Resource Guide for Commingling ADA and Non-ADA Paratransit Riders (2011)

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30 This section of the Resource Guide provides a suggested operations decision process developed for use by transit agencies that are planning to commingle ADA and non-ADA paratransit riders using the same vehicles, although the decision process also can be used by agencies choosing to provide ADA and other paratransit services using separate vehicle fleets. This guidance is based on the background research conducted as part of this project, including a survey of 121 transit agencies of various sizes from across the country. The survey information was supplemented by site visits and telephone interviews with 18 transit agencies, along with additional research and the research team’s own knowledge of the industry. As stated in Section 1, the research team recognizes that sometimes the decision to commin- gle paratransit riders is made based on the outcome of a formal planning process and other times the decision may be based on political decisions or other external influences with little formal planning input. Even if the decision already has been made, it is useful to review the steps out- lined in the planning decision process described in Section 1 to identify any areas that warrant further discussion prior to moving into the operations decision phase. In particular, it is useful to document in writing the stated purpose and goals for commingling riders. This exercise is very helpful if issues arise later because service has evolved or changed from its original design or implementation. It is also critical to identify any potential capacity and/or funding constraints that could affect sustainability of the program, particularly any potential negative impacts on the provision of required ADA paratransit service. The materials in this section are designed to stimulate a logical thought process to ensure that what has been planned—formally or informally—is put into operational practice to achieve the stated purpose and goals of the commingled services. This document is not intended to provide a step-by-step guide to operating paratransit services; there are many other resources that provide that type of information, some of which are documented in Appendix C. Additionally, there are numerous reports, trainings, workshops, and webinars that are offered through govern- ment and trade associations including the American Public Transportation Association (APTA), Community Transportation Association of America (CTAA), Easter Seals Project ACTION (ESPA), FTA, National Transit Institute (NTI), and the TCRP. A 43-page resource document—Innovative Practices in Paratransit Services—was published by ESPA in 2002 and may be useful as a supplement to this report (Multisystems 2002). The operations decision process presented in this section focuses on developing policies, procedures, practices, and performance monitoring strategies to ensure success. An overview of the operations decision process is shown in Figure 2-1. In the electronic version of this report (available online at www.trb.org by searching for “TCRP Report 143”), each major compo- nent of the operations decision process is color coded as follows: A. “Establish Passenger Eligibility Requirements” is shown in red. B. “Develop Operating and Cost Allocation Policies and Procedures” is shown in blue. S E C T I O N 2 Operations Decision Process

Calculate marginal cost/trip Changes needed No changes needed Same policies for ADA and non-ADA Decision to implement commingled ADA & non-ADA service Continue to monitor ADA & Non-ADA service performance Establish rider eligibility processes: - ADA paratransit rider eligibility - Non-ADA paratransit rider eligibility Develop operating policies Develop cost-sharing policies Document operating policies and procedures Different policies for ADA and non-ADA Develop billing procedures for non- ADA programs Calculate fully allocated cost/trip Calculate cost/trip for commingled non-ADA service Negotiate agreements with non-ADA programs Assess changes needed for technology Document reporting requirements Develop information and marketing materials Design monitoring and evaluation program Assess performance of ADA and non-ADA service Meets ADA regulatory service criteria? Adjust performance as needed OPERATING POLICIES COST ALLOCATION PASSENGER ELIGIBILITY TECHNOLOGY MARKETING & EDUCATION MONITORING Procure needed technology Develop detailed reporting procedures REPORTING Separate program info Combined program info Meets other performance criteria? Figure 2-1. Operations decision flow chart.

C. “Identify Reporting Requirements and Assess Technology Needs” is shown in orange. D. “Develop Marketing, Education, and Monitoring Programs” is shown in green. As with the planning decision process described in Section 1, there are no right or wrong answers to the various operational issues, other than the fact that compliance with the ADA must be maintained for those riders that are ADA eligible, and the decisions made relative to structur- ing and commingling paratransit services are ultimately local decisions and should be based on the specific characteristics of the service to be provided. A. Establish Passenger Eligibility Requirements Without a doubt, one of the most important aspects of any successful paratransit service is to establish the eligibility requirements for the riders who will be served under a particular program or programs, and then to develop a thorough eligibility determination process to ensure that potential riders who meet specific programmatic requirements are able to access those services. In addition to identifying who is allowed to use service and for which types of trips, eligibility transcends all aspects of commingled paratransit services and may be used to calculate fares for individual riders, establish when and where trips may be taken, what performance criteria must be met to satisfy the funding agency requirements, and how much a sponsoring agency will be billed for some or all of the trip cost. Because of the potential complexities of cost allocation and other programmatic requirements, eligibility also becomes a factor in determining what technolo- gies might be used for reservations, scheduling, and dispatching, as well as for recordkeeping, invoicing, and performance monitoring. This section describes the basics of eligibility determination and discusses the importance of accurate eligibility determination, particularly when riders may be eligible both for ADA and non-ADA paratransit service, depending on the trip. ADA Paratransit Eligibility ADA is civil rights legislation that requires transit agencies operating fixed route bus and rail service to provide ADA complementary paratransit service for individuals who cannot use fixed route service for some or all of their trips. The U.S. DOT ADA regulations include specific ADA paratransit eligibility standards, which are described in 49 CFR §37.123, and ADA determina- tion process requirements, which are described in 49 CFR §37.125. Although transit agencies may provide paratransit service for other riders who do not qualify for ADA paratransit service, the ADA regulations require that transit agencies meet the ADA paratransit service criteria described in 49 CFR §37.131 for ADA paratransit eligible customers; the service criteria requirements are listed in the next section (Developing Service and Cost Allo- cation Policies). Specifically, ADA paratransit service must be provided for all eligible trips and there may not be a pattern or practice of trip denials nor can trip priorities be applied to ADA paratransit eligible individuals. The ADA eligibility determination process has evolved over the past two decades and many transit agencies have developed sophisticated processes, which include written applications, in- person interviews, and functional assessments of individuals’ cognitive, physical, and visual functional abilities to determine whether and to what extent they may be able to use fixed route services for some or all of their trips. As such, ADA paratransit eligibility may be “unconditional,” allowing customers to use the service for all of their trips, or “conditional,” meaning that ADA eligibility applies only to certain trips under particular circumstances as identified during the 32 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

