Practices for Establishing ADA Paratransit Eligibility Assessment Facilities (2015)

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13 1,000 ADA eligibility determinations per year; seven between 1,000 and 2,999 determinations per year; seven between 3,000 and 4,999 determinations per year; three from 5,000 to 9,999 determinations per year; and three make 10,000 or more determinations per year. ELIGIBILITY DETERMINATION PROCESSES AND SOURCES OF INFORMATION Table 5 shows the sources of information and processes used by each agency to make eligibility determinations. This includes how information is gathered from applicants and professionals identified by applicants, and the types of in-person functional assessments used. Agencies are again listed from smallest to largest service area size. Applicant Forms Nineteen of the 24 transit agencies have forms that are com- pleted by applicants. Eleven request that applications be mailed in and reviewed before in-person interviews and functional assessments are scheduled. Eight agencies ask applicants to bring completed forms to the interviews. One agency [Regional Transportation Commission of Southern Nevada (RTC)] completes the application form as part of the interview and one agency [Orange County Trans- portation Authority (OCTA)] completes a form by telephone and then asks applicants to sign it when they come in for interviews. Three agencies do not use application forms; all information from applicants is obtained through in-person interviews. Professionals Verification All 24 agencies use information from medical or health pro- fessionals familiar with applicants’ disabilities or functional abilities to help make eligibility determinations. In 11 of the agencies, part of the application form must be completed by a professional. Eight agencies request information from a medical or health professional only when needed and ask applicants to identify appropriate professionals when this is required. Five agencies invite applicants to submit information from medical or health professionals; however, this is not required. A survey was developed with Project Panel input to gather information about eligibility determination processes, facil- ities, and equipment from selected transit agencies. A copy of the survey is provided in Appendix A. The survey requested information about: • Types of information used to make eligibility determi- nations • Process elements (application forms, interviews, assess- ment) • In-house versus contractor responsibilities • Eligibility determination facility ownership • Eligibility determination facility features and equipment • Initial facility set-up costs • Annual facility operating costs • Features of outdoor routes (if used) • Process and outcome statistics. Transit agencies were also asked to provide floor plans of eligibility determination facilities and maps of any outdoor assessment routes. The survey was sent to 30 transit agencies identified as using in-person interviews and functional assessments to make determinations of eligibility. Recent research reports, as well as the general knowledge of the study team and Project Panel, were used to identify the types of processes used by each agency. Agencies were also selected to provide geographic and system size diversity. A total of 24 transit agencies completed the survey, an 80% response rate. One small agency responded indicating that, contrary to what was stated in the literature, they did not conduct in-person interviews or functional assessments. The following is a summary of information provided. RESPONDING AGENCIES Table 4 lists the 24 transit agencies that responded to the sur- vey, organized by service area population. The service area population, number of ADA paratransit applications received per year, and number of eligibility determinations made each year is provided for each agency. Respondents represent systems of varying size. The service area population ranges from 245,069 [Anchorage Public Transportation Depart- ment (Muni in Anchorage)] to 11,638,106 [Access Services, Inc. (ASI) in Los Angeles]. Four respondents make less than chapter three SURVEY RESULTS

14 Acronym Transit Agency City, State Service Area Population (2012 NTD) ADA Paratransit Applications/ Year (1) ADA Paratransit Determinations/ Year (1, 2) Muni Anchorage Public Transportation Department, Anchorage, AK 245,069 797 705 CCRTA Corpus Christi Regional Transit Authority, Corpus Christi, TX 342,412 927 785 STA Spokane Transit Authority, Spokane, WA 394,120 1,818 2,008 Pierce Pierce County Public Transportation Benefit Area, Tacoma, WA 557,069 3,233 3,233 SamTrans San Mateo County Transit District, San Carlos, CA 737,100 2,888 2,888 JTA Jacksonville Transportation Authority, Jacksonville, FL 838,815 1,209 968 DTS Department of Transportation Services, Honolulu, HI 953,207 4,629 4,673 CMTA Capital Metropolitan Transit Authority, Austin, TX 1,023,135 3,029 2,889 COTA Central Ohio Transit Authority, Columbus, OH 1,081,405 2,056 1,910 ACCESS Port Authority of Allegheny County, Pittsburgh, PA 1,415,244 725 725 TriMet Tri-County Metropolitan Transportation District, Portland, OR 1,469,790 3,338 3,338 MTA Nashville Metropolitan Transit Authority, Nashville, TN 1,583,115 1,132 1,020 BCT Broward County Transit, Ft. Lauderdale, FL 1,780,172 5,358 3,758 RTC Regional Transportation Commission of S. Nevada, Las Vegas, NV 1,886,011 5,560 5,560 KC Metro King County Metro, Seattle, WA 1,957,000 6,122 4,834 UTA Utah Transit Authority, Salt Lake City, UT 