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KENTUCKY STATE UNIVERSITY POLICIES AND PROCEDURES

KYSU Online Standards of Instruction

VOLUME, SECTION & NUMBER: 1.3.3

ENTITIES AFFECTED: Online Faculty Subject Matter Experts Online Students ADMINISTRATIVE AUTHORITY: Office of the Provost/Vice President for Academic Affairs Office of Online Education APPROVED BY: The Office of Online Education The Kentucky State University Board of Regents EFFECTIVE DATE: 7/1/2024

The purpose of the KYSU Online Standards of Instruction is to establish the guidelines for how online faculty will engage in regular and substantive interaction with students in online courses. These standards provide a framework for ensuring a consistent student experience in KYSU Online courses that combines well-designed online courses with an active faculty presence.

The KYSU Online faculty who receive course load assignments are the course instructors. As such, the instructor is “an individual responsible for delivering course content and who meets the qualifications for instruction established by an institution’s accrediting agency” (34 CFR 600.2 “Distance education”).1 Additionally, the online faculty are responsible for monitoring student engagement and satisfactory academic progress in online courses. Online faculty are the primary instructional presence within each online course.

Online faculty are responsible for ensuring that students are academically engaged with their online courses and that regular and substantive interaction occurs between instructors and students.

The instructor in an online course must engage students with regular and substantive interaction. According to the Department of Education,

“[S]ubstantive 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; or (v) Other instructional activities approved by the institution’s or program’s accrediting agency” (34 CFR 600.2 “Distance education”).²

Furthermore, an institution ensures regular interaction between instructors and students by –

“(i) Providing the opportunity for substantive interactions with the student on a predictable and scheduled 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” (34 CFR 600.2 “Distance education”).³

Several characteristics of regular and substantive interaction emerge from this information: teaching, learning, assessment, assignment feedback, responding to student inquiries, facilitating discussions, etc. Additionally, its timing is predictable, scheduled, proactive when needed, and responsive when contacted.

These federal regulations for Distance Education provide the framework for effective online interaction between KYSU Online faculty and students.

See also Regular and Substantive Interaction: Background, Concerns, and Guiding Principles.4

Online programs require regular and substantive interaction (RSI) between faculty and students. While physical distance can separate faculty and students, asynchronous online learning presents additional challenges to RSI for faculty and students.5

To align with the Department of Education’s RSI guidance to provide “the opportunity for substantive interactions with the student on a predictable and scheduled basis commensurate with the length of time and the amount of content in the course or competency,” instructors will initiate regular communication with students. They will be present for interaction, instruction, and outreach.

To align with the “Providing direct instruction” aspects of the Department of Education’s Regular and Substantive Interaction guidance, instructors may use announcements, emails, assignments, activities, and other means to provide direct instruction to students. Direct instruction entails any faculty-led interaction with a group or individual specifically engaging in course-related guidance.

Faculty must be attentive to the frequency and quality of their interaction with students. The frequency of faculty interaction with students must be regular; regular interaction provides “the opportunity for substantive interactions with the student on a predictable and scheduled basis commensurate with the length of time and the amount of content in the course.”6

A predictable and scheduled basis for regular interaction can be achieved by the course design, scheduled learning activities across its modules, and the instructor's actions before the course starts, while the course is active, and after the course concludes.7

The course design in the learning management system should include elements that facilitate regular engagement. For example, course designers should create an ungraded community discussion forum for general communication and online student conversations. The community forum allows students to engage with their classmates and instructors informally. This approximates the informal interaction in a residential class before and after class periods as students enter and exit their classrooms. It helps cultivate a sense of community, inclusion, and support among students.

