Academic Policy  1200.50 

Distance Education Online Standards for Courses taken for Academic Credit

I.           Overview.

The University of Arkansas complies with federal and state definitions of a credit hour and federal and state definitions of instruction for distance education courses taken for academic credit.  Distance education courses, denoted as online courses, are defined by Academic Policy 1622.12.  

The U.S. Department of Education (ED) expects that each institution of higher education facilitates scheduled and predictable opportunities for substantive interaction between students and instructors in online courses and creates expectations for instructors to monitor each student’s engagement and substantively engage with students on the basis of that monitoring.  

This policy meets the federal expectation by ensuring that instructors teaching online courses for academic credit understand and abide by expectations of federal requirements for those courses. Instructors must define how their online course meets these federal requirements in their syllabus.  These requirements apply uniformly in all academic semesters and terms. 

II.           Requirements and Definitions. 

The regulations associated with Part 600 of the Higher Education Act of 1965, amended in 2020 (34 CFR § 600.2), require that online courses provide regular and substantive interaction between the instructor and the students enrolled in the course.  These interactions must be initiated by the instructor, be regular and consistent, and be focused on the content in the course.  Interactions between students and graduate assistants (GAs) assigned to a course count towards the federal requirements but interactions between students and class assistants or other individuals who have not met the faculty qualifications defined in Academic Policy 1435.50 do not count towards meeting the federal requirements.

Regular interactions are interactions that provide the opportunity for substantive interactions between the instructor and the student on a predictable and scheduled basis commensurate with the length of time of the course, the amount of content in the course, and the academic level of the course (lower-level undergraduate, upper-level undergraduate, or graduate).  Interactions initiated by students cannot be counted towards meeting the regular interaction requirement.

The instructor must, as part of this regular interaction requirement, monitor the student’s academic engagement and success.  The instructor is responsible for promptly and proactively engaging in substantive interactions with students when needed on the basis of such monitoring of their academic success or upon request by the student. The instructor must share with students the course’s expectations and norms for how the instructor will monitor their academic engagement and success as well as how they will promptly and proactively engage in substantive learning interactions with each other.   

Substantive Interactions are those that engage students in teaching, learning, and assessment consistent with the content under discussion and also includes at least two of the following:

1. Providing direct instruction.

      1. This may be accomplished through synchronous technology such as Blackboard Collaborate, Zoom, or the like.  Asynchronous instruction (recorded lectures or other activities) do not meet the federal threshold for direct instruction.  Only synchronous direct instruction is considered substantive interaction as per federal guidelines.  Per Academic Policy 1622.12, direct instruction is not an option in 100% asynchronous online courses.

2. Assessing or providing feedback on a student’s coursework.

      1. An automated grading system that provides feedback based on a programmed response, interactions with artificial intelligence, adaptive learning systems or other forms of interactive computer-assisted instructional tools do not meet the definition of substantive interaction per federal guidelines.

3. Providing information or responding to questions about the content of a course or competency, in a scheduled interaction to align with the regular interaction requirement.

4. Facilitating a group discussion regarding the content of a course or competency, in a scheduled interaction to align with the regular interaction requirement.

5. Other instructional activities approved by the institution’s or program’s accrediting agency.

      1. The University’s accrediting agency, the Higher Learning Commission, has not approved any additional instructional activities under this definition.  A department head/chair must notify the Office of the Provost of the addition of an instructional activity by a program’s accrediting agency.

In general, it is recommended but not required that instructors provide at least one substantive interaction, as defined above, in every week of instruction for a three-credit course delivered over fifteen weeks.  The exact number of regular and substantive interactions with students is at the discretion of the instructor and/or academic unit commensurate with the length of time, amount of content, and the academic level of the course.  The methods by which an instructor elects to meet the federal regular and substantive requirements must be recognized by faculty members in the instructor’s discipline at peer institutions as sufficient for meeting the expectations for federal requirements at those institutions.  Academic unit practices and BOT 405.1 affords faculty academic freedom in determining how to develop and deliver online courses in a way that complies with this policy and the federal requirements it implements. 

III.           Controls and Compliance.

In addition to defining expectations for instructors to monitor student engagement, the Department of Education requires that institutions establish sufficient internal controls and demonstrate that they have established a system for monitoring or periodically evaluating its online courses to ensure that its instructors continue to observe such policies over time.  All online courses offered by the University of Arkansas meet this federal expectation by being created in conjunction with Global Campus, which during the initial instructional design process of a new course, is the unit responsible for apprising instructors of applicable federal requirements.  Global Campus, in conjunction with the academic departments, schools, and colleges, will periodically assist instructors and academic units in their evaluation of University of Arkansas online courses scheduled for rebuilding for continued compliance with federal requirements.   

Instructors have the primary responsibility for providing required instruction, monitoring academic engagement and performance of students, designing interactions that are appropriate and tailored to meet the needs of students, and ensuring compliance with these federal requirements, which is shared with Global Campus, Department Chairs/Heads, and designated Assistant/Associate Deans within each college or school under the supervision of the respective academic dean.  

IV.           Relation to Federal Definition of a Credit Hour

As per Academic Policy 1200.40, students enrolled in distance education courses earn academic credit where instruction is regular and substantive, and the student has the opportunity to demonstrate evidence of achievement of intended learning outcomes that is equivalent to the amount of instruction and student work in campus/face-to-face courses.

This equivalent instruction should approximate no less than 50 minutes per credit hour of synchronous direct instruction or an equivalent amount of time of asynchronous learning activities that the student has the opportunity to engage in each week over a fifteen-week semester. This engagement need not be monitored for each individual student in a course but instructors must regularly monitor the student’s academic engagement and success either through tools provided in the campus’ Learning Management System, or through the student’s academic performance and progress in the course and promptly and proactively engage in substantive interactions with students when needed on the basis of such monitoring.


October 11, 2023