Strategy Guide to Enable and Promote the Use of Fixed-Route Transit by People with Disabilities (2014)

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118 A final strategy for enabling and promoting use of fixed-route transit services is implement- ing an ADA paratransit eligibility determination process that assists persons with disabilities with identifying abilities to travel independently, identifies travel options, and supports other programs and efforts. The components of this strategy include: • Developing an eligibility process that stresses abilities rather than limitations. • Developing a process that accurately and thoroughly identifies conditions under which use of fixed-route transit is appropriate and reasonable. • Using the process to identify specific trips that can be made by fixed-route transit. • Linking the process to travel training and other support programs. This section first provides background information on ADA paratransit eligibility and eligibil- ity determinations. Common processes and the state-of-the-art practice in making eligibility determinations are then discussed. Recommended approaches for implementing each of the above noted strategy components are then presented. As part of the research, information was collected from transit agencies identified as hav- ing exemplary eligibility processes. This included Seattle (WA) Metro, Access Transportation Systems, Inc. (ACCESS) in Pittsburgh, PA, Intercity Transit in Olympia, WA, SamTrans in San Carlos, CA, and the Utah Transit Authority (UTA) in Salt Lake City, UT. Information from these transit agencies is used in this section to provide examples of processes and approaches that have been implemented successfully. 9.1 ADA Paratransit Eligibility Public entities that operate fixed-route transit services are required by the ADA to also provide complementary paratransit service. Complementary paratransit is intended to be a “safety net” for persons who, because of their disabilities, are prevented from using fixed-route transit services. Transit agencies that provide complementary paratransit must also have a process for deter- mining who is “ADA paratransit eligible.” The U.S.DOT regulations implementing the ADA provide specific criteria that define ADA paratransit eligibility and require that transit agencies use these criteria to make determinations. In essence, the regulatory criteria indicate that the following are considered ADA paratransit eligible: • Persons who, because of a disability, are not able to use fully accessible fixed-route transit systems. This includes persons who may not be able to “navigate” fixed-route transit services even if they are fully accessible. C h a p t e r 9 ADA Paratransit Eligibility Determinations

aDa paratransit eligibility Determinations 119 • Persons who, because of a disability, cannot use fixed-route transit because the bus route or transit station they want to use is not yet accessible, or they cannot board or alight at the stop they want to use. • Persons who cannot get to or from stops or stations because barriers in the environment, in combination with their disability, “prevent” them from getting to or from the transit stop or station. A wealth of information is available to assist transit agencies with interpreting and apply- ing these regulatory criteria for eligibility. The following documents, each funded by FTA, were issued to assist the industry with thorough and accurate ADA paratransit eligibility determinations. Resources for Understanding and Determining ADA Paratransit Eligibility Weiner, R., TCRP Synthesis 30: ADA Paratransit Eligibility Certification Practices, TRB, National Research Council, Washington, D.C., 1998. (54) TranSystems Corp., Determining ADA Paratransit Eligibility: An Approach, Guidance and Training Materials, Easter Seals Project ACTION, Washington, D.C., 2003. (55) Disability Rights Education and Defense Fund (DREDF), Topic Guides on ADA Transportation: Eligibility for ADA Paratransit, Federal Transit Administration, Washington, D.C., 2010. (56) Conditional and Trip Eligibility The U.S.DOT ADA regulations not only identify the criteria under which individuals are ADA paratransit eligible, but note that certain trips may be eligible while other trips are not. Section 37.123(b) of the regulations states “If an individual meets the eligibility criteria . . . with respect to some trips but not others, the individual shall be ADA paratransit eligible only for those trips for which he or she meets the criteria.” This notion of trip as well as individual eligibility has given rise to different types of ADA paratransit eligibility. Common types of eligibility granted to individuals include: • Unconditional eligibility (a/k/a All Trips eligibility)—granted to persons who are not able to use fixed-route transit services under any conditions. • Conditional eligibility (a/k/a Limited or Some Trips eligibility)—granted to persons who are able to use fixed-route transit services some of the time under certain conditions. • Temporary eligibility (a/k/a Transitional eligibility)—granted to persons whose disability or health condition is expected to last less than the standard term of eligibility. Temporary eli- gibility can be either unconditional or conditional. Unconditional and temporary eligibility are relatively straightforward. Conditional eligibil- ity is more involved. There are many different types of physical, environmental, and transit system barriers that may affect travel by persons with disabilities. In addition, individual func- tional ability may vary from day to day or from trip to trip. Types of travel issues that apply to conditional eligibility include: • Path-of-travel issues (presence of sidewalks, curb ramps, slopes and cross-slopes, uneven or unstable surfaces, detectable and safe paths of travel).

