SystemTeaching, Learning & Online Education

Regular and Substantive Interaction Monitoring

Regular and substantive interaction, read post by post in every online course, cited weekly and fixed mid-term

Every online section’s instructor interaction cited weekly, and gaps fixed mid-term.

See one case, screen by screen ↓
demo9,412interactionsinstructor posts, replies, feedback comments and messages read and labeled overnight, on this sample day
demo41sectionsof 1,148 online sections more than 7 days without a substantive interaction on the Monday morning
demo27 of 36sectionsclosed their gap within three days of one private note from the compliance director
target8daysthe longest a gap runs before a person sees it, not until the audit
In short

What is Regular and Substantive Interaction Monitoring?

Regular and Substantive Interaction Monitoring is software for online learning offices that checks every online course for regular and substantive interaction between instructors and students. Seven agents read every instructor post, reply, feedback comment, message and live session each night, label each one against the five federal elements with the deciding passage quoted, and measure gaps against the course's own posted schedule. When a gap passes seven days, a private, supportive note is drafted for the compliance director to edit and send.

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The problem

Why regular and substantive interaction is checked too late, and by counting

Regular and substantive interaction is the line the Department of Education draws between distance education and a correspondence course. Under 34 CFR 600.2 an online course counts as distance education only when a qualified instructor engages students in teaching, learning and assessment through at least two of five activities — direct instruction, feedback on coursework, answers to questions about content, facilitated discussion, or an activity the accreditor approves — on a predictable, scheduled basis, and monitors who falls behind. An institution where half its courses or students are in correspondence study loses Title IV eligibility.

Today an online learning office meets those requirements with a checklist and a term-end spot check of a handful of courses. It counts posts, and a count cannot tell an auto-released announcement or a “Nice work!” on every submission from teaching. A gap is found when it can no longer be fixed for those students, or years later at an audit. Regular and Substantive Interaction Monitoring reads every interaction in every online section each night, measures it against the course's own posted schedule, and puts a private, supportive note in front of the compliance director when a gap opens.

typical$712.7Mrecommended for return in one inspector general audit of an online university's interaction (2017)
typical50%of courses, or of students, in correspondence study and the institution loses Title IV eligibility
typical2 of 5elementsthe least a course must include for its interaction to count as substantive
Where a compliance reviewer's hours go for one online section in one termestimated
By hand7.5 hours
With the solution0.5 hours
  • Pulling announcements, discussions, feedback and messages out of the learning management system1.5 → 0 h
  • Reading each post and deciding whether it is substantive3 → 0.3 h
  • Checking the syllabus's posted schedule against what happened, week by week1 → 0.1 h
  • Writing to the instructor when a gap shows0.5 → 0.1 h
  • Assembling the record for program review or an auditor1.5 → 0.1 h

Estimated split for one section of about 360 instructor interactions a term (the demo college's volume), checked by hand and with the agents; the agents' time is not counted — our arithmetic, kept modest.

How it works

How a week of interaction is checked

Seven agents read, label, re-check and measure every instructor interaction; the compliance director and the dean decide.

What comes in
Interactions in5 systems · LMS, student information, syllabi, financial aid, Faculty Agreement
Agents at work
Interaction readerevery post, matched to its section
Then
Classifierfive federal elements
Skeptic5% + close calls
Regularity agentposted schedule
Then
Nudge agentprivate, supportive draft
Title IV agentdistance or correspondence
Then
Record agentdated record, redacted
A person decides
Compliance director and deansend, escalate, sign
What comes out
Weekly pulse
Gaps closed mid-term
Record for reviewers
One case, step by step

One section's regular and substantive interaction, from a 16-day gap to a released record

Brandvale Community College, Fall 2026, week 8 of 16. ACCT 101-03, Principles of Accounting I, is taught online by an adjunct, Paul Whitcombe, to 34 students, 22 of them with Title IV aid. Here is one week of RSI monitoring, screen by screen, in the working solution.

  1. 01Overnight

    Every instructor interaction read before the office opens

    Interaction reader and Classifier

    The Interaction reader took in 9,412 new announcements, discussion replies, feedback comments, inbox messages and live sessions, each matched to its section and instructor of record. The Classifier labeled 72% substantive. On the interaction pulse, one row per online section, solid beats teach, hollow beats are automated or empty, and every stretch over 7 days without a solid beat is shaded with its length.

    41 of 1,148 online sections have gone more than 7 days without a substantive interaction. ACCT 101-03 is first, at 16 days.

  2. 02Monday, 8:00 a.m.