2,165,290 1,161 1,133 Metro Mobility Metro Mobility, Minneapolis, MN 2,314,701 8,612 8,561 DART Dallas Area Rapid Transit, Dallas, TX 2,423,480 3,732 3,067 OCTA Orange County Transportation Authority, Orange, CA 3,014,923 7,871 6,166 SEPTA Southeastern Pennsylvania Transportation Authority, Philadelphia, PA 3,320,234 6,295 2,989 Valley Metro Valley Metro, Phoenix, AZ 3,629,114 4,753 4,753 MBTA Massachusetts Bay Transportation Authority, Boston, MA 4,181,019 11,114 12,352 RTA Regional Transportation Authority, Chicago, IL 6,133,037 15,960 13,298 ASI Access Services, Inc., Los Angeles, CA 11,638,106 39,483 39,483 (1)Self-reported “annual” data. Likely CY 2013 or FY 2013 or 2014 as data were provided in January and February 2014. (2)Annual determinations can vary slightly from applications received depending on the number of applications in process. TABLE 4 SURVEY RESPONDENTS TriMet asks applicants to identify a medical or health professional and sign a medical release form. Agency staff then contacts these professionals directly to get information. In addition to acquiring information from professionals in appli- cation forms, Spokane Transit Authority (STA) follows up with professionals if new information is brought up in inter- views. Massachusetts Bay Transportation Authority (MBTA) follows up with professionals in all cases before applicants are found not eligible. Valley Metro asks applicants to provide the name of a professional who can be contacted if needed, and encourages applicants to provide any verification they have, but does not require this information. In-Person Interviews Twenty-two of the 24 agencies conduct in-person interviews. Fourteen require all applicants, or at least all new applicants, to participate in interviews. Valley Metro officially requires interviews, but noted that in rare cases where immediate ser- vice is needed and eligibility is clear it has made determinations without interviews. KC Metro conducts phone interviews with all persons who submit applications forms. Five agencies make some determinations based on infor- mation from applicants and professionals and only require some applicants to participate in interviews. RTA, Tri-County Metropolitan Transportation District (TriMet), and ASI require all new applicants and most, but not all, riders seeking recertifi- cation to participate in interviews. Muni requires interviews of all applicants except those with end stage renal failure who are using the service primarily for dialysis transportation. Southeastern Pennsylvania Transportation Authority (SEPTA) noted that interviews are part of the functional assessments conducted by contractors. Broward County Tran- sit (BCT) refers some applicants for functional assessments. While the contractor who conducts the assessments may discuss issues with applicants during the assessment, BCT does not consider this to be a separate interview. Physical Functional Assessments All 24 agencies include physical functional assessments as part of the eligibility determination process. Thirteen include the Tinetti Balance and Gait test as part of the assessment. Corpus Christi Regional Transit Authority (CCRTA) uses the Timed Get Up and Go test rather than the Tinetti test. Port Authority of Allegheny County (ACCESS) noted that PTs who conduct the assessments sometimes record vital signs (pulse and blood oxygenation levels) before, during, and after the assessment. (Note that many other agencies most likely do this as well but did not note it separately.) Four agencies conduct physical functional assessments outdoors in the real environment. Five agencies have created indoor routes and do not take applicants outdoors. Fifteen

15 Transit Agency Application Form Professional Verification In-Person Interviews Physical Assessments Cognitive Assessments Vision Assessments M ai le d In B ro ug ht to In te rv ie w Co m pl et ed at In te rv ie w O th er Pa rt of A pp lic at io n Fo rm O bt ai ne d as N ee de d Ca n be S ub m itt ed (O pt. ) R eq . o f S om e A pp lic an ts O th er R eq . o f A ll A pp lic an ts Fo r S om e A pp lic an ts O th er Ti ne tti B al an ce /G ai t T es t In do or R ou te O ut do or R ou te O th er FA CT S M M SE Pa rt of O ve ra ll A ss es s. O th er B y O & M S pe ci al ist Pa rt of O ve ra ll A ss es s. O th er Muni (1) CCRTA (2) (3) STA (4) Pierce (5) (6) SamTrans JTA (7) DTS (8) CMTA COTA ACCESS (9) (10) TriMet (11) (12) (13) MTA BCT RTC (14) KC Metro (15) (16) UTA Metro Mobility DART (17) OCTA (18) SEPTA (19) (20) Valley Metro (21) (22) MBTA (23) (24) RTA (12) (25) (26) (26) ASI (27) Notes: (1)Interviews required for all applicants except those with end stage renal disease applying mainly for dialysis transportation. (2)Timed Get Up & Go test. (3)Cognitive assessment developed by transit agency. (4)New information brought up during interview is verified by eligibility contractor. (5)Power mobility device boarding/deboarding and use. (6)Psychologist to perform as needed standardized testing, in-person interviews with travel training staff. (7)Applicants bring visual acuity statement to interview. Decision based on interview and vision information. (8)During inclement weather, assessments are done in office building where interviews are conducted. (9)Indoor bus mock-up. When appropriate (based on diagnosis) physical therapist also uses pulse oximeter to measure pulse and oxygen saturation at baseline, during and after exertion. (10)ESPA recommended approach. (If low vision but not legally blind, assess as