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Suggested Citation:"Background." National Academies of Sciences, Engineering, and Medicine. 2011. Resource Guide for Commingling ADA and Non-ADA Paratransit Riders. Washington, DC: The National Academies Press. doi: 10.17226/14474.
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Suggested Citation:"Background." National Academies of Sciences, Engineering, and Medicine. 2011. Resource Guide for Commingling ADA and Non-ADA Paratransit Riders. Washington, DC: The National Academies Press. doi: 10.17226/14474.
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Suggested Citation:"Background." National Academies of Sciences, Engineering, and Medicine. 2011. Resource Guide for Commingling ADA and Non-ADA Paratransit Riders. Washington, DC: The National Academies Press. doi: 10.17226/14474.
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Suggested Citation:"Background." National Academies of Sciences, Engineering, and Medicine. 2011. Resource Guide for Commingling ADA and Non-ADA Paratransit Riders. Washington, DC: The National Academies Press. doi: 10.17226/14474.
×
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Suggested Citation:"Background." National Academies of Sciences, Engineering, and Medicine. 2011. Resource Guide for Commingling ADA and Non-ADA Paratransit Riders. Washington, DC: The National Academies Press. doi: 10.17226/14474.
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Page 11

Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

This Resource Guide for Commingling ADA and Non-ADA Paratransit Riders was prepared as part of TCRP Project B-34, funded by the FTA and was conducted through the TCRP, which is administered by the TRB of the National Academies. The primary purpose of the Resource Guide is to provide practical planning and operating assistance to fixed route transit agencies that are deciding whether or not to commingle their ADA eligible paratransit riders with “other” paratransit riders and, if so, how to implement the practice. Commingling ADA and non-ADA riders is a newly coined term for a practice that has been operating in many communities since transit agencies began operating paratransit services required by the ADA. For this project, “commingling” is defined as “routinely transporting ADA eligible paratransit riders with ‘other’ non-ADA paratransit riders on the same vehicles at the same time.” The following are examples of other paratransit riders who might be commingled with ADA paratransit riders: • Medicaid beneficiaries • Older adults with transportation service funded by Title III of the Older Americans Act or other programs • Job Access and Reverse Commute (JARC) program beneficiaries • New Freedom program beneficiaries • Other individuals with disabilities or older adults who participate in support services, for example: – Developmentally disabled individuals – Rehabilitation services participants – Human service agency customers – Adult day care program participants – Hospital discharges – Dialysis patients – Children (including Head Start participants) Most, but not all, of these categories of riders fall under the broad definition of “human service transportation” or “transportation disadvantaged” individuals. These are described in more detail below. Overview The concept of commingling—although it was not called that—began in the early years of the ADA as one approach to addressing the anticipated costs of complying with the ADA service requirements. Besides, it was anticipated that many riders currently being served by existing 7 B A C K G R O U N D

specialized transportation programs would be determined to be eligible for the new ADA para- transit service. At the time, commingling was referred to as “selling transportation services to non-ADA eligible riders” and listed as one of a number of “heretical ways to increase revenues and reduce costs in ADA paratransit services” in a paper written in 1993 (Rosenbloom and Lave 1993). The authors examined several approaches that transit agencies could use to reduce the cost of delivering ADA paratransit service or increase revenues for providing the service. Specifically, their “commingled” approach proposed that transit agencies might obtain additional revenues by selling paratransit services to human service agencies that wanted transportation for their clients. The paper notes this approach would not be appropriate in all situations but could be worthwhile to pursue when the marginal cost of the additional trips for non-ADA riders is less than the average cost of the transit agency’s paratransit trip and where the human service agencies are interested in purchasing service. The paper qualified the approach by noting that transit agencies will have to estimate the cost implications of providing the non-ADA service as part of its ADA paratransit service. This notion of the importance of assessing the cost implications of providing non-ADA service is one of several lessons learned through this research project. Since the mid-1990s, there have been many permutations of commingling. According to the survey of transit agencies conducted late in 2006 as part of this research project, 61% of the transit agencies indicated that they serve both ADA and non-ADA riders, with just over one-half (53%) commingling ADA and non-ADA riders on the same vehicles and 8% serving both ADA and non-ADA riders but using separate vehicles for the two rider groups. The remaining 39% of the survey respondents indicated that they served only ADA riders, however about one third of this group (18 respondents) indicated that while they had commingled ADA and non-ADA riders in the past, they no longer do so. A summary of the survey results is included in Appendix A. The survey results were somewhat unexpected, given current concerns in the transit industry about increasing costs for ADA paratransit services. This project’s case study research provided the opportunity to examine the practice of commingling in greater detail and understand the genesis of commingling and the operational parameters of the practice (see summaries in Appendix B). Note that for this project, commingling riders on the same vehicles is viewed as distinct from a transit agency providing paratransit services to ADA eligible and other paratransit riders using sep- arate vehicles (i.e., perhaps coordinating service but not typically mixing passengers). As directed by the TCRP B-34 Project panel, the research team focused on transit systems that commingle their ADA customers with other riders funded by human service agencies and other community pro- grams, medical services (including non-emergency medical transportation funded by Medicaid), and other programs that specifically subsidize transportation service for their customers (e.g., JARC and New Freedom). The research team did not focus on systems that coincidentally mix ADA and non-ADA riders on the transit agency’s vehicles as a result of loosely defined eligibility criteria or grandfathering of non-ADA eligible riders. Much has been written over the years about coordinating human service transportation services and in recent years this topic has become a focal point of the FTA’s United We Ride and Mobility Services for All Americans (MSAA) initiatives. It is not the intent of this project to repeat the findings from these efforts but to use those resources to help inform decisions about how and whether to commingle. A summary of relevant resources is included as Appendix C. The research found three basic factors that seemed to affect decisions regarding whether or not to commingle: • Evolution. For a number of transit systems, paratransit service was historically part of the mix of services that they operated and when the ADA was passed in 1990, the transit system added ADA paratransit into the paratransit mix of services that it already offered. ACCESS in Pittsburgh 8 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