    Click a hollow beat and read the post behind it

    Teresa Lindqvist · Director of Distance Education Compliance

    Teresa opens the first hollow beat after September 26. It is an announcement released by the learning management system on its own, created on August 20 as a delayed post and attaching a module video recorded in Spring 2025. The label reads “Not substantive · automated or scheduled”, with its confidence and a link to the original.

    “Module 6 is now open. Please watch the walk-through video and complete Homework 6 by Sunday at 11:59 p.m.”

  3. 03One click

    Measured against what the syllabus promised

    Regularity agent

    The section record shows the last substantive interaction: a discussion reply on Saturday, September 26, at 9:14 p.m., explaining accrual versus cash basis. Since then there have been 46 instructor messages and none substantive: 21 automated announcements, 19 grade comments such as “Nice work!” and 6 logistics replies. The syllabus promises feedback on every homework set within 7 days, discussion twice a week and a weekly video walk-through; 4 students missed Homework 5 and 6 with no outreach found in the gradebook.

  4. 04Close calls

    Below 0.80 confidence, a person decides

    Classifier

    A feedback comment in PSYC 101-11 would meet the second element, feedback on coursework, but it was written by an embedded tutor, not the instructor of record, so the Classifier stopped at 0.58 and showed its steps. Teresa keeps the label, or counts it because the tutor is a qualified co-instructor on file, and records a reason code either way.

  5. 05Re-check

    A second agent re-checks the first, without seeing its answer

    Skeptic

    On a different model, the Skeptic labeled a random 5% of week 7 and agreed on 1,295 of 1,310 (98.9%), and agreed on 385 of the 412 posts near the line (93.4%). The 42 disagreements wait for Teresa, side by side, one at a time or in bulk with one reason code. Week 6's disagreements are why ACCT 101-03 shows now: Classifier v3.1 had counted auto-released recordings as direct instruction, and v3.2, approved on October 9 by Teresa and the learning systems administrator, re-read weeks 1 to 7 and changed 1,904 labels.

  6. 068:12 a.m.

    A private, supportive note, edited and sent by a person

    Teresa Lindqvist

    The Nudge agent's draft starts with Paul's own good work — his Homework 2 feedback showed a student where a $340 difference came from — then says what the record shows, offers three small ideas and help, and passed all six of the Skeptic's tone checks. Teresa edits one line and sends it at 8:12. She sends the other 33 clean drafts at 8:19; the two that needed an edit go at 8:26.

    “This note is private. It goes only to you, is not shared with your chair, and is never used in evaluation.”

  7. 07Monday

    The instructor sees his own record, and only his

    Paul Whitcombe · Adjunct instructor, Accounting

    Paul's view shows his section's pulse, the note and what counts, taken from his own course: his Homework 2 feedback and his September 26 discussion reply count; the Module 6 announcement and “Nice work!” on 19 submissions do not. He can reply, book 20 minutes with the online teaching team, or ask for a second look at any label.

  8. 08Thursday, 4:30 p.m.

    Three days later, most gaps closed

    Interaction pulse

    Paul posted on adjusting entries on Tuesday at 7:42 p.m., wrote feedback with content on 31 Homework 6 submissions on Wednesday, and held his live office hour. Across the college, gaps over 7 days fell from 41 to 15, and 27 of the 36 nudged sections closed their gap. Three sections remain on Title IV watch, with 63 students who have aid.

  9. 094:31 p.m.

    Week 8 turns solid, and the record is prepared

    Teresa Lindqvist

    ACCT 101-03's record now shows 38 substantive interactions in week 8, elements i to iv met, the live office hour recorded (52 minutes, 11 attended) and all 4 students who fell behind contacted. Teresa prepares the section record: 412 interactions, 37 pages, student names replaced with codes and the “not for evaluation” notice on.

  10. 104:40 p.m.

    Prepared by one person, released by another

    Marcus Ebbing · Dean of Online Learning

    The dean releases the record for the program review file at 4:40 p.m.; the person who prepared it cannot. The release, Teresa's nudges and the Classifier's labels of Paul's 31 feedback comments sit on the same audit trail, with who, what, when, why and the evidence.

Who it’s for

Built for everyone who answers for an online class.

The same week, seen by the people who carry it — what their day looked like, and what it looks like now.

