Substantive Interaction and Administrative Drop Policy

Regular and Substantive Interaction Policy for Faculty and Students


All students – regardless of the modality of course delivery – are deserving of regular attention and support by Truman faculty.  The academic enterprise is a mutual activity.  Thus, for the effectiveness of their own education, Truman students are expected to regularly engage with course content and activities that are initiated by faculty.  Likewise, faculty should, at a minimum, meet certain expectations for regular and substantive interaction with their students. In taking steps to ensure such interaction, Truman complies with federal policies pertaining to the distribution of Title IV financial aid and helps ensure a predictable, quality learning experience regardless of modality.  It also protects the student by ensuring that fewer financial aid or personal dollars are expended in situations where learning is not taking place.

Definitions (as directly quoted from 34 CFR 600.2 as amended in 2020

Academic Engagement:  “Active participation by a student in an instructional activity related to the student’s course of study that–

1) Is defined by the institution in accordance with any applicable requirements of its State or accrediting agency;
2) Includes, but is not limited to-

  • i) Attending a synchronous class, lecture, recitation, or field or laboratory activity, physically or online, where there is an opportunity for interaction between the instructor and students;
  • ii) Submitting an academic assignment;
  • iii) Taking an assessment or an exam;
  • iv) Participating in an interactive tutorial, webinar, or other interactive computer-assisted instruction;
  • v) Participating in a study group, group project, or an online discussion that is assigned by the institution; or
  • vi) Interacting with an instructor about academic matters; and

3) Does not include, for example-

  • i) Living in institutional housing;
  • ii) Participating in the institution’s meal plan;
  • iii)  Logging into an online class or tutorial without any further participation; or
  • iv) Participating in academic counseling or advisement.”

Distance Education:  Distance Education is:

1) “Education that uses one or more of the technologies listed in paragraphs (2) (i) through (iv) of this definition 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.

2) The technologies that may be used to offer distance education include–

  • i) The internet;
  • ii) One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices;
  • iii) Audio conference; or
  • iv) Other media used in a course in conjunction with any of the technologies listed in paragraph (2)(i) through (iii) of this definition.”

Instructor:  “For purposes of this definition, an instructor is an individual responsible for delivering course content and who meets the qualifications for instruction established by an institution’s accrediting agency.”

Substantive Interaction:  [As a subset of the definition of distance education, subsection (4)] “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–

  • i) Providing direct instruction;
  • ii) Assessing or providing feedback on a student’s coursework;
  • iii) Providing information or responding to questions about the content of a course or competency
  • iv) Facilitating a group discussion regarding the content of a course or competency; o
  • v) Other instructional activities approved by the institution’s or program’s accrediting agency.”

Institutional Assurance  [As a subset of the definition of distance education, subsection (5) “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–

  • i) Providing the opportunity for substantive interactions with the student on a predictable and regular basis commensurate with the length of time and the amount of content in the course or competency; and
  • ii) 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.”

Truman adopts and implements the United States Department of Education definitions cited above and aims to guarantee regular and substantive interaction through a variety of quality student engagement strategies involving regular faculty-initiated interactions that require student responses.


Faculty-Initiated Substantive Interaction and Monitoring

A quality learning experience requires a combination of interactions between faculty and students (both initiated by the instructor and the student) as well as between students and the curriculum developed by faculty.  In most face-to-face classes, appropriate interaction is occurring as a matter of course.  Distance courses especially must demonstrate that at least two of the interaction types listed (above and below) in the definition of “Substantive Interaction” are taking place on a regular basis commensurate with the length of time and the amount of content in the course. Instructors are expected to regularly initiate communication with students for the purposes of creating the kinds of substantive interactions defined above, and provide timely and regular feedback to students on their performance.  Faculty are expected to monitor student success and provide prompt and proactive interaction with students in need of further support. Interaction must be active and initiated by the faculty member, not merely passive and awaiting requests for interaction by students.

Federal Guidance: What is Substantive?

For purposes of compliance, Truman is following guidance provided by the WICHE Cooperative on Educational Technology (WCET) and the State Authorization Network (SAN) as obtained in a clarifying letter from the Department of Education dated March 10, 2022.

As stated above, faculty can meet the “substantive” part of the requirements by providing 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.

Face-to-face courses would typically meet these requirements by holding regular class lectures and discussions and consistently holding office hours. Distance courses (including online) need to be able to implement virtual equivalents. The items listed below are common pedagogical tools in support of both online and on campus classes. While courses may automate some of these functions, the tools must be used in an active, non-automated fashion if they are used to satisfy the minimum requirements of regular and substantive interaction. To clarify:

Direct Instruction, in a distance education context, is defined by the Department of Education as “live, synchronous instruction where both the instructor and the student are online and in communication at the same time.”  The Department of Education’s interpretation of direct instruction does not disqualify asynchronous instruction. It only means that asynchronous video instruction does not qualify as “direct instruction” for purposes of showing substantive interaction in a course.

Office Hours might be one of the two required types of engagement, provided they are made available on a regular and predictable basis. For distance classes these office hours should be virtual. Student attendance is not required, but the Higher Learning Commission has indicated a strong belief that consistent and regular attendance should be documentable for this to count.