In addition to the community discussion forum, the course design should include graded discussion forums focused on the course content at planned intervals. These discussion forums approximate the more formal discussions that typically occur in a residential class setting, where students express their points of view on the subject matter or discuss content presented in lectures or assigned readings. The role of an instructor is to prompt these discussions with thought-provoking questions, guide the direction and tone of the discussion as it develops, and help students appreciate the strengths and weaknesses of various points of view. This looks different in a residential classroom lecture than in an online course. However, a well-designed online course will provide assigned discussion forums in various course modules to ensure regular interaction with the course content.

Although online courses allow for asynchronous academic engagement, the course must follow a schedule. The course schedule outlines the modules' sequence and the corresponding learning activities, assignments, and deadlines. Module deadlines ensure that students complete and submit work throughout the course (typically eight weeks) rather than submitting most of their assignments (or perhaps all their assignments) at the end of the course. The course schedule also plans for a regular

feedback loop of substantive interaction whereby the online instructor evaluates students' work and instructs them accordingly. Students can learn from and respond to the instructor's substantive feedback as the course progresses. The course schedule should be posted in the syllabus within the online course.

Before the online course is made available to students, the online instructor should complete a few setup tasks to establish a welcoming presence within the course.

Fostering a positive faculty-to-student relationship is vital in building community in online courses. A well-written and personable faculty profile can set a positive tone for the course. This puts students at ease and increases their confidence to reach out with questions and ask for help.8 Instructors should set up a profile, including a brief bio, professional headshot, contact information, email, best contact hours, and any other desired information before the course launch in a timeframe specified by the institution. Apart from this faculty information displayed within the online course, the course can feel “uninhabited” when students explore the course upon gaining access.

In addition to personalizing the course with faculty information, the instructor should also post a welcome announcement and display it on the landing page for the online course. The welcome announcement further conveys an active faculty presence within the course. It is an initial point of connection with students and provides them with guidance on the next steps to take upon gaining access to the course.

This communication should focus on essential course- and content-specific items rather than student policy and logistical information. For example, the welcome announcement might introduce the following:

The welcome announcement should be posted before students gain access to the course; a good target would be 5 days before the start of the course (which typically falls on a Thursday). However, after students gain access, the welcome announcement should be sent by email to the student as well (this might require the instructor to select an option to email the announcement once the course goes live;

the announcement should not be sent as an email prior to students gaining access to the course). This proactive, multi-channel communication from the course instructor will prompt students to engage with the syllabus immediately.

Textbooks are integrated into online courses as electronic resources. Sometimes, these resources require separate login credentials or verification codes from students. The instructor should include guidance about the form of the textbooks and the way students access those resources. If a printed textbook is required, instructors should include guidance on how students should obtain the printed textbooks as soon as possible so as not to delay progress in the course.

The community forum is an excellent way for the instructor to introduce oneself to students less formally, describing hobbies and other background information appropriate to the online course. This is also a great place to invite students to introduce themselves to the instructor and classmates. For example, the instructor could ask students to introduce themselves and share their degree program and current city or occupation. These self-introductions in the community forum are like those often occurring on the first day of a residential course. The goal is to create a welcoming, inclusive, friendly, and collegial environment for students to engage with one another and their instructor(s).

Responding to each student's post in an introductory discussion forum effectively allows faculty to show presence and establish rapport in the learning community. This should be done where applicable. However, faculty can choose to build community with a summative response to the students' introductions.

An introductory post is a minimal expectation, but instructors are encouraged to use other methods of facilitating community.

In the first week, students must exhibit academic engagement in an online course to avoid being dropped. This involves completing a course assignment or engaging the instructor about the course content.9 The instructor must ensure that each student who has not participated in the course through academic engagement is marked as “inactive” on the course roster. At the end of the first week, the instructor must send the current roster to the Registrar for processing.

See the federal requirements to document students' attendance for financial aid purposes (34 CFR 668.21(c)). See also the KYSU Online Course Attendance Policy (1.3.1).

At the start of the course, online faculty should be aware of their responsibility to facilitate a learning environment that upholds standards of academic conduct and coordinates reasonable

accommodations for students as needed. This involves several policies cited in the syllabus and webpages of KYSU. Online faculty should engage with students about the policies as relevant.

