance education per the federal regulations on this matter and does not ensure compliance with other State laws or regulations (such as ADA compliance) not within its jurisdiction” (ACCJC Distance Education Review – Frequently Asked Questions)
REGULAR INTERACTION QUESTIONS
Does my course need to include evidence of both regular interaction categories on the RSI rubric in order to pass the RSI review?
“Each course section reviewed must include evidence of both activities [categories] to qualify as meeting the expectations for regular interaction” (ACCJC Addendum to the Protocol for Distance Education Review).
“For regular interaction, unlike substantive, where you need two of the criteria, here you need to meet both criteria” (ACCJC May 2025 Distance Education RSI Webinar transcript)
What does “regular” mean, exactly? How frequently does an instructor need to interact with students to qualify for regular interaction?
“ACCJC relies on institutions to set their own policies and procedures in the context of their mission and expectations for particular programs or courses, as well as curriculum development processes that would identify what is appropriate given varying lengths of time and amount of content in any given course or competency.” In other words, ACCJC leaves the burden on institutions to explain and defend their choices rather than issuing concrete requirements (ACCJC Distance Education Review – Frequently Asked Questions)
“…at the baseline, you have policies and procedures clarifying how often and when the instructor will interact; you communicate this in course materials (response times, office hours). Office hours must be regular and predictable…I’m not going to give an exact number because it depends (a 4-week vs. 16-week course, English vs. Biology vs. Auto). (ACCJC May 2025 Distance Education RSI Webinar transcript)
Can you quantify what “some” assignments mean? Could you clarify the nuance/differences between “consistently” and “frequently?”
“The qualitative terms in the rubric are intended to provide a description of progression among the levels. This provides flexibility and support for institutions in the continuous improvement process. Consistently means there is some regularity; frequently means it happens a lot” (Responses to Questions asked at the May 2025 Distance Education RSI Webinar)