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

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A literature review was conducted as part of this research project. The objective of the review was to glean insights relevant for the project from existing reports, studies, and published materials. In particular, we were seeking information on practices related to the commingling of ADA and non-ADA (other) paratransit riders. There is a large and growing body of literature on transporta- tion coordination, with recent interest spurred by the federal United We Ride (UWR) initiative. Commingling of paratransit riders is one aspect of coordination; commingling ADA and non-ADA riders using ADA vehicles is a specific type of commingling and the primary focus of this project. In the review, however, we found little discussion that targeted the specific commingling of ADA and non-ADA riders using ADA paratransit vehicles, except in the general context of the desire for expanded coordination of services in order to gain increased capacity, greater economies of scale, or a reduction in the duplication and/or fragmentation of services offered by multiple service providers operating in the same geographic area. Given the large amount of material on coordination, we focused our review on more recent materials and those that might potentially offer relevant information for the study. We grouped the documents into several primary topical areas: • Coordination research • Government documents • Technology tools Table C-1 lists the primary resource documents reviewed and brief summaries of each are provided following the table. Research Documents Burkhardt, Jon E., Koffman, David, and Murray, Gail. TCRP Report 91: Economic Bene- fits of Coordinating Human Services Transportation and Transit Services. Transportation Research Board of the National Academies, Washington, DC, 2003. Summary: As the title states, this TCRP report attempted to identify the economic benefits of coordinating human service transportation and transit services. It quantified the high impact benefit of coordination and providing the most cost-effective transportation services; for example, the cost savings associated with transferring Medicaid paratransit trips to fixed route, which is much cheaper to provide on a cost per trip basis and has the added benefit of permitting program beneficiaries to use transit passes for their other transit trips. The report also documented economic benefits associated with coordinating human service transportation with transit, as well as encouraging human service transportation providers to coordinate among themselves. The report pointed out that not all coordination benefits translate into lower total costs, but that they may result in increased productivity, improved mobility for customers, and overall reductions in cost per trip, allowing for increased ridership. 89 A P P E N D I X C Additional Resources

90 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders Document Title Sponsor/Author Research Documents Economic Benefits of Coordinating Human Services Transportation and Transit Services, 2003. TCRP Report 91/Westat and Nelson\Nygaard Toolkit for Rural Community Coordinated Transportation Services, 2004. TCRP Report 101/Westat et al. Medical Care and Community Transportation: Perfect Together, Community Transportation, Summer 2006. Community Transportation Association of America (CTAA) Transit Agency Participation in Medicaid Transportation Programs, 2006. TCRP Synthesis of Transit Practice 65/KFH Group Coordination Primer: A Guide to Help Your Community Navigate Transportation Coordination, August 2006. Illinois Interagency Committee on Coordinated Transportation Coordinated Human Service Transportation: State Legislative Approaches, January 2005. National Conference of State Legislatures Barriers and Obstacles to Coordination of Public and Human Services Transportation: Final Report and White Paper, 2005. National Consortium on the Coordination of Human Services Transportation/TranSystems Strategies to Increase Coordination of Transportation Services for the Transportation Disadvantaged, 2004. TCRP Report 105/TranSystems et al. Transportation Services for People with Disabilities in Rural and Small Urban Communities, 2006. Easter Seals Project ACTION/TranSystems Government Documents Final Policy Statement on Coordinated Human Service Transportation Planning, October 1, 2006. Federal Interagency Coordinating Council on Access and Mobility (CCAM) Vehicle Resource Sharing, Policy Statement, October 1, 2006. CCAM Framework for Action: Building the Fully Coordinated Transportation System: Self-Assessment Tools for Communities, n.d. CCAM The Current State of Transportation for People with Disabilities in the United States, 2005. National Council on Disability (NCD) Transportation-Disadvantaged Seniors, Efforts to Enhance Senior Mobility Could Benefit from Additional Guidance and Information, GAO-04-971, August 2004. U.S. Government Accountability Office (GAO) Transportation-Disadvantaged Populations: Federal Agencies Are Taking Steps to Assist States and Local Agencies in Coordinating Transportation Services, GAO-04-420R, February 2004. GAO Transportation Disadvantaged Populations: Some Coordination Efforts Among Programs Providing Transportation Services, but Obstacles Persist, GAO-03-697, June 2003. GAO Transportation Coordination: Benefits and Barriers Exist, and Planning Efforts Progress Slowly, GAO/RCED-00-1, October 1999. GAO Technology Solutions Documents Mobility Services for All Americans Phase 2: Foundation Research Final Report, 2005. USDOT Joint Program Office/SAIC et al. ITS Applications for Coordinating and Improving Human Services Transportation, August 2006. USDOT, FHWA-JPO-05-056. Table C-1. Primary resource review items. Relevance to Commingling: Regarding the commingling of ADA and other non-ADA riders, the report included the following: • The largest magnitude of economic benefit described in the report had to do with bus pass programs, which began with Medicaid but could be extended to other customer groups. By transferring passengers from expensive paratransit to fixed route service, transit agencies and human service agencies can save a lot of money, sometimes in the millions of dollars for larger programs. • Because some ADA paratransit customers may also be eligible for human service transportation, if the transit agency provides commingled service, the transit agency can invoice human service providers for eligible trips, helping to manage the demand for and cost of providing non- sponsored ADA trips. Working cooperatively with human service agencies can also reduce the amount of trips that are transferred to ADA service when they could have been paid for by another source. • The report also points out that the transfer of trips from ADA paratransit to human service transportation providers may benefit the transit agency by freeing up ADA resources and also affording customers more personalized service, appropriate to their needs.