Weekly announcements inform students about course expectations for the week ahead. These posts are most effective when they are concise, cover the basic requirements for the week, and are written or recorded professionally.

By 9:00 a.m. Eastern Standard Time on the first day of each module, the instructor should post a written or recorded announcement in the LMS introducing the new module to students. This weekly announcement should highlight essential aspects of the learning activities. It should also introduce the assignments for the week and invite students to contact the instructor if additional guidance is needed. It is an opportunity to engage in a personable way while conveying information on items such as reminders and the workload for the week. Specifics such as items that tend to be more challenging, intensive reading for the week, or a significant assignment being due are essential to highlight in these weekly announcements.

The weekly announcements are a point of regular and substantive interaction between the instructor and the students. The consistent posting at the start of each week establishes an expectation that students progress collectively from one module to the next and that the course progresses from start to completion.

In addition to posting the announcement on the course landing page in the LMS, instructors should use the LMS to email the announcement to students directly. The arrival of the email in students' inboxes each week will help drive their academic engagement with the course.

Most online courses are asynchronous and do not involve synchronous lectures. However, video recordings of lectures or recorded presentations are commonly used instead or in combination with synchronous learning opportunities within the parameters specified by programmatic accreditors. The instructor might host a voluntary video conference for students to attend, recording and posting it for those who could not attend to view later. Instructors may find this is an effective way to facilitate academic engagement with students and efficiently discuss their questions about course assignments. Other effective practices include synchronous sessions by appointment or synchronous group projects.

In asynchronous online learning, the instructor must avoid requiring students to participate in synchronous course elements to avoid creating conflicts with how the programs are marketed to students (i.e., professors must avoid requirements that conflict with the advertised program requirements). Additionally, in most online classes, it is not practical to coordinate students' schedules across time zones for a synchronous meeting.

Robust feedback is essential for all online students, whether they struggle or do an impeccable job with an assignment. This mode of interaction is one of the most direct ways faculty members can teach, guide, inspire, and redirect students' efforts. Meaningful, constructive feedback will be timely, specific, actionable, and cordial. Utilizing assignment rubrics as a guide and rationale for the students' scores

also enhances students' ability to understand the strengths and weaknesses of their work. The use of rubrics is recommended where applicable.

All coursework should be graded within six (6) days of the due date to mitigate the effects of the accelerated pace of online courses and allow students to adjust for subsequent assignments. There are noted exceptions to the six-day deadline for courses in which the grading load is heavier (e.g., writing-intensive courses), and the Office of Online Education will specify which courses have increased flexibility based on recommendations from program coordinators and SMEs. In these instances, communication with students regarding when they will receive feedback is recommended, and instructors are encouraged to time the feedback so that the student has sufficient time to implement instructor recommendations before submitting the next assignment.

Assignments submitted early should be graded within six (6) days of the due date, not the early submission date. Coursework submitted late should be graded within six (6) days of the submission date. The same exceptions noted above also apply to this recommendation.

When assessing student work in online courses, instructors should return grades and feedback as soon as possible due to the faster pace and compressed timeline of courses in the online subterm. The standard requirement is a six (6) day turnaround time for grades. For assessments graded automatically by the LMS, instructors should review the scores and determine if there are patterns of missed questions and whether those patterns reveal an underlying issue with the question itself or the aligned instruction. In those cases, an instructor's discretion should be used to adjust a system-generated score on an assessment. Additionally, the instructor should determine whether to adapt/eliminate a problematic question from an assessment or develop supplementary/replacement instruction in the primary course shell. The procedure for doing so is detailed elsewhere, but changes to the primary course shell should be communicated to the Faculty Mentor and the SME.

