3.2 - Federal DE Definition & Requirements: Interaction & Authentication

Regular and Substantive Interaction

The federal definition of distance education (DE) comes from Title 34 of the Code of Federal Regulations (CFR), §600.2 Links to an external site.. The definition notes several technologies which may be employed in DE, but in terms of regulation, the key part of the DE definition is: 

Distance education means education that uses [technology] to deliver instruction to students who are separated from the instructor or instructors and to support regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously. [emphasis added]

With substantial updates to federal regulations in 2020, expectations for "regular and substantive interaction" (RSI) became much more detailed than previously. But all along, RSI has been understood to distinguish "distance education" from "correspondence education," which is vitally important to a higher education institution's federal financial aid status. 

Further, California Title 5 DE regulations were updated in 2022 to closely align with the federal RSI regulations, and our accreditor (ACCJC) bases its DE evaluation solely on federal standards, which for RSI state:

For purposes of this definition, substantive interaction is engaging students in teaching, learning, and assessment, consistent with the content under discussion, and also includes at least two of the following -

1. 1. 1. Providing direct instruction;
      2. Assessing or providing feedback on a student's 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.

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. 1. 1. Providing the opportunity for substantive interactions with the student 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 student's academic engagement and success and 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.

 The LACCD's AP 4105 reflect these regulations.

Authentication, or Student Identity Verification

A little further along the CFR, §602.17(g) Links to an external site. outlines expectations of accreditors in several areas, including that an accreditor:

"Requires institutions to have processes in place through which the institution establishes that a student who registers in any course offered via distance education or correspondence is the same student who academically engages in the course or program."

The most straightforward way to comply with the regulation is by using Canvas, which requires students to use credentials (username and password) provided by LACCD.

You may note that the federal regulation also seems to indicate a broader concern with academic integrity that isn't fully addressed simply by using Canvas. After all, a student can easily share their credentials with someone who could then complete classwork on their behalf. Historically, while this is certainly an important concern of educators and institutions, it has not been understood as a mandate for accreditors to enforce in the context of this regulation.