part of physical functional assessment. If legally blind, grant at least conditional eligibility.) (11)Obtained for all applicants by eligibility determination staff with Medical Release Form. (12)Required of all new applicants and most, but not all, recertifications. (13)Fixed-route trip on bus and/or light rail as appropriate. (14)Determinations for applicants with vision disabilities based on interviews and professional verification information. (15)Phone interviews conducted with all applicants who submit completed application forms. (16)Assess additional cognitive skills using portions of FACTS test. (17)Determined through interviews, application, and information from professionals. Have O&M specialist under contract who can be consulted. (18)Completed via phone, verified, and signed at interview. (19)Interviews conducted as part of functional assessments by contractors. (20)If vision screening (i.e., field test) is provided by the applicant’s eye care practitioner, it is sent to the contracted vision professional for interpretation; if applicant does not have an eye doctor, applicant is scheduled for a vision assessment by the contracted vision professional. (21)Professional contact information is requested and applicants are encouraged to provide it, but it is not required. (22)Interviews have been waived in very rare cases where immediate service is needed and eligibility is clear. (23)Requested prior to “not eligible” determinations. (24)Verification from vision care specialists at state Commission of the Blind, as needed. (25)Primarily outdoor assessments but use indoor depending on weather; use curb and lift platforms indoors; use modified Tinetti. (26)Observations also made as part of physical assessments if this is also conducted. (27)Required of all new applicants. After three-year certification period, some recertification applicants may be required to participate in in-person interview to continue eligibility if there is reason to believe their functional abilities may have changed. TABLE 5 ADA PARATRANSIT ELIGIBILITY DETERMINATION PROCESSES

16 agencies have both outdoor and indoor routes that are used for physical functional assessments. In some cases, part of the route is indoors and part is outdoors. In several cases, the indoor route is used during inclement weather. For example, Department of Transportation Services (DTS) noted that dur- ing inclement weather the assessments are done in the office building where the eligibility staff is located. TriMet noted that it includes a ride on the bus and light rail service as part of the physical functional assessment. Pierce County Public Transportation Benefit Area (Pierce) noted that it includes an assessment of power wheelchair users’ command of the device and ability to board and deboard from transit vehicles (likely done by other agencies as well). Cognitive Functional Assessments Fifteen agencies have separate cognitive assessments that are used with applicants who report cognitive disabilities. Eleven use the FACTS test (explained in chapter two) and 10 use the MMSE (also explained in chapter two). Six of these agencies use both FACTS and MMSE. CCRTA noted that it has developed its own cognitive functional assessment. KC Metro noted that it uses parts of the FACTS test. Eight of these agencies also make observations regarding cognition during the physical functional assessment to supplement the FACTS and MMSE tests. SEPTA indicated that its contractors use psychologists to administer standardized tests of cognition. SEPTA also noted that some applicants with cognitive disabilities are interviewed by its travel trainers as part of the process. Seven agencies assess cognitive abilities as part of a com- bined assessment along the same routes that are used to assess physical functional abilities. Vision Assessments Only one agency [Utah Transit Authority (UTA)] uses O&M specialists to assess applicants with vision disabilities. Sixteen agencies assess vision along the same outdoor or indoor route used to assess other abilities. Dallas Area Rapid Transit (DART), SEPTA, Jacksonville Transportation Authority (JTA), ACCESS, MBTA, RTC, and Central Ohio Transit Authority (COTA) base determinations for applicants with vision disabilities on information provided by applicants and professionals who are familiar with them. SEPTA refers applicants to a contracted vision professional if they do not have their own professional to provide a visual acuity statement. MBTA requests information from the State Commission for the Blind if applicants are not able to provide verification of disability. AGENCY AND CONTRACTOR RESPONSIBILITIES Twenty of the transit agencies surveyed contract out for assistance with the eligibility determination process. Table 6 shows the division of responsibilities between transit agency staff and contractor staff. Four agencies have hired staff with appropriate qualifications and perform all parts of the process in-house. In most cases, transit agency staff reviews application forms, reviews or obtains information from medical professionals, and conducts interviews. Contractor staff sometimes assists with reviewing application materials and collecting informa- tion from professionals, but are more often involved in admin- istering functional assessments. Transit agency staff is responsible for reviewing application material in 13 programs; contractors do this in one program, the task is shared in seven programs, and in three processes there are no application