TL
Teresa LindqvistCompliance director · watches 1,148 online sections
Director of Distance Education Compliance
Before
Counts posts in a handful of courses at term end, because nobody can read 410,000 of them.
Now
Starts the week with every section read, the worst gaps first, and 36 private notes drafted for her to edit and send.
ME
Marcus EbbingDean · approves escalations, signs status changes, releases records
Dean of Online Learning
Before
Answers for every online class at program review with a checklist someone filled in.
Now
Decides the few escalations after written notice, signs any status change second, and releases records he did not prepare.
PW
Paul WhitcombeAdjunct instructor · teaches ACCT 101-03 online, 34 students
Adjunct instructor, Accounting
Before
Hears about a gap at the end of term, if at all, and from someone above him.
Now
Gets an early, private note that starts with his own good work, and sees his own record and what counts.
GN
Gloria NwosuFinancial aid director · relies on each section's status
Director of Financial Aid
Before
Disburses Title IV aid without knowing which online courses are at risk of being correspondence.
Now
Sees each section's status, the watch list with aided students, and acknowledges the week's status every Friday.
RC
Ruth CallowayInternal auditor · reads everything, changes nothing
Internal auditor
Before
Rebuilds who decided what, and on which evidence, from emails and spreadsheets.
Now
Filters the trail by people or agents and exports it, with every decision's reason and evidence.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven agents read, label, re-check and measure every instructor interaction; the compliance director and the dean decide.

Interaction reader

Takes in announcements (with the scheduled-post flag and attachments), discussion posts and replies, feedback and rubric comments, inbox messages and live sessions, and matches each to its section and instructor of record; posts by people on no roster go to the director.

  • Never writes to the learning management system
  • Never reads award amounts
Classifier

Labels each interaction against the five federal elements of substantive interaction, with its confidence and the passage that decided it.

  • Never labels below 0.80 confidence without a person
  • Never counts a post by someone who is not an instructor
Skeptic

On a different model, re-labels a random 5% and every post below 0.80, blind to the first label, and checks every nudge for tone.

  • Never sees the first label
  • Never settles a disagreement; the director decides
Regularity agent

Reads each syllabus's posted schedule, measures gaps against the stricter of it and the 7-day default, and checks outreach to students who fall behind.

  • Never infers a schedule the syllabus does not state
Nudge agent

Drafts a private, supportive note: the instructor's own good work first, what the record shows with citations, two or three small ideas, an offer of help and the faculty agreement notice.

  • Never sends; the director approves and sends
  • Never mentions evaluation, a chair or another instructor
  • At most one note a week
Title IV agent

Records distance or correspondence status per section and term, watches the institution's 50% limits nightly, and tells financial aid what changed.

  • Never changes a status without two signatures
Record agent

Keeps each section's dated weekly record, builds the export for each reviewer, replaces student names and IDs with codes, and seals and logs each export.

  • Never releases an export; the person who prepared it cannot release it either
Compliance director and dean

Send nudges, escalate, sign status changes. The agents propose; a named person decides.

Ask in plain words

Ask about any section, label, gap or status

The assistant answers with the sources cited and opens the screen it is talking about.

Why is ACCT 101-03 at the top of the pulse?

Its last substantive interaction was a discussion reply on Sat Sep 26 at 9:14 p.m. Since then the instructor has posted 46 times: 21 automated announcements, some with a Spring 2025 recording, 19 grade comments such as “Nice work!” and 6 logistics replies. None meets an element of the federal definition, and the syllabus promises feedback within 7 days. That is a 16-day gap. 22 of its 34 students have Title IV aid.

Which sections with Title IV students are on watch?

Two sections are past 14 days: ACCT 101-03 and HIST 201-02, with 41 students who have aid. Each stays “distance education” until you and the dean agree otherwise, and the college is far from the 50% limit.

Show me the nudges that need an edit before they go

34 drafts passed the tone check. Two did not: COMM 110-03 mentions a “department review”, which reads as a warning, and ECE 140-01 asked in August for messages by email, so I changed the channel. Every claim in a draft is cited to the record.

Prepare the program review record for ACCT 101-03

The record holds every interaction this term with its label and citation, the posted schedule, the gap and how it closed, the re-check results and every decision. Student names are replaced with codes and the “not for evaluation” notice is on. You prepare it; the dean releases it.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

