Practices in No-Show and Late Cancellation Policies for ADA Paratransit (2005)

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A primary focus of this synthesis project is to identify current no-show and late cancellation policies and practices used by transit agencies in the provision of ADA complementary paratransit service. As part of this report, a survey was con- ducted with U.S. transit agency ADA coordinators and managers to identify current policies and practices. The infor- mation gathered through the survey also helped to identify innovative policies and practices for monitoring and manag- ing no-shows and late cancellations. A copy of the survey is included in Appendix A. The results for all survey questions are described in this chapter. It should be noted that the numbering of questions varies between the on-line and paper versions of the survey; how- ever, the questions and their order are the same. In addition to the survey, respondents were asked to sub- mit copies of their no-show/late cancellation policies for review as part of this synthesis project. A total of 63 policies were received. A summary of innovative ideas gleaned from the policies is provided in chapter four. CHARACTERISTICS OF SURVEY RESPONDENTS In all, 134 completed surveys were returned, for a response rate of 47.3%. Surveys were returned from transit agencies in 36 states and the District of Columbia (see Appendix B). They represent a cross section of small, medium, and large transit agencies, ranging from 46 to 2.5 million one-way ADA paratransit trips annually, and averaging 304,150 trips per year. The average passenger no-show rate reported by those agencies was 2.9% (that rate also includes what some systems term “late cancellations”). To better understand how transit agencies operate their ADA paratransit systems, the survey asked the respondents to identify whether they provide ADA paratransit only, a combination of ADA paratransit and other paratransit ser- vices using the same vehicles for both, or a combination of ADA paratransit and other paratransit services using differ- ent vehicles for each. Of the 132 agencies responding to this question, 64 (48.5%) reported that they provide both ADA paratransit and other paratransit services using the same vehicles, 52 (39.4%) indicated that they provide ADA para- transit service only, and 16 (12.1%) indicated that they pro- 10 vide ADA paratransit and other paratransit services using different vehicles (see Figure 1). Systems also were asked to describe the level of driver assistance provided: curb-to-curb, door-to-door, or door- through-door. Respondents could check more than one answer. More than half of the 120 respondents who answered the question 75 (62.5%) indicated that service is provided curb-to-curb, 61 (50.8%) that service is provided door-to- door, and 8 each (6.7%) that service was provided door- through-door or in some “other” way (see Figure 2). Most of the “other” responses indicated that service is provided door- to-door on request or on a “common sense” basis. Survey respondents were asked to identify which entity— transit agency, broker, or contract operator—performs par- ticular functions related to ADA paratransit operations including (1) initial trip reservations/advance cancella- tions/changes, (2) same-day cancellations, (3) “where’s my ride?” calls, (4) “will calls” or “call when ready” calls, (5) scheduling, (6) dispatching, (7) vehicle operation, and (8) customer comments and complaints. Multiple answers were permitted. The results are summarized in Figure 3. With the exception of vehicle operations, the table shows that most functions are conducted by transit agency staff, ranging from 54% (dispatching) to 92% (customer comments and com- plaints). In the case of vehicle operations, 62% of the respon- dents use contract operators and 53% of transit agencies operate ADA paratransit vehicles. Very few of the systems surveyed indicated that they use brokers (ranging from 5% to 8%, depending on the function). OVERVIEW OF SURVEY RESULTS The discussion of survey results is divided into five topical areas: (1) operating policies and practices, (2) definitions used to describe no-shows and cancellations, (3) no-show and late cancellation policies, (4) personnel practices related to no-shows and late cancellations, and (5) no-show and late cancellation outcomes. Operating Policies and Practices A number of questions were asked dealing with the design of the ADA paratransit system and how daily operations are handled. These design characteristics included (1) CHAPTER THREE SURVEY OF TRANSIT AGENCIES

FIGURE 1 Paratransit services provided. FIGURE 2 ADA paratransit level of driver assistance. FIGURE 3 Functional responsibilities.

FIGURE 5 Normal cutoff time for placing a trip request. FIGURE 4 Timing of trip requests. 12 making trip requests and scheduling trips and (2) using technology to monitor and manage no-shows and late cancellations. Making Trip Requests and Scheduling Trips Respondents were asked to indicate the maximum number of days in advance that trip requests can be made. When adopted, the ADA regulations required transit agencies to accept reservations at least 14 days and up to 1 day in advance of the trip. As noted in chapter two, that requirement was changed in 1996, allowing transit agencies—with pub- lic input—to shorten the advance reservation time frame. Of the 130 responses, 56 (43.1%) accept reservations up to 14 days in advance, 32 (24.6%) accept reservations up to 7 days in advance, and 16 (12.3%) accept reservations more than 14 days in advance (see Figure 4). When systems that provide ADA complementary paratransit service only are included, the results are similar. Next, respondents were asked to indicate what the normal cutoff time is to place a trip request (not including will calls or call when ready trips). Of the 131 systems that responded, 67 (51.1%) reported that the normal cutoff time is 5 p.m. the day before a trip is requested, 17 (13.0%) accept reserva- tions the same day as the trip request, 12 (9.2%) accept trip requests until 6 p.m. the day before, 8 (6.1%) accept trip requests until 4 p.m. the day before, and 27 (20.6%) reported other cutoff times (see Figure 5).