forms. Transit agency staff review or obtain information from pro- fessionals in 14 programs, contractors have responsibility for this task in four programs, the task in shared in four programs, and there is no specific responsibility for obtaining information from professionals in two programs. Transit agency staff conducts interviews in 12 programs, contractors conduct interviews in ten programs, the task is shared in one program, and there are no interviews in one program. Contractors perform physical functional assessment in 17 programs, transit staff in five programs, and the responsi- bility is shared in two programs. Contractors also perform cognitive assessments in 14 pro- grams, transit staff in six programs, and both in four programs. Greater involvement of transit staff in cognitive assessments reflects that these assessments can be conducted by trained staff with various experience and backgrounds. Contractors perform vision assessment in 12 programs, transit staff in two systems, and both in three systems. As noted earlier, this is done in most cases using a combined physical/cognitive/vision assessment process. In seven pro- grams, determinations for applicants with significant vision loss (legal blindness) do not involve functional assessments and are instead based on information provided by applicants and professionals. Most transit agencies (19) retain responsibility for making final determinations, contractors are given this responsibility in three programs, and decisions are a shared responsibility in two programs. Twelve of the 18 transit agencies that contract out for assistance with the process work with local contractors. This

17 includes a variety of rehabilitation and disability service companies and agencies. Eight transit agencies contract with national companies that provide eligibility determination services. NUMBER, LOCATION, AND OWNERSHIP OF ELIGIBILITY DETERMINATION FACILITIES Table 7 provides information about the number of facilities used by transit agencies that responded to the survey. It also indicates facility ownership and whether the eligibility services are located with other transit agency or contractor services or in separate facilities. Number of Determination Locations All but two of the transit agencies that completed the survey indicated that a single eligibility determination facility is used. Two agencies—RTA and SEPTA—indicated multiple facil- ities; SEPTA has three facilities that serve its four-county service area, RTA has five facilities that serve a large six- county area. One agency (ASI) has a main facility to serve most of its area. It then has two temporary locations and a mobile evaluation unit to serve two parts of the service area that are somewhat separate and remote. Ownership and Location At 14 locations, the eligibility facilities are owned or leased by the transit agencies. In nine of these programs the eligi- bility facilities are located in buildings that also house transit agency administrative offices or are in transit centers. In eight programs, the eligibility facilities are in buildings with other transit administrative offices. The facility at STA is located in a downtown transit center. In five programs, the eligibility determination services are housed in a separate building leased or owned by the transit agency. Contractors provide the facilities in ten programs. In four programs, the eligibility services are housed in build- ings that are used by the contractor to provide other services Transit Agency Contractor(s) R ev . A pp lic at io n Fo rm s O bt ai n Pr of es sio na l V er if. Co nd uc t I nt er vi ew s Co nd uc t P hy sic al A ss es s. Co nd uc t C og ni tiv e A ss es s. Co nd uc t V isi on A ss es s. M ak e Fi na l D et er m in at io n Muni N/A T T T T T T T CCRTA Two OTRs T B B B B B T STA Innovative paradigms; Nurse Tammy RN B C C C B C T Pierce NW Center for Integrative Medicine; psychologist B T C B B B T SamTrans C.A.R.E. evaluators N/A N/A C C C C C JTA Industrial ATC, LLC T T T C C N/A T DTS Paratransit, Inc. N/A C C C C C C CMTA Concentra B B T C C C B COTA N/A T T T T T N/A T ACCESS Easter Seals of Western Pennsylvania T T T C T N/A T TriMet Medical Transportation Management T T T C C N/A T MTA Functional Solutions T T T C C C T BCT Neurological Rehab. Center Program Services, Inc. B T N/A C C C T RTC Nevada Community Enrichment Program T T T C B N/A T KC Metro Harborview Medical Center, Dept. of Rehabilitation Medicine T N/A T C C C T UTA Orientation & mobility specialist (personal services contract) T T T T T B T Metro Mobility N/A T T T T T T T DART N/A T T T T T N/A T OCTA C.A.R.E. evaluators B B C C C C T SEPTA Moss Rehab.; Bryn Mawr Rehab.; Mercy Health Systems T T C C C C T Valley Metro C.A.R.E. evaluators C C C C C C T MBTA Paratransit, Inc., dba Innovative Paradigms N/A C C C C N/A C RTA Community Alternatives Unlimited, Inc. B T C C C C T ASI C.A.R.E. evaluators B B C C C C B T = transit agency staff; C = contractor staff; B = both; N/A = not applicable. TABLE 6 AGENCY AND CONTRACTOR RESPONSIBILITIES