Burkhardt, Jon E., et al. TCRP Report 101: Toolkit for Rural Community Coordinated Human Services Transportation and Transit Services. Transportation Research Board of the National Academies, Washington, DC, 2004. Summary: This TCRP report reviewed strategies and practices that are used for coordinat- ing rural transportation services and identified model practices used to coordinate services in rural communities. The report also identified ways to improve coordination, documenting the key factors that help determine whether coordination will be successful or not in sustaining rural public transportation services. Relevance to Commingling: The focus of the report is coordination within rural com- munities, but the issue of coordinating services specifically with ADA paratransit programs include the following: • The report’s planning guidelines note that public transit agencies and specifically their ADA paratransit services should be included in local planning efforts for coordination. • One of the coordination strategies included involves human service agencies providing ADA paratransit services under contract to the transit agency. While the description does not speak to commingling of riders, this might be an option, though the objective of the strategy is to save costs for the transit agency, since the cost structure of human service agencies typically is less than that for transit agencies. • The strategy of “ride sharing” is discussed, where the transit provider would initiate coordinated dispatching communitywide, so that all the vehicles in use would be coordinated and riders from different agencies and funded by different programs would be transported together. The report specifically includes the mixing of ADA paratransit riders with other types of riders in the “ride sharing” strategy as one that has the potential to improve productivity and provide cost savings for the public transit provider, with lower per trip costs for the ADA paratransit service. Medical Care and Community Transportation: Perfect Together, Transportation Magazine, Summer 2006. Published by Community Transportation Association of America (CTAA), Washington, DC. • Summary: This magazine issue focused on the role of community transportation providers in serving transportation needs for non-emergency medical trips (NEMT). Several articles describe the role that community and rural transit systems provide in serving the growing need for NEMT. The issue included a discussion of the LYNX ADA paratransit program in Orlando, Florida, which also provides NEMT service. The general theory expressed throughout the issue is that community transportation is a cost effective way to keep patients healthy and independent. • Relevance to Commingling: Given the large role that Medicaid plays as a funder of special- ized transportation, it is important to assess coordination opportunities that exist with this federal/state program. Particularly in rural and small community areas, transit programs have historically worked with Medicaid, often mixing riders of various programs on their transit services. While this material did not address commingling ADA and non-ADA riders specifically, it did focus on the role that community transportation providers have in coordinating services for their riders. Hosen, Kenneth. I., and Fetting, Elisabeth. TCRP Synthesis of Transit Practice 65: Transit Agency Participation in Medicaid Transportation Programs. Transportation Research Board of the National Academies, Washington, DC, 2006. Summary: This report summarized tasks necessary for a public transit and non-emergency medical transportation (NEMT) partnership to be successful. Medicaid is a very large funding source for transportation across the country. Transportation coordination efforts should examine Medicaid as a potential partner. The report identified and reviewed barriers and Additional Resources 91

