How EdTech & RSI Coexist [Learner Engagement Summit]

Brianna Bannach 0:05
Thank you for joining the session called assuring measuring and documenting regular and subsequent interaction how Ed Tech and RSI coexist. I'm excited to introduce introduce you to the speakers. We have Russ Poulin, who leads the WICHE cooperative for educational technologies, which advances learning, learner access and success through post secondary digital learning. For a more equitable world, we also also have Katherine currency Director of Digital Learning police policy and compliance. Sorry, can't talk today for the state authorization network, a division of WCET. And then it is very own Brian Verdine, who is our VP of academic product engagement. Everyone here is an expert and knows a lot about this topic. So please listen up and learn what I'll toss over to us.

Russ Poulin 0:58
Okay, let's go to the next slide. And this is about WC. T. We're while we're part of witschi, which is a regional high education compact, that we were a little bit different from them that we focus on distance learning and educational technologies that we have member institutions, corporations, state agencies, accrediting agencies, organizations from throughout the US, and if you otherwise, and we do a lot of focus on policy issues. And so that's one of the reasons we're here today, Katherine alternative.

Kathryn Kerensky 1:31
Thanks, Ross. And thanks, Briana, for the introduction. As you said, I'm Kathryn Kerensky. I'm with the state authorization network, which is a division of WCET. And just to mention a little bit about the state authorization network. It's a national organization of more than 800 institutions and agencies. Our mission is to empower members to successfully resolved post secondary educational technology challenges as they relate to regulatory compliance. We provide training support opportunities for staff to engage, and to offer and collaborate on sound implementation practice for regulatory compliance. So we really want to stay at the forefront and keep our members apprised of timely issues that touch added state activity compliance. Now, advanced the slide so we can get started with our content today.

Russ Poulin 2:15
We want to give you all thank you, everyone for for joining us today and for having us here and wanted to give you a little bit of background about me, what is this regular and substantive interaction thing. So it's helpful to have some of this background and probably say this a couple times, it'll be helpful to understand that the word internet interaction, it's not always what you think it is, it's not always the academic notion of interaction. And we'll get we'll get to that in more detail in a little bit. Also, this will frustrate some of you I know that but some of the definitions are from the Department of Education are intentionally left vague, because they have to hit have to fit the wide variety, of course, instructional and institutional models found throughout the US. So with that, let's go ahead and move to the next slide here. And talk about the purpose of this and that the term came about, because it was for defining federal financial aid eligibility in Congress in 1992 created a distinction between the definitions of distance education on the one hand, and Correspondence Education, the other, there had been some financial aid fraud and Correspondence Education around that time. And department wanted to make sure to protect students who were taking courses via the emergent emerging Distance Education modality and makes sure that they can be eligible to receive federal financial aid. So remember, this is all based in financial aid definitions. And then the marker used to distinguish between the categories of distance versus Correspondence Education was that distance education includes this notion of regular and substantive interaction, we'll define that more, whereas correspondence courses do not. So they were trying to define these in opposition to each other. Until recently, the only type of interaction so that was counted were activities initiated by the instructor, such as lectures, tests, assignments, those sorts of things, video videos, and instructor initiated activities are still the bulk of the interaction. And it's counted that a lot of things around students, students or other types of interactions are counted only in certain certain places. Let's go ahead and move to the next one. Let's see. So, so important, put in compliance in the context and who will actually be reviewing this. There are essentially three sources of those who will review it and then the first being the US Department of Education because it is after all, their definition and they wanted to have it for or federal financial aid purposes. And what happens is that department staff will conduct reviews or audits, their financial aid staff or the Office of Inspector General will conduct reviews or audits of institutions to ensure that they're in compliance. The definition is centered on the purpose of financial aid accounting. And again, I said, as I said before it less than the academic notions of interaction, although they sort of use that as a proxy for quality, distance education courses are eligible for financial aid. Grants, if an institution has more than half of its courses are more than half of its enrollments classified as Correspondence Education in the institution loses financial aid eligibility. So it's important to note that aid eligibility is based upon this institutional measure, and not course, by course. So when of course is ruled to be really correspondence, it's, that's that doesn't necessarily say that it can't be available for financial aid. As a result of your found out of compliance, that that you could, the institution could reuse aid or that there could be other repayment of tuitions or fines that could happen. Another group that does the review would be accreditors. But because some of them have, we're doing substantive interaction in their policies and want to make sure that it's you're following that forward distance education courses, and then fly in. And also that last would be internal institutional reviews, that you can see offices making sure that that you're in compliance or worrying about the quality or what's going on or making sure that you're in compliance with the department and that you will be looking at yourselves. And then when it's not on the slide here is that the there are some states and so I'm thinking of the California Community Colleges have a related expectation for eligibility for state financial aid. That's called regular and substantive engagement. And it's very close, but a little bit different. Of course, you know, governments can be a little bit different. So you have that on there. But we won't be talking about that today. But just wanted to note that you may have something similar in other other states. And let's go to the next one. And do you Katherine?