18 (e.g., rehabilitation services and community services). In six programs the contractors have leased space in buildings sepa- rate from any other services they might provide in the area. The contractor for the RTA, which has five separate facilities, has a combination of facilities located together with other services and facilities that are separate from other services it provides. CO-LOCATED PROGRAMS AND SERVICES The survey also asked if transit agencies co-locate their eli- gibility programs with travel training services or transporta- tion information and resource centers. Results are shown in Table 8. Twelve of the transit agencies that have travel training programs have co-located these services with their eligibility determination programs. If applicants indicate interest in travel training, this allows them to meet with travel trainers at the same time. Ten transit agencies noted that other transportation infor- mation and resources are available at the eligibility deter- mination facility. In some cases, specific resource centers have been created. Figure 1 shows the resource center cre- ated by KC Metro, which includes information on avail- able transportation services as well as safety equipment for traveling in the community, provided to interested appli- cants free of charge. In other cases, eligibility is co-located with customer service centers or other outlets with transit information. INDOOR FACILITY SPACE, AMENITIES, AND PROPS Table 9 provides information about the types of spaces, ame- nities, and props located at each of the eligibility facilities. Most program facilities (22) also housed administrative staff involved in eligibility determinations. Administrative staff was at different locations in two programs. One program (RTA), which has multiple facilities, indicated that administrative offices are located at one facility and other facilities are used just for interviews and assessments. Most program facilities (14) also had space for eligibility file storage. In some cases, central files were at other locations. Some systems have also implemented paperless processes; all information is scanned or entered electronically and there are no paper files. All 24 programs had waiting areas and restrooms. All but two programs also had interview rooms. Muni did not indicate rooms designated specifically for interviews. BCT noted that its functional assessment contractor does not conduct formal Transit Agency No. of Facilities Facility Ownership/Location Transit agency Contractor Other In transit facility Separate In contractor facility Separate Muni 1 CCRTA 1 STA 1 Pierce 1 SamTrans 1 JTA 1 DTS 1 CMTA 1 COTA 1 ACCESS 1 TriMet 1 MTA 1 BCT 1 RTC 1 KC Metro 1 UTA 1 Metro Mobility 1 DART 1 OCTA 1 SEPTA 3 Valley Metro 1 (1) MBTA 1 RTA 5 ASI 1(2) (1) Co-located with a new customer service center. (2) One central location in the Los Angeles basin. Temporary sites and a mobile evaluation unit to evaluate applicants in the Santa Clarita and Antelope valleys. TABLE 7 ADA PARATRANSIT ELIGIBILITY DETERMINATION FACILITIES OWNERSHIP AND LOCATION

19 six agencies obtain information about the weight of mobility devices from applicants or other sources. The survey also asked agencies what specific props were located within the facilities to assist with physical functional assessments. Nine agencies indicated that facilities included extensive props for simulating all types of physical environ- ment and transit equipment features. This includes: • A measured course for determining maximum reason- able walking distance; • Curb and curb ramps; • Ramps with various slopes and cross-slopes; • Varied surfaces, such as grass, uneven pavement, or unstable surfaces (gravel); • A transit bus or a mock-up of a bus; and • A simulated street crossing complete with simulated traffic controls. Facilities at three other agencies had most of these same features: SEPTA notes that it has a simulated street crossing, but no traffic controls; RTC reports that its facility has all of these features except a bus or bus mock-up; and Capital Metropolitan Transit Authority (CMTA) had all features except a simulated street crossing and ramps. Eleven agencies noted that their indoor facilities have more limited props. These agencies conduct physical functional assessments primarily outdoors in the real environment and use their indoor facilities as a back-up when there is inclement weather. These facilities typically had an indoor route that could be used to determine maximum reasonable walking distance and simulations of curbs or curb ramps. Three also had mock-ups of transit buses. Four agencies (Pierce, DTS, DART, and MBTA) relied mainly on outdoor assessments. Facilities were used as a back-up and typically had an indoor measured course that could be used as needed, but did not have special props such as simulations or mock-ups as part of the facilities. Transit Agency Other Programs and Services at Facility Travel training Transportation information and resources Other Muni CCRTA STA (1) Pierce SamTrans JTA DTS CMTA COTA ACCESS TriMet (2) MTA BCT RTC KC Metro UTA Metro Mobility DART (3) OCTA SEPTA Valley Metro (4) MBTA RTA ASI Source: TCRP Report 163 (5). (1) Customer service and call center for fixed-route transit. (2) While there is no transportation resources center at the facility, other transportation services are discussed during the interview. (3) Located in DART Headquarters, which has transit information and DART retail store. (4) Customer service center. TABLE 8 OTHER PROGRAMS AND SERVICES CO-LOCATED AT ADA PARATRANSIT ELIGIBILITY DETERMINATION FACILITIES interviews, but rather discusses travel issues with applicants as part of the assessment. Eighteen of the 24 transit agencies that completed the survey indicated that scales for weighing applicants and their wheelchairs are located at the eligibility facilities. The other FIGURE 1 KC Metro (Seattle) Transportation Resource Center. (Courtesy: TranSystems.)