is probably one of the best known examples. The ACCESS program predates the ADA by more than a decade and has evolved to incorporate ADA paratransit into its service mix. Designed as an administrative paratransit brokerage, ACCESS is responsible for coordinating the pro- vision of approximately 2 million trips annually for 120 agencies through a network of about a dozen for-profit and non-profit transportation providers. General public customers also may use ACCESS services, but must pay a fare that covers the full cost of their trip. • Cost-sharing. Another reason for commingling was the need for public transit and local human service agencies to cooperate, particularly related to managing costs and cost-sharing for paratransit service. Prior to passage of the ADA, many human service agencies were responsible for their own program participants’ transportation. With implementation of the ADA, many of these program participants were determined ADA eligible, but rather than just shifting their riders and the associated transportation costs to the public transit authority as some human service agencies have done, these organizations worked together to coordinate service and develop agreements for equitable cost-sharing. In contrast, some transit agencies decided not to commingle or to discontinue commingling their ADA and non-ADA riders (e.g., Maryland Mass Transit Administration and Broward County in Florida). Factors contributing to a transit agency’s decisions not to commingle tend to focus on cost allocation or service quality/control issues. • State-level commitment to coordination. In some cases, coordination requirements and incentives at the state level may influence or require commingling of ADA and non-ADA rid- ers. A 2005 report published by the National Conference of State Legislatures found 21 states with specific legislation related to human service transportation coordination and another 16 states that require human service coordination but not specifically in public transportation. Governors have executed executive orders in 9 states, and at least 27 states and the District of Columbia have attempted local coordination initiatives without a state requirement (Sundeen et al. 2005). It is clear that transit agencies in states such as Florida and Pennsylvania, with des- ignated funding set aside for coordinated transportation efforts, tend to provide services in a commingled fashion. ADA Complementary Paratransit Regulatory Requirements It is important to remember that fixed route public transit agencies must maintain their ADA complementary paratransit services in accordance with U.S. DOT regulations under the ADA. As long as a transit system meets the ADA regulatory criteria without capacity constraints, it is free to tailor its operations in response to the needs of the community it serves, including commingling ADA and non-ADA riders if desired. However, if there are capacity constraints for ADA riders, the transit agency must make that aspect of the service compliant. Public entities operating non-commuter fixed route transportation services for the general public are required by the U.S. DOT regulations that implement the ADA to provide ADA complementary paratransit service for individuals who are unable to use the fixed route system because of their disability. The FTA is responsible for ensuring compliance with the ADA and the U.S. DOT regulations. In addition to the ADA paratransit eligibility standards described in 49 CFR §37.123, these regulations include service criteria, which must be met by ADA complementary paratransit service programs as outlined in 49 CFR §37.131. These criteria are meant to ensure that paratransit service is comparable to service that is provided by the fixed route system. These criteria state that the ADA complementary paratransit service must, at a minimum • Operate in the same service area as the fixed route system, which generally includes a 3⁄4-mile corridor on either side of a fixed route as described in 49 CFR §131(a). Background 9

