Practices for Establishing ADA Paratransit Eligibility Assessment Facilities (2015)

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25 provided as Figure 2. This plan shows the lobby and adminis- trative office area, and includes a waiting area (A), a separate reception area with two desks and office equipment (B), four staff offices that serve as interview rooms (C), an open area between the offices (D), and a kitchen area with an informa- tion technology closet (E). The center is 1,932 ft2 in size. Accessible restrooms are located a short distance from the main entrance of the eligibility center, down the common hallway. When applicants arrive at the eligibility center, they are asked to complete a four-page intake form to verify general information (name, address, phone number, etc.) already on file. Applicants are also asked to sign a release of information form to allow staff to contact and obtain additional infor- mation from professionals such as medical, vision, or men- tal health care providers; social workers; or therapists. An Applicant Agreement, which details the eligibility process, is included in the four page packet, and applicants are asked to acknowledge that they have read the agreement by signing the form. The intake form is reviewed by intake staff and a tablet com- puter is used to take a photo of the applicant, which is used to create a photo ID card if the applicant is determined to be eligible. The applicant is assigned to one of three mobility coor- dinators (MCs) at the center. The MCs are required to have experience working with people with disabilities, such as job trainers or counselors, or occupational therapy assistants (OTAs). Other center staff includes two administrative assis- tants, a travel trainer, and a manager who also conducts inter- views as needed (seven total). The MCs review the information in the intake form and then conduct an extensive interview. If information obtained in the interview indicates a physical disability, MCs perform a Tinetti Gait and Balance test at the end of the interview. This test is done in the central open area between the staff offices. If the Tinetti test indicates a high risk of falling, no further physical functional assessments are conducted. If the results of this test indicate no significant risk of falling, applicants are asked to complete a walk with the MC. The walk involves using the building elevators to get to the first floor (A) and then an outdoor walk along a measured course that is 0.5 mile This chapter contains more detailed information about eligibility determination processes and eligibility facilities used by several of the transit agencies that were surveyed. Transit agencies highlighted were selected to illustrate the range of possible approaches—from basic facilities with limited special props, to elaborate facilities with extensive props. Agencies were also selected to illustrate processes that rely primarily on outdoor assessments in the real environment (with limited indoor facilities often used as a back-up) and processes that conduct indoor assessments with more elaborate facilities and indoor props. DEPARTMENT OF TRANSPORTATION SERVICES, HONOLULU, HAWAII DTS uses a process that relies primarily on outdoor assess- ments in the real environment with limited indoor facilities and props. DTS contracts with Paratransit, Inc. (dba Innovative Paradigms), which manages all aspects of the process. Eligibility Determination Process and Facilities To apply for ADA paratransit eligibility, new and recertifying individuals simply contact DTS’s eligibility center to arrange a date and time for an in-person interview and functional assess- ment. DTS does not require applicants to complete a paper application. Information from health/medical professionals is required of some applicants or obtained as needed. Contrac- tor staff at the eligibility center gathers general information from applicants such as name, address, phone number, type of disability, and mobility aids used at the initial contact. Staff informs applicants that they may be asked to participate in an outdoor walk and reviews a list of the information they should bring to the interview. Applicants with psychiatric or vision disabilities are requested to bring documentation of the dis- ability to the interview. Applicants are invited to bring any available information that might be helpful for understanding their disability and functional ability, but this is not required. Staff also asks if transportation to and from the interview is needed; if so, this is arranged in conjunction with the DTS paratransit contractor. DTS’s single eligibility center is located on the 8th floor of an office building at 1100 Ward Avenue in downtown Honolulu, and serves the DTS paratransit area that encom- passes the entire Island of Oahu. A floor plan of the center is chapter four CASE EXAMPLES

26 long (2,640 ft). A map of the outdoor route is provided as Figure 3. Photos showing some of the outdoor route features are provided in Figure 4 (a–d). After exiting the building, applicants walk one block on Ward Avenue, cross Ward Avenue at a light-controlled inter- section to a park (B), navigate various surfaces within the park (C), and return to Ward Avenue where they cross again and travel one block on South Beretania Street (D). They then cross Hale Makai Street at a light-controlled intersection (E), travel one block on Hale Makai Street (F), cross again at an uncontrolled intersection (G), walk one block on South Hotel Street to the building entrance (H), and return using the eleva- tors to the eligibility center (marked as HVEC on Figure 3). In addition to the controlled and uncontrolled street crossings, the route includes curbs, curb ramps, stairs, hills, broken pave- ment, and various other surfaces. There are also driveways that create cross-slopes. In the unlikely event of bad weather in Honolulu, an indoor measured route has been established using the hall- ways, lobby area, and elevators within the office building (see Figure 5). Applicants with dementia or memory-related disabilities may be asked to complete the Mini Mental Status Exam (MMSE). Depending on the results and on information from the interview, they may also be asked to complete the out- door or indoor walk. Their ability to follow instructions to complete the course, use the elevator, safely cross streets, and remain oriented to their location is assessed along the walk. Applicants with some vision loss, but not legally blind, may also be asked to complete the outdoor or indoor walks. The ability to read street signs, navigate along the pathways, and safely cross streets is assessed. Determinations for appli- cants with significant vision loss are based on information provided by applicants and professionals familiar with appli- cants. Determinations for applicants with psychiatric disabili- ties and seizure conditions are also based on information from applicants and professionals. To allow for a paperless environment, all records are scanned, saved on a secure server, and any paper is shredded. Decision-Making Process DTS implemented its current process in 2009. Prior to this, determinations were made based largely on a paper application, with in-person interviews and assessments conducted on an as-needed basis. Leading up to the current process, DTS had experienced a steady increase in demand for its ADA para- transit service (The Handi-Van). A study was commissioned Main Entrance (A) (B) (C) (C) (C) (C) (D) (E) Legend (A) Waing area (B) Recepon area (C) Interview rooms (D) Open area (E) Kitchen/IT FIGURE 2 DTS eligibility center floor plan. (Courtesy: DTS and Innovative Paradigms.)

27 (A) (B) (C) (D) (E) (F)(G) (H) FIGURE 3 DTS outdoor assessment route. (Courtesy: DTS and Innovative Paradigms.)

28 (a) (b) (c) (d) FIGURE 4 Photos of DTS outdoor route: (a) Sidewalk; (b) Controlled intersection; (c) Varied surfaces; (d) Dirt path in park. (Courtesy: DTS and Innovative Paradigms.)

29 FIGURE 5 DTS indoor (back-up) assessment route. (Courtesy: DTS and Innovative Paradigms.) of the The Handi-Van service to help ensure that its trips were provided when riders truly could not use fixed-route transit. One of the suggestions was for a more thorough eligibility determination process. The study included extensive community outreach. DTS’s active advisory committee was also involved in the study, the preparation of a Request for Proposal (RFP) for an eligibility contractor, review of proposals, and the final design of the current process. Build-Out and Operating Costs DTS reported that the contractor allocated approximately $86,000 to build-out the eligibility center; almost all of which was spent on building and equipping the offices, waiting area, and other common areas. Beyond the photo ID equipment and a scale for weighing mobility devices, no special equip- ment was purchased and no props were built. Annual rent, utilities, and other facility costs total $96,142.