actions that can facilitate or hinder coordination with Medicaid at the local level, with a focus on how transit agencies can coordinate their services with Medicaid. Relevance to Commingling: There are a number of examples of ADA paratransit systems that also serve Medicaid transportation. Based on case studies, the synthesis reported a number of findings regarding the coordination of NEMT and ADA paratransit: • Different levels of service are required for NEMT than for ADA paratransit and these levels of service are different in different areas, because some transit agencies provide more than the minimum required ADA paratransit service. • Trying to fit both NEMT and ADA onto one system can be difficult. • Broward County, Florida, and Portland, Oregon, operate ADA and Medicaid transportation in their region, but each service is a separately managed and operated program within the transit organization. Some of the trips are commingled, but not routinely. Broward County recently ended its involvement with NEMT. • There is an issue of who pays for the trip of an ADA paratransit eligible Medicaid participant to travel for a medical need. Is this the responsibility of the state Medicaid agency or the local transit agency? If the Medicaid agency pays, does it pay the regular paratransit fare, the local share of the full cost of the trip, or the full cost? • One transit agency reports that provision of NEMT can cause disruptions with ADA paratransit service for several reasons: in-take process, billing system, customer service, staffing, no-shows, cancellations, and database maintenance. • One state has a 30-minute will-call/return pickup requirement for NEMT requiring that the driver wait with the Medicaid customer, which would be very expensive for an ADA paratransit program to provide. • Findings from case studies suggest that “cost transferring” Medicaid trips onto paratransit, including ADA paratransit, is problematic. This may make transit agencies less likely to want to coordinate with NEMT, including commingling the riders. • Commingling ADA paratransit customers and Medicaid participants can be problematic if the Medicaid participants require transportation to locations outside the paratransit program’s service area. Illinois Interagency Coordination Committee on Transportation (ICCT). Coordination Primer: A Guide to Help Your Community Navigate Transportation Coordination. ICCT Clearinghouse, Macomb, IL, 2006. Summary: The primer was designed to assist in the development of a community transit system and in preparing to secure funding. It was produced for the Illinois Interagency Coordinating Committee on Transportation (ICCT), which was created in 2003 to “address ways to broaden coverage and reduce duplication of transportation services to help disadvan- taged citizens of Illinois get to work, work-related services, and other life sustaining activities for health and well-being.” The primer provided the federal definition of public transportation systems, outlined the steps necessary to implement a transportation system, and gave abbreviated summaries of the types of federal and state funding programs available to transit systems, including federal reimbursement for administrative, operating, and capital costs, and the local or state matching requirements for operating and capital costs. There is also a description of an outline of requirements for the Downstate Operating Assistance Program (DOAP), a funding program for local governments (in Illinois) to support administrative and operating costs of a public transportation system. The ICCT divided the process of coordinating transportation into four specific phases (Phase 1—Transportation Planning Group; Phase 2—Needs and Resources; Phase 3—Action 92 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

Plan; Phase 4—Funding) and provided a list of action items and parties involved for each phase. The primer also provided pre-designed scorecards for each phase to be used to document progress toward each subsequent phase. Phase 1 brings together representatives from many types of service providers to form the Transportation Planning Group, including representatives from human service agencies, medical and healthcare providers, employment and job training agencies, government agencies, senior public officials, employers, community leaders, and others. During Phase 2, the Transportation Planning Group conducts an assessment of needs and inventory of services to determine what services are currently provided, to whom, and on what basis. Using the Framework for Action, a Community Action Plan is developed during Phase 3. The plan includes a clear set of steps; a list of who is responsible for carrying out each step; a timeline for tasks; and a strategy for communication within the group. Phase 4 focuses on the application for and procurement of appropriate funding. Relevance to Commingling: Though the primer did not specifically address the issue of com- mingling passengers, the steps for each phase highlighted the need for coordination. Several of the barriers to coordination that were cited are also applicable to commingling of riders: • Reluctance to change transportation routes and/or schedules • Regulatory or legislative restrictions on use of funds • Perceived incompatibility among diverse passengers • Organization and staffing problems • Perceived or actual regulatory barriers on vehicle use and operation Sundeen, M., Reed, J., and Savage, M. Coordinated Human Services Transportation: State Legislative Approaches. National Conference of State Legislatures, Washington, DC, January 2005. Summary: This report, produced for the National Consortium on the Coordination of Human Services Transportation, focused on state-level coordination of human transportation services, with an emphasis on state legislation. The report is intended to serve as a resource to help states and their legislators assess different coordination approaches and determine an appropriate course of action for their own jurisdiction. The report cited considerable activity among states regarding transportation coordination, and found some success through a variety of approaches. Among the various approaches employed, 34 states have statutes with coordination requirements or authorization for coordination. Of those, 21 states require coordination of human service transportation, approached in varying ways. Two states require consolidation through legislative action, while other states have encouraged coordination through local efforts, either requiring or supporting coordination. The report also found that coordination can happen in the absence of any state effort. Wyoming, for example, has no state statute or executive order regarding coordination, but the local transit authority in Sweetwater County operates a single, coordinated demand response program that serves a wide range of riders, using technology to help manage services. Relevance to Commingling Issue: The report does not specifically deal with the issue of commingling, except to the extent that it is implied in some states’ approach to coordination. The report also finds that the effectiveness of state legislatively mandated coordination is unclear. Additional Resources 93