120 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities • Street crossing issues (width of streets, intersection design, amount of traffic, lack of or type of traffic controls). • Distances to and from stops and stations. • Weather conditions (snow, ice, rain, heat, humidity, cold, smog). • Fixed-route transit system accessibility (bus routes, bus stops, transit stations). • Fixed-route transit system’s amenities (benches, shelters, and stops and stations). • Complexity of trips (single routes, transfers, complex stations). • Times of trips (peak-hour crowding, day/night levels of light). • Individual travel abilities (good days/bad days, familiar versus unfamiliar trips or areas). Abilities to use fixed-route transit could be affected by each of these issues. Moreover, many persons may be affected by several of these issues. For example, persons who use manual wheel- chairs are likely to be impacted, at a minimum, by physical barriers in the environment (e.g., a lack of sidewalks, a lack of curb ramps, or steep slopes), severe weather conditions (e.g., snow or ice), distances to and from bus stops or rail stations, and the accessibility of bus routes, stops, and rail stations. Persons with vision disabilities might be affected by paths of travel that are not detectable or safe, intersections and street crossing issues, levels of light, and types of trips (familiar versus unfamiliar). Current Use of Conditional and Trip Eligibility Because of this complexity, the use of conditional eligibility and the extent to which it is applied varies. The 2012 survey of transit agencies conducted as part of this research found that the majority of agencies apply the concept of conditional eligibility. Survey respondents were asked “Are some applicants found eligible for only certain trips (aka “conditional” ADA paratransit eligibility)?” Responses are shown in Figure 9-1. Of the 141 transit agencies that provided a response, 63% indicated that some applicants were granted conditional eligibility. Thirty percent of respondents reported not using conditional eligibility, meaning that applicants were simply found either unconditionally eligible or not eligible. Seven percent of respondents were not sure. While the majority of transit agencies apply the general concept of conditional eligibility, the thoroughness and specificity varies. Some agencies apply only certain conditions or generalize Figure 9-1. Reported use of conditional eligibility (n 5 141).

aDa paratransit eligibility Determinations 121 the conditions (e.g., winter eligibility or summer eligibility). Fewer still apply conditions of eligibility to trip requests made by eligible riders. Conditional eligibility may be granted, but trips are not screened against these conditions and riders can schedule trips regardless of the conditions set. A TCRP synthesis study in 1998, which gathered information from 30 transit agencies, reported that “less than half” applied conditions of eligibility to rider trip requests. (54) The study also noted that “most” agencies that reported applying conditions to trip requests only applied certain, easy to determine conditions, such as eligibility for extreme weather seasons (e.g., winter or summer eligibility). The 2012 survey conducted as part of this research found little change between 1998 and 2012. The survey asked transit agencies, “For riders granted conditional eligibility, do you apply the conditions to trips that they request (i.e., make “trip-by-trip” decisions in operations)? Eighty- two of the 89 agencies that indicated using conditional eligibility provided a response. Thirty- one (38%) indicated that they do trip eligibility for certain limited conditions. Twenty-seven (33%) indicated that they do trip eligibility for many different types of conditions. Seventeen (21%) indicated that they did not make trip eligibility decisions. And seven (8%) were not sure. Applying the concept of conditional eligibility is an important first step in using the eligibil- ity determination process as a way to enable and promote use of fixed-route transit services. If applicants are able to use fixed-route transit services some of the time, granting them con- ditional eligibility recognizes their abilities and communicates the message that fixed-route transit service is an appropriate travel option under certain conditions. However, thoroughly applying conditional eligibility and making decisions on trip eligibility remains a significant challenge for transit agencies. Doing so requires an eligibility process that captures detailed information about travel abilities. It also requires an organized process for communicating and applying determination outcomes. A few transit agencies have, however, been successful in making trip eligibility determinations. The results and benefits at those agencies, as explained below, have been significant. 9.2 Common Processes for Determining ADA Paratransit Eligibility The research determined that there are three basic sources of information that can be used to make ADA paratransit eligibility determinations. These are: • Information provided by applicants. This can be in the form of a paper application, responses to questions in an interview, or both. • Information provided by professionals familiar with applicants. This can involve asking appli- cants to obtain information from professionals on a form developed by the transit agency as Use of Trip Eligibility # of Respondents % of Respondents Use for some limited conditions (e.g., seasonal eligibility) 31 38% Use for many different types of conditions 27 33% Do not use trip eligibility 17 21% Not sure 7 8% Totals 82 100% Table 9-1. Reported use of trip-by-trip eligibility.