13 When asked to describe their basic scheduling process, 84 (63.6%) of the 132 transit agencies answering this question noted that they accept trip requests one or more days in advance and scheduled while the customer is on the tele- phone and 33 (25.0%) that they accept trip requests one or more days in advance and then trips are batch scheduled. One transit agency (0.8%) accepts same-day trip requests and 14 (10.6%) noted they had some “other” process for scheduling trips, typically some combination of the first two responses (see Figure 6). The survey next asked whether passengers were routinely called back to confirm their scheduled pick-up times. Of the 132 agencies that responded to this question, 114 (86.4%) answered “no” and 18 (13.6%) answered “yes” (see Figure 7). Of the 33 transit agencies that accept reservations and then batch schedule them later, only 7 (21.2%) reported that they routinely call customers back to confirm the pick-up time. In a follow-up question, several respondents stated that cus- tomers are advised to call back the evening before or day of their trip to confirm their pick-up time. In several cases, respondents mentioned that only customers whose trips have to be shifted more than 10 min are called back to advise them of the change in their pick-up times; otherwise, the estimated pick-up times (or windows) are honored by schedulers. Additionally, transit agencies were asked to describe the pick-up window they use when scheduling trips. The pick-up window is the time before and after a trip is scheduled that a passenger is expected to be ready to travel. Most systems use some type of pick-up window to give schedulers and drivers some flexibility in the actual pick-up time and still be con- sidered on time. By far the most prevalent answer was 15 min before to 15 min after the scheduled pick-up time. The most frequently cited pick-up windows are listed here: • 15/15 pick-up window, used by 38.6%. • 10/10 pick-up window, used by 6.8%. • 0/30 pick-up window, used by 5.3%. • 20/20 pick-up window, used by 4.5%. • 5/5 pick-up window, used by 3.0%. • 0/20 pick-up window, used by 3.0%. The survey also asked how long a driver is instructed to wait for a passenger, assuming that the driver arrives during the designated pick-up window. The most common answer was that drivers were to wait for 5 min, which was reported by 100 (75.8%) of the 132 transit agencies answering this question (see Figure 8). Other transit agencies reported wait times of 0 min, 2 (1.5%); 2 min, 3 (2.3%); 3 min, 9 (6.8%); 4 min, 2 (1.5%); 10 min, 5 (3.8%); or “other,” 11 (8.3%). Of FIGURE 6 Scheduling trip requests. FIGURE 7 Passenger call backs to confirm trips.

FIGURE 9 Designated pick-up locations for paratransit. FIGURE 8 Driver wait times for passengers. 14 the two systems that reported waiting zero minutes for a pas- senger, one defined the pick-up window as 5 min before to 10 min after the scheduled pick-up time; the other defined the pick-up window as 15 min before to 15 min after the sched- uled pick-up time. The survey also asked whether systems have designated pick-up locations at large facilities (e.g., main entrances at hospitals or particular store entrances at shopping malls). Of the 132 agencies that responded to this question, 58 (43.9%) have designated pick-up locations without paratransit stop signs and 20 (15.2%) have designated pick-up locations with paratransit stop signs. Slightly more than one-third, 48 (36.4%), indicated that they do not have designated pick-up locations (see Figure 9). Using Technology Resources The survey included a section about what technology resources were used by the respondents. Figure 10 shows that most respondents 99 [(79.2%) of the 125 respondents] reported using computerized scheduling and dispatching software. Of those, 77.7% indicated that their software included a no-

15 show/late cancellation module and 68.9% indicated that they have used that module. Additionally, 36 (28.8%) have auto- matic vehicle location (AVL) and 34 (27.2%) have mobile data terminals (MDTs). In an open-ended question, respondents also were asked how they use technology to help reduce no-shows and late cancellations. Of the 83 respondents to this question (61.9% of 134), 34.9% indicated that technology aids in the docu- mentation and monitoring of no-shows and late cancellations and 18.0% that technology helps dispatchers rework sched- ules in real time. AVL was credited by 9.6% of the respon- dents with helping dispatchers identify the actual locations of vehicles to confirm the driver’s location. That same percent- age also credited technology with helping to create more pro- ductive schedules. Another 6.0% stated that technology allowed them to offer same-day trips. One transit agency commented that “the software tracks the no shows, and with enforcement of policy we have reduced no shows from 12% to approximately 2%.” At the same time, according to 20.5% of the respondents, technology provides no benefit to han- dling no-shows and late cancellations. Respondents were asked whether their software included a no-show/late cancellation module. Of the 103 respondents to this question, 77.7% indicated that their software does provide a module to monitor and manage no-shows and late cancellations. Respondents also were asked whether they used the module. Of the 90 responding to this question, 68.9% said they used the module. A more detailed discussion of the use of technology is included in chapter four. Definitions Used to Describe No-Shows and Cancellations Every system has its own terminology to describe various circumstances. What is important is to understand how a given system uses particular terms. To better understand how passenger no-shows and cancellations are defined and han- dled by