Kathryn Kerensky 7:23
Thanks, wrestling. So we're going to talk a little bit about what these terms actually look like in terms of how they're defined. So as Russ mentioned, the Department of Education defines distance education. And we're going to go and see what that definition is, it seems like a simple definition. But there's really a lot to look at here. So it's defined distance education is defined as education that uses one or more of the technologies listed to deliver instruction to students who are separated from the instructor, and to support regular and substantive interaction between the students and the instructor either synchronously or asynchronously. So there's a lot of little points here in this definition, to understand and it's important to know a lot of these other terms are now defined. So you have to look at other definitions to fully understand this definition. In fact, only as of July of 2021, were some of these extra terms defined. So in 2021, the last set of the distance education, innovation regulations from the department went into effect. So these had updates to the definition of distance education. And most notably, the terms regular and social interaction were actually defined for the first time, they weren't previously defined. So what that meant is institutions essentially had to piece together guidance from the department in order to determine what is necessary for compliance. And it was very difficult to do that. And it could be a risky endeavor to be wrong. And this is because as Ross said, it's important to have RSI any distance education course, for purposes of financial aid. And given that this, this title of this session is about Ed Tech, and RSI and coexisting just one other definition, one to highlight here is about technology. So that's actually defined in terms of the technologies that can be used. Just wanted to note here, you can see the definition on this slide. I won't read all the points here. But there are really only minor revisions to the language when these updates were put out in 2021. And it was mostly just to update the types of technologies that are being used, and to remove some references to outdated technology. So you can see the updates here on this slide. We're happy to answer any questions, but do want to mention that, given the context of our presentation today, and then Ross, I believe I'll hand it back to you to talk about regular the definition of regular substantive