TranSystems. Barriers and Obstacles to Coordination of Public and Human Services Transportation: Final Report and White Paper. National Consortium on the Coordination of Human Services Transportation, January 2005. Summary: The National Consortium on the Coordination of Human Services Trans- portation is a group of non-profit organizations representing public and private transportation providers, human services agencies, units of government, and advocacy organizations. To fulfill its mission of promoting coordination efforts between organizations that are concerned with ensuring mobility for transportation disadvantaged individuals, the Consortium conducts research, disseminates information, and provides educational opportunities and technical assistance on the topic of coordinating human services transportation. As one of its activities, the Consortium designed a research project to explore barriers to coordination in detail. In addition to a review of the literature regarding coordination obstacles, project tasks included outreach to Consortium members and others and iden- tification of case study examples that illustrate effective strategies for addressing coordi- nation barriers. The project’s final products included a report and white paper, which document the research and outreach that was conducted and reflect the findings and con- clusions that resulted. After summarizing the coordination barriers identified through research and con- sultation with transportation and human service organizations, the report and white paper suggested actions or policy changes for federal agencies, Congress, and other gov- ernmental entities that will reduce or eliminate common obstacles. Recognizing the fact that a federal action may not be the only or most effective response to some coordina- tion barriers, the report and white paper also identified approaches and strategies that have been successfully employed at the state, regional, or local levels to address specific barriers. Relevance to Commingling: Several of the barriers to coordination that were identified throughout the course of this project relate to commingling passengers. Each barrier is described below. • Shared use of resources (categorized as a Communication Barrier) Much of the doubt that human services and transportation organizations may have about coordinating transportation services centers on the combined use of vehicles and other resources. There is ongoing uncertainty about the use of federally funded vehicles, facilities, and other resources to provide transportation to riders other than those in the customer group that the vehicles were acquired to serve, and about mixing the resources and participants associated with different programs. Proposed solutions to this barrier included the following: – Communicating federal or state policies to entities at the state or local levels – Coordination among technical assistance teams • Coordination partners are unsure about how to allocate the costs of a coordinated service or system among the participating organizations and/or funding programs (categorized as a Funding Barrier) Federal legislation and regulations are often vague about how vehicles and other resources may be used to serve more than the customer group or type of trip for which they were originally obtained, and how costs for shared use are to be divided among programs or agencies. State/ local organizations, therefore, are often unaware of the options they have. For example, typical questions a recipient of federal funds may have include the following: Who decides, and how, if the shared use interferes with the program or service that was originally funded? Is the sharing 94 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

of resources allowable only among programs administered by the same federal agency, or also among multiple federal agencies or multiple grantees? If one organization makes transportation services available to another, what elements should the rates it sets for its services include? Is it able to make a profit on its services? It appears that the real barrier regarding cost allocation is that organizations do not have enough information about what is allowable at the federal level, or about the mechanics of cost allocation. • Cost allocation among federal agencies or programs requires data that can be burdensome to collect (categorized as an Information/Data Barrier) The allocation of the costs of a coordinated service or system among participants and their funding sources requires human services agencies and transportation providers to track information about riders, trips (date, time, origin/destination, mileage, purpose), and expenses. Collecting and compiling such information can become onerous or prohibitively difficult, especially if – The basis for reimbursement varies among the agencies purchasing service from the provider (per trip, per vehicle mile or per vehicle hour, for example). – Participants of different programs are transported together in the same vehicle. – Participants are eligible for the transportation services of more than one agency or program. Proposed solutions to these two barriers included the following actions: – Promote Intelligent Transportation Systems (ITS) capabilities as a way to track clients and associated transportation costs through conferences, brochures, and other public media – Clarify federal interagency guidance on cost-sharing – Coordination among technical assistance teams TranSystems et al. TCRP Report 105: Strategies to Increase Coordination of Transportation Services for the Transportation Disadvantaged. Transportation Research Board of the National Academies, Washington, DC, December 2004. Summary: TCRP Report 105 documented the work undertaken for TCRP Project H-30. The objectives of the project were to identify strategies for improving coordination among services provided for transportation disadvantaged individuals (defined as older adults, persons with disabilities, low income individuals, and others with little or no access to private auto transportation), and to put together current, practical guidance for state and local organizations that are considering, planning, or engaged in some type of coordination initiative. Background research was conducted in three basic areas that related to transportation services for the transportation disadvantaged: service options, funding sources, and decision- making processes. Innovative approaches were examined in more detail through case studies. Coordination trends, themes, and challenges were identified from the findings of the research and case studies and presented in TCRP Report 105. Relevance to Commingling: Several of the case studies contained in TCRP Report 105 featured transportation systems and providers that group passengers from different agencies and programs on the same vehicles. Two of those case study sites are summarized briefly below. This document will be particularly useful for case study background that could be updated for mini case studies for this project. • State of New Mexico—Client Referral, Ridership, and Financial Tracking System (CRRAFT). The CRRAFT system is a statewide technology deployment that originally grew out of an investigation of the transportation barriers affecting individuals transitioning from welfare to work. Subsequent study helped to demonstrate that coordination between different agencies could be beneficial to both the transportation disadvantaged individuals and the Additional Resources 95