transit agencies, the survey asked respondents to define the following terms: (1) no-show, (2) advance cancel- lation, (3) cancellation, (4) late cancellation, (5) same-day cancellation, (6) excessive no-shows and cancellations, and (7) beyond the rider’s control. No-Show The survey asked respondents to describe how they define a passenger no-show. Of the 127 responding to this question, 72 (56.7%) defined a passenger no-show as “when a passen- ger cannot be located at the specific pick-up location OR refuses a trip”; 38 (29.9%) defined a passenger no-show as “when a passenger cannot be located at the specified pick-up location” (see Figure 11). The difference between the two definitions is whether customer contact was made (and the customer refused the trip). Operationally they may be the same, but a transit system may track these numbers sepa- rately for documentation purposes. Some other definitions of a no-show included trips that are cancelled within 1 or 2 h of the scheduled pick-up time: other systems might call trips cancelled 1 to 2 h in advance a late cancellation (described later in this section). This terminol- ogy becomes important in the discussion of no-show/late cancellation policies in chapter four. Advance Cancellation The survey requested that transit agencies indicate how they defined an advance cancellation. The most common answer was “not applicable,” which was selected by 40.9% of the 127 respondents answering this question. The most common defi- nition of an advance cancellation was “a trip that is canceled more than 1 day before a scheduled trip,” with 21.3% of the responding transit agencies selecting that answer. The second most common definition was “a trip that is canceled more than 2 hours before a scheduled trip,” with 11.8% selecting that answer, followed by “a trip that is canceled more than 1 hour FIGURE 10 Use of technology.

16 before a scheduled trip,” with 8.7%. A few respondents defined an advance cancellation as occurring 30 min, 90 min, or 3 h before the scheduled trip. Again, the definition of late cancel- lation that a system uses will be important to the discussion of no-show/late cancellation policies in chapter four. Cancellation In contrast to the definition of advance cancellations, “cancel- lations” were cited as “not applicable” by only 17.5% of the respondents. Of the 126 responses received, 27.0% defined a cancellation as “a trip that is canceled at least 1 hour before a scheduled trip,” 19.0% defined a cancellation as “a trip that is canceled at least 2 h before a scheduled trip,” and 7.1% defined a cancellation as “a trip that is canceled at least 1 day before a scheduled trip.” Those that checked “other” tended to elaborate on the definitions provided in the survey and were more specific about what exactly constitutes a cancellation (e.g., a cancella- tion that occurs before 4:30 p.m. the day before or a cancella- tion received before a trip has been dispatched, and so on). Same-Day Cancellation Almost one-half of the 127 respondents who answered this question (46.9%) indicated that the term “same-day cancella- tion” was not applicable to their systems. With respect to the definition, 15.7% described “same-day cancellations” as “a trip that is canceled less than 2 hours before a scheduled trip.” Almost the same percentage (15.0%) described that period as 1 h before a scheduled trip, with another 13.3% defining same-day cancellations another way. Some of the variations in the definition included “after 10 p.m. [the] day before and more than 4 hours before scheduled ride,” “any cancellation received after the first bus pulls out from the garage the DAY the trip is scheduled to be taken,” or “a trip that is cancelled prior to [a] vehicle heading to pick up client.” Late Cancellation The survey asked transit agencies to indicate how they define a “late cancellation.” The responses varied considerably. The most common definition of a late cancellation was “a trip that is canceled less than 1 hour before a scheduled trip” (cited by 24.4% of the 127 respondents), followed by “a trip that is canceled less than 2 hours before a scheduled trip (cited by 21.3%); 17.3% offered “other” definitions. Of the 22 “other” definitions, 9 were variations of previous day cancellation (e.g., “a trip that is canceled after 5 p.m. the day before the trip” or “a trip that is canceled after 5:00 p.m. the day before the scheduled trip and up to 2 hours before the pick up time”). Eight percent did not use the term “late cancellation” at all. Excessive No-Shows and Late Cancellations In open-ended questions, respondents were asked to define what they consider to be “excessive no-shows” and “exces- sive late cancellations.” For the definitions, respondents were prompted to indicate the number or percentage of occur- rences of no-shows or late cancellations during a specified period of time. Table 1 summarizes the usable responses from these two questions. The first column shows the num- ber of occurrences, the second column indicates how many respondents gave that number of occurrences for their no- show definition, and the third column indicates how many respondents gave that number of occurrences for their late cancellation definition. Because these were open-ended ques- tions (Questions 35 and 40), more than half of the respon- dents did not provide sufficient detail in their responses to complete the table or else they skipped the questions. A total of 64 respondents (47.8%) provided definitions of excessive no-shows and 47 respondents (35.1%) provided definitions of excessive late cancellations. These are the definitions that would typically trigger no-show or late cancellation penal- ties. The most frequent response for both definitions was FIGURE 11 Definitions of a passenger no-show.