eligibility determination process. (Visitor and temporary ADA paratransit eligibility also must be offered as described in the regulations.) Non-ADA Paratransit Rider Eligibility Non-ADA services will have their own eligibility requirements and determination processes, based on the particular non-ADA riders who are being commingled. The non-ADA riders may be sponsored or affiliated with a particular human service agency or funding program, or they may be non-sponsored or unaffiliated, generally meaning they are part of the general public. Such non-sponsored riders may be funded through local transit agency dollars provided through the city or county as well as through federal Section 5311 in rural areas. The funding programs often provide funds to serve particular categories of riders, for example, riders categorized by age, economic status, or disability type. It is also important to note that riders may be eligible for more than one program—including ADA paratransit service—depending on the trip type. For example, Title III of the Older Americans Act (OAA) funds certain trips for persons aged 60 and older under a program administered by local Area Agencies on Aging (AAA). As such, a local AAA may provide its own transportation service or may purchase service. A fare may not be charged, although donations are accepted. Many OAA eligible riders also may qualify for ADA paratransit so it becomes important to properly identify the trip type in order to bill the proper program for the cost of the trip and to properly account for any applicable fare. The Medicaid Non-Emergency Medical Transportation (NEMT) program is another example. Each state is responsible for managing its own Medicaid services and a variety of transportation service options are possible, ranging from fixed route passes, to taxi vouchers, to mileage reimburse- ment, as well as contracting for paratransit trips. As with OAA-funded trips, a fare may not be charged, although donations are accepted. Once again, ADA eligible individuals may also qualify for Medicaid NEMT service and identifying and appropriately billing Medicaid for those trips is an important consideration (as well as not charging a fare for Medicaid eligible trips). There are many other funding partners that also have specific eligibility requirements and include overlapping eligibility among themselves and with ADA paratransit riders. Notable state- level examples include the Shared Ride Program (SRP) in Pennsylvania and the Transportation Disadvantaged (TD) program in Florida. Both programs identify eligible riders and provide funding to subsidize the cost of eligible trips. In Pennsylvania, the SRP pays 85% of the trip costs for seniors age 65 and older. Riders or their sponsoring agencies (including senior centers and other program sponsors) pay the remaining 15%. Both ACCESS in Pittsburgh and Southeastern Pennsylvania Public Transportation Authority (SEPTA) in Philadelphia commingle ADA and SRP trips (see case study descriptions in Appendix B) and both programs are able to charge eligible trips for seniors to the SRP, while using transit agency funds to subsidize ADA paratransit trips for individuals younger than 65 or for trips that are not eligible under SRP. The Florida TD program funds trips for persons who are transportation disadvantaged as defined in the Florida Administrative Code (generally seniors, people with disabilities, low-income individuals or children-at-risk who do not have access to a vehicle). Similar to the Shared Ride Program, but with more limited funding, the TD Trust Fund subsidizes the cost for eligible trips and individuals may be eligible for TD, ADA, NEMT and other sponsored trips. Discussion In most cases, the research team suggests that the transit agency staff manage the eligibility deter- mination process, particularly for ADA paratransit eligibility, conducting functional assessments Operations Decision Process 33

or applicant interviews. Having said that, the transit agency may choose to contract for the pro- vision of functional assessments by occupational therapists, physical therapists, orientation and mobility specialists, and others who are well-qualified to assess an applicant’s functional ability to use fixed route transit. By either method, the information gained through these assessments can then be used to make a final eligibility determination. ACCESS Transportation Systems in Pittsburgh (described in Appendix B) has developed a rig- orous and highly regarded ADA eligibility determination process and the agency’s manager is one of the primary trainers for a National Transit Institute training course, “Comprehensive ADA Paratransit Eligibility” (NTI 2010). ACCESS is a non-profit brokerage and not the local transit agency, with a long history of providing coordinated transportation services predating the ADA; the ADA paratransit actually constitutes only a portion of its overall service. Most of the time, eligibility for non-ADA paratransit is made by the agency sponsoring the trips (e.g., the AAA or other human service agency). It is important to develop a mechanism for updat- ing eligibility rosters on a regular basis. It also is important to code riders according to their pro- gram eligibility. Not only is this step important for billing and fare payment purposes, but it also helps to identify the payer of choice for the trip, based on program rules (e.g., charging Medicaid for eligible trips rather than using transit agency funds, when appropriate). This information also assists with monitoring to ensure that performance requirements are met for each program. B. Develop Operating and Cost Allocation Policies and Procedures The concept of developing policies and procedures for paratransit services is familiar. These policies and procedures create a set of expectations for how service will be operated, coupled with a set of procedures designed to support the stated operating policies. These policies and proce- dures define the level of service to be offered and will affect the cost and quality of that service. The groundwork for establishing policies and procedures was introduced during the planning process described in Section 1, where the importance of defining the purpose and goals for com- mingling services was discussed and the consideration of service parameters was introduced. Sec- tion 2 continues with a more detailed discussion of specific policies that should be addressed when establishing commingled service operations. The focus of the discussion here is on those policies and procedures that are unique to ADA paratransit and non-ADA paratransit pairings and not the multitude of operating policies and procedures that are commonly addressed as part of normal service operations (e.g., maintenance procedures, personnel policies, and so on). As shown in Figure 2-1, the topics of developing service operating policies and determining cost allocation are somewhat intertwined and, therefore, the research team has chosen to address them together. The level of service to be offered is typically defined first so that costs can be iden- tified and allocated among the partners. The process may require some negotiation, as indicated by the two arrows connecting the operations policy and cost-sharing policy boxes. This can be a complicated process if operating policies are significantly different among participating pro- grams. Clearly, defining the service to be provided and negotiating any changes should result in a better integration of services and will reduce the likelihood of misunderstandings related to service quality and cost issues that could arise down the road. Operating Policies A useful way to begin is to compare the ADA paratransit service requirements with non-ADA service requirements for the programs that will be commingled with the transit agency’s ADA 34 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

