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SECTION 3 Lessons Learned This research revealed numerous lessons learned from transit agencies that have opted to commingle or not to commingle their ADA paratransit riders with other non-ADA paratransit riders. Among the most common lessons learned were the following: There is no one "right" answer. First and foremost, it should be remembered that there is no one right answer and a decision not to commingle may be just as valid as a decision to commingle. ADA regulatory requirements must be met. ADA is civil rights legislation. As such, the U.S. DOT regulatory requirements for ADA paratransit service must be met, even if that negatively affects service for other non-ADA riders. ADA paratransit service must be provided for any trip purpose and no trip purpose may be prioritized over another. There may not be a pattern or practice of trip denials for eligible ADA paratransit trips. These requirements and others can sometimes conflict with trip requests from non-ADA riders. There's no such thing as a free ride. Be careful about well-intentioned efforts to extend service to non-ADA riders who are not supported by an identified or adequate source of funding. Where commingling is successful, funding for expanded paratransit service is available. Although this point may seem obvious, the case study research found that the sources of funding for non-ADA riders varied for agencies that commingle, but the key was to ensure that adequate and sustainable funding is available to support service for the non-ADA riders. When funding becomes problematic, is cut significantly, or is withdrawn, commingling becomes difficult, if not impossible, to sustain. State and local conditions matter. The factors that enter into the decision whether or not to commingle ADA and non-ADA riders vary locally and often are dependent on (a) specific state and local regulatory requirements and ordinances; (b) recognition of the compatibility of rider groups to be served by the commingled program; (c) the availability of adequate fund- ing to sustain the service; (d) an identification of appropriate cost allocation strategies among participating program sponsors; and (e) other specific local resources and conditions that may affect the success of the local effort. Florida is an example of a state with a long-standing history of coordinating and commingling service for persons defined as transportation disadvantaged. In addition to coordinated planning and service provision, the Florida Commission for the Transportation Disadvantaged provides funds through its Transportation Disadvantaged Trust Fund. Some areas may find commingling to be inherently easier than others. Transit agencies in small urban and rural settings generally seem to have found it easier to commingle services, where there may be a history of coordination given scarce local resources. Similarly, as was the case for Pittsburgh, systems with paratransit programs that predate the ADA seem more likely to be agencies that commingle, adding the ADA service to their existing mix of specialized and human service transportation. Finally, it generally appears that transit agencies without 48

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Lessons Learned 49 a history of providing paratransit service before adoption of the ADA have tended to shy away from introducing non-ADA paratransit into the ADA paratransit program. Planning is key. Ideally, planning should commence at the very beginning as part of a formal process to assess the pros and cons of commingling and to develop strategies for success. Even if a "decision" to commingle was already made as a result of political or regulatory processes, it is still important for the transit agency staff to identify key aspects of the service to be provided, to work through any potential obstacles to commingling, to develop contingency plans, and to ensure that adequate resources and adequate funding are available to sustain service. Any potential obstacles should be identified and resolved prior to implementing service. Be flexible. While planning is important, it is also important to understand that even the best plans cannot account for all contingencies. Assumptions made during planning may not be entirely correct and/or circumstances may change. Transit agencies should be prepared to be flexible going forward and strive to find solutions that make sense for their area. Determining rider eligibility is critical. An important aspect of a commingled system is to identify individual rider's eligibility for each of the various services offered as part of a commingled system. This effort is important both to ensure that the proper agency is billed for the cost of the trip and to ensure that riders are getting the appropriate level of service based on their program eligibility (e.g., ADA paratransit, Medicaid Non-Emergency Medical Transportation, Title III of the OAA, and others). ADA paratransit service standards are often higher than other program standards. It is generally recognized throughout the transit industry that even the minimum ADA paratransit service criteria often exceed the service standards for other programs such as Medicaid. As a result, the cost of commingled service may in fact increase overall, as it is common for the ADA service standards to be applied to other riders in a commingled system in order to make operating policies and procedures consistent. Ongoing performance monitoring is a must. Service standards should be set and measured at regular intervals to ensure that programmatic requirements are being met, particularly with respect to ADA regulatory compliance. Technology is a useful tool. Recent advances in technology allow transit agencies to better serve their customers in a variety of ways from reserving, scheduling, and dispatching trips, to recordkeeping and performance monitoring. Technology and electronic fare media are especially helpful for accounting for trip-making by individual riders and collecting fares that may vary by passenger type. Technology can also assist with real-time and retrospective performance monitoring to ensure that service standards are being met for on-time performance, ride times, and other important service parameters. Educate board members and other policymakers. Many transit agencies mentioned the importance of educating their boards and other policymakers about the nature of commingled services, regulatory requirements, operating practices, funding, and program performance. An educated board can more readily understand and support the transit agency when issues arise, particularly related to funding, programmatic differences, and service provision. Educate transit agency staff. It is important that everyone involved in the commingled program understands how it is organized, how eligibility is determined for various program sponsors to ensure riders receive the appropriate service and pay the appropriate fare, and how the funding sources are structured to ensure accurate and appropriate billing and financial reporting. Educate riders. An equally important aspect is to educate riders, their families and caregivers, and sponsoring agencies about the services offered by the commingled system and why there may be variations. This is especially important when there are variations in service levels offered (e.g., service area or service hours), fares, and other aspects of day-to-day service delivery. Some agencies have found that marketing and branding the different services help to explain the differences for passengers and the general public. They also found that education efforts cannot be a one-time event, but must be continual and sustained over time. Education materials

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50 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders also need to be provided in various formats including written materials (brochures, newsletters, updates), presentations at meetings and activity fairs, through written and audio public service announcements, and other efforts. Manage demand. One issue that eluded a consensus lesson was what to do if there is rapid growth in ridership, making it difficult to meet the demand for ADA and non-ADA riders, keeping in mind the requirement to serve all eligible ADA paratransit trips. To address paratransit demand, transit agency managers are advised to be proactive, to control elements that can be controlled, and to acknowledge those elements that may be out of the control of the transit agency, such as population growth, demographics of aging, and so on. By being proactive and monitoring service and market trends, growth-related issues may be spotted early and brought to the attention of policymakers and funding agencies before service deteriorates. For example, while transit agencies are required to provide un- constrained ADA paratransit service and not to exhibit a pattern or practice of trip denials, it is understood that from time to time trips may be denied during unexpected peaks in demand. However, having said that, FTA expects and requires that transit agencies plan for future growth through the budgeting process and make funding adjustments to stay compliant with the regulations. An obvious starting point is to be sure that the eligible riders are properly screened for both ADA and non-ADA services, keeping in mind that ADA paratransit service should be viewed as a safety net for passengers who are unable to use fixed route service for some or all of their trips because of the nature of their disability. It is not intended for use by riders who are able to use fixed route, nor is it intended to be a comprehensive system of transportation that meets all of the travel needs of persons with disabilities. By practicing proper eligibility determination--particularly from the start--the transit agency can help to curb unnecessary growth. Additionally, it is mutually beneficial to encourage use of fixed route, shuttles, and other flexible routing that will meet rider needs and that will be more cost-effective as measured by cost per trip than paratransit. Allocate costs and invoice properly. It is also important to work with funding agencies on an ongoing basis to ensure that all costs are properly allocated among the funding partners. It is also important to ensure that the funding sources are being properly invoiced for trips they sponsor and that riders who are eligible for multiple programs have trips assigned appropriately for invoicing purposes.