17 [The transit agency] defines a Late Cancellation as canceling a trip within 30 minutes of its arrival time. Late cancels are con- sidered as no-shows. [The transit agency] defines Same Day Cancellations as trips canceled on the same day of the trip greater than 30 minutes before the trips arrival time. Excessive is defined as: Twenty (20%) percent or more reservations a month with at least five (5) same-day cancellations in the month. For example, rider (A) canceled (same-day) 5 out of 20 trips in November. Rider (A) would have canceled 25% of their trips and had at least 5 same-day cancellations. Rider (A) would be considered excessive. While rider (B) canceled (same-day) 4 out of 10 trips in November. Rider (B) same-day canceled 40% (greater than 20%) but only canceled 4 (less than 5) trips. Rider (B) would not be considered excessive. Several agencies described using point-based systems, which assign different point values to late cancellations and no-shows used to assess suspensions. For example, 18 points in a 30-day period equals a 15-day suspension, 36 points in a 60-day period equals a 30-day suspension, 54 points in a 120-day period equals a 90-day suspension, and 90 points in a 180-day period equals a 6-month suspension. Beyond the Rider’s Control Additionally, respondents were asked whether the no-show/late cancellation policies included provisions for no-shows that were “beyond the rider’s control.” Of the 123 responding to the questions, 67 (54.5%) said “yes.” Eighty-five (71.2%) went on to identify circumstances that would be considered beyond the rider’s control. • 49%—situations such as a family emergency or sudden illness that would affect the customer’s ability to travel and contact the transit agency to cancel a trip; • 38%—no-shows would be reviewed on a “case-by- case” or nonspecific basis; • 8%—transit system errors such as a late vehicle or incorrect information that was not the fault of the cus- tomer; and • 6%—issues related to no-shows were addressed in the appeals process. As noted in chapter two of this synthesis report, a defini- tion of beyond the rider’s control is included in Appendix D of the U.S.DOT’s ADA regulations and should be reflected in a transit agency’s passenger no-show policies. A rider will not be considered a no-show if any of the following occurs: A. The vehicle arrived at the pick-up location early or late and the passenger was not ready, had left to call, or made other arrangements. B. A sudden family emergency caused the person to change plans and did not allow time to notify the dispatcher of this change. C. The person had made a reasonable effort to notify Metro that service would not be needed but experienced an unrea- sonable delay on the phones. D. A sudden turn for the worse for a passenger with a variable condition caused them to miss a trip (Federal Register, Vol. 56, No. 173, p. 45747). TABLE 1 DEFINITION OF EXCESSIVE NO-SHOWS AND LATE CANCELLATIONS Excessive No-Shows Excessive Late Cancels Occurrences Number (n = 64) Number (n = 47) 2 in 7 days 1 1 3 in 14 days — 1 2 in 30 days 3 2 3 in 30 daysa 28 8 4 in 30 days 5 5 6 in 30 daysb 4 6 8 in 30 days — 1 9 in 30 daysc — 1 3 in 60 days 2 2 4 in 60 days — 1 6 in 60 days 1 3 8 in 60 days 1 — 2 in 90 days 1 — 3 in 90 days 6 5 4 in 90 days 1 — 5 in 90 days 1 — 15 in 90 days — 1 3 in 120 days 1 1 15 in 120 days — 1 2 in 180 daysd 1 2 3 in 180 days 1 1 4 in 180 days 1 — 5 in 180 days 1 — 6 in 180 days 2 1 7 in 180 days — 1 8 in 180 days 2 2 15 in 180 days 1 — 30 in 365 days — 1 NOTES: Question 35: Describe how “excessive no-shows” are defined (column 2). Question 40: Describe how “excessive late cancels” are defined (column 3). aMost frequently cited definition for excessive no-shows and excessive late cancellations. bMost “lenient” excessive no-show