paratransit service. The easiest way to do this is to start with the ADA minimum service criteria included in 49 CFR §37.131 (see the following bulleted list). It should be noted that the ADA allows public entities to provide service to ADA paratransit eligible individuals that exceeds the minimum criteria included in this section; however, the ADA-required service must be operated without capacity constraints. The ADA minimum service criteria include the following: • Service area. ADA paratransit service is required to be operated 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. This is one of the operating policies where there is likely to be a difference between the ADA and non-ADA paratransit service, according to the project’s research efforts. When commin- gled services have different service areas, it will be important to educate riders, call-takers, and vehicle operators about the differences. • Comparable response time. Response time is defined as the elapsed time between a request for service and the provision of service. The ADA requires that requests for trips be accepted through normal business hours the day before service is to be provided. When possible, it is helpful to have the same advance reservation period for all rider types, which makes it easier for call-takers to handle trip requests and easier for riders to understand, especially for those who may be eligible under multiple trip sponsors. This approach is taken by most of the proj- ect’s survey respondents that serve both ADA and non-ADA riders. • Comparable fares. Comparable fares are required for ADA paratransit, which means they may be no more than twice the base, non-discounted adult fare for fixed route services. In contrast, many human service transportation programs do not allow a fare to be charged, although dona- tions may be accepted (e.g., Medicaid and Title III of the OAA). In some cases, transit agencies may charge a premium fare for non-ADA service provided to non-sponsored or general public riders. Again, fare differences must be explained to riders, vehicle operators, and call-takers. • No trip priorities. No trip priorities are allowed for ADA paratransit and there may be no trip limits for individual ADA riders. In contrast, most HST service is intended only for agency- approved travel (often to/from agency activities). Service for non-sponsored riders may also be restricted, based on local or other funding parameters. For example, if a community pro- vides funds for non-sponsored seniors, that funding may have a cap and that total amount may then be spread out over a year with a set number of trips available each month or week. In addition, the ADA regulations do allow for subscription/standing order trips to be offered; however, if there are any service constraints, then no more than 50% of trips may be subscrip- tion based during any given time of day. • Days and hours of service for ADA paratransit must be the same as for the fixed route service operating in the same area. For most large urban systems, this means that ADA paratransit service is operated seven days a week. For smaller or rural systems, fixed-route service days and hours vary, and ADA paratransit must be offered during those same time periods. • Capacity constraints are not allowed for ADA paratransit service. This means that there can be no pattern or practice of a substantial number of trip denials, no wait lists for trips, no trip caps or limits on how many trips an individual may make and no untimely pick-ups or excessively long trips. In practice, HST service is usually restricted to approved programs and services because of funding source restrictions (e.g., Medicaid or OAA Title III). The non-ADA funding programs may also choose to limit how many trips an eligible participant may make during a certain period of time. However, for certain policies, notably timely pick-ups and reasonable trip lengths (mea- sured by time), good practice suggests that the ADA service and non-ADA service should match. An important decision to make is whether the operating policies for ADA and non-ADA paratransit will be the same, although in practice it is rare for all aspects of service to be identical given fare restrictions and so forth. When setting service providers, consider the following: • Involve as many stakeholders as possible (including funding agencies, customers, and vehicle operators) Operations Decision Process 35

• Identify those operating policies that can be universally applied to all programs (e.g., on-time pick-up and drop-off windows, driver wait time, and no-show/late cancellation policies) To the extent appropriate and feasible, the establishment of consistent operating policies makes it easier for vehicle operators, customer service and call-takers staff, and riders to understand, manage, and use the system. While there may be necessary differences among program require- ments (e.g., different fare requirements), on-street operations should be as consistent as possible among rider types served. The following are examples: • Call center policies and procedures should be consistent. • The on-time pick-up window should be the same for all riders (e.g., vehicles arrive within a 30-minute on-time pick-up window). • The on-time drop-off window for appointment-based trips should be the same (e.g., riders will be dropped off on-time up to 30 minutes in advance of their scheduled arrival time but not after). • When possible, no-show policies should be the same for all passengers (e.g., suspension levels and procedures for forgiving no-shows beyond the rider’s control). • On-board travel time standards should be consistent for all riders. The issue of trip denials can be an important one for commingled services. Specifically, tran- sit agencies must ensure that there are no trip denials for eligible ADA riders. Negotiation is permitted within the ADA regulatory structure for pickup times; however, all eligible trips must be accommodated. For non-ADA riders, denials may be permitted, depending on any specific parameters of the non-ADA funding program or agreements between the transit agency and funding partner. For example, given funding limitations, a senior center program may only be able to fund a specific number of trips per day or month. In that case, trips may be allowed on a first-come/first-served basis or based on a specific number of trips permitted to be taken by an individual during a specified period of time. Once those trips have been scheduled, no further trips may be accommodated for that particular senior center program. Another important area is telephone hold times and ensuring that riders are able to get through to the call center in a reasonable amount of time. If hold times are too long or callers encounter busy signals, it can dissuade them from using service and that can be construed as a barrier to service. Although there is no “standard” for telephone hold times, the American Public Transportation Association (APTA) has established a working group to address this concern, and it has drafted a recommended practice for call center hold times, which is due to be published in 2010. Along with ensuring the policies developed meet the minimum ADA requirements, it is important to under- stand the specific policy requirements for non-ADA service being commingled with the ADA service. Because human service agencies typically provide transportation as a support service for agency programs, they may not have well defined transportation policies to govern the provision of service, which may translate to service requirements that are less stringent than that required by ADA standards. Once the policies have been developed, they should be documented into standard operating procedures. The policies and procedures will then need to be incorporated into training pro- grams for vehicle operators and customer service/call center staff. Riders also must be educated about the policies and procedures affecting them, including any changes as a result of comin- gling service. It is important to document the following: • Minimum ADA requirements and how they will be implemented (e.g., no trip priorities, advance reservation policies) • Required and optional service policies of the ADA program (e.g., use of will calls for return trips or subscription trip protocols) • Non-ADA minimum program requirements and how they will be attained (e.g., allowable trips, any trip purpose restrictions) 36 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

