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

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Operations Decision Process 35 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)

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36 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders 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)

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Operations Decision Process 37 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.

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38 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders 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.

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Operations Decision Process 39 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

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