definition. cMost “lenient” excessive late cancellation definition. dMost “strict” excessive no-show and late cancellation definitions. three occurrences in 30 days, cited by 28 respondents (44%) as a definition of excessive no-shows, which was also cited by 8 respondents (17%) as a definition of excessive late cancellations. The most “lenient” policy definition of excessive no- shows was six occurring in 30 days (cited by 4 respondents) and the most lenient policy reported for defining excessive late cancels was 9 occurring in 30 days (cited by a single respon- dent). The strictest policies for defining both excessive no- shows and excessive late cancels was 2 occurring in 180 days, cited by 1 respondent (1.6%) for no-shows and 2 respondents (4.3%) for late cancellations. Some respondents described definitions that did not fit read- ily into the categories show in Table 1. For example, one sys- tem uses a percentage-based system in which an agency defines excessive late cancellations as late canceling of 25% of the scheduled trips in 30 days. Similarly, another system has a more elaborate percentage-based system, as described here:

FIGURE 13 Late cancellation penalties. 18 No-Show and Late Cancellation Policies Several questions were included in the survey to identify potential issues that might conflict with the regulations or recent regulatory guidance and interpretations provided by FTA. A summary of the survey results is provided in the fol- lowing sections. Written No-Show and Late Cancellation Policies When asked whether transit agencies had written passenger no-show/late cancellation policies, 115 of the 123 respon- dents (91.3%) said “yes.” Of those, 111 (90.2%) reported that their policies include suspensions for “excessive no-shows,” 25 (20.3%) reported that their policies include fines for excessive no-shows, and 9 (7.3%) did not impose fines or suspensions for excessive no-shows (respondents could check more than one answer) (see Figure 12). In con- trast, only 68 (56.2%) said they include suspensions for excessive late cancellations, 16 (13.2%) include fines for excessive late cancellations, and 49 (40.5%) do not impose fines or suspensions for excessive late cancellations (see Figure 13). In follow-up questions, the survey asked respondents to describe their suspension and/or fine procedures for no- shows and late cancellations. Transit agencies provided information about their suspen- sion policies in response to an open-ended question. As a result, it was somewhat difficult to summarize the results. In general, however, it was noted that suspensions usually became longer as the number of no-show incidents increased. Of the 75 responses that indicated a suspension period for the first offense, 34 (45.3%) cited 30 days, 20 (26.7%) indicated a suspension period of 5 to 7 days, 18 (24.0%) a suspension period of 10 days to 2 weeks, and 3 (4.0%) other lengths of time (3 weeks, 90 days, and 180 days). Fines and other fees are assessed in a variety of ways, sometimes for each trip, other times after one or more viola- tions occur. In some cases, the transit agency indicated that it charged the fare for each no-show, either beginning with the first or third; others appeared to impose an amount that may not be directly tied to the fare or cost of the trip. Some examples of fines are listed here. • A passenger is assessed a $9.00 fee for each no-show. Three or more unpaid no-shows will result in a suspen- sion from service until the outstanding balance is paid in full. • Full fare reimbursement for a no-show must be paid before service reinstatement. If a passenger pays the full fare reimbursement, he or she can be reinstated the same day. (Note: This is after a “courtesy” no-show is given to the passenger.) FIGURE 12 No-show policy penalties.

