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PRACTICES IN NO-SHOW AND LATE CANCELLATION POLICIES FOR ADA PARATRANSIT SUMMARY Periodic passenger no-shows and late cancellations are an expected cost of doing business for most paratransit systems. However, at a time when the cost of providing Americans with Disabilities Act of 1990 (ADA) complementary paratransit is growing and all eligible demand for paratransit trips must be met, excessive no-shows and late cancellations can adversely affect the efficiency of service and significantly add to the cost. In response, many transit agencies have implemented policies to address no-shows and late cancellations. What has not been clear, however, is what impacts these various no-show/late cancellation policies have had on service efficiency and on the mobility of riders. The purpose of this synthesis report is to document current and innovative practices of U.S. transit agencies in the development and implementation of passenger no-show and late cancellation policies for paratransit programs operating under the regulatory requirements of ADA. U.S.DOT regulations implementing ADA address the issue of no-show/late cancella- tion policies in ADA complementary paratransit service programs. In addition to documenting regulatory requirements, this synthesis includes a summary of recent interpretations provided by FTA based on recent ADA paratransit compliance reviews and complaint responses. This report also describes how existing no-show and late cancella- tion policies are administered, the community response, and the effectiveness of these poli- cies in small, medium, and large transit agencies surveyed throughout the United States. The synthesis examines no-show and late-cancellation policies both as a way to improve system productivity, efficiency, and capacity, and as a way to better serve riders with dis- abilities who may experience difficulties with the advance reservation nature of most ADA complementary paratransit operations. The synthesis includes a comprehensive overview of the regulatory requirements of ADA. The regulatory overview is supplemented by a review of the findings published by the FTA Office of Civil Rights in recent ADA compliance reviews and in response to formal com- plaints filed with that office. Several telephone interviews were conducted with FTA staff to clarify issues related to FTA findings and interpretations. This synthesis also includes a review of relevant literature and resources. A detailed on-line survey was conducted to gather feedback from U.S. transit agencies that are responsible for providing ADA paratransit services. A total of 134 surveys were com- pleted, for a return rate of 47%. The survey included questions about organizational struc- ture; reservations, scheduling, and dispatching practices; no-show and late cancellation poli- cies; public involvement and outreach efforts; technologies used to manage the service; and operating statistics. Based on the survey results and a review of 63 no-show policies sub- mitted by survey respondents, key practices were highlighted that appear to support the intent of the ADA regulations and FTA findings. The findings suggest that there is a diversity of interpretations with respect to what con- stitutes excessive no-shows and/or late cancellations.
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2 The findings also suggest that there is a divergence of opinion and practice with respect to when a late cancellation becomes the functional equivalent of a no-show. For example, in letters of finding in connection with recent ADA paratransit reviews, FTA stated that a no- show policy that counted cancellations made after 5 p.m. on the day before service in its determination of a pattern or practice of missed trips was not consistent with the regulations and, therefore, should not be considered the "functional equivalent" of a no-show. A third finding suggests that no-show/late cancellation policies should include the provi- sion of adequate notice to passengers regarding apparent no-shows and provide a formal appeals process for contesting no-shows in accordance with the ADA regulations. A related issue is advising passengers that no-shows that are beyond the passenger's control are not to be counted against a passenger when documenting no-shows. The regulations require the for- giveness of apparent no-shows that are the fault of the transit agency or are a result of unfore- seen illness, hospitalization, and so on that prevent the passenger from contacting the transit agency in a timely manner. There are numerous examples of specific actions that transit agencies appear to be tak- ing with respect to no-show policies that are in keeping with the ADA regulations and FTA letters of finding. These elements are highlighted in the report, including examples of pas- senger incentives, alternative approaches to policy development, technology as a tool to manage no-shows and late cancellations, documentation and record keeping practices, determination of what is beyond the rider's control when missing a trip, and passenger infor- mation dissemination. The synthesis includes a description of elements that transit agencies may wish to include when developing or reviewing no-show and late cancellation policies. Finally, the report identifies several areas that could benefit from additional research, par- ticularly the cost of implementing a proactive and active no-show/late cancellation policy, as well as the overall system cost of incurring excessive no-shows and late cancellations.