Estimated reading time: 6 minutes

Real and Substantive Interaction (RSI) is a term created by the US Congress, in 1992, to block correspondence schools from receiving federal student aid. These schools were shown to have excessive student loan default rates vs. US colleges and universities and the US government wanted to stop taxpayer money flowing to them. RSI meant faculty had to interact with students, not just give them books to read and assignments to complete without any feedback.

The 2008 reauthorization of the US Higher Education Act clarified and extended RSI to differentiate between courses taught via “distance education” (eligible for federal student aid) and “correspondence” (not eligible). While all this may seem obvious, or peculiarly American, to readers outside the US, things got very serious in 2017 when the US Department of Education determined Western Governor’s University failed to meet the basic standards of RSI and was therefore required to repay $713M in federal financial aid.

What is(n’t) RSI?

This question has sparked significant debate in the educational community. As the US Department of Education stated in a recent circular about their 2021 update to the policy:

This key phrase, “regular and substantive interaction,” was never defined, thus creating numerous conversations and arguments about the role of and types of interaction pedagogically appropriate in online education.

Rather than directly defining RSI, the Office of the Inspector General (OIG) chose to define what isn’t considered RSI. This goes along with their goal to “incentivize, don’t punish, institutions for being innovative and creating programs that expand educational opportunity.” They define RSI as NOT:

  • Computer-generated feedback on objective assessments.
  • Recorded webinars, videos, and reading materials if the course design materials did not require the students to watch the webinars and then interact with an instructor.
  • Contact with mentoring staff who are not directly providing instruction on the course’s subject matter

A 2022 response letter to the Director of Digital Learning, Policy & Compliance at the WCET State Authorization Network made it even more clear that there is no hard and fast rule of what is or isn’t RSI when they stated:

the Department’s position is that the definition of “regular and substantive interaction” must be applied on a case-by-case basis to each institution and its academic program, and careful analysis would be necessary to determine whether an individual institution was complying with the definition.

What is RSI?

The DoE seems to be channeling US Supreme Court Justice Potter Stewart, whose famous test for obscenity, in his Jacobellis v. Ohio opinion, was “I know it when I see it.” The University of Texas Rio Grande Valley has helped fill the void left by the DoE with this thorough reference work. They focus on four key aspects of RSI. Interactions must be:

  1. with an instructor that meets accrediting agency standards
  2. initiated by the instructor
  3. “regular” and somewhat frequent
  4. “substantive” — of an academic nature

The article includes a handy checklist for designing RSI-compliant courses. One point from their checklist shines through as being crucial for meeting RSI standards and also for providing quality in-person education.

“There is at least one assignment per week where substantial feedback from the instructor is provided.”

What is “substantial”? As the University of Alaska Southeast’s CELT Knowledgebase states, a way feedback could fail to be RSI compliant is if:

No personalized feedback on any assignments – comments like “good job” or “needs improvement” do not count as personalized.

If you attended higher education in the US, you’ve probably experienced something similar. A paper you worked on for 3 weeks comes back with “B+, nice job” scrawled on its cover. Or week after week of video lectures and computer-graded, multiple choice exams, with a professor who could make eye contact and never recognize you from the third row of his Tu/Th lecture. Other systems of higher education, like the UK, New Zealand, Singapore, and Australia, invest far more in systems to create personalized, actionable feedback. They do more writing with their students than the average US college program, ensure multiple readers (or “markers”), and audit to ensure consistency and depth across instructors and courses.

Regardless of where you attended college, students also remember the faculty who go out of their way to engage them. Who provided meaningful, timely feedback. Who created a culture of inquiry that inspired you to stick around after lectures and ask questions, to work hard at revising projects, or rewrite for a little bit of extra credit. 11trees builds solutions for these educators, whether in the US or the UK, teaching at the college level or middle school. RSI might sound like a term dreamed up by an actuary (it kind of is), but 11trees believes it is the aspirational, baseline goal of any educator. Feedback is the building block of RSI and student engagement, as we detailed in our post on “The Science Behind Effective Feedback”:

Feedback is essential to helping students grow and achieve their goals. Research by Hattie and Timperley (2007) found that effective feedback could double the speed of learning. Similarly, Kluger and DeNisi’s (1996) meta-analysis demonstrated a strong connection between well-executed feedback and improved student performance. When students receive constructive, actionable input from their teachers, they can better understand how to improve their work. By incorporating effective feedback, you can create a more engaging and productive learning environment for your students.