Ideally, instructors will provide brief written comments for each student. The tone of the comments should be that of an encouraging coach – identifying positive elements of the student’s work while focusing on areas for improvement and ways to improve. Many instructors will find that this type of feedback can open communication with a student who would not otherwise engage based merely on a system-generated score. Feedback on assessments will convey the instructor’s active presence in the course and with student success.

Collaborative learning assignments encompass a range of assignments such as discussion forums, social annotation of an article, interactive maps and timelines, capstone projects, and interactive videos. As a minimum requirement to promote regular and substantive interaction, an online course will commonly include discussion forums as collaborative learning assignments. In an 8-week online course, it is common for the course to include two (2) or three (3) graded discussions.

Well-designed discussion forums and collaborative learning assignments effectively support learning, foster critical thinking, and give a human touch to the online classroom. Beyond a well-designed

assignment or activity, an active faculty member can foster transformative learning experiences and drive student retention.10

Depending on the nature of the discussion forum prompt, the elements a professor evaluates will show up differently in scoring and feedback. For example, suppose an assigned discussion forum invites a range of opinions about a course topic. In that case, the instructor may be most concerned with evaluating the level of engagement, clarity of communication, and quality of argumentation students exhibit in their posts. In other discussion assignments, the instructor might be more focused on evaluating the quality of each student's comprehension, analysis, evaluation, and synthesis of the course readings.

For this reason, students and instructors will be helped by a rubric tailored to each discussion assignment. Although each instructor will use professional judgment when evaluating students' work, the rubric is helpful guidance that enables students to formulate quality posts in alignment with specific criteria. The rubric is also beneficial in relating assignments to course learning outcomes and assessing students' proficiency.

In addition to using a rubric to assess students' discussion assignments, instructors should provide written feedback to help students understand the strengths and weaknesses of their work and how to improve on future assignments. Once again, substantive feedback on discussion assignments promotes student success and reinforces a sense of the instructor's presence within the online course. Like other written assignments, feedback should be meaningful, constructive, timely, specific, actionable, and cordial.

Aside from written discussion assignments, online courses often include more formal writing assignments such as reviews, essays, or research papers. Each written assignment should have an accompanying rubric. The rubric forecasts to students the general framework within which the instructor will evaluate and score their work. It also prevents an instructor's "pet peeves" from being unduly determinative in a student's grade on more significant assignments such as research papers.

Since writing assignments such as research papers are often due in the last week or two of a class (especially during the 8-week subterms), they often showcase the cumulative knowledge, skills, and abilities students have developed throughout the course. The assignment's focus and the instructor's evaluation should involve the course learning outcomes directly or indirectly. Therefore, in addition to faculty evaluating each student's ability to produce work following relevant formatting conventions, instructors should use professional judgment about how much time the instructor should devote to marking up errors with formatting and grammar in students' written work.

more robust set of markup tools than the LMS, but they require several extra steps of downloading, saving, then uploading the file back into the LMS).

Whatever the markup tools and method an instructor uses, the instructor should score the written assignment using the rubric and provide substantive, summative feedback to each student. Some instructors will prefer to write a few sentences of feedback to the student; others will prefer to record a short video message using the tools in the LMS. In either case, the instructor should adopt the tone of an encouraging coach – unafraid to identify areas of improvement while remaining committed to, and focused on, helping the student improve and achieve success.

The LMS includes tools that assist instructors in deterring and detecting plagiarism. This is essential to upholding the KYSU Online's policies and safeguarding the quality and results of the school's degree programs. Even so, the use of plagiarism detection software alone is not enough. Instructors in online courses have an active, and perhaps more influential, role in promoting a culture of academic integrity among the students.

When instructors introduce writing assignments in their weekly announcements or other communication with students, they should remind students that all their work will be scanned for plagiarism. This allows students to contact the instructor to discuss strategies for engaging secondary sources and citing them in a way that avoids plagiarism. Instructors might find that performance anxiety, inexperience, or cross-cultural differences can influence students' research and engagement with sources. By reminding students to be vigilant in avoiding plagiarism, the instructor invites opportunities for academic engagement with students.