Russ Poulin 9:50
that'd be great. Yeah. And, and we had mentioned that there's been some changes to this in the last few years but But prior to that, that there it was really not well defined. and uses their regular. Okay, so regular could be in the eye of the beholder, I guess. And so one of the things that van Davis and I did about six or seven years ago is that we looked at everything that was out there dear colleague letters, federal financial aid audits and whatever we could find and try to figure out what what are they when they're reviewing institutions? What are they thinking regular means, in that it was another one of these where it was really loose. Where is it, the students had a fairly set schedule, that are not too far apart, but what's not too far apart or anything. So I was involved in the rulemaking that went on and T's 2019. Now that worked, worked on this. And so we tried to do a little bit more. And again, it's not perfect, and that it is purposely a bit vague, because you have to take in so many different types of institutions. But you see out there that there's two different things, and you must fulfill both of these to be regular one is that it must be any predictable and scheduled. And we added the emphasis in here, basis, you know, depending on the length and content of the course. And so again, this is intentionally inexact, because when you're rulemaking we're trying to say, well, what if it's once per week? Well, if you have a three credit semester course that you have in six weeks, that once per week is really not too great. And so that didn't work out. And we tried creating a formula department tried creating a formula for different lengths of courses. And then you could tell competency based education there. And so we left it with this is the exact wording that you see here in italic step is something that gives you an idea that really helps you can put in a you know, if you put things in the syllabus, and people can see, well, they know when things are going to happen, then it's going to be the state to state this state or every Wednesday that there's a quiz or however you do it for predictable. And remember, you have to do both of these. And that's monitoring the students engagement, the academic engagement and what they're what they're doing. And that takes two parts. One is that you're able to show that you're monitoring the progress of the student, and that if they're not moving forward that you reach out to them. And the second part of that is that you also in here's here's the first time that we've seen where something where it's not that the instructor initiates it, but where the the faculty instructor needs to engage with the student upon requests, the student has a question that there's a way for them to answer, ask that question and get a get a response. And again, there's not a set time so that for all this because it's sort of based back on that notion of what is commensurate with the type, the content and the timing of the course. Now, let's go to the next slide, which gives you some some examples here. And you will get these slides as I understand it. So you can look at these a little bit more. But again, for the most part, the interactions are things that are except for that last one where the student asked question that most of the rest of it is things that are initiated by the faculty members, such as setting up a discussion and monitoring a discussion, having quizzes, having tests having having synchronous discussions or asynchronous discussions, yeah, all these sorts of things all fit into the regular interaction. Let's now move to the other big word substantive. Some people laugh at the way I say substantive, but I hope that but previously, again, the term was not substantive was not well defined, either. In our review that talked about that, really, the only thing they really said was that the QAT did the content had to be relevant to the subject matter, which was, you know, pretty good. If you're talking about Shakespeare, you should be talking about Shakespeare and not about cats, or basketball, or the weather, or those sorts of things. Those don't, those don't count unless it's Shakespeare related weather. But from the recent changes, regularly substantive interaction, the department is now defined it a little bit more. And while the one above you had to do all those things, and this one, you just have to do at least two, okay, hear me at least two of these, you do not have to do all of these for the course to be considered distance ed. And so the first one is direct instruction. And recently we found out that they had that term in there and it was never defined. And so we asked him, What do you mean by that? Because we thought we knew and they do mean synchronous instruction, that don't freak out. Didn't you hear that? It's only synchronous instruction can because maybe it's two of these fives. So pretty much for assessing and providing feedback, providing and responding to questions, providing information, responding to questions or facilitating group discussions, that those three pretty, we'd hope that most distance ed courses that are worth their salt will probably have all three of those, then they have this nebulous one that kind of took in, you know, other innovations that may be coming along that people will be doing that they didn't think of. And then, as long as the accrediting agency approves, approves it, as in gives you a letter saying that, yes, this is substantive, that would count too. So again, these things you know, shouldn't be related to the, to the content. With that, I'm going to go to the next slide with some some examples here. Again, you can look at the these sorts of things in terms of, uh, you know, again, uh, you know, monitoring, monitoring a discussion or course specific materials that are relevant to the course and getting those out there. And, and so with that, I think I'm going to go ahead and move to the next one and go to Catherine.

Kathryn Kerensky 16:18
Yeah, so I just wanted to give a quick update here. And Ross already kind of mentioned, the update that we'd heard from the department about how they interpret direct instruction. So we just wanted to point out and give a little bit of context about that. So the definitions are helpful. But essentially, a lot of our members still have some questions on how to best implement it, we have a lot of very conscientious and diligent members who want to make sure they understand things. So we wrote a letter to the department back in 2021, after asking some of these questions to them asking for guidance. And late last year, around October, November of 2022, we got the response. And then we wrote a blog, which is linked here, where we analyze that, and that's one of the points that you can see in the blog is that interpretation of of direct instruction. But, and I don't want to take too much time here to make sure we can get to Brian into questions. But essentially, there is still a lot of wiggle room here. I mean, the department's probably not going to issue a lot more specific guidance. But they do lean on the in credit the creditor for some interpretations and guidance. So definitely with questions, you want to rely and ask your creditor for some things, especially as it relates to instructors. And in addition, a lot of information was gathered as institutions undergo these reviews that Russell is talking about. So we're hoping to gather more information about what those reviews are like, and what kind of information is asked for those. And we can share that out and be able to give people more information. But I guess that you should be able to get all that in the link there. And feel free to ask us any questions too. When we get to questions. I do want to quickly just talk a little bit about some compliance tips and strategies. Like I said, there is some room for institutions to develop processes and policies that best suits your needs. The department, you know, hasn't really laid out any specific requirements here except just that there are policies in place and at the institution follows their own policies. But you do. The key is you do want to have a reasonable good faith effort in interpreting these requirements, and monitoring compliance at your institution. So that'll look different everywhere. But these regulations and the guidance, they they essentially provide some guideposts where the lanes that institutions should be working in when they develop their policies. So just a little bit of information on what exactly are those guideposts? What is the department going to look for when they're reviewing things? It's these five factors here, and it's essentially a distillation of the regulations just stated a little more directly, that the online instruction is delivered through an appropriate form of media, instructors regulary, incidentally, interact with students accredit instructors meet the requirements of the creditor, there's two forms of substantive interaction, scheduled unpredictable opportunities for interaction, and then that instructors are responsive, responsive to students request for support.