30 Process Statistics and Outcomes DTS reported that its contractor conducts 4,629 interviews each year. A total of 4,348 functional assessments are per- formed each year. The contractor makes eligibility decisions and then pre- pares and sends letters of determination. DTS spot checks determinations and oversees the appeals process. The DTS contractor has found 75.7% of all applicants to be unconditionally eligible, 12.1% to be conditionally eligible, 7.7% to be eligible for temporary service, and 4.5% to not be eligible. Overall Experience and Lessons Learned DTS indicated that it has been pleased with the new process. Staff noted that there were some initial concerns expressed by applicants and the community—primarily about the time and distance to get to and from the eligibility center, and ques- tions about staff qualifications. These issues have been far outweighed, however, by satisfaction with how easy it is to complete the new process—there is no application or need to visit medical professionals to acquire health information, and everything (the interview and assessment) can be accomplished in one visit. The DTS contractor, which also manages similar pro- cesses in Boston (Massachusetts) and Spokane (Washington), described several lessons learned from its experiences at all current locations. • It is important to consider access to the eligibility center by paratransit vehicles. The amount of pickup and drop- off space depends of the application volume and the percentage of applicants who will need transportation. The number of applicants who use the paratransit service will also depend in part on ease of access by fixed-route transit as well as private automobile. In larger operations, care must be taken to simultaneously accommodate multiple paratransit vehicles in order to move applicants in and out of the facility. This can impose a large space demand outside of the facility itself. Depending on the physical layout, the logistics of moving paratransit vehi- cles in and out can be challenging. Space needed to load and unload wheelchairs is significant. • Access by private automobile must also be considered. Depending on the community, many people may arrive at the facility in personal vehicles and parking needs to be provided. If there are fees for parking, vouchers to cover the cost of the trip should be included in the budget and made available to applicants. • While Innovative Paradigms offers a paperless process, some communities may still require paper applications or the archiving of certain paper records. If this is the case, space for record storage must be included in the facility design. • The accessibility of the center, as well as any larger building and area within which it is housed, must be considered. This includes push button access on all doors that applicants might use. The accessibility of restrooms and other common spaces must also be considered. • Waiting areas for individuals arriving or departing from the eligibility process should be large enough to accom- modate the anticipated volume including companions, family, or others who may come with them. • The administrative staff managing the waiting area should be separated from visitors if at all possible (an arrangement similar to that used in medical offices works well). This is important because receptionists are often occupied making appointments or communicating with others about confidential matters. • Some entertainment in the waiting area is appropriate. The DTS contractor noted that videos of I Love Lucy are shown in the waiting areas of facilities it manages. PORT AUTHORITY OF ALLEGHENY COUNTY/ ACCESS TRANSPORTATION SYSTEMS, PITTSBURGH, PENNSYLVANIA Access Transportation Systems (ACCESS) serves as the paratransit broker for the Port Authority of Allegheny County (PAAC). ACCESS manages the eligibility determination process for ADA paratransit services as well as contracting of service delivery. ACCESS is considered a pioneer in the development and implementation of in-person interviews and functional assessments for determining ADA paratransit eligi- bility. Physical functional assessments are conducted outdoors in the real environment whenever possible. Some indoor props are used to supplement the outdoor route. Cognitive assess- ments are done using the FACTS and MMSE tests. Eligibility Determination Process and Facilities Persons interested in applying for ADA paratransit eligi- bility contact ACCESS to receive a paper application form. Applicants are also required to provide professional verifica- tion of disability that includes diagnosis, date of onset, and prognosis. More detailed information from medical profession- als is obtained by ACCESS staff for applicants with psychiatric disabilities, vision impairment, and seizure conditions. Applicants return the form and verification to ACCESS, which then reviews it to ensure that all required information has been provided. ACCESS then contacts applicants to sched- ule in-person interviews and functional assessments. Based on the information provided, some applicants are scheduled for interviews only and not functional assessments. During calls to schedule appointments, staff explains the in-person process so that applicants will be prepared for an outdoor walk. Staff also requests that applicants come with any mobility device or devices they use when traveling in the community, reminds them to take any prescribed medications, and asks if they need transportation. If transportation is needed, it is scheduled on

31 the ADA paratransit service. Because ACCESS is located close to reliable fixed-route transit and with ample nearby parking, about half of all applicants use transit or arrive by car. All new applicants are required to appear in person. Recertification is done approximately 85% of the time based on simply an updated paper application. Subsequent inter- views and functional assessments are required only if there a change in a mobility device(s) that significantly affects func- tional abilities. The assessment center and eligibility staff are located in the ACCESS offices, which are on the 4th floor of an office building at 650 Smithfield Street in downtown Pittsburgh. A floor plan of the ACCESS offices, including the eligibil- ity determination areas, is provided as Figure 6. Photos of props and other facilities at the eligibility office are shown in Figure 7 (a–c). ACCESS administrative offices, including the office of the eligibility program manager are labeled (A). When applicants arrive, they are greeted at the main reception area (B1) and directed to the eligibility waiting room (B2), which is furnished with chairs, a water cooler, magazines, a clock, and a television monitor that plays selected public tele- vision shows featuring various neighborhoods in Pittsburgh. ACCESS has two full-time employees who process appli- cations, schedule appointments, arrange transportation, con- duct interviews, give the FACTS and MMSE tests, make final 1 2 Legend (A) Admin. offices (B1) Main recepon (B2) Eligibility waing room (C) Restrooms (D) Interview rooms (F) Physical funconal assessment area (G) FACTS test area FIGURE 6 ACCESS main offices, including Eligibility Determination Program. (Courtesy: ACCESS Transportation Systems.)

32 (a) (b) (c) FIGURE 7 ACCESS indoor eligibility facilities: (a) Half-bus mock-up; (b) Disembarking using bus ramp; (c) Securement area in bus mock-up. (Courtesy: ACCESS Transportation Systems.)

33 determinations, and send out determination letters. ACCESS contracts with Easter Seals of Western Pennsylvania for the service of two PTs, who work at the ACCESS offices and perform physical functional assessments. A member of the ACCESS staff meets applicants in the eli- gibility waiting room, shows them to one of the two offices used for interviews (D), conducts the interview, and, if the applicant has a cognitive disability, administers either the MMSE or the FACTS test. Props for the FACTS test are located in the space marked (G) in Figure 6. A photo of the applicant is also taken. The staff person next decides if a physical functional assessment is needed. Determinations are made for about 30% of applicants based on information derived from appli- cation forms, medical/health professionals, and interviews (including cognitive assessments). The FACTS or MMSE tests are performed about 18% of the time, while about 67% of applicants participate in physical functional assessments. If a physical functional assessment is required, a PT meets the applicant and escorts them to the physical functional assessment area (F). The PT explains the process, conducts a brief interview, and uses a pulse oximeter to record baseline pulse and blood oxygen levels. The PT then conducts a Tinetti Balance and Gait test to determine the applicant’s risk of falling—in part to determine if applicants can stand on a mov- ing vehicle and navigate certain terrain, but also to help decide if it is appropriate to proceed with a full functional assessment. A mock-up of a curb and curb ramp and of a low-floor bus are located in the assessment area (see Figure 7 a–c) and are used to determine if the applicant can step up and down 6-in. curbs, navigate curb ramps, use ramps to enter and exit low-floor buses, and navigate to and from a seat or securement area. Next, the PT requests that the applicant walk to the eleva- tors, go to the first floor, and complete the outdoor assessment. A full outdoor route, as well as a shortened route, are avail- able. The full route (called Route Two) is shown in Figure 8, the shortened route (Route One) is Figure 9, and photos taken along the routes are provided in Figure 10 a–d. The full outdoor assessment is 0.5 mile long and involves the following: • Navigating two curb ramps and crossing a light-controlled intersection at 7th Avenue and Smithfield Street; • Proceeding down 7th Avenue to Grant Street and navigating curb ramps and a controlled crossing at 7th Avenue and William Penn Place; • Navigating two more curb ramps and a controlled street crossing at 7th Avenue and Grant Street; • Proceeding down Grant Street to Strawberry Way, navi- gating additional curb ramps, and crossing Strawberry Way; • Proceeding up Strawberry Way across William Penn Place, which is an uncontrolled street crossing. Beyond William Penn Place, Strawberry Way is a smaller alley with uneven and broken pavement and a variety of walk- ing obstacles (see Figure 10d). • Navigating two more curb ramps and a second uncon- trolled street crossing at Strawberry Way and Smithfield Street; and • Proceeding along Smithfield Street back to the ACCESS offices. Along the way there are benches and natural resting areas (places where applicants can sit or lean to rest). If it becomes obvious that the applicant cannot complete the full route, the PT has the option to shorten the route by taking one of the side streets before Grant Street. A route that is half the distance (0.25 mile) involves crossing at William Penn Place [see Alternate Route (Route One) in Figure 9]. In severe weather, the PT uses the hallways in the building to simulate an outdoor walk. Even in severe weather, ACCESS tries to have applicants at least complete one street crossing— the crossing at Smithfield and 7th Avenue, which is just out- side the entrance to the building. Applicants with limited vision, but who are not legally blind, also participate in the indoor and outdoor functional assessments. Applicants who are legally blind are granted at least conditional eligibility and any conditions are developed using information provided by the applicant and profes- sionals familiar with them. Similarly, determinations for appli- cants with severe psychiatric disabilities or seizure conditions that significantly affect their ability to travel independently by fixed route are made based on information obtained from the application, medical professionals, and the in-person interview. Applicants with less severe psychiatric disabilities or seizure conditions who also have a physical disability might be asked to participate in the indoor and outdoor functional assessment. Unlike many other agencies that responded to the survey, ACCESS does not have a scale for measuring the weight of the applicant’s mobility devices at its assessment center. ACCESS staff noted that vehicles in the system can accom- modate up to 800 pounds and it is rare they encounter mobility devices that exceed this weight. Rather than ask all mobility device users to be weighed, ACCESS gathers information on an as-needed basis. If a large applicant using a power wheel- chair applies, general questions about the person’s weight are asked. The make and model of the wheelchair, as well as any add-ons such as extra batteries, are noted. ACCESS staff researches the weight of the mobility device online and calculates the combined weight of the applicant and the wheel- chair. If the 800-pound maximum is exceeded, the applicant is alerted to the problem. Attempts are made to agree on ways that transportation can continue to be provided, such as using another mobility device when traveling by transit or having the person board separately from the mobility device. ACCESS does have a template on the floor of the indoor functional assessment area that is used to determine if mobil- ity devices exceed the maximum width or length than can be accommodated on vehicles.