20 Transit Agency Admin. Offices File Storage Waiting Area Restrooms Interview Room(s) Scale Physical Assessment Props Separate Cognitive Assess. Area Other M ea su re d Co ur se Cu rb /C ur b Ra m p R am ps V ar ie d Su rfa ce s B us o r B us M oc k- up Si m ul . S tre et C ro ss in g Si m ul . T ra ffi c Co nt ro ls O th er Muni CCRTA (1) STA Pierce SamTrans (2) JTA DTS (3) CMTA (4) COTA ACCESS (5) (6) TriMet MTA BCT RTC KC Metro UTA Metro Mobility DART OCTA SEPTA Valley Metro MBTA (7) (8) RTA (9) (10) ASI Notes: (1)Area for taking vital signs. (2)Bus stop signs. (3)ID card printer; identification photos taken on iPad. (4)Conference/meeting room. (5)Elevator. (6)Paratransit broker administrative offices. (7)Indoor route only used if weather prevents use of outdoor route. (8)IT server room, kitchen area. (9)At one site only. (10)Lift platform. TABLE 9 INDOOR FACILITY SPACES, AMENITIES, AND PROPS Several agencies noted other spaces or props not included as choices in the survey, such as a space for recording vital signs, a transit lift platform (rather than a full bus mock-up), an eleva- tor, bus stop signs, break rooms/kitchen areas, and equipment for taking ID photos. It is likely that other agencies also have this type of equipment (particularly ID photo and break rooms), but did not mention it separately in the survey. Ten agencies indicated that their facilities also include spaces created for administering cognitive functional assess- ments. This is typically a space for administering the FACTS test (see chapter two and Appendix C). FACILITY SIZE AND COSTS Transit agencies were also asked to provide information about the size (square footage) of their eligibility determination facilities, the costs for building out and setting up the facilities, and the annual costs of facility operation (nonlabor costs such as rent, utilities, maintenance, etc.). The information provided is shown in Table 10. Nineteen agencies provided information about the size of the space used for eligibility determinations. This included indoor space for assessments, office space for eligibility staff,

21 and common space such as waiting areas and restrooms. Facility size ranged from 702 ft2 (DART) to 19,500 ft2 (ASI). Fourteen agencies provided build-out cost information. Build-out costs ranged from a low of $765 (CCRTA) to $1,200,000 (Valley Metro). Fourteen agencies also provided annual facility operating costs, which ranged from $4,500 per year (STA) to $320,000 per year (Valley Metro). Much of the variation in size appears to relate to the extent of indoor assessment props. Table 11 outlines facility size, build-out costs, and annual facility operating costs for the 11 agencies that indicated extensive indoor props (see Table 9 and previous discussion) compared with facility size for the 13 agencies with more limited indoor assessment props that rely primarily on outdoor physical assessments. Facilities with extensive indoor props averaged 7,884 ft2 in size (4,708 not including Valley Metro and ASI) compared with 2,538 ft2 for facilities with more limited props. Build-out costs for the facilities with extensive props ranged from $50,000 to $1,200,000 and averaged $326,225— although this figure was skewed by the cost of the Valley Metro facility. The average cost was $163,470 if Valley Transit Agency Facility Size (ft2) Who Did Build-Out Reported Build-Out Cost Reported Annual Operating Cost Year Occupied Muni N/A T N/A $27,200 2002 CCRTA 1,962 T $765 (1) N/A (2) 2009 STA 1,765 T $242,653 $4,500 2012 Pierce 2,858 T (3) (2) 2007 SamTrans N/A C (4) (4) 2013 JTA 1,900 T N/A $6,421 2007 DTS 1,932 C $86,000 $96,142 2009 CMTA 3,750 T $175,000 (5) $281,100 2013 COTA 3,276 T $147,980 (6) $12,000 2011 ACCESS 2,230 T $25,000 $20,700 2000 TriMet 8,330 T $250,530 $144,000 2010 MTA 1,658 T $2,000+ (7) (2) 2012 BCT 3,800 C N/A N/A N/A RTC 1,420 C (4) $17,928 2004 KC Metro 4,064 T/C $17,000 (8) (4) N/A UTA 5,625 T N/A N/A 2006 Metro Mobility N/A T (3) (2) N/A DART 702 T N/A (3) N/A (2) 2003 OCTA 5,800 C $50,000 $102,142 2010 SEPTA N/A C $58,842 (9) $20,000 (9) 2000 Valley Metro 15,317 T/C (10) $1,200,000 (11) $320,000 2011 MBTA 5,100 C $171,000 (12) $272,000 2012 RTA N/A C N/A N/A N/A ASI 19,500 (13) C $310,000 (13) $124,959 2008 T = transit agency; C = contractor; N/A = not available. (1) $265 for medical equipment (2 oximeters, blood pressure cuff, and stethoscope); $500 for mock-up of street crossing, including street