Instructors know that the results of automated plagiarism detection software in the LMS are not definitive. The software's scores and reports require an instructor's interpretation and professional judgment. For example, it is not uncommon for these platforms to return a score above 30% on the average paper; every correctly formatted and cited quotation of a source will be flagged, contributing to the overall plagiarism score returned for the file. Instructors should carefully evaluate these results. Should further action be required, based on the instructor's professional judgment about the plagiarism detection report, the instructor should consult with their supervisor to navigate the relevant Academic Conduct policies and procedures.

The bottom line is that online instructors can help deter plagiarism by reminding students of the expectations and that their work will be scanned by software.

Online faculty will participate in discussion assignments by actively interacting with the students and content. This should take several forms for optimal effect, including responding in the forum to specific student posts, pointing out strong arguments, tactfully correcting incorrect information, asking follow-up questions to promote conversation, and perhaps pointing students to additional resources on the given subject, such as embedding a video link, journal article, blog, etc.

Regarding regular and substantive interaction (RSI), faculty are encouraged to comment two (2) to three (3) times in each graded discussion forum and collaborative learning assignment. These comments can be concise or more expansive but should be instructional. Such comments could

highlight thoughts from students' posts that are especially strong in content or reasoning. Additionally, they could spur the discussion deeper or redirect it as needed. It is recommended that the instructor not always respond to the same students, which can create perceptions of an inequitable classroom atmosphere.

At the end of each week, when there is such an activity, faculty are encouraged to post a summary within the forum to the class, providing feedback on themes they observed in the students' posts, strengths and weaknesses, redirection, and corrections where the discussion may have drifted. This is yet another teaching moment to stress the objectives of the assignment.

Faculty-to-student feedback related to grades for discussion forums/collaborative learning should be private in the LMS gradebook, not placed in the forum itself.

Additionally, instructors might decide to host a voluntary, synchronous video meeting with students using a platform like Microsoft Teams or Zoom.

Due to the often-accelerated nature of online education, timeliness in all online-related communications is one of the most critical factors for faculty engagement and student success. To ensure that students have timely responses to inquiries, instructors should respond to student emails, phone calls, or other modes of communication within twenty-four (24) hours ideally, but no later than forty-eight (48) hours. Written communications to students should be cordial, address the student by name, be well-written and thorough, and should answer content-related questions.

Internal communications between faculty and administration regarding urgent online matters require timely responses to triage and mitigate specific issues. When such an issue is flagged as urgent (which should be somewhat rare), please respond to applicable communication as soon as possible.

KYSU Online does not require that online faculty hold virtual office hours, but instructors can choose to offer this to their students. Due to the nature of online learning and the unique needs of online students, faculty are expected to schedule online appointments with students who request to one. Although KYSU Online does not require a minimum number of virtual office hours each week, instructors should invite students to schedule synchronous communication such as phone calls or video conferences when needed (on platforms like Microsoft Teams or Zoom).11 The instructor should be reasonably available and accommodating to student’s meeting requests within a couple of days. Additionally, online faculty should be reasonably flexible to accommodate the schedules of online students, who sometimes prefer meetings outside the regular business hours of 9:00 AM to 5:00 PM.

Sometimes students inquire about the course content via email, but a response is more effectively communicated in a conversation rather than an email response. Instructors should proactively embrace

these opportunities to engage students on a scheduled call. In other cases, instructors should use the scheduled calls to support student success and retention efforts.

Faculty should intentionally identify and assist struggling students. This is an essential piece of a broader student support infrastructure. To that end, faculty should deploy a consistent range of strategies to help that portion of the student population.

Online faculty should contact students who miss assignment due dates. If a student misses an assignment due date or fails to post to the discussion board, instructors should contact them within 48 hours to indicate concern and to offer relevant support. Depending on instructor policies, the communication can encourage the submission of assignments even if there are late penalties and seek ways to work with the student to re-engage with the course.