34 Decision-Making Process ACCESS was one of a handful of transit agencies that used in-person functional assessments to determine eligibility for paratransit services before the passage of the ADA. A simple test of whether riders could board and exit inaccessible buses using stairs was used. Individuals with physical disabilities were asked to participate in this assessment. Eligibility for riders with other types of disabilities was determined based on a paper application process. It was therefore natural for ACCESS to consider continu- ing with in-person assessments after the passage of the ADA. Alternatives for expanding the prior assessment to cover all C = curb ramps D = hills/slopes E = broken pavement F = other surfaces G = uncontrolled intersecons H = controlled intersecons Street Start here FIGURE 8 ACCESS’ full 0.5 mile outdoor assessment route. (Courtesy: ACCESS Transportation Systems.)

35 categories of ADA paratransit eligibility were developed as part of the ADA paratransit planning process in 1991. The process included extensive outreach, public workshops, dis- cussions with ACCESS’s consumer advisory committee, and a public hearing. The input was largely in support of continu- ing an in-person process. The primary concern and request from the community was that the process be equitable and fair, and that all applicants be asked to appear in person, and not just individuals with physical disabilities. Because the development of the eligibility determination process was completed at the same time that the ADA para- transit plan was being developed, all aspects of ADA para- transit service were discussed together. Primary community concerns about the plan were: (1) that the service area not be reduced from all of Allegheny County to just the minimum required 0.75-mile corridors; and (2) that fares not be raised to the maximum allowed, which was twice the fixed-route fares. ACCESS and PAAC agreed that if the community C = curb ramps D = hills/slopes E = broken pavement F = other surfaces G = uncontrolled intersecons H = controlled intersecons Street Start here FIGURE 9 ACCESS’ alternate 0.25 mile outdoor assessment route. (Courtesy: ACCESS Transportation Systems.)

36 supported thorough eligibility determinations they would attempt to continue to serve the entire county and preserve ADA paratransit fares similar to fixed-route fares. The agencies have been able to keep this agreement. In 2002, ACCESS was one of the transit agencies selected by ESPA to assist with the development of guidance for in-person eligibility determination processes. ACCESS closely follows the guidance that was developed. Multiple facilities were not considered during the plan- ning process. Downtown Pittsburgh is the geographic center of Allegheny County and ACCESS staff noted that getting to the commercial business district rarely takes more than 30 minutes. One eligibility assessment site was considered adequate to serve residents throughout the area. Build-Out and Operating Costs ACCESS reported that the new props for its indoor assessment area were constructed with the assistance of Port Authority of Allegheny County (PAAC) maintenance and construction employees. Total cost for the indoor equipment and props came to $25,000. The office space for the eligibility program was available within the larger ACCESS offices and minimal costs were incurred in the ensuing renovation. Annual rent, utilities, and maintenance for the assessment program portion of the facility is approximately $20,700. Process Statistics and Outcomes ACCESS makes about 725 ADA paratransit eligibility deter- minations each year. The relatively small number of determi- (a) (b) (c) (d) FIGURE 10 ACCESS’ outdoor assessment route: (a) Controlled intersection at Grant and 7th Avenue; (b) Uncontrolled street crossing; (c) Curbs and uneven surfaces; (d) Uneven surfaces along Strawberry Way. (Courtesy: ACCESS Transportation Systems.)

37 nations for the size of the population is because state lottery funding pays for paratransit service for seniors, which greatly reduces the number of seniors who request ADA paratransit eligibility. ACCESS finds 48.8% of all applicants to be uncondition- ally eligible, 28.6% to be conditionally eligible, 9.2% to be eligible for temporary service, and 13.4% to not be eligible. Lessons Learned ACCESS indicated that it has been generally pleased with the process. Staff also noted that there has been good community acceptance from the start, which can be attributed to the exten- sive outreach and community involvement that was conducted. For many years ACCESS used low-cost indoor props in order to be as cost-effective as possible. This included a static bus lift and a simple plywood mock-up of a curb and curb ramp. The agency recently worked with PAAC to construct the more elaborate bus mock-up and curb/curb ramp mock-up shown in Figure 7. Greater applicant satisfaction and confidence in the process has been reported from those who have completed the functional assessment since the improved props were added. ACCESS strongly believes that outdoor assessments in the real environment provide the most accurate picture of true travel abilities. With a substantial reliance on outdoor assess- ments, and limited indoor props, it can be a challenge to ensure thorough determinations when severe weather precludes out- door walks; therefore, the experience and training of the PTs becomes critical when indoor assessments are done. Maxi- mum reasonable walking distance must be estimated based on more limited and less stressful indoor walks, and the ability to navigate various surfaces must be deduced based on the Tinetti test. The ability to safely cross streets is the most difficult issue to determine using only indoor observations, which is why ACCESS almost always has applicants go outside briefly and cross one busy intersection, even in severe weather. It is also important to plan for emergencies and develop a strong safety plan when doing outdoor functional assess- ments. The PTs who conduct assessments are given dedicated cell phones that ring immediately in the ACCESS offices and have no other purpose. The PTs try to ensure that the appli- cants do not venture so far on the outdoor course that they will find it difficult to return. However, this does happen on rare occasions. ACCESS keeps mobility devices on hand that can be used to assist applicants who start but cannot finish the outdoor route. A logistical lesson that was learned from experience is that if the assessments are on the upper floors of a shared building it is important to have more than one elevator. Otherwise the process can be delayed and interrupted while waiting for elevators to become available. ACCESS staff also noted that it is important when in a leased office facility to be sure that restrooms are fully acces- sible and preferably located on the same floor and close to the eligibility determination area. ACCESS has learned that the waiting area needs to be large enough to not only accommodate the maximum number of applicants expected at any time, but those who might accom- pany them. It is also important that the area be able to accom- modate all applicants if there are issues with transportation and some have to wait for rides (or when others arrive early). ACCESS also noted that it is important to ensure privacy throughout the process. The functional assessment area should be separate from spaces where other applicants or employees might be located. Interviews rooms and waiting rooms should not have a view of the functional assessment area. Finally, ACCESS staff noted that keeping the process on schedule can be a challenge. Although ACCESS requires that applications be completed and sent in advance, which helps to plan the types of assessments that likely will be needed, interviews can run long and functional assessments that were not initially expected might have to be conducted. Some down time needs to be built into the scheduling of appointments. In addition, it can be helpful if the eligibility staff is cross- trained to assist with parts of the process. TRI-COUNTY METROPOLITAN TRANSPORTATION DISTRICT, PORTLAND, OREGON The Tri-County Transportation District (TriMet) has facil ities for both indoor and outdoor functional assessments. TriMet utilizes FACTS and the MMSE for assessments of applicants with cognitive disabilities. A contractor assists with functional assessments. TriMet staff review applications, gather infor- mation from health care professionals familiar with appli- cants, conduct interviews, and make final determinations. Eligibility Determination Process and Facilities Individuals interested in applying for ADA paratransit eligibil- ity are required to complete an application form. Applications can be requested from TriMet eligibility staff or downloaded from TriMet’s website. Human service and disability agen- cies in the service area also have copies of application forms that they make available to clients and program participants. TriMet works closely with these agencies to ensure that they have the latest version of the application materials. Part of the application form requests the name of a health professional who can be contacted to acquire information about the applicant’s disability and functional abilities. The form also includes a release of such information that is to be signed by the applicant.

