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35 CHAPTER SIX CONCLUSIONS For most paratransit systems, periodic passenger no-shows cellations is established based on a threshold for what a tran- and late cancellations are an expected cost of doing business. sit agency considers "excessive no-shows." However, at a time when the cost of providing Americans with Disabilities Act of 1990 (ADA) complementary para- Many transit systems have used 3 no-shows in a 30-day transit is increasing and all eligible demands for paratransit period as the definition of "excessive no-shows." However, trips must be met, excessive no-shows and late cancellations FTA has stated that three no-shows in a 30-day period would can adversely affect the efficiency of service and prove to be not constitute a pattern or practice and that transit agencies costly. In response, many transit agencies have implemented should consider the frequency of use when defining exces- policies to address no-shows and late cancellations. What has sive no-shows. FTA also stated that, because of the nature of not been clear, however, are what impacts these various no- the service and that many individuals may rely on ADA com- show and late cancellation policies have had on service effi- plementary paratransit for their transportation, the period of ciency, the mobility and the rights of riders, and whether they suspension should be appropriate to the infraction. However, are in compliance with the ADA regulations and subsequent FTA has not indicated what period of suspension would be FTA interpretations. acceptable. The results of this regulatory review and survey of transit Another concept that has been defined in the ADA regu- agencies in regard to no-show and late cancellation policies lations, but applied in different ways by transit agencies, provides useful information about current policies and prac- relates to excusing passenger missed trips (no-shows) that tices. Most of the focus of this synthesis is on how the are "beyond the passenger's control." This concept is requirements of the ADA regulations are addressed vis--vis addressed in the Appendix D regulatory guidance for Section no-show and late cancellation policies developed by transit 37 of the ADA. That guidance states that only actions within agencies. For the purpose of this synthesis study, no-show/ the control of the passenger can be counted as part of a pat- late cancellation policies were compared with the ADA reg- tern or practice of no-shows. These events that should not be ulations and evolving FTA guidance from recent ADA com- counted against the passenger might include operator error plementary paratransit compliance reviews and complaints (such as a late trip or carrier missed trip), a sudden turn for filed with the FTA Office of Civil Rights. This concluding the worse in someone with a variable condition (e.g., multi- chapter reviews those issues and the concerns raised during ple sclerosis), or a sudden family emergency that makes it this synthesis project and suggests future research needs. impracticable for the individual to travel at the scheduled time or for the individual to notify the entity in time to can- Several definitional issues have been reported as having cel the trip before the vehicle comes. an impact on how no-show and late cancellation policies are structured, including what constitutes a "pattern or practice" Many transit agencies take into account no-shows that are of no-shows and what is considered an excusable no-show beyond the passenger's control when establishing a determi- because it is "beyond the passenger's control." Although nation of excessive no-shows. Some mirror the ADA lan- these terms are defined to some degree in the ADA regula- guage, whereas others leave resolution of the issue to the tory language, the way in which these definitions have been appeals process. Some transit agencies charge a no-show put into practice can vary based on interpretation. The same against a passenger even if the vehicle was late and the pas- is true for late cancellations. senger had left or decided not to take the trip without notify- ing the transit agency. As described in chapter two, the ADA allows entities to suspend service for a reasonable period of time if an individ- The ADA makes reference to no-shows, but not to cancel- ual establishes a pattern or practice of missing scheduled trips. lations. Nonetheless, transit agencies have begun to consider Appendix D of Part 37 of the ADA provides additional regu- late cancellations as problematic and have started to incorpo- latory guidance: "A pattern or practice involves intentional, rate them into their no-show policies. The survey and policy repeated, or regular actions, not isolated, accidental, or sin- review indicated that there is wide variation in how transit gular incidents." A pattern or practice of no-shows and can- agencies define terms relating to no-shows and various types

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36 of cancellations, particularly late cancellations, which are of does not specifically address penalizing passengers for mak- specific interest to this synthesis. ing advance cancellations. Although it is true that late cancellations made close to the Other agencies have addressed the issue of excessive actual time of the scheduled pick-up can affect service deliv- early cancellations by ensuring that there are no trip denials, ery and waste time and resources, how late cancellations are which makes individuals relatively certain that they will get defined by an individual transit agency will affect how they the trip they want without having to reserve it well in impact paratransit operations. Some transit agencies use a advance. definition of late cancellations as occurring 1 to 2 h before the scheduled pick-up, believing that resources are already As described in chapter two, FTA has taken a position that committed to providing that trip. Other agencies do not see it in the event of an apparent passenger no-show, remaining as a problem, because they can always shift trips, fill holes, trips for that day are not to be automatically canceled and the and add vehicles that are in the unscheduled file. The survey transit agencies "take every step possible to ensure that an does show that dispatchers are sometimes able to make use assumed `no-show' is an actual `no-show' before canceling of the slack time created by late cancellations to reassign the return trip." However, to date FTA has not provided guid- trips, keep the schedule on time, and create driver breaks. ance on what it would consider "every step possible." New technologies are aiding in this effort and making it eas- ier for dispatchers to reassign trips in real time. ADA paratransit systems use a variety of technologies to enhance service provision, including handling gaps in sched- Some transit agencies have defined a late cancellation as ules created as a result of no-shows and late cancellations. any made after 5 p.m. (or 10 p.m. in some cases) the day Based on comments from the survey and interviews with sev- before a trip is scheduled, noting that they have in effect lost eral transit agencies, it appears that there is a better chance of the ability to provide another trip in that time slot because the using the time resulting from a late cancellation than from a reservations process is closed and schedules are complete at no-show at the door. According to the survey responses, the most commonly used technology applications are computer- that time. As a result, customers could be penalized for can- ized scheduling and dispatching (79.2%), automatic vehicle celing trips after 5 p.m. the day before the trip is scheduled location (AVL) (28.0%), and mobile data terminals (27.2%). even if it is still many hours in advance of the scheduled pick- With recent advances in scheduling and dispatching and the up time. FTA has gone on the record as saying that defin- integration of AVL and mobile data terminals, many of the ing late cancellations in this way is "unreasonable" and has concerns with the timing of late cancellations and no-shows encouraged systems to reconsider that approach. Other tran- may improve somewhat as trips are more easily transferred sit agencies indicated that a cancellation that is many hours among drivers based on real-time knowledge. in advance of a trip is sufficient notice, having little effect on system operations because such occurrences are generally In addition to providing enhanced capabilities for the transit expected. agency, an added benefit of technology is that it helps to give the rider more information, such as when a vehicle is coming Several of the transit agencies interviewed for this report and time saved in booking and canceling trips. However, as indicated that their no-show policies grew out of a need to pointed out in the case studies, it is important for the dispatch- address the issue of passengers making extra reservations ers to have direct control over the drivers. Some systems have and then canceling most of them at the last minute after decentralized dispatching or the schedules must go though a deciding which trips to actually make (i.e., trip hoarding). third party. Responding quickly to unrouted trips generated This practice could be related to concerns on the part of pas- every few minutes in a large system requires a same-day sched- sengers that there may be capacity constraints and that they uler or router to focus on the unrouted trips and a large enough may not get the trip they requested; therefore, they hoard dispatch staff to ensure that driver routes (trip times) are con- trips until they know exactly what they want to do. sistently updated throughout the day. Updated routes are criti- cal to sound routing decisions. AVL is also invaluable for find- In practice, other transit agencies have taken measures ing the closest vehicle to a waiting rider so that a trip can be to reduce excessive advance cancellations by shortening the assigned. The name of the game is balance, achieved through number of days in advance in which rides may be scheduled flexibility and effective communication to driver and patrons. (e.g., reducing the maximum reservation time from 14 days in advance to 7 days in advance). One transit agency reported Interactive voice response (IVR) allows customers to use that it has a no-show/cancellation policy that incorporates the keypad on their touch tone telephone to communicate penalties for so-called early cancellations, which are made with the computer's database to cancel trips, check scheduled while reservations are still being accepted for that time period. pick-up times, and book trips during any hour of the day or In that case, a 7-day suspension is given when 50% or more night. Dallas Area Rapid Transit has been using this tech- of the trips in a given month are canceled in advance during a nology for several years. Both Hillsborough Area Regional 30-day period (based on a minimum of eight trips). The ADA Transit in Tampa, Florida, and Niagara Frontier Transporta-

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37 tion Authority in Buffalo, New York, are in the process of the same time, it is unlikely that a one size fits all approach phasing in IVR. Hillsborough Area Regional Transit also men- and specific operational requirements may work everywhere. tioned that it cuts down on telephone hold time. IVR promises to be another tool for consumers to use at their convenience. There will always be a small percentage of passengers who abuse the system and generate no-shows and late cancella- Several transit agencies have adopted point-based no- tions without regard to its effect on fellow passengers or the show policies, which sometimes include a reward system for transit agency. On the other hand, passengers with occasional passengers who do not incur no-shows during a certain no-shows may simply require a gentle reminder or ongoing period of time (e.g., 6 months). The idea originated with the education about how to anticipate and report no-shows and Regional Transportation Commission of Southern Nevada in late cancellations. At the same time, this synthesis has identi- Las Vegas. Several other agencies have followed suit, includ- fied potential concerns including definitional issues, the ing the Utah Transit Authority. Points for late cancellations are impacts associated with developing no-show policies (partic- valued at less than the points for no-shows, and penalties ularly the definition of excessive no-shows/late cancellations are assessed based on the point system. To date, FTA has not and the magnitude of the penalties associated with them), out- commented on a transit system that uses a point-based