• Have a comparable response time, where response time is defined as the elapsed time between a request for service and the provision of service. Comparability is defined as accommodating trip requests for ADA paratransit eligible individuals at any requested time on a particular day in response to a request for service made during normal business hours on the previous day as described in 49 CFR §131(b). • Have comparable fares. Comparability is defined as fares that are no more than twice the base, non-discounted adult fare for fixed route services as described in 49 CFR §131(c). • Meet requests for any trip purpose (i.e., no trip purpose restrictions) as described in 49 CFR §131(d). • Operate during the same days and hours as the fixed route service as described in 49 CFR §131(e). • Operate without capacity constraints for ADA trips requested by ADA eligible passengers (e.g., no waiting lists, trip caps, or patterns and practices of a substantial number of trip denials, untimely pick-ups or excessively long trips). 49 CFR §131(f). Finally, 49 CFR §131(g) allows for public entities to provide ADA complementary paratran- sit service to ADA paratransit eligible individuals that exceeds the minimum criteria included in this section. If transit agencies commingle ADA and non-ADA riders, they must preserve the integrity of the ADA paratransit service (i.e., ADA service criteria must be met for all ADA eligible trips), even it means curtailing other non-ADA-required services. Before passage of the ADA, many fixed route transit agencies provided or supported some level of specialized transportation for people with disabilities and older adults. These services were sometimes supported by human service agency funds, such as from Title III of the Older Americans Act or through limited locally generated (i.e., non-sponsored) funds. After the ADA was passed and the requirement to provide ADA complementary paratransit for all eligible per- sons with disabilities came into effect, many transit agencies had to make a decision about whether and how to provide non-ADA specialized transportation. Models for Commingling ADA and Non-ADA Paratransit Riders During the course of this project, four models for commingling ADA and non-ADA paratran- sit riders were identified, representing the spectrum of commingled approaches. The first three models were the most commonly observed in the project survey; the fourth model does not truly fit the definition of commingled service used for this project but was identified as a commingling strategy by several transit agencies. The four models include the following: • Model #1: Human Service Transportation + ADA Paratransit Pre-ADA human service transportation providers that added ADA paratransit services after passage of the ADA. This model includes programs with roots in human service trans- portation that have been expanded to include ADA paratransit service. In practice, this model includes two subtypes: non-profit agencies that have become the ADA paratransit service provider for the local transit agency and transit agencies that have incorporated former non- profit transportation programs into their paratransit service structure. That latter practice was more common when ADA paratransit was first introduced and systems were merged. It is less likely to occur now. • Model #2: ADA + Human Service Transportation ADA paratransit service providers that added human service transportation service after their ADA paratransit service. This model is the focus of this research project and of the 10 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

decision-making processes described in the Resource Guide. It includes transit agencies that started as ADA paratransit service providers and later added HST or other paratransit services to their service structure. • Model #3: General Public Dial-A-Ride + ADA Paratransit Service Public dial-a-ride services that operate in coordination with ADA paratransit service (or serve “would-be” ADA customers). This example includes a coordinated system of local dial-a-ride service providers that have been expanded to include ADA paratransit in commingled services. • Model #4: Two-Tiered ADA Paratransit Service ADA paratransit service providers that offer enhanced demand response services outside the ADA service area. The research found several transit providers that consider their provision of ADA-type paratransit service beyond the required 3⁄4-mile fixed route corridors to be “commingled” services. Under this model, transit agencies are basically providing ADA paratransit service beyond the minimum service required by the ADA and not truly commingling riders. Although not the focus of this report, this model is what some agencies labeled “commingled” and it was included in the review. Transit agencies considering whether to commingle passengers today would most likely identify with Model #2, which was the intended focus for this Resource Guide. Resource Guide Approach The core features of the Resource Guide are two decision-making flow charts designed for use by fixed route public transit agencies wishing to explore whether and how to commingle ADA paratransit and non-ADA paratransit riders. The flow charts are presented and discussed within two sections in this Resource Guide: • Section 1: Planning Decision Process • Section 2: Operations Decision Process Section 3 of the Resource Guide highlights the lessons learned from this project. Supplemental information is included in several appendices including a summary of the results of the transit agency survey that was conducted at the onset of this project (Appendix A), a summary of the case study findings (Appendix B), and highlights from the reference review (Appendix C). Background 11

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TRB’s Transit Cooperative Research Program (TCRP) Report 143: Resource Guide for Commingling ADA and Non-ADA Paratransit Riders is designed to help public transit agencies explore whether and how to commingle Americans with Disabilities Act of 1990 (ADA) paratransit and non-ADA paratransit riders.

The guide is designed to help practitioners define the purposes and objectives for commingling riders, identify potential capacity and funding, evaluate service compatibility, and consider primary service parameters.

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