122 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities part of paper applications. Agencies can also accept information in other forms that appli- cants may already have from professionals. Or, it can be obtained by transit agencies through direct contact with professionals identified by applicants. • Assessments of functional abilities. Transit agencies may ask applicants to participate in assess- ments designed to determine functional abilities specific to the use of fixed-route transit services. The 2012 survey of transit agencies conducted as part of this research asked about the use of each of these sources of information. Responses from 127 agencies that answered this question are summarized in Table 9-2. Note that many agencies reported using several different sources of information, so the total responses exceed the number of agencies responding. Most transit agencies (85%) indicated that they have a paper application form. The agencies that did not use paper applications obtained information from applicants through in-person interviews. Most agencies (70%) also indicated obtaining information from professionals familiar with applicants to verify the existence of a disability and to get information about specific functional abilities. Just under half of all respondents (48%) indicated the use of in-person interviews. Twenty- seven percent said interviews were conducted with all applicants, while 21% said interviews were conducted with only some applicants. Thirty-seven percent of respondents indicated that in-person functional assessments were used—with 13% saying all applicants participate in assessments and 24% using assessments only some of the time. Ten percent of respondents noted using “other” information. Types of other information noted were telephone follow up with applicants, “actual community assessments,” and infor- mation obtained from family members or friends who might be part of the in-person interview. Fifty-one respondents, or 40%, indicated that they only use paper applications and/or infor- mation from professionals. Sixty percent of respondents use in-person interviews or functional assessments to some degree. Forty respondents, or 31%, use both in-person interviews and functional assessments. Respondents were also asked to subjectively rate, on a scale of “1” to “5,” with “1” being “Not Effective” and “5” being “Very Effective,” the effectiveness of the sources of information Sources of Information Total % of Total Respondents Paper applications completed by applicants or others on their behalf Information from professionals familiar with applicants In-person interviews of all applicants In-person interviews of some applicants In-person functional assessments of all applicants In-person functional assessments of some applicants Other 85% 70% 27% 21% 13% 24% 10% Total Respondents 115 95 37 28 18 13 33 127 Table 9-2. Types of information used to make ADA paratransit eligibility determinations.

aDa paratransit eligibility Determinations 123 and process used. Effectiveness ratings varied by the type of information used. Respondents who indicated only using paper applications and/or information from professionals rated their processes, on average, as moderately effective (3.3). Transit agencies that included some level of in-person interviews or assessments had an average rating of 4.0. And agencies that combined all sources—paper applications, information from professionals, in-person interviews, and functional assessments had an average rating of 4.2. 9.3 Suggested Strategies The research identified several strategies that have been used successfully to enable and pro- mote the use of fixed-route transit services. This section provides a description of these strate- gies. Six different strategies, in order of level of complexity, are presented. Information gathered from case studies on each approach is included. Important Considerations The following issues will ideally be carefully considered if any of the suggested strategies are pursued. Accessibility and Usability of the Fixed-Route Transit System It is important to ensure that fixed-route transit services are accessible and usable by persons with disabilities before the ADA paratransit eligibility process is used to direct people to these services. It would be disingenuous at best to suggest through the eligibility determination process that people with disabilities should be using fixed-route transit services if those services are not truly accessible and usable by riders with disabilities. Minimum efforts that should be taken to ensure that fixed-route transit services are accessible are detailed in Chapter 4 of this report. Transit agen- cies need to ensure that: • Buses and rail cars that are advertised as accessible meet ADA design standards. • Stations and bus stops that are advertised as accessible meet ADA design standards. • Lifts, ramps, elevators and other accessibility features are maintained and in good working condition. • On-board stop announcements and external route identification announcements are being made. • Employees are trained to proficiency to safely operate accessibility equipment, to provide appropriate assistance to riders with disabilities, and to serve riders with disabilities in a respectful and courteous manner. • Transit service to persons with disabilities is monitored to ensure that policies and procedures are being followed. If these minimum requirements are not being met, the eligibility process could inappro- priately conclude that applicants can use fixed-route transit when, in fact, the services are not really accessible and usable. Transit agencies will also have greater success encouraging use of fixed-route transit ser- vices through the eligibility determination process if other efforts beyond the minimum requirements are made. If agencies are proactive in making bus stops more accessible, addi- tional opportunities to use fixed-route transit will be identified by the eligibility process. If fare It would be disingenuous at best to suggest through the eligibil- ity determination process that people with disabilities should be using fixed-route transit services if those services are not truly accessible and usable by riders with disabilities.