• Required and optional service policies of the non-ADA programs (e.g., how many times a vehicle will attempt to pick up a rider who has been no-showed, whether there are any special documentation requirements such as signing driver manifests) Placing the policies in a chart makes for easy review and identification of similarities and differ- ences. It is important to reach consensus on service policies so that all appropriate stakeholders understand how the commingled service will operate. There is not a right way or wrong way to structure service policies for commingled service. The development of service policies should fit the unique circumstances of each transit agency and service area. Discussion The project’s research efforts revealed that transit agencies take different approaches to defin- ing their service operating policies for commingled services. Relevant Survey Results. The survey of transit systems found some differences in service policies for those agencies that commingle ADA and non-ADA paratransit service. • Service Area The survey asked respondents to define their ADA paratransit service area as well as the service area of their other non-ADA service area. Agencies that provided ADA service within only the required 3⁄4-mile corridors and also provide additional non-ADA service tended to serve a larger service area for their non-ADA riders, for example, serving the entire city or county rather than just the ADA-required service area. Those agencies that provided ADA service to an area beyond the ADA-required minimum, such as an entire city or county and also served non-ADA riders, tended to use the same service area for their ADA and non-ADA riders. More specifically, the survey showed that the majority of commingling transit agencies provide their ADA paratransit service only within the required 3⁄4-mile corridors (60%) and provide their other service to a larger area, most frequently within a county (47%), with the next most frequent service area being a city or town (38%). • Response Time (i.e., Advance Reservation Period) Survey respondents were also asked about their advance reservation time period. The responses show that the most frequent time period, for both ADA paratransit and non-ADA service, is from one day in advance up to “more than seven days in advance.” For those respondents who commingle ADA and non-ADA riders, the most frequent response was that riders must reserve “a minimum of one day in advance” for both ADA and non-ADA service (44 respondents, 77%). For the “maximum number of days in advance” for reserving trips, the most common response was “more than seven,” for both ADA and non-ADA service (35 respondents, 66%). • Service Days and Hours Those transit agencies that commingle ADA and non-ADA riders using the same vehicles were asked about differences in service days and hours for their different rider groups: ADA and non-ADA. A total of 61 transit agencies provided a response for weekday service, with 64% indi- cating that the same service hours are used for ADA and non-ADA service. For Saturday service, 54 agencies responded, with 63% citing the same service hours for both services. For Sunday, 41 agencies answered the question, with 66% indicating the same service hours for the two ser- vices. The large majority did not differentiate their service hours by weekday or weekend day. However, the question did not capture the extent to which transit agencies may provide service on different days, depending on whether the service is ADA or the other non-ADA paratransit. Relevant Case Study Observations. Our case study research found transit agencies that mix ADA and non-ADA service have taken various approaches toward using the same or different service policies for their different rider groups. Operations Decision Process 37

• Service Area Of the 15 case study transit agencies that commingled ADA and non-ADA paratransit service and have authority over the non-ADA service, 11 agencies have different service areas for their ADA and non-ADA service. Of these, half reported that they provide ADA paratran- sit service within the required 3⁄4-mile corridor of fixed route service and non-ADA service countywide. The remaining agencies with different service areas for their ADA and non-ADA riders have varying approaches, primarily providing slightly larger service areas for their ADA riders in order to match specific fixed routes that travel outside jurisdictional boundaries. One of the transit agencies with different service areas specifically noted that the differ- ences have caused confusion for the riders. One transit agency that no longer commingles riders noted that even its then small differences in service area for ADA and non-ADA rid- ers generated complaints, in this case, from the non-ADA riders who were not able to access a certain destination (a regional transfer point, located at a shopping area) available only to ADA riders. • Response Time (i.e., Advance Reservation Period) Seven of the case study transit agencies that commingled non-ADA service with their ADA paratransit had different advance reservation time periods for their riders. Typically, the ADA riders have somewhat greater opportunity to book trips, for example, the ability to book Mon- day trips on the preceding Sunday to ensure compliance with ADA requirements, while non- ADA riders must book Monday trips by the preceding Friday. The remaining agencies use the same advance reservation hours established for their ADA riders for the non-ADA riders. • Fare Structure Eleven of the case study transit agencies have established different fare structures for their ADA and their non-ADA service, with the remaining using the same structure. Several of the agencies with differing fare structures have adopted specific procedures for operationalizing the differences. One agency quotes the fare to the rider when the rider books his or her trip, so that riders know exactly what must be deposited in the farebox. Another agency requires riders to pay by ticket and provides tickets of varying colors to the riders, with the color depending on the particular type of rider. ADA riders, for example, have tickets of a certain color, and non-ADA riders, sponsored by various agencies, have tickets of different colors. • Service Days and Hours Ten of the case study transit agencies operate different service hours/days for their ADA and non-ADA service, although the differences tended to be minor. For example, one of the larger commingling agencies provides service from 6 a.m. to 12 midnight daily. Trips for ADA riders only will be provided outside these hours if there is comparable fixed route service at those times and only for trips where the origin and destination are within the 3⁄4-mile ADA fixed route cor- ridor. The remaining agencies operate the same hours/days for all their paratransit service. • Capacity Constraints The ADA service criterion related to capacity constraints is a key area that transit agencies must consider when operationalizing their policies. Trip denials, for example, were not addressed in the survey of transit agencies but were discussed during the case study research. This in-depth research found several examples where the commingling transit agency turned down trip requests for their non-ADA riders when capacity was a problem. The specifics var- ied by the individual case study transit agencies but, in at least one case, the denials of non- ADA riders became a lightening rod that ultimately undermined the commingled service. It is critically important for commingling transit agencies to monitor their capacity and take action when capacity begins to become a problem. Such action should include, as a start, dis- cussions with the transit agency governing body so that the policymakers are made aware of the situation. 38 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