19 • A $3.00 fee will apply to each no-show/late cancella- tion starting with the third one in the month. Suspension is considered after four or more in a month, or with a case-by-case review. • Riders who accumulate five or more no-shows within the calendar year will be suspended from using the [ser- vice] until they pay the full cost of each no-show over four. In this instance, full cost of a one-way trip is the actual billing rate: as of January 1, 2004, the cost was $10.51 per trip. Once payment is made, service will be resumed. Each additional no-show will suspend service again until full payment is made for that no-show. Suspension of service will last until payment has been received. One agency did describe an elaborate system for assess- ing fines and no-shows based on trip-making frequency: Fines: $5 per no-show, although payment is not currently enforced. Suspensions: 1–14 trips per month—a maximum of 2 no-shows per month, 15–39 trips per month—a maximum of 4 no-shows per month, 40–59 trips per month—a maximum of 6 no-shows per month, 60–79 trips per month—a maximum of 8 no-shows per month, 80–99 trips per month—a maximum of 10 no-shows per month, 100 or more trips per month—a max- imum of 12 no-shows per month. 1st violation—letter of warn- ing, 2nd violation—1-day suspension, 3rd violation—3-day suspension, 4th violation—7-day suspension of service, 5th violation—30-day suspension of service. Violation history covers a 6 month floating window. It should be noted that the imposition of fines or other financial sanctions are not specifically addressed in the ADA regulations or in FTA compliance reviews or letters of find- ings to date. Appeals Process An open-ended question asked the survey respondents to describe their appeals process. A total of 112 agencies responded to the question. Of those, 53.6% described a for- mal appeals process mirroring the one described in the ADA regulations and 36.6% described a more informal appeals process primarily based within the transit agency without a formal hearing. Advance Notification Respondents were asked whether their policies included advance notifications or warnings before suspensions or fines were assessed (as required by U.S.DOT regulations). Of the 122 respondents, 88.3% said “yes.” When asked to describe the procedures, approximately half reported that they send written notification in advance of a suspension or fine. Approximately one-third of the respondents indicated that they have a progressive policy that generally begins with a call or warning letter or postcard and then escalates until the suspension or fine is levied. Eleven of the respondents stated that they mail a postcard or letter after every no-show, and five use door hangers to notify passengers that they had been recorded as a no-show. One respondent noted that customers are required to call to confirm trips after accruing several no-shows within a short period of time. Passenger Incentives Agencies were asked to identify any incentive programs they had initiated that reward passengers who do not incur no-shows or late cancellations. Only five respondents reported that they provide incentives for passengers who do not incur no-show or late cancellation sanctions. The incen- tive programs include either forgiving past points assessed for late cancellations or no-shows or earning free ride coupons for not being assessed any penalties. Policy Development Respondents were asked to review which activities were undertaken during development of their no-show and late cancellation policies. ADA regulations require that the development of no-show policies include public input. Of the 121 transit agencies responding to the survey, 84 (69.4%) indicated that their policies were developed with input from their passenger advisory committees, 55 (45.5%) that their policies were developed internally with input from staff, and 31 (25.6%) that their policies were developed with public input from other meetings (see Figure 14). Respondents could select more than one response. A cross-check was done to determine whether those who had checked “the policy was developed internally by staff” also used public input in formulating the policy. Of the 55 who responded, 56.4% also used their advisory committee for input, 29.1% used other meetings to gather public input, and 16.4% used “other” input. “Other” input included hiring a consultant, checking with peer transit agencies, and solic- iting formal approval at their board of directors’ meetings. More detailed examples of public input processes are described in chapter four. Policy Implementation Respondents were also asked how information about no-show and late cancellation policies is provided. Respondents could check as many answers as were applicable. Of the 124 agen- cies responding to this question, 99 (79.8%) indicated that the policy is described in rider brochures, 50 (40.3%) that the pol- icy is described in the eligibility determination materials, 39 (31.5%) that the policy is described on the transit system’s Internet website, and 35 (28.2%) that the policy is described in newsletters and/or passenger bulletins. “Other” reported methods of providing information varied from verbal discus- sions with dispatchers and drivers to providing additional

FIGURE 15 Distribution of information about no-show/late cancellation policy. 20 written information in the no-show/late cancel suspension letter process (see Figure 15). Policy Enforcement Respondents were asked to indicate how much their no- show/late cancellation policies had been enforced during the past year. Of the 125 responding, 56 (44.8%) reported that the policy had been actively enforced, 39 (31.2%) that it had been enforced to some degree, and 18 (14.4%) that it had not been enforced at all (see Figure 16). Personnel Practices Related to No-Shows and Late Cancellations In this section, respondents were asked to describe the processes used by drivers, dispatchers, service monitors, and other personnel in the event of an apparent customer no-show, with most of the responses centering on drivers and dispatchers. Respondents also were asked whether con- tract operators are paid in the event of a passenger no-show and it is not the fault of the carrier. Drivers An open-ended question asked respondents to describe what procedures are followed by drivers (also called oper- ators in some systems) in the event of an apparent passen- ger no-show. Of the 124 respondents, 91.1% indicated that drivers are to contact dispatch, either for instructions or to confirm the passenger no-show, before they proceed. Of those, 15.3% instruct the driver to leave the vehicle to look for passengers. Five respondents also mentioned leav- ing a door hanger or card to notify passengers that they had arrived for a pick-up. Six of the 74 systems that pro- vide only curb-to-curb service indicated that they would instruct drivers to leave the vehicle to attempt to locate a passenger or leave a door hanger or card. Most transit agencies indicated that drivers were instructed to wait 5 min before contacting dispatch for assistance, FIGURE 14 Development of no-show/late cancellation policies.