agencies themselves. Several significant barriers to coordination were identified, including the following: – Human service agencies feared their funds would be used to pay for transportation of other agencies’ customers – Varying reporting requirements among different funding agencies created administrative problems for transportation providers – Funding agencies were unsure how to most efficiently standardize their customer referral, ridership, and financial information The web-based CRRAFT system enables 27 rural transportation providers that utilize Section 5311 and JARC funding to certify human service agency participants, schedule trips, track riders, prepare invoices, and generate reports in a standardized way. As a further enhance- ment of the system, integration of a multi-purpose electronic fare card system and in-vehicle card readers for processing information from passengers’ Electronic Benefits Transfer (EBT) cards was scheduled to be completed in 2005. The CRRAFT system demonstrates how technology can be used to facilitate the collec- tion of client, trip, and financial data that is needed when passengers are commingled on vehicles. • St. Louis Transportation Management Association (TMA) The St. Louis TMA serves the City and County of St. Louis and adjoining St. Charles County, Missouri. Led by the East-West Gateway Coordinating Council and Bi-State Devel- opment Agency (now known as Metro), the TMA originally included three transportation providers: OATS, Medical Transportation Management (MTM), and Care Cab Transporta- tion Service. The focus of the TMA’s coordination effort was a linked trip reservations and scheduling system. The call centers and radio dispatch centers of the original paratransit providers were linked by means of a communications network of T1 lines. This network, together with paratransit reservation and scheduling software, enables the agencies to book trips for their customers on vehicles operated by the other providers. Mobile Data Terminals (MDTs) installed in all the providers’ vehicles are used to communicate with drivers and to capture operational data. Because of the linked dispatch centers, dispatchers are able to assign trips to the most appropriate vehicle, even if it is operated by another provider. As a result, empty seats are filled, trips are shared, and riders from different agencies and programs are mixed on the same vehicles. Resources, particularly vehicles and drivers, are used more effectively and client agencies receive the benefit of more revenue when they are given riders from other programs. Some service to the general public in rural areas can be accommodated by mixing these trips with agency trips. Otherwise, these general public trips could not be served because of program eligibility restrictions. TranSystems, RLS & Associates, Nelson\Nygaard Consulting Associates. Transportation Services for People with Disabilities in Rural and Small Urban Communities. Easter Seals Project ACTION, Washington, DC, 2006. Summary: Easter Seals Project ACTION sponsored this study to obtain better infor- mation on how to develop, implement, and operate cost-effective transportation services in rural and small urban areas to meet the needs of persons with disabilities. The study involved surveys of rural and small urban transportation providers and of human serv- ice agencies and disability organizations to identify issues, concerns, and challenges in the provision of accessible transportation services to people with disabilities and the identification of model practices drawn from actual experience across the country in meeting these needs. 96 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

Relevance to Commingling: Regarding the commingling of ADA and other non-ADA riders, the report includes the following: • It has been a challenge in some areas to integrate newer ADA paratransit services with already existing paratransit services that have operated in a community along with fixed route service prior to the ADA. Sometimes, the new ADA service has been integrated and, in other com- munities, a separate ADA paratransit service has been implemented. • In some communities with both ADA and non-ADA paratransit services, the policies of the older paratransit service have been extended to the ADA paratransit service. But as ADA para- transit service has grown, separate policies for the ADA service, which are more limited, have been created. Where riders may be eligible for both services, this creates a situation where different policies and procedures apply to the same riders, one set when traveling in the ADA service area and a second set of policies when traveling outside the ADA service area. This can be confusing for riders and for the provider, and may be difficult to market. • Managing different eligibility determination processes in communities with both ADA and non-ADA paratransit services can also create difficulties as the different criteria may not be clearly explained to riders. • Combining the two types of service may be difficult for the provider to operationalize. • An example of coordinated ADA and non-ADA paratransit service can be seen at Lane Transit District (LTD). The District’s paratransit program, known as RideSource, serves persons with disabilities, seniors, and other transit dependents, as well as ADA eligible paratransit persons. The program is operated by a non-profit transportation provider, and the provider and transit district reportedly have a close working partnership. LTD also provides a “shopper service,” which mixes riders of different types, including lower income persons, on a space available basis. ADA eligible riders are given first priority on the service. Government Documents Federal Interagency Coordinating Council on Access and Mobility (CCAM). Final Policy Statement: Coordinated Human Service Transportation Planning. Washington, DC, October 1, 2006. Summary: On October 1, 2006, CCAM issued the following policy statement: “Member agencies of the Federal Coordinating Council on Access and Mobility resolve that federally-assisted grantees that have significant involvement in providing resources and engage in transportation delivery should participate in a local coordinated human services transportation planning process and develop plans to achieve the objectives to reduce duplication, increase service efficiency and expand access for the transportation-disadvantaged populations as stated in Executive Order 13330.” The CCAM recommended that agencies providing transportation plan collaboratively to more comprehensively address the needs of populations served by various federal programs, by increasing efficiency and expanding access for older individuals, persons with disabilities, persons with low incomes, children, and other disadvantaged populations. Relevance to Commingling: Commingling ADA and non-ADA paratransit customers is a potential strategy in achieving CCAM’s stated goal under the policy statement. Federal Interagency Coordinating Council on Access and Mobility. Final Policy Statement: Vehicle Resource Sharing. Washington, DC, October 1, 2006. Summary: As part of the United We Ride initiative and its efforts to implement Execu- tive Order 13330 on Human Service Transportation Coordination, the Federal Intera- gency Coordinating Council on Access and Mobility (CCAM) issued policy guidance to Additional Resources 97