38 Two TriMet administrative staff (accessible transporta- tion program assistants) review the application forms once they are received. If the Medical Release Forms are com- plete, they immediately (same day) fax forms to the named health professionals requesting verification of disability and information about functional ability. The goal is to obtain such information in all cases and to have this information prior to the time of in-person interviews and functional assessments. The administrative staff also assigns applications to one of four eligibility coordinators (ECs). The ECs review the appli- cation form and enter the information into TriMet’s eligibility computer module. Once the information has been entered, a full-time staff person (eligibility scheduler) contacts the applicants to arrange in-person interviews and assessments. The interview and assessment are briefly described so the applicants will be pre- pared for a possible outdoor walk. Applicants are also asked to bring the mobility device or devices that they use when traveling within the community. Applicants are also asked if they will need transportation; if yes, this is arranged through TriMet’s ADA paratransit service. All new applicants are requested to participate in an interview and assessment as needed. Most riders who are recertifying are also asked to appear in person; however, for some riders a second in-person interview and assessment is waived and recertification only involves submitting an updated application form. TriMet only recently implemented this sim- plified recertification process for riders whose functional abilities are not likely to change. The agency indicated it will most likely expand the simplified process in the future. When applicants arrive they are greeted by an Accessible Transportation Program (ATP) assistant and the appropriate EC is also alerted. TriMet indicated that applicants are typi- cally assigned to the EC that originally reviewed the applica- tion form, but that for scheduling flexibility any EC can meet with any applicant at this time. The ECs greet the applicants and proceed to an area where they can take photos and measure and weigh mobility devices (as needed). This is followed by the interview. If an applicant has a cognitive disability, the EC may also conduct the MMSE. Based on information in the application form, obtained from medical professionals, and obtained in the interview, ECs decide if functional assessments are needed. If so, the ECs notify TriMet’s functional assessment contractor— Medical Transportation Management (MTM). MTM provides an on-site manager and two assessment evaluators (AEs). One of the AEs escorts the applicant to where functional assessments are conducted. Applicants with physical disabilities complete an indoor assessment, as needed, followed by an outdoor assessment. Applicants with cognitive disabilities, primarily those with intellectual disabilities, are asked to participate in the FACTS test. Some applicants with vision disabilities also participate in indoor or outdoor assessments. Determinations for persons with significant vision impairments are made based on infor- mation they themselves provide and verification of disability and abilities from medical professionals. Similarly, some appli- cants with psychiatric disabilities and seizure conditions may also be asked to participate in assessments, particularly if there is an indication of some independent travel. However, deter- minations for applicants with significant psychiatric or seizure conditions are made based on information from the applica- tion forms, interviews, and a professional(s) familiar with their medical history. TriMet’s Transit Mobility Center is located across from the agency’s downtown transit mall in Portland. It is notable that TriMet carefully chose the name of the facility to empha- size that the goal of the process is to assess broader transit mobility skills, rather than just determine eligibility for ADA paratransit services. The facility has two distinct areas; one is the area that houses TriMet staff and is used to conduct inter- views, the other is where indoor functional assessments are conducted and that houses MTM staff. Figures 11–13 show the floor plans for these two areas. Photos that show portions of these areas, with letter codes are provided as Figure 14 (a–f ). A summary of TriMet staffing is also provided on Figure 11. As shown in Figure 11, the main entrance of the Center is off NW Davis Street. The TriMet area includes administrative offices (A), a reception area and waiting room (B), a restroom (C), five offices for the ECs (D), an area for measuring and weighing mobility devices (E), a kitchen/break area (F), and banks of file cabinets for file storage (H). The waiting area has 15 chairs and there are three others nearby—adequate seating for the number of applicants sched- uled plus others who might accompany them. The waiting area has bottled water, magazines, and a telephone. A TV wall moni- tor shows classic shows such as Little House on the Prairie and I Love Lucy, which are intended to help applicants relax before their interview and assessment. To access the assessment area, applicants exit on NW 5th Avenue and proceed about one-half block up the avenue. The main entrance to the assessment area is on the same block, just up NW 5th Avenue (see Figure 12). The MTM administra- tive space in the assessment area includes a reception/waiting area (A), four offices for the manager and two AEs (B), open offices for future expansion as needed (C), an interview room (D), a conference room (E), and a kitchen/break room (F). The large open area is used for indoor assessments. The location of indoor assessment equipment and props is shown in Figure 13. Applicants wait in the reception area just inside the main entrance. Interviews are conducted in the designated interview room, the conference room, or one of the staff offices (depending on the schedule and number

TriMet Transit Mobility Center Administra ve Offices (Eligibility) Mobility Device Evals Main Entrance Eligibility Administra on (A) • In-person interviews, device evalua ons, eligibility process administra on • TriMet ATP staff include: ATP Assistants (2) Eligibility Coordinators (4) Sr. Eligibility Specialist (1) Manager (1) (B) (C) (D) (D) (E) (H) (H) (H) (A) (A) (D) (D) (D) (F) Legend (A) Admin. offices (B) Recep on/wai ng room (C) Restroom (D) EC offices (E) Weighing/measuring area (F) Kitchen/break area (H) File cabinets FIGURE 11 TriMet Transit Mobility Center administrative offices. (Courtesy: TriMet.) TriMet Transit Mobility Center – Assessments Main Entrance Open Offices Assessment Contractors (MTM) (3-4 Contractors) Assessment Course Assessments & Transit Educaon (F) • Funconal Assessments • ATP Outreach • Conference Room available for agency use (A) (B) (B) (B) (B) (C) (C) (E) (D) (F) Legend (A) Recepon/ waing area (B) Staff offices (C) Open offices (D) Interview room (E) Conference room (F) Kitchen/break room FIGURE 12 TriMet Transit Mobility Center contractor administrative area. (Courtesy: TriMet.)

