Practices for Establishing ADA Paratransit Eligibility Assessment Facilities (2015)

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PRACTICES FOR ESTABLISHING ADA PARATRANSIT ELIGIBILITY DETERMINATION FACILITIES All public transit agencies that operate fixed-route transit services also provide complementary paratransit service for persons who, because of a disability, are prevented from using the fixed-route service for some or all of their trips. Complementary paratransit is required by the Americans with Disabilities Act of 1990 (ADA). Each transit agency that provides com- plementary paratransit also has a process for determining who is “ADA paratransit eligible.” Eligibility for complementary paratransit is complex and trip-based—that is, if eligible individuals can make some trips by fixed-route transit, they are only eligible for paratransit for the trips that cannot be made by bus or train. Processes must determine not only if applicants are eligible, but the specific travel abilities and the conditions under which they can and cannot use fixed-route transit services. Given the complexity of ADA paratransit eligibility, many transit agencies have gone beyond paper applications to include in-person interviews and functional assessments in their eligibility determination processes. As of 2012, 48% of transit agencies conducted in-person interviews and 37% requested that some applicants participate in functional assessments. This report examines the state of the practice in implementing and conducting determinations of ADA paratransit eligibility. In particular, it looks at the various processes, facilities, equip- ment, and tools used by transit agencies that include in-person interviews and functional assessments. The study included: • A review of the literature related to ADA paratransit eligibility; • A survey of 30 transit agencies, with responses from 24 (80%), identified as using in-person interviews and functional assessments to make eligibility determinations; and • Follow-up with five agencies selected as case examples to gather detailed information on the design of outdoor routes and indoor facilities used for conducting functional assessments, the decision-making process used to develop the approach and facilities, and experiences and lessons learned. The literature review identified guidance and tools for assessing travel abilities, including guidance specific to assessing those travel skills needed to use fixed-route transit, as well as tests and tools of general physical and cognitive abilities that are used as part of overall assessments. Little literature was identified regarding the actual design or operation of eligibility assessment centers or facilities. The survey of selected transit agencies indicated that different approaches and processes are used. The primary differences can be characterized as follows. Outdoor versus indoor assessments: In some cases, agencies assess the ability to get to and from transit stops and stations by walking with applicants in the real environment whenever possible. A few agencies include rides on buses or trains as part of the assessment. Indoor facilities are used when travel in the real environment is precluded or to test certain abilities that are not always observed on the walk—such as getting on and off buses if an actual bus SUMMARY

2 trip is not taken. In other instances, all aspects of travel in the community and on buses and trains are simulated using indoor facilities and props. Separate versus combined assessments: Some agencies use separate assessments for applicants with physical, cognitive, and sensory disabilities. Different types of professionals are also used in some instances to make each type of observation (e.g., physical or occupational therapists to assess physical abilities). Other agencies make observations of all types of abilities using a combined assessment that is designed to test physical, cognitive, and sensory skills. The 24 agencies surveyed were fairly evenly divided in their approaches. Nine rely pri- marily on outdoor assessments, with limited indoor facilities that are used mainly as a back- up. Ten conduct assessments outdoors whenever possible, but also have some indoor props with which to make certain observations. Five do assessments entirely indoors with props and simulations. Fourteen agencies have separate tests and tools for assessing applicants with physical versus cognitive disabilities. Ten make combined observations over a common assessment course. Only one agency indicated a specific assessment for applicants with vision disabili- ties. Most others either make general observations of vision abilities as part of a combined assessment or make determinations of eligibility for applicants with significant vision dis- abilities using information from application forms, interviews, and professionals familiar with the applicants. Most agencies use contractors to assist with the process—mainly with functional assessments. Nineteen of the 24 systems use contractors to assist with physical functional assessments, 18 use contractors to assist with cognitive assessments, and 15 use contractors to assist with assessments of applicants with vision disabilities. Transit agency staff often review applica- tion forms and collect information from professionals familiar with applicants. Responsibility for initial interviews was split, with transit agency staff conducting interviews in 12 cases, contractors conducting interviews in 10 cases, and both in one case (one agency does not have initial interviews). Twenty-two of the 24 transit agencies surveyed have one central facility for eligibility determinations and assessments. Two agencies with very large service areas have multiple eligibility facilities (one has three and one has five). One of the agencies that has a primary central facility also has two temporary sites and a mobile evaluation unit to conduct assessments in remote parts of its service area. Fourteen of the 24 transit agencies own or lease the facilities used for making eligibility determinations. Contractors provide the facilities at the other 10 agencies. The size of the facilities used ranges from 702 ft2 to 19,500 ft2. The average size is 7,884 ft2 for processes that relied more heavily on indoor simulations and props. Where assessments are done mainly outdoors, facilities average 2,538 ft2. Facility build-out costs also varied significantly, from $765 to $1.2 million. The average cost was $336,225 where significant indoor simulations and props are used and $89,927 where assessments are performed mainly outdoors. The case examples indicated that most transit agencies used guidance developed by Easter Seals Project ACTION (ESPA) to construct indoor props to simulate travel by fixed-route transit. Most agencies that rely significantly on indoor assessments have mock-ups of curbs and curb ramps, various surfaces (uneven and broken pavement, gravel, and grass), ramps of various lengths and slopes, and pathways with cross-slopes. Most also have mock-ups of buses or full-sized buses located within the facilities.

3 ESPA guidance is also widely used to design outdoor assessment routes. Such routes are typically up to 0.5 mile (2,640 ft) in length; include pathways with curbs, curb ramps, varied surfaces, slopes and cross-slopes; and uncontrolled as well as controlled intersections. Besides the specific design of indoor and outdoor routes and props used for functional assessments, the case examples also identified important facility design considerations, including: • Adequate sized waiting areas for applicants, as well as other individuals attending the interviews and assessments; • Adequate sized pickup and drop-off areas for applicants arriving by paratransit; • The maintenance of privacy in areas where interviews and assessments are conducted; and • Multiple elevators if facilities are in shared buildings. The case examples revealed that public involvement is important if eligibility determination processes are changed to include in-person interviews and functional assessments. Public input is also important in facility design. Staff at all five transit agencies studied in detail indicated that they were generally pleased with the change to in-person interviews and functional assessments. Staff at these agencies also indicated that their local communities had largely accepted the new processes. Several agencies noted that well-designed and equipped facilities helped them build public confidence in the overall eligibility determination process.