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Suggested Citation:"Chapter Six - Conclusions." National Academies of Sciences, Engineering, and Medicine. 2005. Practices in No-Show and Late Cancellation Policies for ADA Paratransit. Washington, DC: The National Academies Press. doi: 10.17226/13856.
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Suggested Citation:"Chapter Six - Conclusions." National Academies of Sciences, Engineering, and Medicine. 2005. Practices in No-Show and Late Cancellation Policies for ADA Paratransit. Washington, DC: The National Academies Press. doi: 10.17226/13856.
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Page 37
Suggested Citation:"Chapter Six - Conclusions." National Academies of Sciences, Engineering, and Medicine. 2005. Practices in No-Show and Late Cancellation Policies for ADA Paratransit. Washington, DC: The National Academies Press. doi: 10.17226/13856.
×
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Page 38
Suggested Citation:"Chapter Six - Conclusions." National Academies of Sciences, Engineering, and Medicine. 2005. Practices in No-Show and Late Cancellation Policies for ADA Paratransit. Washington, DC: The National Academies Press. doi: 10.17226/13856.
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35 For most paratransit systems, periodic passenger no-shows and late cancellations are an expected cost of doing business. However, at a time when the cost of providing Americans with Disabilities Act of 1990 (ADA) complementary para- transit is increasing and all eligible demands for paratransit trips must be met, excessive no-shows and late cancellations can adversely affect the efficiency of service and prove to be costly. In response, many transit agencies have implemented policies to address no-shows and late cancellations. What has not been clear, however, are what impacts these various no- show and late cancellation policies have had on service effi- ciency, the mobility and the rights of riders, and whether they are in compliance with the ADA regulations and subsequent FTA interpretations. The results of this regulatory review and survey of transit agencies in regard to no-show and late cancellation policies provides useful information about current policies and prac- tices. Most of the focus of this synthesis is on how the requirements of the ADA regulations are addressed vis-à-vis no-show and late cancellation policies developed by transit agencies. For the purpose of this synthesis study, no-show/ late cancellation policies were compared with the ADA reg- ulations and evolving FTA guidance from recent ADA com- plementary paratransit compliance reviews and complaints filed with the FTA Office of Civil Rights. This concluding chapter reviews those issues and the concerns raised during this synthesis project and suggests future research needs. Several definitional issues have been reported as having an impact on how no-show and late cancellation policies are structured, including what constitutes a “pattern or practice” of no-shows and what is considered an excusable no-show because it is “beyond the passenger’s control.” Although these terms are defined to some degree in the ADA regula- tory language, the way in which these definitions have been put into practice can vary based on interpretation. The same is true for late cancellations. As described in chapter two, the ADA allows entities to suspend service for a reasonable period of time if an individ- ual establishes a pattern or practice of missing scheduled trips. Appendix D of Part 37 of the ADA provides additional regu- latory guidance: “A pattern or practice involves intentional, repeated, or regular actions, not isolated, accidental, or sin- gular incidents.” A pattern or practice of no-shows and can- cellations is established based on a threshold for what a tran- sit agency considers “excessive no-shows.” Many transit systems have used 3 no-shows in a 30-day period as the definition of “excessive no-shows.” However, FTA has stated that three no-shows in a 30-day period would not constitute a pattern or practice and that transit agencies should consider the frequency of use when defining exces- sive no-shows. FTA also stated that, because of the nature of the service and that many individuals may rely on ADA com- plementary paratransit for their transportation, the period of suspension should be appropriate to the infraction. However, FTA has not indicated what period of suspension would be acceptable. Another concept that has been defined in the ADA regu- lations, but applied in different ways by transit agencies, relates to excusing passenger missed trips (no-shows) that are “beyond the passenger’s control.” This concept is addressed in the Appendix D regulatory guidance for Section 37 of the ADA. That guidance states that only actions within the control of the passenger can be counted as part of a pat- tern or practice of no-shows. These events that should not be counted against the passenger might include operator error (such as a late trip or carrier missed trip), a sudden turn for the worse in someone with a variable condition (e.g., multi- ple sclerosis), or a sudden family emergency that makes it impracticable for the individual to travel at the scheduled time or for the individual to notify the entity in time to can- cel the trip before the vehicle comes. Many transit agencies take into account no-shows that are beyond the passenger’s control when establishing a determi- nation of excessive no-shows. Some mirror the ADA lan- guage, whereas others leave resolution of the issue to the appeals process. Some transit agencies charge a no-show against a passenger even if the vehicle was late and the pas- senger had left or decided not to take the trip without notify- ing the transit agency. The ADA makes reference to no-shows, but not to cancel- lations. Nonetheless, transit agencies have begun to consider late cancellations as problematic and have started to incorpo- rate them into their no-show policies. The survey and policy review indicated that there is wide variation in how transit agencies define terms relating to no-shows and various types CHAPTER SIX CONCLUSIONS

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

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

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

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TRB’s Transit Cooperative Research Program (TCRP) Synthesis 60: Practices in No-Show and Late Cancellation Policies for ADA Paratransit examines 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 operated under the regulatory requirements of the Americans with Disabilities Act of 1990 (ADA). The report reviews the administration, community response, and effectiveness of policies in small, medium, and large transit agencies. The report addresses policies as a way to improve system productivity, efficiency, and capacity, and as a means to better service riders with disabilities who may experience difficulties with the advance reservation aspect of most ADA complementary paratransit operations.

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