Cost Allocation Policies and Procedures Proper cost allocation policies and procedures are particularly important when commingling paratransit riders to ensure the programs pay their fair share and that programs are not inadver- tently subsidizing the cost of service being provided for other riders. The more similar the oper- ating policies and procedures are for each rider group, the easier this is to do. Over the years it has been sometimes difficult, particularly for human service agencies, to iden- tify the full cost of providing service often because staff and resources are shared within the agency or because some in-kind services are performed and never show up as an actual expense. As a result, agencies are sometimes surprised to find out the full cost of providing paratransit trips. A resource to help agencies with cost allocation titled “Transportation by the Numbers: Getting the Most out of Human Service Transportation, Understanding Costs, Benefits, and Opportu- nities” is available on-line and in print from Easter Seals Project ACTION (ESPA, 2007). The document is a workbook with an accompanying spreadsheet to help agencies—in particular human service agencies—determine their full costs of operating transit service. The workbook is designed to help human service organizations identify expenses related to the provision of transportation services. Understanding the true cost of providing transportation will help to facilitate the discussions needed when human service agencies and transit agencies are looking to consolidate services. The workbook also includes a discussion of contracting for transporta- tion services including a discussion of billing rate structures and a discussion of policies and pro- cedures that should be included in contract negotiations. When looking at cost allocation, be sure to identify the following: • Calculate fixed costs—items that must be covered irrespective of the number of trips, includ- ing facility rent and utilities, costs for management labor. • Calculate variable cost of providing service—operating staff labor, particularly drivers, addi- tional vehicle mileage costs including fuel and maintenance, etc. • Consider the marginal costs of adding service, especially when that added service comes from non-ADA service requirements or demands. • Determine cost allocation/cost sharing policies and impacts. • Estimate a reasonable level of productivity (i.e., number of trips per revenue hour). • Develop detailed billing procedures for non-ADA program trips. • Determine whether there are special requirements for non-ADA riders that cost extra (e.g., excessive administrative expenses related to eligibility verification, special training required for personnel or other activities that are atypical to transit-based services). • Negotiate contracts with HST agencies. Discussion A careful review of the required standard operating procedures and any added costs that may be incurred for special procedures required by a particular service is one component of the final contract to be negotiated to cover the cost of non-ADA riders. It also helps to build in a periodic review of the assumptions that have gone into the cost allocation process in case things have changed over time. For example, suppose an agreement was made to serve riders from an agency that projected 10% of its riders would require accessible boarding via lift- or ramp-equipped vehicles. That mix of passengers may appeal to an agency that has an average wheelchair boarding rate of something like 25% or 30%, and an assumption is made that the current fleet will be sufficient to serve that mix of passengers. If, however, it turns out that the non-ADA agency’s riders who use wheel- chairs is actually 30%, it may mean that there are not enough wheelchair securements in service at one time to accommodate all the trip requests, especially during peak hours in the morning and afternoon. In that case, the transit agency may need to acquire additional vehicles to avoid Operations Decision Process 39

potential service denials for its ADA riders. The cost of the new vehicles will need to be added to the mix (i.e., marginal costs) and an adjustment may be necessary. Another factor to consider when contracting with human service agencies is whether addi- tional service requirements are necessary. If, for example, an agency requires the transit provider to have a van aide on-board when transporting its clients, the additional costs associated with that aide must be recognized, including the labor costs for the aide and the additional cost of picking up the van aide. Special reporting needs and the cost to implement and manage the monthly reporting requirements also need to be considered and factored into the cost allocation. The three most common measures for allocating transportation costs among different pro- grams are • Cost per trip, • Cost per mile, and • Cost per hour. Cost per trip. The cost per trip is essentially an average cost computed by dividing the total cost of providing all trips by the number of trips, either projected or actual. For example, if it costs $1 million to provide 100,000 trips, each agency purchasing trips would be charged $10 per trip ($1 million divided by 10,000 trips). Using a straight average cost is the easiest cost allocation to understand and implement. If a human service agency’s clientele is taking 25,000 trips out of 100,000 trips, the agency will pay 25% of the cost of service. This method works best if the service area, days, and times of service are fairly consistent across all transportation services being provided. When using this method, one service factor to be aware of is the trip lengths taken by various passengers. If an agency has trips that are shorter than other agency or ADA trips, the agency may feel that it is paying more than its fair share for service. If, on the other hand, an agency has longer trip lengths than other commingling agencies or the ADA services, the transit agency may feel the non-ADA agency is not paying a fair share of costs associated with the service. It is important that some assessment and comparison of trip lengths be made when developing a cost allocation procedure. Cost per mile. The cost per mile is also an average cost computed by dividing total costs by projected or actual number of miles driven. If it costs $1 million to provide service and it is esti- mated that vehicles will travel 500,000 miles the rate would be $2 per mile. This method works well if clients of a human service agency have exclusive use of a vehicle for a specific period of time. This cost allocation method becomes more complicated when riders from more than one organization are traveling on the vehicle at the same time, which is often the case for paratran- sit services. When rides are shared, a question arises as to how the shared time on the vehicle is to be billed to each agency. Are costs to be shared among organizations? If so, how are they shared? Or does the transit agency record how many miles each passenger traveled while shar- ing the vehicle? Whatever the answer, additional data collection and recordkeeping are needed by the transit agency. Also to be considered is how the cost of deadheading (garage to first pick up and last drop off to garage) is paid for by the participating agencies. Cost per hour. The cost per hour is calculated in the same manner as cost per mile except that the denominator in the unit cost calculation is hours instead of miles. Like cost per mile, this method works well if an agency has exclusive use of a vehicle for a specific period of time. This method also raises the same issues and questions about shared time on the vehicle and the issue of who pays for deadhead time. As with cost per mile, this method will likely require addi- tional effort and recordkeeping effort on the part of the transit agency. It is important to understand that these three methods of cost allocation described may be the most common ones used, but are not the only ones. A transit agency may decide to use a com- 40 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