Automated feedback, while it may be used in the course, does not satisfy one of the five criteria for substantive interaction as it does not provide personal feedback to the student. Even if automated feedback provides detailed answers in response to potential answers, such feedback is not sufficient to meet the requirement.

Discussion Boards can meet the requirement for substantive interaction provided that the faculty member regularly and consistently engages in the discussions taking place there. Passive grading of discussion board activity without engaging meaningfully in the dialog would not meet the requirement. Grading the students’ comments and responses alone will not satisfy the requirement.

Federal Guidance: What is Regular?

The Department of Education expects that substantive interaction will happen on a “predictable and scheduled basis.”  Evidence of this is typically going to be found in the syllabus or the course’s LMS shell.

Notice and Documentation of Planned Engagements

Each term, faculty are responsible for submitting to their unit head a copy of their syllabus which provides the details articulated in SB4022.  It is expected that faculty provide a schedule of activities and a list of deadlines/due dates that document regular and predictable instructor-student interaction.  Schedules and deadlines may be adjusted as the course progresses provided that students are notified of the changes in a timely manner. Faculty must use the university’s official Learning Management System (D2L Brightspace) to display the syllabus and gradebook in order to create a documented record of interactions for future Department of Education audits. In order to facilitate documentation of the types of Regular and Substantive Interaction listed above, faculty are very strongly encouraged to use other tools within the official Truman LMS for online courses as they create a documented pattern of interaction. In very rare instances, departments which use other ITS-supported, routinely archived course tools may use these tools with the approval of their Dean and Provost, and after consultation with ITS. Google Classroom is not supported by ITS.

Student Academic Engagement and Administrative Drops From Class

Students are expected to actively engage in the courses in which they are enrolled.  Active engagement in response to faculty-initiated interactions, as well as the content of the curriculum is essential to successful progress in, and completion of, coursework.  Toward that end, students who do not actively engage in their coursework within a defined timeframe face administrative removal from their course(s).

Administrative Removal of Students From Coursework

Students must demonstrate academic engagement (as defined above) in each of their courses, each semester, during the period commencing the first day of the first week of courses and ending at 11:59 pm Central Time on the Saturday ending the first week of courses.  The Registrar may make adjustments to this schedule for condensed course lengths, such as eight-week or five-week terms and holidays.  Failure to engage in a course or to notify the instructor of the course of extenuating circumstances (such as technological problems, health emergencies, etc.) will result in the student being removed administratively by the Registrar.  Said removal shall be completed no later than the end of the second full week of classes in the semester.  Applicable dates shall be published on the Registrar’s website each term and shared with faculty.

Faculty shall be responsible for:

  1. initiating a substantive interaction with students to which they must demonstrate engagement during the designated period
  2. providing a clear statement in the syllabus describing the engagement requirement and the consequences for not engaging;
  3. contacting all students who fail to meet the interaction requirements, no later than 5 pm Central Time on the Monday immediately following the conclusion of the first week of class, providing a warning and soliciting information respecting extenuating circumstances related to non-engagement;
  4. informing the Registrar no later than 5 pm the Wednesday following the first week of class of the interaction status of all students enrolled in their classes via the provided web interface.
  5. For all students who engage during the first week, but who subsequently disengage from the course, provide to the Registrar (at the time final grades are assigned) the last day of attendance or engagement for those students earning an F.

For internships, thesis credit, research credit, and courses where a physical or virtual meeting may not formally take place during the first week of the course, faculty should initiate email contact with the student and the student should verify that they have received the course syllabus and are ready to begin the assigned tasks. Faculty with students who add a class late in the first week, after the conclusion of the first week’s class meetings or the assigned due date for the first course tasks, should have a conversation with the student to ascertain with a reasonable degree of certainty that they will be active participants in the class going forward. In this instance, they may be marked as engaging.

Consequences of Disenrollment

Students receiving financial aid will have the appropriate amount of aid, as defined by Truman policy and federal regulations, returned.  Students who have paid tuition to the University will receive refunds in accordance with the substantive interaction refund policy.  To ensure the maximum refund, if applicable, students should drop a class or classes they do not intend to participate in during the free add/drop period, and students should withdraw from all classes for the applicable semester if they do not intend to participate in any classes.

Model Syllabus Statement on Student Interaction

Truman policy and federal regulations require that students demonstrate that they are academically engaged in the courses they take.  You are required to meet this requirement within the first calendar week of the semester, beginning at 12:00 am on (insert date) and ending 11:59 pm Saturday (insert date).  Failure to do so, or to provide an explanation of an extenuating circumstance by that date and time will result in your removal from the course.  Under certain circumstances, removal could impact your scholarship eligibility or financial aid.  For the purposes of this class, establishing academic engagement requires, at a minimum, [Insert assignment you need them to complete.] [Note for faculty:  Attendance at a live class session or a synchronous online session is sufficient to meet this requirement for first-week student participation.  For an online course, completion of some modest introductory assignment, such as a discussion board post, is sufficient.  Merely logging-in to the Learning Management System is not sufficient. The Registrar will publish dates to insert into the model statement each term.]

Webpage updated: 08-10-23