Instructors should regularly reach out to students below a “C” average in a course throughout the term. This communication can include additional learning resources, i.e., assignment examples, field questions on challenging content, supplemental readings, videos, etc. Additionally, instructors can offer deadline extensions or re-submissions if appropriate.

Instructors will be trained to be well-versed in the specific student support services that will help triage these situations. Instructors are encouraged to discuss these situations with their Faculty Mentors.

Students participate in the online course by demonstrating academic engagement with the content. They do this initially by completing a course requirement or assignment or communicating with the instructor about the course content. See the “Establishing the Active Roster” section for more details.

After that, students must remain in regular academic engagement with the course to avoid an unsanctioned period of inactivity lasting 21 days. At any point in the course, if a student does not participate by demonstrating academic engagement for 21 days, that student should be administratively withdrawn from the course. When a student is administratively withdrawn from a course due to an unsanctioned period of inactivity lasting 21 days, it is to establish the date that the student ceased attendance in the class. Instructors should work with their Faculty Mentor to communicate this status to the Registrar and other administrators on the 22nd day of non-attendance.

See also the KYSU Online Course Attendance Policy (1.3.1).

Online faculty should be familiar with the various student services available to online students. Information about service offices can be found on the KYSU website. Online faculty can refer students to these resources as relevant for online students to ensure that each student is aware of their access to support.

To improve courses and instructional practices over time, instructors must promote the end-of-course surveys and encourage students to participate. The results of these surveys enable sound, data-driven course improvements and edits based on the student experience.

Response rates to student end-of-course surveys are rarely 100% in online courses. For this reason, the instructor must promote the survey during the concluding week of the course. The instructor should also clarify to students that the surveys are anonymous, and the instructor can only access responses once final grades have been posted.

Instructors must be attentive to the deadlines set by the Registrar for posting final grades. There is typically less time to complete grading and post final grades in online courses than in a residential, semester-based course. This is due to the online subterms, which often occur one after the other throughout the year.

For example, the Fall C subterm might start within a week of the Fall B subterm's conclusion. Students' ability to register for C-term classes might depend on their final grades achieved during the B-term courses. Faculty mentors will coordinate with the registrar and adviser to determine if the final grades of specific students should be prioritized in the roster to prevent any issues in their subsequent academic progress.

Despite this compressed timeline for final grades in online education, instructors should allocate sufficient time to provide quality substantive feedback on the final assignments in the course. Instructors should coordinate with their Faculty Mentor and the Registrar to determine procedures for granting extensions to students, requesting grading extensions for online faculty, or posting a grade of Incomplete.

After posting final grades, the instructor should post a concluding announcement in the LMS on the course landing page. Students will retain access to the course for a period after the end date, and this announcement signals that their work has been graded, their final grades have been posted, and that the instructor has concluded instructional activities apart from any special arrangements with students regarding extensions or Incomplete grades.

The concluding announcement is not simply an administrative close to the course; it enhances the student experience at the school. One of the most rewarding aspects of higher education is the

opportunity to have some impact on a student. Students often take a moment to thank an instructor after a course or on an end-of-course survey. Likewise, instructors should use the concluding announcement to express appreciation for the students and gratitude for their efforts in the class.

In summary, the concluding announcement should express farewell to the students while notifying them that grades are finalized.

After final grades are posted, the student end-of-course surveys will be available to the instructor. Instructors can access the results within the LMS.

The surveys will help instructors assess the strengths and weaknesses of the course. Survey responses related to the course design, assignments, learning materials, and other aspects of the course are most relevant to the faculty member serving as the SME. Nevertheless, the instructor's perceptions of those responses will provide valuable context when online faculty collaborate about adjustments to the course for future terms.

Survey responses relating to the instructor's performance will facilitate instructional improvement and reinforce existing strengths. Faculty Mentors will consider these surveys when conducting performance evaluations of online faculty.