40 of applicants). The Tinetti Balance and Gait test is used to ensure that it is appropriate to ask applicants to complete the assessment course. The indoor assessment then includes: • Navigating to and then up a curb ramp (A) • Activating a pedestrian traffic control device at the top of the curb ramp (B) • Going down a curb ramp (C) and navigating a simu- lated street crossing • Ascending an 8-ft ramp and descending an 8-ft ramp with a 1:8 slope (D) • A bus stop with a bench is then placed after this ramp if applicants need to rest (E) • Walking to and then going up and down a 12-ft ramp with a slope of 1:16 (F) • Navigating a 12-ft area of Astroturf (G) • Navigating a 12-ft area of gravel (H) • Another bench is then located at this point (I) • Navigating 12 ft of uneven pavement (J) • Another rest area is here (bus stop with bench) (K) • Going up and down a 12-ft ramp with a 1:12 slope (L) • Walking to and then boarding a low-floor bus mock-up by means of a ramp, navigating to and from a seat or securement area, and exiting the bus mock-up (N) • Navigating on and off a bus lift and up and down bus stairs (O) • Stepping up and down a 6-in. curb (P). As noted earlier, TriMet asks certain applicants with cog- nitive disabilities to complete the FACTS test (primarily those with intellectual disabilities, which is the population for which FACTS was developed and validated). Part of the test is admin- istered in the Interview Room. The wayfinding portion of the test is set up along the indoor route. This is shown in the photo collage as Figure 14f. If applicants successfully complete the indoor assessment and demonstrate even greater abilities, they participate in an outdoor assessment. The outdoor route is shown in Figure 15. There are several outdoor assessment options. The standard outdoor assessment is as follows: • Up NW 5th Avenue across NW Everett (controlled crossing) to NW Flanders Street (A); • Cross NW 5th Avenue at NW Flanders (controlled crossing) (B); • Down NW 5th Avenue, across NW Everett (controlled crossing) to NW Davis (C); • Along NW Davis, crossing NW 4th Avenue (uncontrolled) to NW 3rd Avenue (D); • Up NW 3rd Avenue to NW Everett (E); • Down NW Everett, across NW 4th Avenue (uncontrolled) and NW 5th Avenue (controlled) to NW 6th Avenue (F); • Down NW 6th Avenue to NW Davis (G); • Along NW Davis to NW 5th Avenue (H); and • Back in the main entrance of the Transit Mobility Center (TriMet offices) (I). The standard outdoor course is 0.5 mile in length (2,640 ft) and passes by or near the main entrances of the Center at TriMet Transit Mobility Center Features of Assessment Course (F): A. Mock curb cut B. Crosswalk signal C. Mock sidewalk and curb cut D. 1:8 slope (16’-0”) w/metal handrails E. Bus stop with bench/pole F. 1:16 slope (24’-0” long) w/metal handrail G. Astroturf surface (12’ 0”) H. Gravel surface (12-0”) I. Bench (NIC) J. Uneven pavement surface (12’-0”) K. Bus stop with bench and pole (NIC) L. 1:12 slope (24’-0” long) M. Shelter with bus stop pole N. LF Bus mock-up with curb O. Bus li” and stairs P. Curb step-upAssessment Course LayoutAddi–onal restrooms in hallway (G) P FIGURE 13 TriMet Transit Mobility Center indoor assessment course layout. (Courtesy: TriMet.)

41 (a) (b) (c) (d) (e) (f) FIGURE 14 TriMet Transit Mobility Center: (a) Waiting area with TV; (b) Mobility device measurement area; (c) Ramps and various surfaces; (d) Low-floor ramp-equipped bus mock-up; (e) Bus lift and stairs mock-ups; (f) FACTS Wayfinding posters along route. (Courtesy: TriMet.)

Full ½ mile route Alternave route (A) (B) (C) (D) (E) (F) (G) (H) FIGURE 15 TriMet outdoor assessment course. (Courtesy: TriMet.)

43 several points in case the assessment needs to be terminated. There are also benches where applicants can rest along the way. If AEs determine from the indoor assessment that an appli- cant can travel some additional distance, but not the full out- door route, an alternative route is used that loops one block around the downtown transit mall—denoted by the dotted line in Figure 15. A third option, as appropriate, is to ask applicants to com- plete a combined bus and light rail trip. At the end of the standard route, applicants can board one of several TriMet buses that travel down NW 5th Avenue along the light rail tracks. After four to six blocks they can exit at a light rail station, wait for and board the light rail train, and return to a station that is one block from the main entrance to the Center (below NW Davis). If AEs believe that an applicant has the ability to always travel by fixed route, and are likely not ADA paratransit eligi- ble, they will typically have them complete the indoor course, the standard outdoor course, and also the trip by bus and train. Decision-Making Process Prior to the implementation of the current in-person process in April 2010, TriMet made eligibility determinations based on a paper application that only obtained information from the applicants. Verification of disability and information from a medical/health professional was optional. There had been a steady growth in riders and ridership. The rising cost of the service raised concerns about long-term sustainability. TriMet also observed changes in the way that eligibility determina- tions were being made across the country, with increased use of in-person interviews and functional assessments. An internal working group, which included staff from the operations, legal, accessibility, and finance departments, was established in 2008 to consider changes to the process. This group reviewed the current process, reviewed the process recommended by ESPA, and examined processes at other transit agencies. Following five meetings over four months the working group presented a recommendation to the Executive Director for review and approval by the internal leadership team. The recommendation to implement an in-person process was approved at the end of 2008. TriMet next took the plan to its Committee on Accessible Transportation (CAT). Together with CAT it convened a public workshop. Extensive outreach was done to riders and local disability and social service agencies. Approximately 90 people participated in the workshop. Community input was gathered from CAT and the workshops during the first six months of 2009. A final plan with the community and CAT support was finalized in July 2009. The Transit Mobility Center was built and an RFP pro- cess conducted for an assessment contractor from July 2009 through the end of the year. TriMet staff and contractor staff moved into the Center in January 2010 and began conducting interviews and assessments for new applicants only in April 2010. Recertification of current riders began a month later, in May 2010, once staff felt confident with the new process. Recertifications started slowly, about 100 per month with the most frequent riders, and were gradually increased (currently there are about 380 recertifications per month). A key part of the plan was to build the Transit Mobility Cen- ter in-house in a building leased by the transit agency. TriMet believed that doing this, rather than contracting out to build the facility, was less expensive. The maintenance shop constructed the bus mock-up and other props using spare bus parts, rela- tively basic materials, and existing staff. Portland also donated the traffic controls used in the simulated street crossing. Build-Out and Operating Costs The build-out of the entire facility, including the TriMet staff offices, the contractor staff offices, and the indoor assessment area cost $250,530 and, as noted earlier, took about six months to complete. Annual operating costs, including rent, utilities, and facility maintenance costs are approximately $144,000. Process Statistics and Outcomes About one-half of all decisions are made at the end of the inter- view without functional assessments and one-half include assessments. Thirty to 50 applicants each month complete the indoor assessment, the outdoor assessment, and also a trip on the bus and light rail. These tend to be applicants that are found to be able to use fixed-route transit for most or all trips. TriMet reports making about 3,300 eligibility determina- tions each year. TriMet finds about 58.7% of applicants to be unconditionally eligible and 26.3% to be conditionally eligible. Temporary eligibility is granted to about 11.6% of applicants, and about 3.4% of applicants are determined to be able to use the fixed-route service for all trips and not eligible for paratransit. Lessons Learned At the outset of the new process, the assessment contractor hired PTs and OTs to serve as AEs. Although these types of professionals are preferred, over time the contractor has found it difficult to attract and keep the necessary PTs and OTs. TriMet believes that most PTs and OTs prefer to work in rehabilitation rather than only perform ability assessments. TriMet and the contractor have actively recruited PTs and OTs, but indicated that other health professionals are also used. One of the current AEs is a recreational therapist and qualified travel trainer; the other two AEs have experience as emer- gency medical technicians and other work experience with people with disabilities.