21 although some drivers were instructed to call earlier. For example, “driver initially honks horn, at 2 minutes knocks on door, at 4 minutes radios dispatch.” Another respondent provided a more detailed answer: “drivers must check that their time is correct, go to the passenger’s door and knock, notify dispatch prior to leaving in case the client is on the phone, and give their arrival/departure times [to dispatch].” Several others also mentioned using MDTs or mobile data computers (MDCs) to contact dispatch in the event of an apparent no-show, which would record the no-show and time of the event. One respondent explicitly mentioned list- ing landmarks as a tool in recording no-shows to be sure the driver was in the correct location. In contrast, 8.1% did not explicitly cite contacting dispatch as a driver procedure. Dispatchers Of the 118 agencies that responded to this open-ended question, 53.4% indicated that they would attempt to con- tact the customer before instructing the driver to declare the passenger a no-show and move on. Only 14.4% specif- ically indicated that they would verify the time and/or location of the scheduled pick-up. Several said they would verify the driver’s location using AVL. Another 37.3% stated that they would log the event and then instruct the driver to proceed without attempting to contact the pas- senger or taking other action. One respondent said it would cancel the return trip and three stated they would instruct the driver to leave a hang tag on the door alerting the pas- senger that the driver had been there to pick them up and the passenger could not be found. One respondent stated: “Use phone numbers to try and track down (passenger). If not successful, if leaving home, passenger will be marked as no-show. If going home, ride moved to ‘will call’ and no-showed if no call by days end.” Service Monitors Twenty respondents answered this question. Almost half 9 (45.0%) of the service monitor personnel were involved in monitoring reports tracking patterns and high rates of no-shows for individuals. Other duties included investigating a location that is causing no-shows, mailing postcards or let- ters to customers advising them of the apparent no-show, or attempting to contact customers to verify their return trip for that day. Other Personnel Twenty-three respondents answered this question. “Other” personnel typically was interpreted to mean supervisors or no-show clerks. Most activities occurred after the no-show, not during the event. Also, most of the activities (70.0%) involve a supervisor monitoring no-show activities and issu- ing suspension notices as needed. The remaining activities related to supervisors or clerks contacting passengers to dis- cuss the no-show or sending a card. One respondent com- mented: “Transit supervisor will call passenger if ‘no-show’ is determined to be within the control of the passenger. Supervisor will explain negative impact of ‘no-show’ on total system and attempt to inform (passenger).” Contract Operators Systems that use contract operators also were asked whether contractors were reimbursed for passenger no-shows. Of the 71 transit agencies answering this question, 63.4% reported that they do pay their contract operators for passenger no-shows. Most—59.6%—pay for trips on a per hour basis and 34.0% pay for trips on a per trip basis. Only 6.4% reported paying on a per mile basis. Respondents also were asked whether the same or a dif- ferent amount was paid for passenger no-shows that were not the fault of the contractor. Of the 59 respondents to this ques- tion, 71.2% indicated there was no difference in payment level, and 28.8% indicated that they paid contract operators less in the event of a passenger no-show. There were many variations in how payments were made. For example, some contract operators were paid a flat amount for passenger FIGURE 16 Enforcement of no-show/late cancellation policy.

FIGURE 17 Handling of return trips when the initial trip is a no-show. no-shows, ranging from $1.00 to $12.00 per no-show; other payments were based on the fare. No-Show and Late Cancellation Outcomes Recording Late Trips and No-Shows Respondents were asked whether a passenger would ever be considered a no-show if a driver arrived after the end of the pick-up window and the passenger could not be located. More than half of 132 respondents (54.2%) answered “no.” However, 45.8% answered “yes” or “sometimes.” Respon- dents who answered “yes” or “sometimes” were asked to describe the circumstances under which a passenger no-show would be declared when the driver arrived past the pick-up window. Most of the responses were variations of the explanation for what their no-show policies were within the stated pick-up window. However, several respondents indicated that riders were expected to wait an additional amount of time past the pick-up window or they would be considered a passenger no-show if the driver arrived late and they were not there. For example, one respondent stated: “any time the bus arrives and the passenger is not there, they are marked a no-show.” Another expressed a similar inter- pretation: “When we are running outside the window we are calling the customer to communicate, they can cancel at that time. If they are not on location they are marked as a no-show.” Others qualified the lateness within a 5- to 10-min time frame. For example, one respondent answered that “if passenger did not call 10 minutes after 30-minute pick-up window to state that ride is no longer needed, the ride would be a No-Show.” Another respondent clarified that a passenger no-show would be assessed if a rider had requested a same-day 22 change to a requested pick-up time resulting in an extended pick-up window to accommodate the special request. If the passenger left during the extended pick-up window the customer would be considered a no-show. Similarly, another system said it would declare a passenger no-show “if we contacted passenger, informed them we were late and they agreed