bination of the methods described or use a different unit to allocate costs. When determining what method of cost allocation to use, the transit agency should consider the effort and record- keeping required to adequately implement a cost allocation process. The advantages and disad- vantages of each suggested cost allocation method need to be weighed. C. Identify Reporting Requirements and Assess Technology Needs When developing protocols for commingling riders, it is especially important to ensure com- prehensive data capture that reflects all the required elements and rider types represented in the system. Each funding agency as well as the transit agency usually has its own reporting require- ments and proper data are needed to substantiate invoices, provide statistical reporting, and monitor performance. The source of the data may either be reported manually (e.g., from paper driver manifests, scheduling and dispatch logs, and similar sources) or captured electronically from transportation operations software. Paratransit Reporting There are three main types of reporting: • Service delivery statistics • Performance statistics • Billing and invoicing statistics All three are inter-related and depend on capturing valid service delivery statistics including number of trips, revenue miles, revenue hours, origin/destination locations, no-shows, missed trips, cancellations, scheduled/actual arrival and departure times at the pick-up and drop-off locations, and other data elements that reflect service on the street. Such service delivery statis- tics are used to generate a variety of reports, including annual National Transit Database (NTD) reporting and are the source data used for performance monitoring and billing/invoicing. Performance statistics use the base data collected by service delivery statistics to calculate outcomes, which are measured against the service policies that have been set for on-time performance, productivity, travel time, and the like. Finally, billing and invoicing statistics are derived from the service delivery statistics, as well as information from billing codes attached to each trip (i.e., funding sources such as Medicaid, Title III or transit agency funds for ADA service). Although ADA paratransit does not require documentation of trip type or individual service usage by individuals, that information may be required by some funding agencies for invoicing purposes. Other areas to incorporate into performance reporting include eligibility determination doc- umentation, no-shows and late cancellation information, telephone call center performance, and maintenance performance. For example, a tracking system should be developed to ensure adher- ence to the 21-day rule for reviewing completed ADA paratransit applications. Specific informa- tion about no-shows and late cancellations is needed to review riders’ adherence to any estab- lished policy on no-shows/late cancels and then to document to riders who may fail to adhere to those policies with a pattern or practice of no-shows and late cancels. To establish any pattern or practice, detailed data are needed. Any appeals for eligibility denials or no-show suspensions must also be tracked. Complaints should be kept in a central file, preferably electronically. It is important to track denials and no-shows by ADA versus non-ADA riders. Complaints should also be distinguished between the two rider types as well. Operations Decision Process 41

The collection and assessment of performance statistics are necessary to ensure compliance with the ADA but doing so is also just good practice to ensure that service is being operated effi- ciently and effectively. Technology as a Tool Advancements in technology have enhanced the ability of paratransit providers to coordi- nate different transportation programs, and the federal government and many state govern- ments have funded projects to continue the advances. For example, Mobility Services for All Americans (MSAA), which is an ongoing project sponsored by the U.S. DOT’s ITS Joint Program Office, is highlighting the use of technology as a tool to assist with coordination efforts, includ- ing commingling ADA and non-ADA riders. The initiative identifies many technologies that may be beneficial for this type of application including the following two categories of software (SAIC 2005): • “Transportation operations software” [e.g., reservations, scheduling, and dispatching soft- ware, often including geographic information systems (GIS)] • “Cost sharing, billing, and reporting software” (e.g., automated billing linked to reconciled trip status) The two types of software are supported by other software and hardware applications includ- ing automatic call distribution (ACD) systems, automatic vehicle location (AVL), electronic fare payment, Advanced Traveler Information Systems (e.g., kiosks and Internet-based services), along with GIS, and other emerging technologies. Technology Interface Effective use of paratransit technology should begin with an assessment of data needs and reporting needs, which then leads to an assessment of technology needs. The technology assess- ment is straightforward and should include the following: • Analyzing what technology is currently available and being used in the industry • Establishing what technology is needed to manage commingled service • Determining whether and what new technologies (or technology enhancements) are desirable The technology needs assessment should describe the existing systems, the anticipated enhance- ments or new systems needed, and an estimate of cost, called a Systems Implementation Plan (SIP). Included in the estimate of cost is not only the cost of acquisition, but the operating and maintenance costs for the various technologies selected. The SIP is not only an assessment of the additional hardware and/or software required and the cost of procurement. It should also include an assessment of the impact on current personnel and any additional personnel or skills needed to implement and maintain the technology. For example, the implementation of new technology may require the hiring of a systems administrator or database administrator. The assessment of technology needs should also include identifying data to be collected and required report formats. Once a clear understanding of the data to be collected and required report formats are obtained, the transit agency can complete the assessment of any changes needed to current technology and make the necessary revisions to current technology. When the technology assessment is complete, the agency can then develop specific procedures for report- ing and revise current report formats or create new report formats, if necessary. A summary of the factors to consider includes the following: • Ascertain program reporting requirements • Review non-ADA program requirements in terms of standards set in previous section 42 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

