Self-Paced Courses Are Not Online Courses
At a recent national conference, a federal regulator leading a Title IV funding workshop maintained that self-paced courses tend to have limited interaction, primarily initiated by the student, and that this fits the definition of correspondence courses, which are generally not eligible for federal student financial aid. This is based on Title 34 of the Code of Federal Regulations part 600.2 which defines distance education courses as including instructor-led regular and substantive interaction and correspondence courses as not.
The consensus of the workshop was that distance education courses at our institutions should be marked by instructor-led regular and substantive interaction and that it may necessarily vary based on the nature of the course.
Here are some guidelines derived from that discussion:
- Instructor Led: The instructor should take primary leadership throughout a course with less skilled and knowledgeable students, but may be able to provide less leadership support throughout a course with higher skilled and knowledgeable students. In either case the instructor should not abdicate leadership nor allow the course to be self-paced or student led, and instead the instructor should provide regular and substantive interaction.
- Regular Interaction: A lower level algebra course may require a great deal more frequency of interaction to keep students on track than a graduate course in research methods where students may stay on track on their own for longer periods of time. But both courses require the instructor to lead substantive interaction with some regular frequency.
- Substantive Interaction: The federal regulator defined substantive as that which is academic in nature and
not merely course logistics. The group went on to say evidence of substantive interaction
- The Instructor
- providing feedback about assignments. Please note that the December 19, 2014 Dear Colleague letter from the U.S. Department of Education Office of Federal Student Aid when speaking about this subject states that "merely grading a test or paper would not be substantive interaction."
- conducting regularly scheduled instructor led learning sessions.
- providing faculty mentoring, consultations, or guidance (synchronous or asynchronous).
- The Students
- submitting assignments at the direction of the instructor.
- participating in online discussions (synchronous or asynchronous) with other students and the instructor.
- participating in an assigned study group.
- engaging in interactive tutorials (these should not stand alone as the only method of interaction).
- The Instructor
In any case, the instructor should not leave the content to teach on its own nor students to learn on their own and should instead lead interaction on a regular and substantive basis.
34 CFR 600.2 - Definitions. (n.d.). Retrieved March 03, 2017, from https://www.law.cornell.edu/cfr/text/34/600.2
Competency-Based Education Programs- Questions and Answers. (2014, December 19). IFAP - Dear Colleague Letters. Retrieved March 03, 2017, from https://ifap.ed.gov/dpcletters/GEN1423.html
Interpreting What is Required for "Regular and Substantive Interaction". (2016, September 30). WCET Frontiers Blog. Retrieved March 03, 2017, from https://wcetfrontiers.org/2016/09/30/interpreting-regular-and-substantive-interaction/
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