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Title IV Requirements for Online Learning

What is Title IV?

Title IV financial aid is federal funded aid that includes Pell grants, Supplemental Educational Opportunity Grants, Perkins loans, and subsidized and unsubsidized direct loans. Over 90% of NNU students receive some form of Title IV aid. Distance or online education has specific regulations to be eligible for Title IV aid. For an online course, compliance requires two elements:

  • Online courses must have instructor-initiated, regular and substantive interaction with students. 
  • Syllabii must indicate direct contact hours by activity listings. 14 hours of direct contact for every credit. Final Exams are not included. 
  • Institutions must record the last date of attendance for students who drop, withdrawal, or fail an online course.

In 2006, Congress distinguished distance education from correspondence courses based on the types of media used and the requirement for regular and substantive interaction between students and the instructor. There are substantial limitations on correspondence courses, including: Limitations on cost of attendance components. Limitation to half-time enrollment for Pell Grant purposes; and Loss of institutional eligibility if percentage of correspondence students or courses exceeds 50% of total courses or regular students, respectively

Distance education is not subject to any of these limitations.

Required Course Elements In Online Courses

The regulations published September 2, 2020 sought to provide additional clarity regarding this definition and how distance education was to be treated with respect to several Title IV concepts, including:

Clock Hours and Credit Hours

Clock Hour– In distance education, 50 to 60 minutes in a 60-minute period of attendance in:

    1. A synchronous or asynchronous class, lecture, or recitation where there is opportunity for direct interaction between the instructor and students; or
    2. An asynchronous learning activity involving academic engagement in which the student interacts with technology that can monitor and document the amount of time that the student participates in the activity.
    3. A clock hour in a distance education program does not meet the requirements of this definition if it does not meet all accrediting agency and State requirements or if it exceeds an agency’s or State’s restrictions on the number of clock hours in a program that may be offered through distance education

Important concepts for clock hours offered through distance education:

    • Logging in alone never constitutes attending all or part of a clock hour
    • Clock hours can be earned synchronously (with both instructor(s) and students present) or asynchronously (where only the student is online and academically engaged)
    • School is responsible for demonstrating that students are either present at a virtual class, lecture, or recitation with a real opportunity for interaction or academically engaged in an asynchronous activity throughout the period counted as attended.

Processes that are acceptable to monitor clock hours:

  • In a synchronous setting, the instructor(s) and students use a webcam process whereby the instructor monitors and interacts with students during scheduled class time taking attendance and engaging with all students
  • In an asynchronous environment, a school utilizes technology that monitors not only when a student logs in, but captures all activity within an academic portal demonstrating everything a student does within a specific timeframe (scrolls through reading material, works on assignments, completes a quiz, etc.) All faculty-to-student communications should be conducted within Canvas announcements, Inbox, assessment feedback and forums.

Credit Hours

  • Federal Credit Hour Definition: A credit hour is an amount of work represented in intended learning outcomes and verified by evidence of student achievement that is an institutionally-established equivalency that reasonably approximates not less than: (1) one hour of classroom or direct faculty instruction and a minimum of two hours of out-of-class student work each week for approximately fifteen weeks for one semester or trimester hour of credit, or ten to twelve weeks for one quarter hour of credit, or the equivalent amount of work over a different amount of time; or (2) at least an equivalent amount of work as required in paragraph (1) of this definition for other activities as established by an institution, including laboratory work, internships, practica, studio work, and other academic work leading toward to the award of credit hours.
  • Review Credit Hour Requirements under “New Requirements” below.

Academic engagement

An indicator that combined academic identification (which refers to getting along with teachers, having an interest in the subject matter, and related behaviours and attitudes) and academic participation (which captures the student’s work effort both inside and outside of school, including hours spent on homework, meeting deadlines, not skipping classes, and so on).

  • Instructors must engage in at least two forms of substantive interaction meeting the regulatory requirements during each course or competency. The regulations do not prescribe a specific frequency or combination of each type of interaction except that they must be “predictable and scheduled.”
  • Monitoring a student’s ‘‘academic engagement and success” may include:
    1. Evaluating a student’s level of participation in synchronous class sessions
    2. Monitoring the student’s activity on course websites or materials;
    3. Considering the quality of the student’s coursework or understanding; or
    4. Other forms of monitoring the student’s engagement and success

New Requirements


According to the Middle States Commission on Higher Education’s Credit Hour Policy and the PA Department of Education’s Title 22, “a semester credit hour represents a unit of curricular material that normally can be taught in a minimum of 14 hours of classroom instruction, plus appropriate outside preparation or the equivalent as determined by the faculty” (PA Code, Title 22, § 31.21.b). Hence, a 3 credit course should have 42 hours of classroom instruction, or for online/hybrid courses, 42 hours of direct contact. The final exam is NOT included in the 42 hours of direct contact, but quizzes during the term can be included. Since many online courses are accelerated, the 42 hours of direct instruction will be greater than the 3 hours per week needed for a 14 week course.