Brian Verdine 19:12
All right, thank you, Catherine. And Ross, you know, in thinking sort of how Yellowdig plays a role in meeting these needs, I think the first answer is, first of all, the technology is generally complying with the need for this to be an appropriate form of media, right? So, you know, I listed some of the things that are available inside of yellow day, but it's sort of, in my mind's eye unquestionably meets the needs of the sort of technology in terms of allowing the interactions that, you know, would be necessary, at least for asynchronous interactions. And so, you know, for that one rule that Russ pointed out about direct instruction And, you know, Yellowdig might not be able to meet that need, but it's going to be able to meet, at the very least the three interior ones, you know, that that were more related to to asynchronous or could be a synchronous. If you're gonna go to the next slide, Catherine, you know, one of the other requirements that was in that list was that the instructor be accredited. And while we can ensure that the instructor is accredited, our technology can with the sort of one continuously and globally accessible community, make sure that you your accredited instructor is able to, you know, build RSI events into their courses, and interact with their students, regardless of where they may be in the world or what timezone they might have to try to interact with your course in. So, you know, in terms of, you know, again, the role of the technology here, it's providing the opportunity for these RSI events to to happen. If you want to go to the next slide pattern, that one got really out of whack. There's three things that were supposed to be on this slide. One of them being sort of, on each side, there was supposed to be bubbles for the instructor and student, but basically Oh, there they are, okay, they were they were, they were animated sorry, I didn't realize that there are a number of designed opportunities that you can build into your course using the elevator, so you can set your expectations in the syllabus. As as you need to know Yellowdig has topics and the ability to use different conversation themes throughout the weeks would it would would allow you to do things like have the discussions that are part of of these RSI, you know, events that that that can be counted. The other thing that Yellowdig obviously does is allow for the instructor to reach out as needed. You know, we collect a lot of data in the platform to show, you know, if a student is falling off, or maybe not participating in the class, there's plenty of ways to reach out there, if an instructor notices, you know, students are having some confusion in part of the course, they can sort of supplement their their instruction in various ways and show you know, sort of responsivity to the student needs. And then finally, you know, students are able to initiate an event, which the instructor can then sort of respond to. But it's important as you're sort of thinking about the design and thinking about how to build in these RSI events that you've covered, you know, sort of all three of them, all three of these categories. And in some ways, or maybe you don't need to do that specifically for the requirements. But you probably do need that to make your course more engaging and effective for you to learn as, as well. So, you know, building all three of these into the course is going to be something you're definitely going to want to do. I want to make sure there's time for for questions. So I guess we can jump onto the next slide. I think one of the things that technologies like ours can really play a role in showing evidence of compliance. So for evidence of compliance, you can you can stay on that one big pattern, the previous one. You know, you want to show that your course syllabus and other documentation has these things built into it, you're going to want to show that there are policies and procedures in your university that are consistent with supplying RSI, and then as I was saying some of the data from from your learning management system and other interactive technologies are going to end up playing for most of these courses and major role in documenting that evidence. And at least in in Yellowdig. Our data models are pretty strong. And Catherine if you want to go to the next slide, some of the things that we you know surface right in the platforms and network graph with a table shows you how students are connecting whether they're connecting with the instructor whether they're connecting with each other, how long it's been since they've connected with people. We get participation insights from a reminder system we have so that reminder system automatically sends reminders to students to come into the system. From the perspective of RSI, those kinds of automated things do not count but Uh, what would count is if instructors sees that a student, you know, has not been responsive to those reminders. And the instructor would reach out to the student and kind of say, Hey, what's going on? You know, how are you doing? We have a lot of other reports, data and attendance tracking API is probably one of the biggest ones. And we're continuing to extend that in response to the RSI requirements. But essentially, you know, we already have API's available that will, you know, send data to your systems to be able to store it, about these interactions. So I'm going to stop there. And I think, unless you guys have anything else to add, we're probably looking for questions. Very asked with the interactive lecture video with embedded questions provided on feedback foods. Sound is interactive videos really count as as interaction. Yeah. And

Russ Poulin 26:01
Catherine, and be curious to see what you'd say. But why, best take on that from the clarification that we got from the department in the you can go to the blog posts that we put up before, and the responses from them would be know that if it's some sort of, if it's an automated system, within the videos, that they weren't counting those that there has to be some faculty, faculty involvement? Would you agree with that? Or did I get that wrong, Catherine,