44 TriMet indicated that they have been surprised by the number of service providers, caregivers, and others who accompany applicants to the interviews and assessments. The in-person process has proven to be an excellent opportunity to educate riders and the broader support community about ADA paratransit service—what it is and what it is not. The TriMet Eligibility Manager believes this public education has been as beneficial as the improvements in the accuracy and thoroughness of the determinations. Scheduling appointments with applicants has proven to be one of the more challenging parts of the process. TriMet and the assessment contractor have the resources to be able to offer appointments in only two or three days; however, many applicants would like to schedule appointments several weeks in advance. The process through which information is gathered from medical/health professionals has also evolved. TriMet started by faxing two-page forms to these professionals; however, getting this level of detail was sometimes difficult. A con- densed one-page form was then developed. TriMet has had more success requesting basic disability verification infor- mation at the outset and then following up if more detailed information is needed. The vast majority of applicants (approximately 90%) use TriMet’s ADA paratransit service to get to and from the Center. This is the case even though there is excellent access to fixed-route transit—the downtown transit mall is just across the street—and there is also plenty of parking in the area. To accommodate the number of paratransit vehicles coming and going from the Center, TriMet worked with the city to get a dedicated bus stop in front of the building. This has been important for minimizing pick-up and drop-off delays. TriMet indicated that it has been pleased with the new process. Staff also noted that the community appears to have accepted the new process. The agency credits much of the success to a positive working relationship with the assess- ment contractor. A sound cooperative working relationship has been developed that has allowed TriMet to make changes and improvements to the process as issues are identified. Finally, while building the Center in-house and leasing the facility has proven to be cost-effective, TriMet indicated that in the future it may have limited interest and competition for the assessment contract. Because the contractor is only asked to supply limited staff, not to build-out and provide the facility, the contract is relatively small. There has been less local and national interest in the contract from PT and OT firms than TriMet had hoped. CENTRAL OHIO TRANSIT AUTHORITY, COLUMBUS, OHIO The Central Ohio Transit Authority (COTA) is an example of a transit agency that conducts eligibility determinations in an indoor environment by transit agency staff. It is also an example of a combined assessment that makes observations of physical, cognitive, and sensory abilities along a common indoor course. Eligibility Determination Process and Facilities Individuals interested in applying for ADA paratransit eligi- bility are instructed to call COTA to request an application or to download a copy of the application from COTA’s web- site. Part of the form is completed by the applicant and part must be completed by a medical professional familiar with the applicant. After completing the application, the individual schedules an interview and assessment. At this time, COTA staff confirms that the application (including the professional verification) has been satisfactorily completed and reminds the applicant to bring the form with them to the assessment. Staff also gathers some basic information about disability, provides informa- tion about the interview and assessment so that the applicant knows what to expect, and asks the applicant to bring any mobility device they may use when traveling in the community. Applicants are also asked if they need transportation to and from the assessment center. If transportation is needed, it is arranged with the COTA paratransit operations center. All new applicants are asked to participate in an interview and functional assessment. Some individuals are granted “permanent” eligibility, and are able to recertify using a sim- plified paper application and do not need to appear in-person. Riders not granted permanent eligibility are also asked to appear in-person for interviews and functional assessments. COTA is considering a simplified recertification process that would require completion of an updated application form, but not participation in another assessment, for riders whose functional abilities are not likely to change. The assessment center is located with the ADA paratransit garage and operations center. Two floor plans are provided as Figures 16 and 17. Figure 16 shows the entire facility, includ- ing administrative and storage areas. Figure 17 provides more detail on the assessment course and props and indicates ramp lengths and slopes, types of surfaces, and other design infor- mation. Figure 18 (a–d) is a collage of pictures showing certain parts of the course. As indicated in Figure 16, the reception area and lobby are located outside the main assessment area (A). The waiting area has six chairs (two oversized and four regular), a television that shows a video featuring COTA’s accessible fixed-route and ADA paratransit services, magazines, and community service brochures provided by local agencies. The facility also includes a restroom (B), two offices for COTA’s eligibility administrators (EAs) that also function as interview rooms (C), an area with a scale for assessing the size and weight of mobility devices (D), an Ohio-required lactation room (for mothers who need to breast feed their infants (E), a recovery room with a large comfortable chair and water for individuals who need to rest during or after the

45 assessment (F), a file storage area (G), and an electronics and computer room (H) for the technology that controls the elec- tronics along the assessment course. The indoor course, where assessments are conducted, is in the central part of the facil- ity. COTA administrative offices, including the office of the eligibility manager, are located outside the assessment area. Visitor parking is provided at the building for applicants who choose to arrive by car. Fixed-route transit service is also nearby; however, COTA indicated that the building is in an industrial area and there are no sidewalks from nearby bus stops to the facility. When applicants arrive, they are greeted by a receptionist who collects the completed application form and any other documentation. This material is given to one of the two EAs who conduct the assessment. A photo of the applicant is also taken and used to make a photo ID if the applicant is deter- mined to be eligible. After reviewing the application form and any other infor- mation provided, the EA greets the applicant, proceeds to the assessment course area, and provides an overview of the pro- cess and course. If the applicant is using a wheelchair, the EA records its size and weight. The EA then takes the applicant through the indoor assessment course. The elements and flow of the course are shown in Figure 16. Ramp specifications and other prop descriptions are included in Figure 17. The following is a description of the course: • The assessment begins with a short walk (about 50 ft) that includes ascending a 6-ft ramp with a 1:12 slope. (A) (B) (F) (E) (C) (C) (G) To lobby and recepon (H) (D) Legend: (A) recepon and lobby; (B) restroom; (C) interview rooms; (D) area with scale to weigh and measure mobility devices; (E) lactaon room; (F) recovery room; (G) file storage; (H) computer room. FIGURE 16 Floor plan of COTA eligibility center. (Courtesy: COTA.)

46 • At the top of the ramp is the start of a simulated street crossing with traffic controls. The applicant activates the pedestrian crossing signal, waits for the light to change, and crosses the street. As shown in Figure 18a, the area is painted to resemble a streetscape. • Next, the applicant walks up a 16-ft ramp with a 1:8 slope, turns and descends a 32-ft ramp with a 1:16 slope. • The applicant then walks to and navigates across an area with a variety of surfaces, including artificial grass, gravel, broken and uneven pavement, and sand. • Next, the course loops around the facility, up a 30-ft ramp with a 1:12 slops, down five stairs, and to an area that is a simulated bus stop with a shelter, bench, and modified low-floor ramp-equipped bus. • If the applicant has a cognitive or vision disability, the EA uses a control panel at the bus stop to program the sequenced arrival of several buses. The bus mock-up has light-emitting diode (LED) signs that respond to the programmed sequence. The EA tells the person to look for a particular bus. The applicant identifies the correct bus, boards the bus, and navigates to a seat or securement area. The EA then shows the applicant a photo of where they should disembark. The inside of the windshield of the bus is a television screen onto which videos of actual routes can be projected. Five different routes were filmed and any of the five can be played on the windshield to simulate travel along the route. When the applicant sees the landmark described, she/he signals to exit, and then exits the bus. This portion of the assessment was adapted from the FACTS test. • If the applicant has a physical disability and no cog- nitive or vision disability, she/he simply boards the bus, navigates to and from a seat or securement area, and exits the bus. • The standard assessment is completed once the applicant exits the bus. FIGURE 17 Detail of COTA indoor assessment props. (Courtesy: COTA.)

47 If the EA still has questions about endurance and maxi- mum walking distance, the applicant is requested to walk certain portions of the course again. Additional routes have been measured to simulate walks of up to 0.5 mile (2,640 ft). Once the assessment is complete, the applicant returns to an office/interview room where an interview is conducted. Unlike processes set up by other agencies, COTA con- ducts the interview after the assessment is completed, which allows the EAs to discuss any issues observed along the course. Most applicants are asked to complete the assessment course, including applicants with physical disabilities, mild to moderate cognitive disabilities, and low vision. If the EA determines from the application information or during the initial introduction that an applicant has significant cog- nitive or vision disabilities and cannot independently wayfind, (a) (b) (c) (d) FIGURE 18 COTA Indoor Assessment Course (a) Simulated street crossing; (b) Half-bus with bus stop area and different surfaces; (c) Controls for bus stops routes; and (d ) TV in windshield of bus. (Courtesy: COTA.)