Every online section's regular and substantive interaction, week by weekThe interaction pulse on Monday, October 12, week 8: one online section per row, solid beats for substantive instructor interaction, hollow beats for automated or empty messages, and every gap over seven days shaded. 9,412 interactions were read overnight; 41 of 1,148 sections have a gap over 7 days, sorted longest first, with ACCT 101-03 at 16 days.
Click a beat to read the post behind itA hollow beat opened to its source: an automated announcement in ACCT 101-03 on Monday, September 28, quoted, labeled “Not substantive · automated or scheduled” with its confidence, so no one has to take a count on trust.
One section's record against its own posted scheduleACCT 101-03 with a 16-day gap: the week-by-week pulse, the federal elements met each week, and what the syllabus promised against what happened — the weekly video walk-through not met since September 21 and discussion twice a week not met since September 26, each line cited.
Close calls go to a person, with the reasoning shownLabels near the line: the Classifier shows each step, the five federal elements of substantive interaction and its confidence. A tutor's feedback in PSYC 101-11 stopped at 0.58 because the author is not the instructor of record; the compliance director keeps or changes the label with a reason code.
A second agent re-checks the firstThe independent re-check: a second agent on a different model labels a random 5% and every close call without seeing the first label — 98.9% agree on the sample, 93.4% near the line — and a person decides each of the 42 disagreements, one at a time or in bulk with a reason code.
A private, supportive note, drafted for the compliance director to sendThe Nudge agent's draft to Paul Whitcombe: it starts with his own Homework 2 feedback, cites the record, suggests three small steps, offers help and states that it is never used in evaluation. The Skeptic's six tone checks passed; two other drafts are flagged for an edit.
Regular and substantive interaction examples, from the instructor's own courseThe instructor's own view: his section's pulse, the private note, and examples of what counts and what does not — feedback on Homework 2 and a discussion reply count; an auto-released announcement and “Nice work!” on 19 submissions do not. Any label can go back for a second look.
Three days later: most gaps closedThe same pulse on Thursday at 4:30 p.m.: after 36 private notes went out, 27 of those sections closed their gap and gaps over 7 days fell from 41 to 15. ACCT 101-03 turned solid on Tuesday at 7:42 p.m.
Week 8 turns solidACCT 101-03's record on Thursday: the stretch from September 26 shaded and closed, 38 substantive interactions in week 8, feedback on 31 of 31 Homework 6 submissions, the live office hour recorded, and all 4 students who fell behind contacted.
Escalation and status changes wait for the deanThe dean's desk: two escalations wait for a decision within 3 working days, after written notice under the faculty agreement, and a proposal to mark a Summer 2026 section as not meeting the rule — 24 days with no instructor of record — waits for the dean's second signature.
Distance education or correspondence course, per section and termTitle IV status for each of 1,148 online sections, the watch list with aided students, the institution's 50% correspondence limits with 0 courses and 0 students in correspondence study, and the weekly sign-off financial aid relies on.
A dated record, prepared by one person, released by anotherThe audit trail of people and agents, with who, what, when, why and evidence, and the ACCT 101-03 section record the dean released at 4:40 p.m. for the program review file: 412 interactions, 37 pages, student names replaced with codes.
Versioned agents, models and override reasonsAgent and model governance: every agent's version, model and threshold, the reason for the last change — Classifier v3.1 to v3.2, 1,904 labels changed — and the reason codes a person must give to override a label.
Governance

Built for Title IV and the faculty contract: cited, signed, private.

Six roles, separated by dutyInstructors interact and see only their own record; the compliance director monitors, decides labels and sends notes; the dean approves escalations and releases records; financial aid relies and acknowledges; the learning systems administrator configures; the internal auditor reads and exports, changing nothing.
Two signatures to change a course's statusMarking a course as not meeting the rule needs the compliance director's proposal and the dean's agreement, two different people. On the dean's desk, the person who proposed it sees the approve buttons disabled, with the reason.
Every label quotes the passage that decided itEach beat opens the original post with its label, confidence and the federal element it meets, or why it meets none. Every number on the pulse, the section record, the note and the Title IV view opens its source.
The faculty agreement, enforced in the productInteraction data is never a basis of evaluation or discipline, notes never go to a chair, escalation waits for a note, 7 days, written notice and the dean, and instructors may see their own record and ask for a second look. These settings are locked.
FERPA redaction, access and retentionStudent names and IDs are replaced with codes in every export; post text is read by four roles; financial aid data is counts only; records are kept 5 years after the term, longer than Title IV requires, with legal hold, and student work is never used to train models.
Versioned agents, thresholds and reason codesEvery agent has a version, a model and a threshold; a change is a new version approved by two administrators, and the reason is kept — Classifier v3.1 to v3.2 re-read seven weeks. Overriding a label needs a reason code, and the full audit trail exports for auditors, accreditors and the inspector general.
Configuration

Your regular and substantive interaction policy, as settings

The thresholds every section is measured against are settings, versioned, and changed only when a second administrator approves.