• Develop reporting procedures • Establish reporting format and protocols • Assess technology requirements including the following: – Telephone system capability – Reservations/scheduling software and hardware – Accounting system – Two-way radios – Mobile data terminals (MDTs) – Fare payment and collection including smart cards and other cashless payment systems • Procure needed technology • Develop detailed reporting policies and procedures It should be remembered that technology is only a tool; it is not a substitute for sound decision- making and staff expertise. There is no substitute for a well-thought-out approach to providing service and monitoring performance. In addition to technology needs, a staffing assessment must also be performed to ensure that there are enough people employed to support the work at hand. Adding commingled service may also mean adding call center staff and telephone lines. If separate telephone lines will be needed for different programs, there may be a need to produce reports from the telephone system showing calls to the various lines. Discussion Not surprisingly, a large percentage of survey respondents indicated that they use some form of technology to manage their programs. The majority of the responses indicated that they use paratransit scheduling and dispatching software, AVL, and MDTs or mobile data computers (MDCs) to manage service. Table 2-1 shows the responses to the project’s survey question on the use of technology. The majority (89%) of commingled systems reported using computerized scheduling and dis- patching software; 100% of systems that provided ADA and non-ADA paratransit service using different vehicles reported using computerized scheduling and dispatching software. Almost half (48%) of commingled systems use MDCs/MDTs, 42% reported using AVL, and 25% used elec- tronic recordkeeping and billing. In contrast, for systems that are not commingled, 67% use MDCs/MDTs and AVL; however, the number of respondents is very low. During the case study interviews, use of technology was explored. The large majority of tran- sit agencies participating in the case study research use some form of advanced technology, most Operations Decision Process 43 Technology ADA + Other Same Vehicles N=52 ADA + Other Separate Vehicles N=9 Scheduling and dispatching software 89% 100% Mobile data terminals/computers 48% 67% Automatic vehicle locator 42% 67% Electronic recordkeeping and billing 25% 0% Interactive voice recognition 0% 22% Internet access for passengers for scheduling 6% 11% Electronic fare payment 2% 11.1% None 8% 0% Other 17% 22% Table 2-1. Technologies used for paratransit service.

commonly reservations, scheduling, and dispatching software, which also was used to generate billing statistics, although this was not always directly connected through the software’s pro- gramming. The one notable exception is ACCESS Services of Pittsburgh, Pennsylvania. ACCESS operates as a decentralized brokerage, subcontracting with eight carriers, and only one of the eight contracted carriers uses technology to provide service. During the interviews, case study agencies were also asked about their use of technology for reporting. Most of the sites indicated that they were using software for reporting purposes. The Regional Transportation Program (RTP) in Portland, Maine, indicated that its use of paratran- sit scheduling and dispatching software is beneficial for categorizing trips by funding source or program and, therefore, has been helpful in the billing process. However, RTP noted that the use of technology has not helped with the scheduling of rides as much as was anticipated. PARTA in Kent, Ohio, also found that the software enhanced the ability to commingle trips by accurately tracking the individual trips, which then enabled the agency to properly account for trips to its funding source. Other sites noted some problems using the technology for reporting purposes. Ottumwa Transit Authority (OTA) indicated it uses software for collecting the information necessary for required state and NTD reporting. However, OTA also reported that it was not able to use the software directly to generate reports and invoices for the various funding sources. Waukesha Metro Transit also indicated that data reporting by its non-profit provider has been problem- atic, in particular because the NTD definitions do not address commingled service. While not a “technology” problem per se, Waukesha Metro Transit believes that the introduction of MDC technology would help to resolve this issue. Transit Authority of River City (TARC) in Louisville, Kentucky, has a state-of-the-art reser- vations/scheduling/dispatch system and all authority-owned vehicles are equipped with MDTs with AVL. It was anticipated that this technology would be useful in tracking the riders by various programs, although TARC has had problems using the system to maintain the recordkeeping relative to rides by funding source. The issues raised with regard to reporting problems seems to indicate that it is important to understand the reporting needs for all types of service. The research findings also suggest the need to account for and ensure that available or future technology has the capability of captur- ing and reporting the necessary data. D. Develop Marketing, Education, and Monitoring Programs Now that the transit agency has progressed through the initial planning phase, established the service operating policies and procedures, and moved to implementation, it is time to market the program and, once service begins, to perform ongoing monitoring to ensure that the pro- gram is providing service in accordance with the stated performance standards. Marketing and Education Program Transit agencies sometimes express concerns about “marketing” and “promoting” the use of paratransit services, which are expensive on a per trip basis when compared with fixed route, but agencies will acknowledge that it is important to educate riders and stakeholders about the avail- ability of the service, who is eligible to use it for what types of trips, and how to use the service. Education is particularly important for commingled systems where it may be confusing for riders 44 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