48 the assessment course is not used and the EA proceeds directly to an interview. The course is also not used for applicants with significant and uncontrolled seizure disorders or psychiatric disabilities. Such determinations are based on information from the application, the interview, and from health profes- sionals familiar with the applicant. COTA has two full-time EAs, one full-time mobility coordinator who schedules appointments and arranges trans- portation, and one part-time mobility coordinator who does intake. There is also one full-time program manager. There- fore, in total, there are 4.5 full-time employees dedicated to the eligibility determination process. COTA does not require that the EAs be PTs or OTs. The two EAs at the time of the study were a clinical counselor and an individual with a Master’s Degree in human service management and human ecology. Decision-Making Process Prior to implementing the current process, COTA used a paper application and follow-up telephone call with applicants or professionals, as needed. If additional information was needed, some applicants were asked to participate in interviews conducted by the local Goodwill Industries. There were no functional assessments. Over time, COTA realized that it was difficult to make thorough determinations based primarily on a paper applica- tion, and the current process was implemented so that better determinations could be made. Rising demand and cost was not a major factor in the decision; it was more that COTA wanted to be able to make better determinations. COTA spent about two years investigating alternative pro- cesses and discussing them with the community. It contacted and visited several agencies that had implemented in-person processes. During this time, COTA worked closely with its Accessible Transportation Advisory Committee (ATAC), which is made up of riders, as well as its Mobility Advisory Board (MAB), comprised of local agency representatives. Both committees provided input on the new process and supported the final plan to build an assessment center. COTA and its advisory committees always assumed that a single assessment center would be sufficient. Given the size of the service area, multiple facilities did not need to be considered. In addition to local input, COTA used the guidance pro- vided by ESPA on the recommended elements of a functional assessment. The design work was done by a local architectural firm. ATAC was particularly involved in reviewing plans as they were developed and advising COTA as the facility was being built. Build-Out and Operating Costs COTA’s eligibility center covers 3,276 ft2, about 60 ft by 60 ft. COTA built the operations center from the ground up and incor- porated the eligibility center. The pro-rated building purchase cost for just the eligibility assessment area was estimated by staff to be about $690,000. Build-out of the assessment center cost $147,980, which included everything except the modified bus and the murals on the walls of the Columbus streetscape. The bus was donated by Ohio State University. COTA mainte- nance staff made modifications to the bus to make it exactly like buses in the COTA fleet. The bus—originally a 40-footer—was also shortened by cutting it in thirds and welding the front and back sections together to make a half bus. Facility operating costs are not allocated separately. Based on the portion of the total building space and on the total building costs, COTA estimated that annual facility operat- ing costs were approximately $12,000. Process Statistics and Outcomes COTA makes approximately 2,000 determinations each year. Most recently, 70.2% of all applicants were found to be unconditionally eligible; 19.5% to be conditionally eligible; 9.8% to be eligible for temporary service; and 0.5% to not be eligible. Experiences and Lessons Learned COTA staff indicated that the agency is pleased with the eligi- bility center and the switch to in-person interviews and assess- ments. They also noted that the community largely accepts the new process. Little push-back was received from the commu- nity when the change was made, which COTA attributes at least in part to the extensive public input and involvement. Because the new process was discussed for about two years, most riders were well aware of the coming change. COTA noted that a small percentage of applicants have complained about having to complete the assessment course and a few have refused to participate. This happens most often with applicants who have ambulatory disabilities who believe that completing the course will be a significant effort. In such cases, the EAs conduct interviews and follow-up with medical professionals to verify the disability and extent of functional limitation. With few exceptions, most of these applicants do have significant functional limitations and are found to be eligible. COTA noted that it has received some comments from the community about the indoor assessment not fully simu- lating the real environment—particularly the impacts of severe weather and real-world street crossings. To compen- sate for these limitations, COTA focuses on these issues in the interviews.

49 In terms of lessons learned, the following two things were mentioned: • Two waiting areas—one for arriving applicants and one for applicants waiting for return rides—would be help- ful. With only one waiting area, there can be significant interaction between those who have just completed the process and those waiting for interviews and assess- ments. Minimizing this interaction would be helpful. • COTA indicated that in hindsight it can see the benefit of having an outdoor route as well as indoor props that simulate travel. It would like to add an outdoor route but is challenged by the location. Being located with the paratransit operations center means that the location is in a more industrial area and there are no sidewalks. It was estimated that between 80% and 90% of applicants request assistance with transportation. If transportation is needed to and from the center, it is arranged using the regular ADA paratransit service; something that has worked well. There have been some minor issues with late drop-offs; however, when this occurs, staff at the center contacts the paratransit operations staff and reschedules the return trip to a slightly later time. There is parking for private automobiles at the facility, but relatively few applicants arrive by car. There are also fixed-route bus stops near the center; however, as noted previously, there are no sidewalks to or from the bus stops. VALLEY METRO, PHOENIX, ARIZONA The Regional Public Transportation Authority (or Valley Metro) utilizes both indoor and outdoor functional assess- ments, as well as the FACTS test to make determinations of ADA paratransit eligibility. It has also developed one of the more extensive and elaborate facilities for conducting indoor assessments. Contractor (C.A.R.E. Evaluators) staff is used to complete most process functions; however, Valley Metro staff makes final determinations and prepares the final docu- mentation for all decisions. Eligibility Determination Process and Facilities Individuals must first complete a brief, two-page application form that requests general information about disability and mobility aids. The name of a medical professional who can be contacted on an as-needed basis for verification of disability is requested, but not required. The form can be requested by contacting the eligibility program, can be downloaded from Valley Metro’s website, or can be completed online and then printed. Applicants then bring the completed form with them to the interview. Applicants can also complete an application over the phone, which is then signed when they come in. Once individuals have completed the form, they call the eligibility program to schedule an interview and assessment. During this call, contractor staff requests general information about disability and mobility aids, provides a brief overview of the process so applicants come prepared for an outdoor walk, asks individuals to come with the mobility aid they use when traveling in the community, confirms that the application form has been completed, and reminds people to bring the form with them. Staff also asks if transportation is needed to and from the Mobility Center. Because the Center is on a light rail line and several bus routes, fixed-route options are also available. ADA paratransit service is decentralized throughout most of the area, with several cities operating services. Multiple transfers can be required to travel across the region, which can be cumbersome to arrange. For this reason, rather than using the local ADA paratransit service, Valley Metro has a contract with a local transportation company to provide ser- vice to and from the Mobility Center. Approximately 75% of applicants request transportation. All new applicants are required to appear in-person for an interview and functional assessment as needed. Riders whose functional abilities are not likely to change over time (which is determined as part of the initial assessment) do not need to return to be recertified, but only to submit an updated application form. The Mobility Center is located on the first floor of an office building at the corner of 45th Street and E. Washington Street in East Phoenix. As noted previously, it is convenient to both the new light rail service and to several bus routes. A floor plan of the Center is provided as Figure 19 and a collage of photos of the Center is provided as Figure 20 (a–d). Applicants enter the Mobility Center from the building’s main lobby. They are directed to a check-in area that is just past the waiting rooms (A in Figure 19). At check-in, the completed application is collected, a photo is taken, and the applicant is asked to review and sign several waivers—one giving permission for the assessment and a second acknowl- edging that they did not provide the name of a medical/health professional familiar with them (if this is not included on the application). Applicants are then directed to the arrival waiting room (B). There is a second waiting room for applicants who have completed the process and are waiting for a return ride home. Applicants are assigned to one of the evaluators and the application is provided for their review. The evaluator greets applicants and directs them to one of the offices where interviews are conducted (C). If an applicant has indicated a cognitive disability, locating the correct office is part of the assessment. Offices have numbers similar to bus routes (e.g., 91A) and applicants are asked to identify the correct room. Evaluators decide based on information from the appli- cation and interview whether to conduct one or more func- tional assessments. For applicants with cognitive disabilities

Curb/ Curb Ramp FACTS Wayfinding Poster Area (A) (A) (B) (C) (C) (C) (N) (O) (C) (F) (E) (H) (G)(I) (J) (K) (D) (L) (M) Legend: (A) Check-in area (B) Waing rooms (C) Offices/interview rooms (D) FACTS area (E) Street crossing (F) Varied surfaces (G, H) Ramps (I) Li rail mock-up (J) Curb, curb ramp (K) Bus (L) Restrooms (M) Transp. Coord. Office (N) Travel trng. Office (O) Manager’s office Start here FIGURE 19 Floor plan of Valley Metro Mobility Center. (Courtesy: Valley Metro.)