system. reach and public education efforts, and issues with record keeping and consistently applying no-show policies. Under an incentive program, several agencies offer free ride coupons or passes to passengers based on their having Now that a baseline has been developed to describe how not accumulated no-show points during a specified period of transit agencies are currently managing their no-shows and time (typically 6 months). The Utah Transit Authority also late cancellations, it might be helpful to work with several gives free ride coupons to passengers when there is a carrier transit agencies of varying sizes to develop several model no- failure and the carrier misses the trip. They may be redeemed show and late cancellation policies that are compliant with to erase no-show points as well. ADA regulations and that permit the transit agencies to man- age their no-shows in a fair and effective manner. Specifi- cally, the research could be used to answer the following An important aspect of any no-show/late cancellation pol- questions: icy is conveying information about the policy and receiving feedback from customers and the community. In reviewing What constitutes an "ideal" no-show policy and how the policies and discussion of customer interaction with tran- would it be implemented? sit agencies, it was suggested that policies be developed that What is the cost of managing a proactive no-show/late are (1) easy to understand, (2) reasonable, and (3) fairly cancellation program? administered. What is the expected financial and operating payoff of closely managing no-shows and late cancellations? Several of the systems interviewed emphasized the need to educate their customers before enforcing their no-show This synthesis project has gone a long way toward answer- policies. Town hall meetings were used by some transit ing the first question, although stopping short of naming agencies. Letters or postcards that are automatically gener- "ideal" or "best" practices. The report suggests that a com- ated for each no-show are one tool that many systems are prehensive no-show program requires: starting to use to initiate a dialogue defining why a trip was designated as a no-show. Some systems also leave a door Realistic expectations of riders and drivers; hanger notifying the passenger that the driver was there and Consistently applied operating procedures, particularly that the trip was no-showed. Passengers are typically invited with respect to dispatch and drivers declaring an appar- to contact the agency to resolve any transportation prob- ent passenger no-show; lems. Telephone calls to customers can also provide good A means for passengers to cancel trips as far in advance information and education about no-show policies. One sys- as possible, including during times when the agency tem mentioned that it is often a new passenger who is a no- may not be open for business; show, one who may not understand the rules. One transit Good documentation based on a reliable, consistent system has developed a detailed telephone log sheet to method of recording no-shows and late cancellations; record the attempts to call each no-show and the outcome of Effective computer programs that capture accurate infor- that call. mation and produce reports that facilitate analysis; A system for sending letters to notify passengers about Reviewing various no-show policies and ADA regulations no-shows on a regular--perhaps daily--basis; and FTA findings helps to identify what no-show/late cancel- An effective process for determining excused no-shows lation policies should not include (e.g., policies that apply based on consistently applied criteria; unreasonable no-show requirements such as three no-shows A way to monitor no-shows and late cancellations on an in 30 days), as well as what they should include (e.g., infor- ongoing basis and to impose suspensions at the appro- mation about excused no-shows and the appeals process). At priate time;

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38 Appropriate technological tools such as computerized To determine the effectiveness of a no-show program, scheduling and dispatching, along with AVL and other transit agencies need to be able to technologies to manage no-shows and late cancellations; Public outreach to solicit input and educate passengers Document the actual costs of a no-show, trip refusal (at and their caregivers about the negative effect of no- the door), late cancellation (and how it is defined), and shows and late cancellations; and advance cancellation (and how it is defined); A recognition that imposing sanctions on this popula- Determine the operational effect of late cancellations at tion must be done with due process and concern for various times to decide what would fairly constitute individuals who may rely on ADA paratransit as their a late cancellation that is the operational equivalent of only source of transportation. a no-show for a particular system; Measure the cost of managing a no-show policy; and The cost of managing a proactive no-show policy could Measure customer satisfaction--both of customers who be significant and was not specifically identified in this report. should benefit by a reduction in no-shows and late can- The reaction of some managers to preliminary results of cellations by their fellow customers and of customers about the study findings raised concerns about how expen- who have incurred excessive late cancellations and no- sive it would be to implement a no-show policy with all of shows. the elements described here. In particular, staff time would be needed to The effective of system size would be an important com- Run reports, ponent to include, as well as any cost differences between Analyze results, no-show policies that are administered in-house by the tran- Contact passengers about apparent no-shows and late sit agency or externally by a contractor or broker. This type cancellations on a daily basis, of detailed cost information could help a transit agency Research excused no-shows, decide how comprehensive a no-show policy to implement Investigate operating failures to distinguish between and where to trade off the cost of managing a program ver- passenger no-shows and carrier failures, and sus the cost of running a service with a reasonable level of Manage the appeals process. no-shows and late cancellations.