Whenever a final “Incomplete” grade is assigned, the instructor must work with their Faculty Mentor, the Registrar, and the student to determine the deadline for the student’s outstanding assignments. The instructor must communicate with the student and monitor assignment submissions in the course LMS. The instructor must post a final grade for the student on the date arranged with the Registrar.

N/A

Substantive Interaction: see the “Statutory or Regulatory References” section.

Regular Interaction: see the “Statutory or Regulatory References” section.

Academic Engagement: see the “Statutory or Regulatory References” section.

1.3.1 KYSU Online Course Attendance Policy

1.3.2 KYSU Online Late Work Policy

1.3.11 KYSU Online Grading Scale

STATUTORY OR REGULATORY REFERENCES:

SACSCOC

See the SACSCOC Policy Statement: Distance Education and Correspondence Courses.12

Department of Education

34 CFR 600.2 “Distance education”

According to the Department of Education,

“[S]ubstantive 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; or (v) Other instructional activities approved by the institution’s or program’s accrediting agency” (34 CFR 600.2 “Distance education”).¹³

Furthermore, an institution ensures regular interaction between instructors and students by –

“(i) Providing the opportunity for substantive interactions with the student on a predictable and scheduled 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” (34 CFR 600.2 “Distance education”).¹⁴

See also Regular and Substantive Interaction: Background, Concerns, and Guiding Principles.15

34 CFR 600.2 "Academic engagement"

The Department of Education defines academic engagement:

“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" (34 CFR 600.2 "Distance education")16

The Department of Education specifies that “academic attendance” for financial aid purposes relates to the definition of “academic engagement” and entails institutional documentation of attendance policies which govern when the institution determines that a student has withdrawn:

“(7)(i) “Academic attendance” and “attendance at an academically-related activity” must include academic engagement as defined under 34 CFR 600.2. (ii) A determination of “academic attendance” or “attendance at an academically-related activity” must be made by the institution; a student’s certification of attendance that is not supported by institutional documentation is not acceptable” (34 CFR 668.22(l)(7)).17

The Department of Education provides guidance on how to track the date of withdrawal for financial aid purposes at institutions that do not require attendance. This is relevant in online education for instructors tracking periods of inactivity, which could involve a student's withdrawal from the institution:

“(3) The “date of the institution’s determination that the student withdrew” for an institution that is not required to take attendance is— (i) For a student who provides notification to the institution of his or her withdrawal, the student’s withdrawal date as determined under paragraph (c) of this section or the date of notification of withdrawal, whichever is later; (ii) For a student who did not provide notification of his or her withdrawal to the institution, the date that the institution becomes aware that the student ceased attendance; (iii) For a student who does not return from an approved leave of absence, the earlier of the date of the end of the leave of absence or the date the student notifies the institution that he or she will not be returning to the institution; or (iv) For a student whose rescission is negated under paragraph (c)(2)(i)(B) of this section, the date the institution becomes aware that the student did not, or will not, complete the payment period or period of enrollment. (v) For a student who takes a leave of absence that is not approved in accordance with paragraph (d) of this section, the date that the student begins the leave of absence” (34 CFR 668.22(I)(3)).18

The Department of Education clarifies that an institution must be able to document whether a student has attended the institution during a period in which the student receives financial aid:

"(c) For purposes of this section, the Secretary considers that a student has not begun attendance in a payment period or period of enrollment if the institution is unable to document"

the student's attendance at any class during the payment period or period of enrollment" (34 CFR 668.21(c)).19

POLICY OWNER/INTERPRETING AUTHORITY:

The Office of Online Education

DOCUMENT DATE AND VERSION:

5/25/2024 – 2024.05.25_KYSU_Standards of Online Instruction_v4.docx

19 https://www.ecfr.gov/current/title-34/part-668/section-668.21#p-668.21(c)