light and activation button. (2) Part of transit facility operating costs. Not separated. (3) Space modifications made as part of overall headquarters build. Costs not separated. (4) Part of assessment contract (cost per assessment) and not separated out. (5) Rough estimate. Unable to provide exact figures as some work still in progress. (6) Transit agency purchased building for combined ADA paratransit operations and assessment center. Pro-rated purchase cost for assessment portion of building was $690,000. Build-out of assessment center after purchase was $147,980. (7) Scale cost about $2,000. Curb and curb ramp built in-house and costs not recorded. (8) $7,000 for combined scale/wheelchair measuring device; $10,000 for bus mock-up, curb, and curb ramp. (9) Build-out and annual operating cost for the largest of three contractors (Moss Rehab). (10) Specifications for build-out were developed jointly with the contractor. The owner of the building then made the modifications as part of the lease. (11) $1.2 million cost includes build-out cost for co-located customer service offices as well. Costs not split out between customer service and eligibility. (12) $130,000 building improvements, $41,000 in furnishings, $45,300 in computer and phone equipment (not included in table). (13) Based on 2009 report and study [National Transit Institute 2010 (1)]. TABLE 10 FACILITY SIZE AND COSTS

22 Metro is not included. Build-out costs for facilities with more limited props ranged from $765 to $252,653 and averaged $89,927. Four of the seven facilities with more limited props were built out for less than $25,000. Annual operating costs for facilities with extensive props averaged $80,029. Facilities with more limited props cost an average of $127,407 per year—which was somewhat skewed by costs reported by the MBTA and CMTA. The MBTA has a large facility for a staff that makes more than 12,000 deter- minations per year. CMTA’s is located in a transit facility in downtown Austin, with a high allocated lease (deprecia- tion) cost. Not counting the MBTA and CMTA costs, average annual operating cost for facilities with limited props was $52,836. OUTDOOR ROUTE FEATURES Table 12 summarizes information about the outdoor routes used to make eligibility determinations. Six transit agencies conduct all assessments indoors and do not utilize outdoor routes. Eight of the 15 transit agencies that provided infor mation about the length of their outdoor routes indicated that they are 0.5 mile (2,640 ft) in length—in keeping with the guid- ance developed by ESPA (see chapter two). Two are very close to this recommended distance—2,500+ ft at Pierce and 2,972 ft at BCT. Two agencies have routes of 0.25 mile (1,320 ft), one is 660 ft, and two are 0.75 mile (3,960 ft) in length. All of the outdoor routes have measured intervals so that assessors can time how long it takes applicants to complete each part of the route. Most have rest areas along the way, and the majority also have many of the features suggested in the ESPA guidance, including: • Curbs, • Curb ramps, • Hills, • Broken pavement, • Other surfaces, • Uncontrolled street crossings, and • Controlled street crossings. Transit Agency Facility Size (ft2) Build-Out Cost Annual Operating Cost Facilities with Extensive Indoor Props Muni N/A N/A $27,200 SamTrans N/A N/A N/A COTA 3,276 $147,980 $12,000 TriMet 8,330 $250,530 $144,000 BCT 3,800 N/A N/A RTC 1,420 N/A $17,928 UTA 5,625 N/A N/A OCTA 5,800 $50,000 $102,142 SEPTA N/A $58,842 $20,000 Valley Metro 15,317 $1,200,000 $192,000 ASI 19,500 $310,000 $124,959 Averages 7,884 (1) $336,225 (2) $80,029 Facilities with Fewer Indoor Props CCRTA 1,962 $765 N/A STA 1,765 $242,653 (3) $4,500 Pierce 2,858 N/A N/A JTA 1,900 N/A $90,000 DTS 1,932 $86,000 $96,142 CMTA 3,750 $175,000 $281,100 ACCESS 2,230 $25,000 $20,700 MTA 1,658 $2,000 N/A KC Metro 4,064 $17,000 N/A Metro Mobility N/A N/A N/A DART 702 N/A N/A MBTA (4) 5,100 $171,000 $272,000 RTA N/A N/A N/A Averages 2,538 $89,927 $127,407 (5) N/A = not available. (1) 4,708 ft2 average not including Valley Metro and ASI. (2) $163,470 average not including Valley Metro. (3) Includes bus or bus mock-up. (4) Large number of staff offices to make 12,352 determinations per year. (5) $52,835 average not including MBTA and CMTA. TABLE 11 SIZE, BUILD-OUT COSTS (AS REPORTED), AND ANNUAL OPERATING COSTS (AS REPORTED) FOR FACILITIES WITH EXTENSIVE VERSUS MORE LIMITED PROPS