51 this might include the FACTS test. Part of the FACTS test is conducted in the interview room and part—the wayfinding exercise—is conducted in the space marked (D) in Figure 19. A simulated street crossing (E) is also included along the way. If an applicant indicates a physical disability, baseline pulse and oxygen levels are recorded using a pulse oximeter. A physical functional assessment is then conducted, which includes the following indoor elements: • Navigating across several different surfaces—gravel, grass, uneven pavement (F). • Activating a pedestrian traffic light and completing a 60-ft (six lane) simulated street crossing (E). • Navigating up and down a 30-ft ramp with a 1:12 slope (G). • Navigating up a 16-ft ramp with a 1:8 slope and then down a 30-ft ramp with a 1:16 slope (H). • Using an automatic fare vending machine at a mock-up of a light rail platform and stations (I). • Navigating a curb and curb ramp to reach a mock-up of a bus stop (J). • Boarding and exiting a ramp-equipped, low-floor bus and getting to and from a seat or securement area (K). • Walking other pathways within the center to reach a total distance of 0.25 mile. In addition to the spaces and props indicated earlier, the Mobility Center includes accessible restrooms (L), an office for the Transportation Coordinator (M), a travel training office (N), and an office for the contractor’s on-site manager (O). Areas for lunch or breaks are provided in other parts of the office building. If applicants complete the indoor course, evaluators decide if an outdoor assessment is also appropriate. Approximately 45% of all applicants are asked to complete the indoor route, and about 12% are asked to attempt the outdoor route (or about one in four who complete the indoor route). Valley Metro has a policy of not undertaking outdoor assessments if (a) (b) (c) (d) FIGURE 20 Valley Metro’s Mobility Center (a) Mobility Center from E. Washington Street; (b) Interior from ramp area (H) toward light rail (I) and offices; (c) Full-size bus and boarding area (K); and (d) Boarding low-floor ramp-equipped bus. (Courtesy: Valley Metro.)

52 the temperature is above 105°F. The outdoor route is shown in Figure 21 and includes the following: • Exiting the building and navigating an uncontrolled crossing of N. 45th Street at E. Washington Street (A in Figure 21). • Proceeding down E. Washington Street and crossing 44th Street—six-lane controlled intersection (B). • Crossing the westbound lanes of E. Washington Street (three lanes controlled) to reach a light rail station located in the median (C). • Re-crossing the westbound lanes of E. Washington Street and N. 44th Street (C and B). • Walking along a sidewalk on the grounds of a hotel and office building complex (D). • Walking along DuPont Circle (E) and then navigating an uncontrolled crossing of N. 45th Street back to the Mobility Center. Valley Metro employs one full-time eligibility program coordinator who reviews information provided by appli- cants and contractor staff, makes final determinations, and prepares and sends determination letters. The coordinator also oversees and manages the eligibility contractor. CARE Evaluators, the contractor, employs a full-time manager, a full-time intake receptionist, a full-time transpor- tation coordinator, two full-time evaluators, and one half-time evaluator. Valley Metro’s RFP for an eligibility contractor initially specified that staff conducting assessments be either PTs or OTs. During the procurement process, this was expanded to PT assistants, OT assistants, or persons having a medical, psychology, or sociology background. Current evaluators have backgrounds in sociology and psychology; the manager has a medical background. In addition to the eligibility determination staff, the con- tractor has one full-time travel trainer and one part-time travel training assistant; both are located at the Mobility Center. If applicants indicate an interest in travel training, they are intro- duced to one of the travel training staff for follow-up. Travel training staff also train individuals identified through other outreach efforts. Decision-Making Process Before implementing the current in-person process, Valley Metro made ADA paratransit eligibility decisions using a paper application, supplemented by professional verification and follow-up with applicants and named medical profession- als. Although the process had reasonable outcomes, Valley Metro noted the shift in the industry in the early 2000s to a greater use of in-person processes. A study of the ADA paratransit service, including the eligibility process, was commissioned in 2006. Several public meetings and workshops were sponsored as part of the study. One of the study recommendations was to consider using in-person interviews and functional assessments to make eligibility determinations. The Valley Metro Board supported the recommendation; however, some in the community were concerned about a change in the process. Valley Metro staff continued to meet with riders and agencies from 2007 to 2009 to discuss alternatives. In 2009, Valley Metro visited transit agencies in Las Vegas, Los Angeles, Orange County (California), and Salt Lake City to review the in-person pro- cesses implemented by these agencies. Information from these systems was shared with the community as the discussion about eligibility continued. Several benefits of an in-person process were identified during the public input process. With more thorough and accurate determinations it was agreed that the standard term of eligibility could be extended from three to five years. It was also agreed that many riders would only need to appear in person one time and that a simplified recertification pro- cess could be used for those whose functional abilities were not likely to change. Finally, Valley Metro agreed to implement free fixed-route service for riders who were determined ADA paratransit eligible. Free fixed-route fares had been under consideration for some time, but there was concern that the program would significantly increase the number of paper applications received. An in-person eligibility determina- tion process would help ensure that people did not apply and become eligible just to get the free fixed-route service. Over time, more riders and agencies began to support the idea of an in-person process. Some of the community concern was also addressed with continued meetings and discussion. A tipping point came when Arizona Bridge to Independent Living, the area’s independent living center, expressed its support for a new process. In 2010, Valley Metro developed an RFP for an eligibility contractor and began its search for a location for the Mobil- ity Center. The contractor selected had experience in building eligibility facilities in Los Angeles and San Mateo (California) and worked closely with Valley Metro on the final design. The new Mobility Center was opened and the new in-person eligibility process began being used in 2011. Multiple eligibility centers were considered during the public input process. Valley Metro’s ADA paratransit service area is very large—almost 1,000 square miles. Three distinct areas are served; the Phoenix/Scottsdale area, the East Valley, and the West Valley. A decision was made to have one primary center because of the added cost of building and staffing several centers. Possible inconsistencies in determinations with different staff in separate centers were also raised dur- ing the planning process. To make travel to and from the Center as easy as possible, Valley Metro has a dedicated

(A) (B) (C) (D) (E) FIGURE 21 Valley Metro outdoor assessment route. [Source: TranSystems (developed using Google Maps traffic view).]

54 contract for eligibility transportation. The local paratran- sit service, which requires transfers between communities, is not used. Valley Metro is considering a process that would first involve the review of an expanded paper application form. From the paper application, it would attempt to identify applicants who clearly do not need to participate in indoor or outdoor assess- ments. These applicants would still be asked to appear for an interview; however, several interview sites could be identi- fied throughout the service area. A single facility would still be used for applicants who would be asked to participate in functional assessments. Build-Out and Operating Costs The Mobility Center is located with Valley Metro’s Customer Service Center. The building was modified and space was prepared for both programs at the same time. The Mobility Center occupies 15,317 ft2 of the building. Build-out costs for the Mobility Center were about $1,200,000. Annual facility operating costs (rent, utilities, and building maintenance) for the Mobility Center portion of the building are estimated at $320,000. Process Statistics and Outcomes In calendar year 2013, Valley Metro performed 4,753 eligi- bility assessments. Outcomes for this 12-month period were 67.5% unconditional, 18.5% conditional, 10.9% temporary, and 3.1% not eligible. Staff noted that conditional determinations have increased since August 2013 and were about 25% at the end of the year. Lessons Learned In general, Valley Metro staff indicated that the switch to an in-person process and other changes in eligibility policies have been beneficial. They also noted that the community has largely accepted the new process and that the new Mobility Center has been an important part of that acceptance. Having a well-designed and complete facility has helped with com- munity confidence in the process. Staff at Valley Metro noted several lessons learned: • Extensive community involvement was very impor- tant. In particular, staff noted that the creation of a large stakeholder group, with broad representation from the community, was helpful. This group was able to assist Valley Metro in its outreach to the community and was able to help answer questions that riders and others in the community had about a new process. • Considering the benefits of an in-person process, such as the ability to implement a free fixed-route fare program, extend the term of eligibility, and create a simplified recertification process, was important for community acceptance. • Having both an indoor and an outdoor route helps to better consider things that are difficult to simulate in an indoor setting, such as street crossings, changes in lighting, and outdoor stimulations and distractions. This also helped address community concerns that the process needs to accurately consider travel in the real environment. • Staff qualifications are important. The current evalua- tors, who have psychology and sociology backgrounds, have excellent interviewing and observation skills but more limited skills and experience assessing physical functional abilities. Given that the primary disability of most applicants is physical, Valley Metro is considering changes in requirements in future assessment contrac- tor RFPs to stress experience and skills with physical assessments. • The Mobility Center houses a full-sized low-floor bus. If this is being considered, Valley Metro advises designing the facility to include a pathway and door large enough to remove and replace the bus to prop- erly reflect any changes in the future fleet.