clarify the sharing of vehicles and other transportation resources among federally assisted programs in October 2006. State and local level agencies may believe that, because federal funding programs that sup- port transportation services typically define eligible user groups and/or trip purposes, funds from those programs (and the vehicles and other resources which they are used to acquire) may be used to serve only those users or trips. This misconception can lead to the operation of separate transportation services or programs that serve similar populations and types of trips in an inefficient, fragmented, or duplicative manner. In fact, as the CCAM’s policy guidance explains, federal cost principles allow grantees to share the use of vehicles and other resources with other recipients of federal funds that may be used for the provision of transportation. Those federal cost principles are set forth in several circulars issued by the Office of Management and Budget (OMB) for state, local, and Indian tribal governments (Circular A-87); nonprofit organizations (Circular A-122); and Educational institutions (Circular A-21). The cost principles also require the costs of a program or service that utilizes federal funding to be reasonable, necessary, and allocable. If vehicles and other resources are shared among multiple programs, each program must pay a portion of the costs of the shared transportation service. Costs must be allocated among programs in a fair and equitable manner. The CCAM not only explained in this guidance that the federal government allows trans- portation costs and resources to be shared among programs, but encouraged that practice among grantees, and provided examples of how such coordination might work. The CCAM’s policy statement reads as follows: “Member agencies of the Federal Coordinating Council on Access and Mobility resolve that Federally-assisted grantees that have significant involvement in providing resources and engage in transportation should coordinate their resources in order to maximize accessibility and availability of transportation services.” Relevance to Commingling: At the state and local levels, perceived restrictions against sharing vehicles and other resources among programs and services that are funded with federal grants may be viewed as a barrier to the coordination of transportation services. As a re- sult, separate transportation services and programs may be provided for different user groups or types of trips. For example, in one area, separate transportation services may be provided by a local Council on Aging that receives funding under Title III (b) of the Older Americans Act for the transportation of older adults, a transit agency that uses Section 5307 or 5311 funds for the provision of transportation services for ADA eligible individuals, and a state department of human services that uses Medicaid funding to support contracts with transportation providers for non-emergency medical transportation. In this situation, no commingling occurs— vehicles carry only the individuals that each grantee received federal funding to serve. This policy guidance from the CCAM makes it clear that the sharing of vehicles and other federally funded resources among programs that provide transportation services for different user groups or types of trips is not only allowed, but encouraged. Commingling passengers is one way that vehicles and resources may be shared among programs. Federal Interagency Coordinating Council on Access and Mobility. Framework for Action: Building the Fully Coordinated Transportation System: Self-Assessment Tools for Com- munities. Washington, DC, 2006. Summary: The Toolkit was designed as a self-assessment tool for communities to determine where they are in terms of developing a successful, coordinated transportation program that provides adequate service to all customers. 98 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

The Toolkit is divided into five sections, which are each further broken down into sub- sections for a total of 26 sections. At the end of each section and sub section, there is a self- assessment tool designed to help evaluate a community’s progress toward its overall goals. The self-assessment tool allows for four grading levels, based on the community’s current state of affairs with relation to transportation: Needs to Begin, Needs Significant Action, Needs Action, and Done Well, and each grade is illustrated with a shaded cog to signify the amount of progress made. Section 1: Making Things Happen highlights the needs for individual and organizational desire to jump start a successfully coordinated transportation system. Assessment sub sections focus on governing framework; relationships between neighboring communities and state agencies; and sustained support among elected officials, agency administrators, and other community leaders. Section 2: Taking Stock of Community Needs and Moving Forward is used to assess the capacity of human service agencies to coordinate transportation services through an inventory of assets, expenditures, services provided, duplication of services, specific mobility needs of the various target populations, and opportunities for improvement. Sub sections focus on identification of existing data sources and needs documentation, assessment of use of technology, budgets, stakeholder participation, and strategic planning. Section 3: Putting Customers First focuses on the need to ensure that customers have a convenient and accessible means of accessing information about transportation services, and that they be regularly engaged in the evaluation of services and identification of needs. Sub sections highlight the importance of access to information sources; travel training and consumer education; payment systems that promote consumer choice of cost-effective service; the gathering of customer satisfaction data; and effective marketing and communications strategies. Section 4: Adapting Funding for Greater Mobility is designed to instruct communities on innovative accounting procedures used to support transportation services by combining federal, state, and local funds. The strategy creates customer friendly payment systems, while maintaining an agency’s ability to apply consistent reporting and accounting procedures across programs. Sub sections ask whether such an accounting system and relevant technology is in place and operating effectively. Section 5: Moving People Efficiently focuses on multimodal and multi-provider trans- portation coordination, benefiting customer and provider. Sub sections inquire on coordi- nation agreements, costs, and centralized systems. Relevance to Commingling: Section 4 is especially relevant to commingling, as it is designed to assist communities in developing an accounting system that can support operations funded by multiple programs, while still maintaining accounting integrity and program tracking. Golden, Marilyn, and Weiner, Richard. The Current State of Transportation for People with Disabilities in the United States. National Council on Disability, Washington, DC, June 13, 2005. Summary: This report was written to develop a better understanding of access to trans- portation and mobility for people with disabilities. It covered a range of transportation modes as well as the pedestrian environment. The report assessed existing transportation systems, recognizing that these systems are inadequate due to a chronic lack of funding. Given the emphasis in the United States on automobile travel, all other modes are neglected in comparison. The Americans with Disabilities Act (ADA) has brought great improvements Additional Resources 99

