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32 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders 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

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Operations Decision Process 33 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