Responsible Administrator(s):
Responsible Office(s):
Originally Issued: May 2026

Statement of Purpose

This policy outlines the University’s requirements for regular and substantive interaction in all online classes in order to ensure compliance with recent federal regulatory requirements as well as relevant NSHE Board of Regents’ provision of timely interaction with students set forth in the Distance Education policy. Federal regulations in 2021 updated the definition of “distance education.” Additionally, the 2021 federal regulations specifically defined relevant critical terms, including “instructor”, “regular” and “substantive” in connection with distance education. Failure to comply with federal regular and substantive interaction regulations may significantly impact an institution’s eligibility for Title IV federal financial aid.

Entities Affected by this Policy

Colleges, schools, and academic departments.

Who Should Read this Policy

Deans, Chairs, Administrative leaders of academic units and faculty and/or instructors teaching online courses.

Policy

Any and all employees including faculty and/or instructors who are appointed to teach online courses are responsible for providing regular and substantive interaction with students as defined by the U.S. DOE in 34 CFR § 600.2. Additionally, in accordance with NSHE Board of Regents’ Distance Education policy, each online course must provide opportunity for timely interaction between the student and the instructor or responsible member of the instructional team regarding a student’s progress. (NSHE Handbook Title 4, Chapter 14, Section 14)

Additionally, academic units have the following responsibilities:

  1. To determine which courses may have online sections in any given term as part of the class scheduling process;
  2. To appoint instructors for online class sections based on prevailing standards for the discipline and institutional accreditation standards;
  3. To ensure that instructors understand the requirements to provide regular, substantive, and timely interaction with students; and
  4. To monitor online instructors’ provision of regular, substantive, and timely interaction with students using methods that may include:
    1. Reviewing activity in online learning management systems.
    2. Reviewing syllabi for online class sections
    3. Conversations with online instructors or students

Related Information

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Definitions

Instructor

An individual responsible for delivering course content and who meets the qualifications for instruction established by an institution's accrediting agency.

Substantive interaction

Engaging students in teaching, learning, and assessment, consistent with the content under discussion. And, substantive interaction includes at least two of the following:

  1. Providing direct instruction;
  2. Assessing or providing feedback on students’ coursework;
  3. Providing information or responding to questions about the content of a course or competency;
  4. Facilitating a group discussion regarding the content of a course or competency; or
  5. Other instructional activities approved by the institution's or program's accrediting agency.
Regular interaction

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,

  1. Providing the opportunity for substantive interactions with students on a predictable and scheduled basis commensurate with the length of time and the amount of content in the course or competency; and
  2. Monitoring the students’ academic engagement and success; and
  3. Ensuring that an instructor is responsible for promptly and proactively engaging in substantive interaction with the student when needed, on the basis of such monitoring, or upon request by the student.
Timely interaction

The NSHE Board of Regents Distance Education policy, Title 4, Chapter 14, Section 14) states that “timely interaction between students and instructors in distance education courses may include the following:

  1. Orientation sessions at the beginning of the courses;
  2. Periodically scheduled guidance or tutoring sessions during the semester either on an individual basis or in a group setting; and
  3. Provision for access by the student for advice or consultation with the faculty, either in face-to-face sessions or assisted through technology.