SettingDefaultChoose from
Gap that shades the pulse7 daysThe posted schedule is used instead when it is stricter
Title IV watch14 daysSections past it go on the financial aid watch list
Near the lineBelow 0.80 confidenceGoes to the Skeptic and to a person
Independent re-check sample5% of last week's interactionsPlus every post near the line
Nudge draftsMondays, 8:00 a.m.No instructor gets more than one a week
At least two of the five elementsOnSet by regulation (34 CFR 600.2), locked
EscalationOnly after a nudge, 7 days and the dean's approvalFaculty agreement, locked
Keep records5 years after the termLegal hold; Title IV requires 3 years after the award year (34 CFR 668.24)
Connections

Works with the systems an online learning office already runs on

Learning management systemannouncements, discussions, feedback, inbox and live sessions, read only
Student information systemsections, modality codes, instructors of record and enrollments
Financial aid management systemcounts of aided students per section, never award amounts
Document managementsyllabi and posted course schedules
Faculty contract repositorythe faculty agreement in force
Single sign-onroles from the campus directory groups
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
100%
of online sections with a dated, cited interaction record every week
Every section, every week
each beat labeled and cited
target
3 in 4
gaps closed after one private note, with no report to a chair
27 of 36 in the demo week
closed within three days
target
8days
the longest a gap runs before a person sees it, not until the audit
Term-end spot checksfound at audit
With agents≤ 8 days

Sources: 34 CFR 600.2 (distance education, correspondence course, substantive and regular interaction, instructor) and the final rule, 85 FR 54742 (September 2, 2020; effective July 1, 2021) · 34 CFR 600.7(a)(1) and HEA §102(a)(3) (the 50% correspondence limits) · 34 CFR 668.24 (record retention) · U.S. Department of Education Office of Inspector General audit of an online university (September 2017), recommending the return of $712.7 million, as summarized by WCET · "demo" = seen in the working solution, on its sample data · "target" = design goal, measured in the live solution · "typical" = published figures and regulation · "estimated" = our arithmetic. Brandvale Community College, its faculty agreement and the people named on this page are fictional — characters and sample data in the working solution.

Questions

What online learning offices ask us about regular and substantive interaction.

What is Regular and Substantive Interaction Monitoring?

Regular and Substantive Interaction Monitoring is software for online learning offices that checks every online course for regular and substantive interaction between instructors and students. Seven agents read every instructor post, reply, feedback comment, message and live session each night, label each one against the five federal elements with the deciding passage quoted, and measure gaps against the course's own posted schedule. When a gap passes seven days, a private, supportive note is drafted for the compliance director to edit and send.

What is regular and substantive interaction (RSI)?

It is the Department of Education's test, in 34 CFR 600.2, that separates distance education from a correspondence course. Interaction is substantive when an instructor engages students in teaching, learning and assessment through at least two of five activities: direct instruction, feedback on coursework, answers to questions about content, facilitated discussion, or another activity the accreditor approves. It is regular when it is predictable, scheduled and monitored, including outreach to students who fall behind.

What are examples of regular and substantive interaction?

In the working solution, an instructor's feedback that shows a student exactly where a $340 difference came from counts, and so does a discussion reply explaining accrual versus cash basis. An announcement released automatically with a recording from an earlier term does not, nor does “Nice work!” on 19 submissions. The instructor sees these examples drawn from his own course.

Does an automated announcement count as regular and substantive interaction?

No. The agents read posts rather than count them: automated and scheduled posts, generic praise, logistics and posts by tutors or publishers are each labeled as such, with the passage quoted. That is what a checklist or an activity count misses — a course can look busy with 46 messages and still have none that is substantive.

What happens if an online course does not meet regular and substantive interaction?

To federal student aid it becomes a correspondence course, and an institution where half its courses or students are in correspondence study loses Title IV eligibility. Here the Title IV agent records a section as correspondence only after the compliance director proposes it and the dean agrees, and then tells financial aid which aided students to review.

Is RSI monitoring used to evaluate faculty?

No. Under the faculty agreement settings, which are locked, interaction data is never a basis of evaluation or discipline, notes go only to the instructor and never to a chair, and every export carries a “not for evaluation” notice. Instructors see their own record and can ask for a second look at any label.

Do people stay in control of the decisions?

Yes. The agents read, label, measure and draft; they never send a note, escalate, change a status or release a record. Labels below 0.80 confidence go to a person, the compliance director sends every note, the dean decides escalations, a status change takes two signatures, and a record is released by someone other than the person who prepared it.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your syllabi, your faculty agreement and a term of your learning management system data — and it goes live once every quality gate has passed. We will walk you through it on your own sections first.

See it on
your online sections.

We'll run Regular and Substantive Interaction Monitoring on a term of your own online sections.