Length of Course in Weeks Direct Hours Per Week Total Hours for 3 credit Course
14 3 42
8 5.25 42
7 6 42



New federal Title IV regulations, effective July 1, 2021, require instructors to engage in at least two forms of substantive interaction during each course. The substantive interactions with the student must occur on a predictable and scheduled basis commensurate with the length of time and the amount of content in the course. The regulations define substantive interaction as engaging students in teaching, learning, and assessment, consistent with the content under discussion, and also includes 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
  • Other instructional activities approved by the institution’s or program’s accrediting agency.

The new regulations also require that an instructor monitor the students’ academic engagement and success. The 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. Monitoring a student’s ‘‘academic engagement and success” may include: evaluating a student’s level of participation in synchronous class sessions; monitoring the student’s activity on course websites or materials; considering the quality of the student’s coursework or understanding; or other forms of monitoring the student’s engagement and success.

The Online Instructional Equivalency and Substantive Interaction Grid will assist you in translating instructional activities from a traditional classroom to equivalent online activities to meet the required number of direct contact hours. Most synchronous activities will have an equivalency rate of one to one, e.g., an hour of a live class using a telecommunication tool will equal an hour of direct contact. The equivalency rates will be different for asynchronous activities, e.g., the initial post to a discussion forum could count as 30 minutes of direct contact, but responses to other posts that requires reading all postings and replying to multiple posts could count as one hour of direct contact. The grid also links direct contact hours to types of substantive interaction that a faculty member may use to engage with online students.

Example of Syllabus documentation of Credit Hour Equivalency and Substantive Interaction for an 8 week course.

Activity Contact Hours Academic Engagement
Live Lectures/Guest Presentations Provide Direct Instruction
Asynchronous Lectures 8 Provide direct feedback to questions or problems within the lecture (Ask The Instructor Forum)
Discussion Forums 6 Facilitate group discussion and supply feedback within forum
Synchronous Meetings 2 Provide information or respond to questions
Case Study/Field Study/Simulations 1 Assess and provide feedback
Lab Sessions (Live or Online) Provide information or respond to questions
Office Hours 4 Provide information or respond to questions
Quizzes (Final Exams not included) 4
Student Presentations 1 Assess and provide feedback
Journals/Blogs Assess and provide feedback
Online Resources/Computer-Based Training 13
Group Projects/Peer Review 1 Assess and provide feedback
Review Instructor Feedback/Revise 2 Assess and provide feedback
Total 42


Annual Audit Process

This auditing process is based on workshop sessions and reports from institutions who have been audited by the Office of Inspector General (OIG) on Title IV regulations for distance education courses. This process is not officially outlined by the Department of Education and may vary but it provides an overview of what an instructor could expect an audit to look like.

Auditors initially identify a sampling of students who received Title IV financial aid and were also enrolled in an online class. This sampling typically includes five classes offered in the last semester.

Auditors review the last date of participation recorded, as needed.

Auditors request access to those five classes and review the instructor’s interactions with that student.

Most institutions report that auditors reviewed instructors interaction with the student in the discussion boards and assignment feedback.

Most institutions report that the auditors only look at that one student and not at the instructor’s interaction with the class as a whole.

If auditors find sufficient evidence that regular and substantive interaction is occurring within the first sampling, their audit of classes is complete. If auditors do not find sufficient evidence, they expand their sample size and can look back as far as three years in online classes.

Auditors can report findings on the lack of regular and substantive interaction or failure to keep accurate records of the last date of participation and make recommendations for improvement or penalty.

If an institution has findings in its audit report, the university will have a set amount of time to accept or dispute the findings.

There are several cases where universities had findings on regular and substantive interaction and were able to provide evidence of interactions that cleared the finding from the final report. In instances were evidence was not provided or the OIG found the evidence insufficient, institutions are penalized by returning Title IV financial aid used in the audited courses. If auditors find the majority of courses did not comply with Title IV regulations, they can revoke an institutions eligibility for Title IV financial aid.