23 Transit Agency N/A = not applicable. (1)Stairs, elevators. (2)Driveways, elevators, stairs. (3)Cross-slope. (4)Grass. (5)Use downtown skyways between buildings and through retail space during bad weather. (6)Outdoor route is 2,640 feet (0.5 mile). Together with distance travelled during indoor portion of assessment (0.25 mile), total observed distance is 0.75 mile. (7)Light rail station (not a trip on the rail, but navigating the station). Outdoor Route Features To ta l D ist an ce (f t) M ea su re d In te rv al s R es t A re a(s ) Cu rb (s) Cu rb R am p(s ) H ill (s) B ro ke n Pa ve m en t O th er S ur fa ce s U nc on tro lle d Cr os sin g Co nt ro lle d Cr os sin g B us R id e Tr ai n Ri de O th er Muni N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A CCRTA 660 STA N/A (1) Pierce 2,500+ SamTrans N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A JTA N/A DTS 2,640 (2) CMTA 3,960 COTA N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A ACCESS 2,640 (3) TriMet 2,640 MTA N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A BCT 2,972 (4) RTC 1,320 KC Metro 2,640 UTA 3,927 Metro Mobility 3,960 (5) DART 2,640 OCTA N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A SEPTA 1,320 Valley Metro 2,640 (6) (7) MBTA 2,640 (1) RTA 2,640 (3) ASI N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A TABLE 12 OUTDOOR ROUTE FEATURES

24 Two agencies (TriMet and DART) incorporate bus and rail trips into the outdoor route for some applicants. One agency (UTA) incorporates trips on its rail system as part of the route. ELIGIBILITY DETERMINATION OUTCOMES Table 13 provides determination outcomes for each agency. This includes total determinations per year; the number and percentage of applicants granted unconditional, conditional and temporary eligibility; and the number and percentage found not eligible. Three agencies did not record temporary as a separate category and included these determinations in unconditional or conditional eligibility. One agency granted non-ADA eligibility for applicants needing immediate service for life-sustaining medical treatments. The percentage of applicants granted unconditional eligibil- ity ranged from 48.3% to 84.1%. Conditional eligibility ranged from 12.1% to 36.5% (note that Muni reported 36.7%; how- ever, this includes applicants granted temporary eligibility; therefore, nontemporary conditional was likely 5 to 10 per- centage points lower). Temporary eligibility, for the agencies that recorded this, ranged from 2% to 22.8%. The percentage of applicants found not eligible ranged from 0.6% to 15.8%. TABLE 13 ADA PARATRANSIT ELIGIBILITY DETERMINATION OUTCOME STATISTICS Transit Agency Determination Outcomes (no./%) Totals Unconditional Conditional Temporary Not Eligible Other Muni 383 (54.3%) 259 (36.7%) Included (1) 63 (8.9%) 0 705 CCRTA 592 (75.4%) 143 (18.2%) 29 (3.7%) 20 (2.6%) (0.1%) (2) 785 STA 1,688 (84.1%) 271 (13.5%) Included (3) 49 (2.4%) 0 2,008 Pierce 2,445 (75.6%) 620 (19.2%) N/A 168 (5.2%) 0 3,233 SamTrans 1,958 (68.2%) 464 (16.2%) 398 (13.9%) 51 (1.8%) 0 2,871 JTA 879 (90.8%) 89 (9.2%) 968 DTS 3,536 (75.7%) 564 (12.1%) 362 (7.7%) 211 (4.5%) 0 4,673 CMTA 1,489 (51.6%) 604 (20.9%) 659 (22.8%) 137 (4.7%) 0 2,889 COTA 1,341 (70.2%) 372 (19.5%) 187 (9.8%) 10 (0.5%) 0 1,910 ACCESS 354 (48.8%) 207 (28.6%) 67 (9.2%) 97 (13.4%) 0 725 TriMet 1,960 (58.7%) 877 (26.3%) 387 (11.6%) 114 (3.4%) 0 3,338 MTA 688 (67.5%) 290 (28.4%) 0 42 (4.1%) 0 1,020 BCT 2,698 (80.3%) 482 (14.3%) 97 (2.9%) 83 (2.5%) 0 3,360 RTC 2,687 (48.3%) 1,378 (24.8%) 552 (9.9%) 878 (15.8%) 65 (1.2%) 5,560 KC Metro 3,355 (69.4%) 1,428 (29.5%) Included (3) 51 (1.1%) 0 4,834 UTA 726 (64.1%) 304 (26.8%) 54 (4.8%) 7 (0.6%) 42 (3.7%) 1,133 Metro Mobility 6,601 (77.1%) 1,151 (13.4%) 571 (6.7%) 238 (2.8%) 0 8,561 DART 1,919 (62.6%) 822 (26.8%) Included (3) 326 (10.6%) 0 3,067 OCTA 4,912 (80%) 638 (10.3%) 544 (8.8%) 72 (0.8%) 0 6,166 SEPTA 1,689 (56.5%) 1,091 (36.5%) 170 (5.7%) 39 (1.3%) 0 2,989 Valley Metro 3,207 (67.5%) 881 (18.5%) 520 (10.9%) 145 (3.1%) 0 4,753 MBTA 8,724 (70.6%) 689 (5.6%) 992 (8.0%) 141 (1.1%) 1,806 (14.6%) (4) 12,352 RTA 10,532 (79.2%) 2,370 (17.8%) 263 (2.0%) 133 (1.0%) 0 13,298 ASI 22,385 (56.7%) 7,300 (18.5%) 4,857 (12.3%) 4,941 (12.5%) 0 39,483 (1) Temporary determinations included in conditional determinations. (2) Other is another type of conditional/temporary. (3) Temporary determinations included in unconditional and conditional determinations. (4) Visitors and medical necessity.