to transportation systems, but compliance gaps exist that pose significant problems for transportation for persons with disabilities. Relevance to Commingling: Regarding commingling of non-ADA eligible riders on ADA paratransit: • With passage of ADA, some social service agencies “transferred” their program participants to the ADA paratransit program; the result of this “integration” has been both positive and negative. Positive results include generally higher quality of service in terms of driver training and vehicle condition. Negative results are generally increased costs borne by transit agencies, as typically they have had to absorb some of the costs formerly the responsibility of the social service agencies. • The report included some examples of coordination: – New emphasis on coordination with FTA’s United We Ride Initiative – In Montana, a handbook has been developed to assist with coordination – Eau Claire County, Wisconsin, worked with the City of Eau Claire and its transit program to coordinate service for ADA paratransit riders and program participants of the county’s human services department U.S. Government Accountability Office (GAO). Transportation-Disadvantaged Seniors, Efforts to Enhance Senior Mobility Could Benefit from Additional Guidance and Information (GAO-04-971). Washington, DC, August 2004. Summary: This study was undertaken by the GAO in recognition of the aging of the American population, with access to transportation being a critical link in keeping seniors independent. For seniors who are transportation disadvantaged, issues of mobility are even more critical. The extent of transportation needs for seniors was difficult to document, given that local agencies on aging, responsible for senior services, used different methodologies for determining needs. The report found that local transportation providers have implemented a variety of practices to enhance mobility for seniors. The study concluded that federally sponsored programs are not meeting certain transportation needs of seniors, though the extent of the problem was difficult to quantify and that there are obstacles to addressing the needs of transportation disadvantaged seniors. The report then documented the obstacles and strategies to address these needs center around three themes: • Planning for alternatives as seniors age • Accommodating seniors’ varied mobility needs • Addressing federal and other governmental funding constraints The last issue suggests that improved coordination may enhance transportation services for seniors. Relevance to Commingling: There is no specific discussion of commingling, but the report does document that about 21% of seniors age 65 and older, or about 6.8 million people, do not drive. These individuals could be a good market group for commingling with ADA paratransit riders, particularly given that the majority of ADA paratransit eligible riders are seniors. U.S. Government Accountability Office (GAO). Transportation-Disadvantaged Populations: Federal Agencies Are Taking Steps to Assist States and Local Agencies in Coordinating Transportation Services (GAO-04-420R). Washington, DC, February 2004. Summary: This report was prepared by the GAO to determine whether the four federal agencies which provide the bulk of funds for transportation disadvantaged populations, Trans- portation, Health and Human Services, Labor, and Education, and the federal Coordinating 100 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

Council have taken steps to address the GAO recommendations from the agency’s June 2003 report (see below) on transportation. The GAO found that progress has been made and that this progress should result in better coordination of federal programs at the state and local level. Yet, according to the GAO, the departments have made limited progress to include coordination in their strategic and annual performance plans. The report also documents efforts made by the four departments in launching the United We Ride initiative, which is designed to help states and local communities deal with obstacles to coordination. The Framework for Action, part of the United We Ride initiative, is also discussed, which provides a tool to local communities as well as states to chart progress towards coordination. Relevance to Commingling: This GAO report does not specially address commingling of ADA paratransit and other riders. However, the various efforts documented in the report and particularly the finding that general progress has been made provides an encouraging setting for further coordination, and potentially commingling, in the near term future. U.S. General Accounting Office (GAO). Transportation-Disadvantaged Populations: Some Coordination Efforts Among Programs Providing Transportation Services, but Obstacles Persist (GAO-03-697). Washington, DC, June 2003. Summary: This GAO document is an often-cited report, finding that 62 different federal programs provide some level of funding for transportation disadvantaged persons. While the total amount of funding through the programs is not known, it was estimated based on information available for 29 of the 62 programs, to be at least $2.4 billion in 2001. Efforts to improve coordination, with objectives of improving services and saving costs, have been made, but results vary. The report documented specific efforts made by the Coordinating Council on Access and Mobility, formed by the Departments of Transportation and Health and Human Services and notes that two other departments which provide sig- nificant funds for transportation, Education and Labor, are not involved with the Council. The report further provided information on the obstacles that impede coordination including the following: • Officials may be reluctant to share vehicles and provide funding for coordination • Differing program requirements can impede coordination • Program officials may not know how to effectively coordinate Recommendations are provided focusing on “harmonizing” standards and requirements among the different federal programs, expanding interagency communications with additional information on coordination, and providing financial incentives or coordination mandates. More specific actions under these areas are also recommended. Progress in meeting recommendations made by the GAO in its 1999 report (see below) are also documented, concluding that efforts have produced mixed results. Relevance to Commingling: Commingling is not specifically addressed in this report, though such mixing of riders on the same vehicle is implied in discussions about the benefits of coordination. U.S. General Accounting Office (GAO). Transportation Coordination: Benefits and Barriers Exist, and Planning Efforts Progress Slowly (GAO/RCED-00-1). Washington, DC, October 1999. Summary: This GAO report addressed the issue of transportation coordination with a focus on the role that the federal Departments of Transportation and Health and Human Additional Resources 101

