Why Documenting Interaction Is Key To Staying Compliant

Because it is still unclear whether or not in-person instruction will be possible in the near future, the Department of Education has taken steps to prepare for the continuation of remote online learning in the Fall. As of April 2, the ED has proposed updates to its guidelines for institutions participating in the federal student aid programs authorized by Title IV of the Higher Education Act. The updates include new guidelines around distance learning to ensure that students taking online courses receive quality education. 

In the Spring, schools had to act quickly to provide an online version of their in-person courses in response to the pandemic. The ED provided broad approval in March to schools looking to quickly transition to distance education in the name of public health. But now that schools may need to continue hosting online courses in the Fall, the ED has set new guidelines around distance education.

Updates To Regulations

The new guidelines for distance education by the ED include an emphasis around regular and substantive interaction. Let’s take a closer look at how the ED defines them. The proposed rule would define “substantive interaction” as interaction that engages students in teaching, learning, and assessment consistent with the content under discussion, and includes at least two of the following: providing direct instruction, assessing or providing feedback on a student’s coursework, providing information or responding to questions about the content of a course or competency, facilitating a group discussion regarding the content of a course or competency, or other instructional activities approved by the institution’s or program’s accrediting agency.

The proposed rules would also define “regular interaction” as providing the opportunity for substantive interactions between instructors and students on a predictable and regular basis commensurate with the length of time and the amount of content in the course or competency. In addition, “regular interaction” monitors the student’s academic engagement and success and ensures that an instructor is responsible for proactively engaging in substantive interaction with the student when needed, on the basis of such monitoring, or upon request by the student.

The word “opportunity” is interesting to note in the definition of “regular interaction.” It may be a way to make the treatment of distance education and in-person classes more equitable. When asked why the Department is not worried about the lack of interaction in an in-person course with 500 students, the answer has been that the student has the “opportunity” for interaction with the instructor.

Schools that wish to start or continue with distance education in the Fall may have to apply for ED approval and comply with the accrediting agency’s policies to make sure they’re up to date with these new standards around regular and substantive interaction. And the more rigorous schools are when documenting interaction opportunities, the better off they’ll be during the approval process.

The Importance Of Interaction Documentation

The proposed guidelines emphasizing regular and substantive interaction validate the importance of documenting opportunities of online interaction and engagement. Because consistent engagement and interaction are determining factors for classifying a program as distance education instead of a correspondence course, schools will need to be able to prove that their level of online interaction opportunities meets the new ED requirements.

Schools that document student interaction in online courses will be best positioned for distance education approval down the line. In the case of future audits, they’ll be prepared when accreditors dig deep into school operations. Not to mention, accurate documentation of interaction opportunities will also help protect themselves against future lawsuits.

Even if students aren’t taking advantage of interaction and engagement opportunities, it’s important to document that the opportunities existed. Manually documenting engagement data is a big effort, can take a significant amount of time, and will inevitably result in inaccuracies. So how can schools accurately keep track of and document opportunities for student interaction?

There’s An App For That

The most accurate and efficient way to document interaction opportunities is by using software to record student interaction electronically. Top of the line software will automatically maintain records of student interaction and engagement that schools can reference during an audit or when applying for distance learning approval. School administrators can save their time for other tasks while the software collects accurate and granular data about engagements, assessments, communication, group discussions, and more. What’s more, by providing schools with insight into their level of engagement with students, software empowers schools to make changes if necessary to bring engagement back in line with regulations.

Meeting New Standards

Now that the ED has updated guidelines around distance education, schools that are looking to continue with distance education in the Fall may need to apply for approval. Having a software in place that records any type of interaction and engagement between students and their instructors or classmates will build out schools’ track records of regular and substantive interaction and put schools in a great position to receive approval by the ED to administer distance education moving forward.

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