and potential riders to understand service eligibility and operational differences when traveling with others in a commingled, shared ride system. It is also important to thoroughly educate and train transit agency staff that will be providing the service: everyone from vehicle operators to call center staff, customer service, and managers. It is especially important for staff to understand the different program eligibility requirements to understand why service is provided as it is. For instance, vehicle operators at one transit agency said it was difficult to explain to riders why one particular rider who was funded by the JARC program was able to travel outside the ADA paratransit service area when others riding on the same vehicle could not travel to the same destination. Similarly, riders will notice when other passengers are not asked to pay fares and may question the vehicle operator about why the rider was given a “free ride.” Such questions should be anticipated and included in the vehicle operator training sessions. Discussion Traditional written marketing methods were used by most of the transit agencies interviewed in the research project, which often included short descriptive brochures highlighting service and providing contact information and specifics about how to schedule a trip. Some agencies pre- pared lengthier user guides with more detailed information about the program. More transit agencies are also now relying on their own Internet sites to post information about their services, along with Twitter, YouTube, and other social networks—a recent phenom- enon for marketing transit services. Pace in suburban Chicago, which manages one of the largest ADA paratransit and Dial-a-Ride networks in the country, makes extensive use of its website to provide information about the various paratransit programs that are available. Transit agencies that commingle ADA and non-ADA services should consider creating both general overview materials as well as materials that are targeted to the specific commingled rider groups. All riders may not need to have the specifics of every commingled service, so a lengthy user guide with information about all the programs may be too cumbersome as well as expen- sive to produce. It may be appropriate to have a short “overview” piece with general informa- tion, which also indicates that different services are provided, and separate marketing pieces tar- geted to the individual commingled groups. The transit agency may also need to consider the amount of information that is needed depending on the different commingled rider groups. If the service is more public—obviously the ADA paratransit service is an example—then more detailed information may be appropriate. But if the transit agency has a small contract to pro- vide service to a small group of sponsored riders traveling to and from a senior center program, for example, then less marketing information may be required for the small group of riders. In Olympia, Washington, Intercity Transit operates commingled paratransit services and has separate marketing and public information materials for the individual programs that are com- mingled, as the programs have differing service requirements, policies, and procedures. However, even if detailed descriptions of the services offered on the commingled system are not provided to all riders, it may be helpful to list the various commingled programs so that riders will know about other programs that they might also be able to use. It should go without saying that any written materials should also be made available in acces- sible formats such as large print, audiotape, Braille, or electronic files that can be read by screen readers. Education materials should be provided in various formats including written materials (e.g., brochures, newsletters, and bulletins), presentations at meetings and activity fairs, through written and audio public service announcements, and other efforts. Some agencies have found that marketing and “branding” services help to explain the differences for passengers and the Operations Decision Process 45

general public. They also found that education efforts cannot be a one-time event—for exam- ple, when riders begin using the program—but must be continual and sustained over time. Monitoring Monitoring is essential for any paratransit service but critically important for ADA paratran- sit. A commingled ADA and non-ADA paratransit program must establish a comprehensive monitoring program to collect operational data and analyze that data on a routine basis to track trends, review performance, and watch for unexpected system usage or changes. When monitoring service, it is important to track performance of the overall paratransit sys- tem, as well as track the individual performance of the commingled components. As has been stated throughout this report, it is critical to track ADA paratransit performance and to flag any issues that may arise relating to below par service performance. Remember ADA paratransit is a civil rights program that must afford unrestricted access to service for eligible trips. Transit agen- cies that commingle services must be sure to monitor the following six key ADA service criteria: • Service area—sometimes fixed route service areas change; do not forget to make adjustments as needed • Service days/hours—service may need to be adjusted if fixed route service changes. • Fares • Trip purpose • Service availability • Capacity constraints—service may not be constrained based on capacity constraints [examples of capacity constraints are substantial trip denials, substantial untimely pick-ups, substantial missed trips, or substantial long trips (compared with fixed route service)] Capacity constraints is perhaps the most critical ADA service criterion to monitor. Ridership patterns and increasing demand from riders may impact or degrade service performance. In such cases, transit agencies must make adjustments to ensure there are no capacity constraints. If on-time performance decreases, for example, or travel times begin to lengthen, it may be that the system is at or over capacity and some action will be needed to relieve the pressure. Additional capacity may be needed, or other actions need to be considered to improve service performance. If service performance remains sub-standard, the transit agency may need to consider limit- ing service for non-ADA riders. Keep in mind, however, that the ADA does not require perfec- tion. But if a pattern or practice of denying trips, providing long ride times, making late pickups and/or drop-offs are noted, they must be corrected. Beyond the six ADA criteria, transit agencies should monitor and evaluate service performance through other efforts and assess the different individual services that are commingled to look for any performance differences between the commingled rider groups that merit additional attention. These additional efforts and operational issues to review may include the following: • Customer comment/complaints—establishing a customer comment process so that riders, their caregivers, and other stakeholders can provide feedback (either compliments or complaints) to the transit agency. • Driver wait time—measuring whether the vehicle operator waited the appropriate amount of time and at the correct location before requesting a rider be marked as no show. • No show/late cancel policy with consequences—establishing a clear, measurable, and enforceable no show/late cancel policy with appropriate consequences. • Agency/program specific policies—monitoring policies such as service only to a specific group of clients (e.g., age, income, or residence); or for specific trips (e.g., medical, senior center, or jobs). 46 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

It also is important to monitor the performance of all trip categories provided individually and in the aggregate. If, for example, the transit agency is under contract to a senior center to provide service for that center’s participants, then it is still expected that the transit agency’s com- mingled service will meet the agreed-upon service level. Group subscription trips are one area to watch because trips attempting to serve larger groups of people on a demand response basis can become excessively long if too many riders are grouped on one vehicle at the same time. Procedures and protocols should be monitored at least monthly. Decide whether to review all the trips provided or a representative sample of trips, depending on the number of trips pro- vided. The review should include whether or not the six ADA criteria and other relevant service criteria are being met. ADA requirements are a priority, so if adjustments to policies and service provisions are needed to ensure adequate service performance, the adjustments for ADA purposes must come first. Following this, other service adjustments can be made. System policies and performance measures should be reviewed at least annually and be revised and updated as needed. Finally, monitoring data and information can inform the transit agency’s service planning process. Information gathered and trends that are tracked through service monitoring can be very beneficial for supporting and informing planning decisions as well as providing realistic esti- mates of service growth or patterns of change. Operations Decision Process 47