Kathryn Kerensky 26:34
if I'm understanding how it would work, I would agree. But I do think it'd be a good time to mention just something and we talked about this in our blog, too. Just so it's clear, just because something wouldn't meet RSI, it doesn't mean that it's not a good practice. There's a lot of good practices in courses that shouldn't be done. You know, even just even things that aren't related to the course, like the competency, just like icebreakers or interactions, not related to that just, you know, it's good for building that kind of community in the course. And you know, from what I'm reading in this, like, that sounds like a very good way of teaching, it just wouldn't have, it just wouldn't meet RSI, but you have to have a lot of these other things to kind of fill up the course. So they're still valuable. And it's not like they're prohibited at all from from doing that just because it would not meet RSI

Russ Poulin 27:19
down there adaptive learning things that you know, that, that that certain points that the faculty is, it can be waived in or the student can do that. And that certainly means that second part about you know, watching what students are doing, and and making sure that you're responding to your questions.

Brian Verdine 27:41
And I see that array and also as we providing discussion firms count, as far as I think the regulations talked about sort of facilitating class discussions, were course discussions as being one of the events, I'm not sure if just providing the prompts would would, would be enough to count and I think my my response on a lot of these is sort of like, if you have to ask maybe doing a little bit more is probably a safer thing. Right. But facilitating a course discussion wouldn't be just throwing up a prompt, it would also be, you know, giving feedback to students in response to those prompts or taking part in the conversation. And I don't know, Katharine Ross, do you have anything to add to that, but I would think that, you know, sort of facilitating discussion, in addition to that is something that they would want to see.

Kathryn Kerensky 28:52
Yeah, I would agree with that, Brian, in terms of posting, to me be the equivalent. I feel like I've heard this on a department mentioned this as an example of like, just posting some questions and like never returning to them until the end of semester. Like that would meet the requirements. So just because you like put like, Oh, you have to respond to these things. Like there still needs to be the instructor is like prompting, like more responses or giving feedback on that. And maybe especially using a learning opportunity to say like, oh, this person made this point, what is other people thinking about it and keeping the conversation going, maybe pulling it into other assignments, or other points in teaching and, and just I think using it for review in terms of like, okay, this is what people know, being able to adapt the course based on the types of things that you're seeing in those things. I think there has to be evidence that the instructor is reading them responding to them and using them in ways that benefit.

Russ Poulin 29:45
I would say, that kind of gets to raise peer review questions as well. Is that that I can envision different different versions of that. As Kathryn said, if you put out the peer review and go on vacation till the end of the semester, that ain't gonna work. But if you do the peer review, and you're, it's something that's iterative, and you're as a faculty member, that you're involved that at times and expecting out reports and you're commenting on those reports, then then that's, you know, pretty close to the, it's a different way of putting out assignments and in giving feedback on the Assignments except for getting help in the grading from the students.

Brian Verdine 30:29
I think in one of our earlier conversations, Ross, we were talking and he said something that I thought was fairly helpful in my own thinking about it, right, that sort of like, if you were to be audited and somebody was reviewing one of your courses, would you want to have to defend, you know, putting a discussion prompt in or putting something in and then not responding to it? Odds are if they see enough courses that are sort of, you know, in that current mode or or whatever that is going to become an issue. Yeah. As far as sort of fulfilling the, the intention of some of these, you know, regulations, right, we want to make sure we're fulfilling the intention of them. I think

Russ Poulin 31:16
we call those defensible practices is that what what you want to be able to do is that, let's say that you're sitting across from monitor you want to be able to show, but here's what you said. And here's the policies that we did. Here's the faculty development that we did. So we did try and so we thought from everything that was all the interpretations and it is a little fuzzy, they're not exact that from the interpretations that we had, we felt that we were following it. And here's the evidence of when when we did.

Brianna Bannach 31:46
Okay, well, I don't think there's time to fully talk through any more questions. So if you have any more please drop them in the Yellowdig community and someone will hop in and answer I'm sure. Thank you so much, Ross, Katherine and Brian for this really informative and important session to discuss. Now's the time to announce the raffle. So drumroll. Nancy glass you are the winner of a $50 gift card to your choice of Amazon, your your school bookstore or a coffee. Coffee place. I have your email so I will follow up via email. Thank you again. Speakers. It was a great session. See you soon