Behind LX: Regulations and Putting It All Together

Academic and Wrap-Around Support

In the college and university environments, quality online programs offer robust learner support.  Some learning models in higher education, like MOOCs and micro-credentials, offer very little in the way of human-based support, or have differentiated financial models whereby support, feedback, and assessments are available to learners who pay for the course, but individuals could also audit a course and receive the “bare bones” version.

Let’s take a look at a few examples of what support services are available.  It’s important to note that support services take a variety of terms – everything from Virtual Student Support to Online Student Services, and several other terms in between!  In many cases, support services designed for online learners are also gaining adoption from on-campus learners, as the anytime/anywhere aspect of the support is quickly becoming both a consumer expectation, and is also a necessity of modern life.  Remember that the post-traditional learner often targeted for online programs oftentimes both works and has a family.  Traditional “business hours” aren’t relevant to their lives – they need help to meet them where they are.

Support services include:

  • eTutoring
  • Career Services
  • Academic Advising
  • Orientation
  • FYE (First Year Experience)
  • Accessibility Centers

Typically technical help is also provided as a resource, as is the library.

Valencia College

Valencia offers a range of support services online.  Check out their website that lists their support services here.


Penn State World Campus

Penn State University has a large online presence called World Campus.  Some of the support services available at Penn State World Campus are described in this selection from their site quoted below.

We can help you:

— get started by walking you through the course application process, including identifying the required supporting documentation; finding financial aid, scholarships, and other types of financial support; and preparing you for learning in an online environment

— use our University systems so you can access course syllabi and assignments; interact with professors and peers; make tuition payments; get your textbooks and software through the online bookstore; and use the University Libraries system, the 9th largest research library in North America, with a collection of more than 662 online research databases, 386,000 e-books, 105,000 scholarly journals (many available online and in full text) and 7.3 million print materials (books, maps, CDs, DVDs, and more) available for check out.

— take advantage of resources for online students including undergraduate advising, career counseling, exam proctoring, tech support, and tutoring in writing and several math-related fields.

— link with communities and special services for military members and veterans, international students, alumni, corporate education, students with disabilities, and those transferring from other universities and colleges

— stay connected in the Penn State community by keeping you up-to-date with events, important dates, and Penn State news

— determine if Transitions, a college and career prep class is a good fit for you. Participants in the nine-week course offered free of charge are selected after a discussion with the faculty. Structured like a standard online course, Transitions eases students back into the learning environment, while helping to improve basic skills, such as computer, study skills and research. The course also provides resources for understanding financial aid and career planning. An admissions counselor can tell you more about possible involvement in the course.

Watch this video on their support services.

Regulations, Accreditation and State Authorization

DOE Regulations

There are many regulations that apply to “distance education”.  The DOE, and Title IV, refer to distance education as separate and apart from correspondence courses.  The technical definition, which can be found here, is:

Distance education means education that uses one or more of the technologies listed in paragraphs (1) through (4) of this definition 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. The technologies may include—

(1) The internet;

(2) One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices;

(3) Audio conferencing; or

(4) Video cassettes, DVDs, and CD-ROMs, if the cassettes, DVDs, or CD-ROMs are used in a course in conjunction with any of the technologies listed in paragraphs (1) through (3) of this definition.

This illustration, from the University of Oklahoma, shows the differences between the modalities in the eyes of the DOE.  Much of this surrounds “Regular and Substantive Interaction”.

Differences between correspondence courses and distance education

Regular and Substantive Interaction

RSI, or Regular and Substantive Interaction, is a requirement of distance education.  It has been interpreted to mean interactions that:

Are initiated by instructor

Are regular and frequent – at least once a week

Are academically meaningful

Are initiated by a highly qualified faculty according to accreditation standards

More about these definitions can be found here, on the Ohio State University websiteThis article, from WCET, also has additional detail.


It is necessary that learners participate in online learning for DOE/Title IV funding, just like they would need to participate in a face-to-face classroom.  However, attendance rules are often misinterpreted, and in some cases, institutions do not even track attendance for online learners.

Page 5-60 of the Withdrawals and the Return of Title IV Funds, 2015-2016, provides guidance that documenting that a learners has logged into an online class is not sufficient to demonstrate academic engagement.  The school has to demonstrate the student participated in an academic activity in the course.  Examples from that document include:

  • “student submission of an academic assignment,
  • student submission of an exam,
  • documented student participation in an interactive tutorial or computer-assisted instruction,
  • a posting by the student showing the student’s participation in an online study group that is assigned by the institution,
  • a posting by the student in a discussion forum showing the student’s participation in an online discussion about academic matters, and
  • an e-mail from the student or other documentation showing that the student initiated contact with a faculty member to ask a question about the academic subject studied in the course.” (para 3, page 5-60,

In institutions that have successfully scaled online learning, it is critical to track this attendance appropriately so as to stay on the right side of regulations.

State Authorization

NC-SARA, or the National Council for State Authorization Reciprocity Agreements, is a voluntary organization designed to create reciprocal arrangements between institutions.  Because schools need to get agreement from a state wherein a learner is participating in an online program from, it became untenable for schools to individually get approval from all other 49 states that they didn’t have a physical presence in.  Instead, NC-SARA was formed.  It is a

“voluntary agreement among its member states and U.S. territories that establishes comparable national standards for interstate offering of postsecondary distance-education courses and programs. It is intended to make it easier for students to take online courses offered by postsecondary institutions based in another state” (para 1.,

Ensuring adherence to regulations, and also participating in initiatives like SARA, require personnel in online learning departments to be knowledgeable about the various components that come into play.

Regional Accreditation

There are six regional accreditors in the United States.  Regional accreditation is more rigorous than national accreditation processes, and, in addition to being accredited as an institution, some online programs also have subject matter specific accreditation requirements.  There are seven regional accreditors that

“operate in six geographic regions of the country through nongovernmental, non-profit voluntary associations. Accreditation is a self-regulatory, peer review process based on rigorous standards. Colleges and universities are judged based on self-evaluations analyzing how well they meet these standards, in light of their mission. Following a review by a team of peers, accrediting commissions determine the accreditation status of the institution and use a variety of means to ensure follow-up as appropriate and further evaluation in the case of substantive change on the part of the institution” (para 1.,

Each regional accreditor has specific requirements surrounding online learning.  Additionally, any program that is offered at a distance must also demonstrate adherence to all the standards that apply to an on-campus program.  One of the concerns that regional accreditors typically have is associated with academic integrity.  How is the institution proving that the learner who is registered for the course is the learner who is actually taking the course?

Partnerships and Innovation

Partnerships and innovation continue to be a critical component of the adoption of, and implementation of quality within, online learning programs.  Funders such as the Bill and Melinda Gates Foundation, Lumina Foundation, Joyce Foundation, and others have all significantly contributed to initiatives that enable institutions to experiment with new models of learning beyond traditional on-campus or online programs.

Many institutions do not have the funding necessary to support experimentation without funders like those from foundations.  A sudden infusion of cash can also be challenging when time comes to bring the project to sustainability.  Many innovations have unproven business models, which increases the challenge.

In addition to grant writers, there are now positions in departments related to Next Generation Learning, strategy, product development, as well as a host of titles relating to regulations, federal aid, and sometimes even specific programs, like direct assessment.

Putting it All Together

Now that we’ve taken a look at the many complex factors relating to online programs, read this perspective on the key members of an eLearning Dream Team entitled 9 Key Players You Need on Your eLearning Team by Christopher PappasIf you need a printable version, find that here.