Services, as well as the Coordinating Council that the two agencies formed in 1986, have taken to foster coordination at the state and local levels. The report documented the history of efforts made since the 1980s and noted that progress has been slow and sporadic. The report also provided specific recommendations that should be taken by the two departments and the Coordinating Council to move coordination forward. Relevance to Commingling: The report documented a number of examples of coordi- nated or consolidated transportation programs that are considered successful on such mea- sures as cost per passenger trip, cost per vehicle hour, and average trips per month. The report did not provide the specifics as to how coordination or consolidation was achieved, so it is not known the extent to which commingling was a strategy. However, an important theme of the report was that transportation coordination is beneficial in reducing federal transportation program costs by clustering riders (e.g., commingling), using fewer trips, and sharing resources such as equipment and staff. Technology Solutions Documents Carter, M., et al. Mobility Services for All Americans Phase 2 Foundation Research. U.S. Department of Transportation, Washington, DC, 2005. Summary: This report is part of an ongoing effort by the U.S. DOT Joint Program Office (JPO) to explore and implement new capabilities and opportunities that are being created in both the transportation and health and human services communities through the use of emerging technologies and innovative services. Pioneering public transportation agencies are using Intelligent Transportation Systems (ITS) to provide centralized coordination of community transportation providers, one stop shopping, and service brokering through integrated automatic vehicle location systems, advanced communications, and universal benefit cards. Others are providing on-vehicle audio annunciation, accessible traveler infor- mation, and flexible routing to assist passengers with disabilities in using conventional transit services. The foundation of this Mobility Services for All Americans (MSAA) initiative is built around the notions of service coordination and technology integration, a key relationship that the FTA and the FHWA hope to expand on as they work toward the ultimate goal of the Mobility Services for All Americans initiative, which is “To develop the architecture/design of a replicable, scalable traveler management coordination center, which will enhance service accessibility and operations efficiency and provide one-stop customer-based travel information and trip planning services.” The report pointed out that there are many technologies that can improve the availability and accessibility of the transportation services for all persons, but especially those who are transportation disadvantaged. These solutions include ITS, which generally contribute to fleet management and operations, traveler information, electronic fare payment (Smart cards), and assistive technologies (AT), which generally contribute to the physical accessibility of transportation systems (e.g., intelligent wayside technologies, audible signs, and per- sonal location monitoring). In addition to ITS and AT, there are some solutions, while not necessarily technology, which can be implemented to meet the needs of transportation disadvantaged individuals, such as boarding assistance and signage and/or information (e.g., tactile and Braille displays and telephone/Internet/cell phone-based information services). Once implemented, many available technologies can help meet the needs, overcome the barriers, and close the gaps of all travelers. 102 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders

These challenges, if not overcome prior to and during implementation, can affect how useful the technology will be. Largely, these concerns can be either institutional or technical. Those which are institutional usually relate to the following: • Financing for technology procurement and deployment • Coordinating with other providers and agencies to jointly procure systems and/or exchange data and information • Lacking ITS technical experience—this can relate to either human or computer resources • Procuring technology from vendors who are unfamiliar or inexperienced with human service agency operations and transportation services U.S. Department of Transportation. ITS Applications for Coordinating and Improving Human Services Transportation (U.S. DOT, FHWA-JPO-05-056). Washington, DC, August 2006. Summary: The report, completed by Oak Ridge Laboratories, highlighted technologies that improve accessibility for transportation disadvantaged persons, with an emphasis on technologies that improve coordination. There were six sites highlighted that have success- fully deployed ITS technologies, including Cape Cod Regional Transit Authority (CCRTA). CCRTA was able to move most of its Medicaid trips from single ride taxi trips to less expensive shared-ride paratransit services after using its technology to analyze origins and destinations of the Medicaid trips. Relevance to Commingling Issue: Similar to other literature summarized here, this doc- ument does not address the specific issue of commingling ADA paratransit and others on the same vehicles, yet it does address the important role that technology can play in advancing coordinated services. Additional Resources 103