Regular and Substantive Interaction shouldn’t be limited to just “distance learning.” RSI, and its core component of personalized, timely, feedback is central to all forms of education.

Annotate PRO: A Powerful Tool for Effective Feedback

RSI and personalized feedback are easy to support until you consider a teacher with 100+ students reading five-page essays. Amazon’s writing-centric culture provides three minutes of reading per page. At that rate, an instructor would spend 25 hours, without any breaks, reading the 100 essays. 11trees built Annotate PRO (AP) to support effective feedback and save instructors time. AP’s customizable, reusable comments promote efficient communication between instructors and their students. For example, when grading essays, instructors can create a comment in Annotate PRO that addresses a common issue, such as weak thesis statements, and use this comment with multiple students while still personalizing each instance to reach that individual. Schools can create shared comment libraries, aligning feedback with curriculum and standards.

How Annotate PRO Enhances Feedback Best Practices

Using Annotate PRO offers numerous benefits:

  • Time-saving features: The reusable comments in Annotate PRO help save time, allowing teachers to provide feedback promptly after an assignment. With a well-organized comment library, you can quickly insert relevant feedback without having to retype the same suggestions repeatedly.
  • Improved feedback quality: Annotate PRO supports deeper learning and a better understanding of course content by allowing educators to provide more precise, targeted feedback. Since the feedback gets saved to be re-used it facilitates dedicating more time to creating higher-quality comments. Over time these comments turn into a fantastic Library of high-quality content.
  • Analytics: We’re still exploring, with a number of highly engaged clients, what it means to have detailed data on feedback. Both for individual faculty (”wow – I wouldn’t have thought 45% of my comments were on grammar and mechanics”) and institutions (”which areas of feedback are receiving the most attention from the 45 faculty in our program. Can we adjust the curriculum to focus more on this area?”).
  • Seamless integration: Annotate PRO’s compatibility with popular learning management systems, such as Canvas and Google Classroom, ensures a smooth experience for both teachers and students across grading and discussion workflows. This integration makes it easy to provide feedback directly within the platform where students submit their work. AP also works with Google Docs and Microsoft Word, supporting draft feedback and a variety of personal tool choices.

AP is free for individual educators

Create as many Libraries as you’d like, save zillions of clicks with our fantastic toolbar for Canvas, Bb, Moodle, Schoology, Teams, Brightspace, Google Docs, and Microsoft Word…


In 2019 the US Department of Education’s Federal Student Aid office disagreed with the audit’s finding and eventually, WGU was cleared. The institution’s reputation, focus on innovation, and a lack of definition on how to evaluate RSI led to the decision. Any measurement, especially when it involves billions of dollars in financial aid, can have unintended consequences. 11trees hopes that the ongoing discussion over RSI brings attention to the quality and quantity of feedback students receive, instructor presence in online courses, and the huge value created through human engagement. As the 2014 Gallup-Purdue survey of 30,000 graduates showed:

If an employed graduate had a professor who cared about them as a person, one who made them excited about learning, and had a mentor who encouraged them to pursue their dreams, the graduate’s odds of being engaged at work more than doubled. Only 14% of graduates have had all three.

Feedback matters.

Sources and Helpful References

Inside Higher Ed, August 2018 – Defining ‘Regular and Substantive’ Interaction in the Online Era

The University of Texas Rio Grande Valley Center for Online Learning and Teaching Technology – Regular and Substantive Interaction (RSI) in Distance Learning

University of Alaska Southeast – CELT Knowledge Base – RSI: Regular and Substantive Interaction

Department of Education – Regular and Substantive Interaction: Background, Concerns, and Guiding Principles (PDF)

Department of Education – Response Letter to Kathryn Kerensky

11trees – The Science Behind Effective Feedback

The 2014 Gallup-Purdue Index Report –