to wait—then didn’t.” Most of these answers appear to put the burden of the no-show on the individual rather than the transit agency that was late (or early). Handling Return Trips If the passenger’s first trip of the day is a no-show, respon- dents were asked to describe how they handle any subsequent trips booked for that day. Of the 128 responding to this ques- tion, 38 (29.7%) indicated that they would leave the remain- ing trips on the schedule unless the customer called to can- cel. Another 29 (22.7%) reported that the remaining trips would be automatically canceled, 25 (19.5%) would make an attempt to contact the customer and if there is no contact the trips are left on the schedule, and 22 (17.2%) stated that they attempt to contact the passenger, and if contact is not made the remaining trips will be canceled (see Figure 17). As described in chapter two, FTA has provided guidance on scheduling and dispatching procedures related to rider no-shows. A letter of finding from February 2001, from FTA to a consumer, related to a complaint that a return ride was automatically canceled by the transit agency after the rider was recorded as a no-show on the “going” portion of the roundtrip, stated: “We find [the transit agency’s] policy to cancel automatically a return trip if the rider was a ‘no-show’ for the first half of the trip not acceptable.” In a follow-up let- ter from April 2001, to the transit agency, the FTA stated:

23 “We ask that you take every step possible to ensure that an assumed ‘no-show’ is in fact an actual ‘no-show’ before can- celing the return trip.” Using Slack Time Created by No-Shows and Late Cancellations Transit agencies were asked whether they were able to reas- sign the slack time created by passenger no-shows or late can- cellations. Of the 128 agencies responding to this question, 13.3% said “yes,” they could use the time and 11.7% said “no,” they could not make use of the opening in the schedule. Another 75.0% indicated that they sometimes are able to make use of the time. When asked how the time was used, responses could be divided into the following categories: • Dispatchers reassign trips or allow drivers to catch up on schedule (55%). • Use time for will calls, same-day service, or to clear wait list/unscheduled trips (29%). • Breaks, reassign from taxi, assist other services in sys- tem (11%). • Use late cancellation time but not no-show time to reas- sign trips (5%). Some of the comments on the use of slack time are listed here: • We use MDCs that enable immediate communication of trip changes as well as trip-by-trip updating of driver manifests, yielding improved scheduling decisions. • We allow same-day calls on a space available basis, so if a passenger happens to call after a late cancellation and they are in the same area of town, we will pick them up soon rather than having them wait 1 to 2 h. • Some of our contractors perform a second batch rout- ing each day at approximately 11 a.m., because most no-shows and cancellations occur during the morning hours. In some cases, they can fill in these empty spots with the limited same day service that we offer. • We use private contract companies to handle our over- flow to avoid denying any rides. In cases of no-shows or cancellations, we pull rides from the contractors (if any) to fill the openings. In addition, our paratransit runs have variable on/off times, so we could pull rides from the end of one run to fill openings on other runs. • With a no-show, no. With a late cancel, sometimes there is enough time available to insert a ride if there is a compatible same-day ride request. • The system is “batched” several times before the actual day of service so late cancellations at least can be addressed in the scheduling process. No-shows on the day of service are simply lost time to the system. Based on the comments, it appears that systems with more flexible scheduling and dispatching practices are more able and willing to use the slack time that may be opened up by late cancellations and sometimes no-shows. SUMMARY The survey respondents represent a broad cross section of transit agencies from very small to very large. The survey results provide information about how ADA complementary paratransit systems are managed and operated. The survey results provided insight into how ADA paratransit personnel and contractors are used to monitor and manage no-shows. Certain operating policies also were identified that might help to improve service efficiency and effectiveness, such as des- ignating paratransit pick-up locations at large activity centers with multiple entrances (e.g., a hospital complex or mall). The responses also suggested that some systems are able (with assistance from some technological tools) to rearrange trips in real time and in response to late cancellations (in advance of the pick-up time), as well as with some no-shows. The survey also provided insight about how ADA com- plementary paratransit no-show and late cancellation policies have been developed and implemented around the country. It has been suggested that some of the policies do not appear to be fully consistent with the ADA regulations or with recent FTA interpretations of the regulations, as described in chap- ter two. For example, some no-show policies appear to trig- ger suspensions after a relatively small number of passenger no-shows (e.g., three in 30 days). As reflected in the regula- tions and in recent ADA compliance reviews, such no-show policies do not demonstrate a pattern or practice of no-shows and are, therefore, unacceptable. The survey also revealed that some of the respondents mentioned that they automati- cally canceled any trips remaining on the schedule after a passenger is declared a no-show. As described in chapter two, FTA has indicated that automatically canceling a return trip is not acceptable and that agencies must “take every step possible to ensure that an assumed ‘no-show’ is in fact an actual ‘no-show’ before canceling the return trip.”