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BACKGROUND
This Resource Guide for Commingling ADA and Non-ADA Paratransit Riders was prepared
as part of TCRP Project B-34, funded by the FTA and was conducted through the TCRP, which
is administered by the TRB of the National Academies. The primary purpose of the Resource
Guide is to provide practical planning and operating assistance to fixed route transit agencies
that are deciding whether or not to commingle their ADA eligible paratransit riders with "other"
paratransit riders and, if so, how to implement the practice.
Commingling ADA and non-ADA riders is a newly coined term for a practice that has been
operating in many communities since transit agencies began operating paratransit services required
by the ADA. For this project, "commingling" is defined as "routinely transporting ADA eligible
paratransit riders with `other' non-ADA paratransit riders on the same vehicles at the same time."
The following are examples of other paratransit riders who might be commingled with ADA
paratransit riders:
· Medicaid beneficiaries
· Older adults with transportation service funded by Title III of the Older Americans Act or
other programs
· Job Access and Reverse Commute (JARC) program beneficiaries
· New Freedom program beneficiaries
· Other individuals with disabilities or older adults who participate in support services, for
example:
Developmentally disabled individuals
Rehabilitation services participants
Human service agency customers
Adult day care program participants
Hospital discharges
Dialysis patients
Children (including Head Start participants)
Most, but not all, of these categories of riders fall under the broad definition of "human service
transportation" or "transportation disadvantaged" individuals. These are described in more
detail below.
Overview
The concept of commingling--although it was not called that--began in the early years of the
ADA as one approach to addressing the anticipated costs of complying with the ADA service
requirements. Besides, it was anticipated that many riders currently being served by existing
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8 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders
specialized transportation programs would be determined to be eligible for the new ADA para-
transit service.
At the time, commingling was referred to as "selling transportation services to non-ADA
eligible riders" and listed as one of a number of "heretical ways to increase revenues and reduce
costs in ADA paratransit services" in a paper written in 1993 (Rosenbloom and Lave 1993).
The authors examined several approaches that transit agencies could use to reduce the cost of
delivering ADA paratransit service or increase revenues for providing the service.
Specifically, their "commingled" approach proposed that transit agencies might obtain additional
revenues by selling paratransit services to human service agencies that wanted transportation for
their clients. The paper notes this approach would not be appropriate in all situations but could be
worthwhile to pursue when the marginal cost of the additional trips for non-ADA riders is less than
the average cost of the transit agency's paratransit trip and where the human service agencies are
interested in purchasing service. The paper qualified the approach by noting that transit agencies
will have to estimate the cost implications of providing the non-ADA service as part of its ADA
paratransit service. This notion of the importance of assessing the cost implications of providing
non-ADA service is one of several lessons learned through this research project.
Since the mid-1990s, there have been many permutations of commingling. According to the
survey of transit agencies conducted late in 2006 as part of this research project, 61% of the transit
agencies indicated that they serve both ADA and non-ADA riders, with just over one-half (53%)
commingling ADA and non-ADA riders on the same vehicles and 8% serving both ADA and
non-ADA riders but using separate vehicles for the two rider groups. The remaining 39% of the
survey respondents indicated that they served only ADA riders, however about one third of this
group (18 respondents) indicated that while they had commingled ADA and non-ADA riders in
the past, they no longer do so. A summary of the survey results is included in Appendix A.
The survey results were somewhat unexpected, given current concerns in the transit industry
about increasing costs for ADA paratransit services. This project's case study research provided the
opportunity to examine the practice of commingling in greater detail and understand the genesis
of commingling and the operational parameters of the practice (see summaries in Appendix B).
Note that for this project, commingling riders on the same vehicles is viewed as distinct from a
transit agency providing paratransit services to ADA eligible and other paratransit riders using sep-
arate vehicles (i.e., perhaps coordinating service but not typically mixing passengers). As directed
by the TCRP B-34 Project panel, the research team focused on transit systems that commingle their
ADA customers with other riders funded by human service agencies and other community pro-
grams, medical services (including non-emergency medical transportation funded by Medicaid),
and other programs that specifically subsidize transportation service for their customers (e.g., JARC
and New Freedom). The research team did not focus on systems that coincidentally mix ADA and
non-ADA riders on the transit agency's vehicles as a result of loosely defined eligibility criteria or
grandfathering of non-ADA eligible riders.
Much has been written over the years about coordinating human service transportation
services and in recent years this topic has become a focal point of the FTA's United We Ride and
Mobility Services for All Americans (MSAA) initiatives. It is not the intent of this project to
repeat the findings from these efforts but to use those resources to help inform decisions about
how and whether to commingle. A summary of relevant resources is included as Appendix C.
The research found three basic factors that seemed to affect decisions regarding whether or
not to commingle:
· Evolution. For a number of transit systems, paratransit service was historically part of the mix of
services that they operated and when the ADA was passed in 1990, the transit system added ADA
paratransit into the paratransit mix of services that it already offered. ACCESS in Pittsburgh