124 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities incentives are provided, riders with disabilities will be more willing to use fixed-route transit. If good public information on accessible transit services is provided, and trip planning and travel training services are offered, riders with disabilities will be better able to transition to fixed- route transit. All five transit agencies that were identified as having successfully used the ADA paratransit eligibility process to enable and promote fixed-route transit use, and were included as case studies on eligibility for this research, are recognized as having accessible fixed-route transit services. All five also: • Offer free fares on fixed-route transit for persons who are ADA paratransit eligible; • Have public information targeted at promoting the accessibility of the fixed-route transit system; and • Either provide travel training directly, or work with other local agencies to provide this service. Suggested approaches for being proactive in each of these areas are detailed in Chapters 5, 6 and 7. Community Involvement and Support Persons with disabilities, disability service organizations, and other stakeholders will ideally be involved in the development and implementation of any changes to the ADA paratransit eligibility process, or in the use of the process to enable and promote greater fixed-route transit use. This is particularly important if changes will be made to the way that ADA paratransit eligibility is determined, if conditions of eli- gibility will be identified for the first time, or if conditions of eligibility will begin being used to make determinations of the eligibility of specific trips. Community involvement is important for several reasons. First, it is required by the U.S.DOT ADA regulations. Section 37.137 (c) of 49 CFR Part 37 requires that transit agencies have an ongoing mechanism for involving persons with disabilities in the development of accessible services. Beyond regulatory compliance, community involvement provides an oppor- tunity to communicate the goals of any programs or strategies that are pursued. It can be help- ful to explain that changes in the eligibility process are being made to better understand travel abilities and to promote the most appropriate travel options for riders. Community involvement also allows important concerns to be identified and addressed. ACCESS in Pittsburgh, PA, one of the first transit agencies to implement trip-by-trip eligibility, identified through an extensive public input process that riders wanted to be able to use para- transit service even if trips could be made on fixed-route transit. It was therefore agreed that these trips would still be provided as non-ADA trips at a higher fare. If trips were found able to be made by fixed-route transit, riders would have the option to still book the trips at twice the ADA para- transit fare (called, locally, the “convenience fare”). ACCESS and the Port Authority of Allegheny County agreed to provide convenience fare trips as long as financially possible. The community agreed to review the amount of the convenience fare if it was overused and became unsustainable. Since it was introduced in 2003, ACCESS reports that convenience fares have remained steady at about only 5% of total trips. While not a large percentage of the ridership, ACCESS reports that this option to choose, developed with community input, has been a major part of community acceptance of the implementation of conditional and trip-by-trip eligibility. To be effective, input needs to be obtained from all segments of the community, including current and potential riders with disabilities, disability organizations and representative dis- ability membership organizations. All points of view are important to include in the discussion of process change—particularly those who are likely to be skeptical or who may at first oppose change. As many different methods as possible and practical should be used to gather people Meaningful and effective commu- nity involvement is important for developing appropriate strategies, and for gaining public support for their implementation.

aDa paratransit eligibility Determinations 125 together in small and large groups to present the concepts and goals and to answer questions in an open and honest method. Focus groups, open houses and forums, the establishment of special work groups, large and small community meetings with questions and answer sessions, formal presentations and networking with human service agencies are all tools which have been used effectively in other locations. Clear, concise public information materials are an important part of the education process. To be meaningful, input and involvement will ideally begin early. The community should be involved in discussing possible options and selecting a desired approach, rather than being asked to support an approach that has already been determined. The goal of the process is to have the community view the implementation of a new process or strategy as a collective effort rather than just a transit agency initiative. For helpful guidance on developing effective and meaningful public involvement, see: TCRP Research Results Digest 107: Developing Partnerships Between Transportation Agencies and the Disability and Underrepresented Communities, Transportation Research Board of the National Academies, Washington, D.C., 2013. (57) Strategy Option 1—Emphasize Abilities and Travel Options Rather Than Limitations Develop an eligibility determination process that stresses ability rather than disability. Instead of screening people for eligibility based on lack of abilities to use fixed-route transit services, focus the process on identifying the abilities of applicants and linking them to the most appropriate transit services. Some ways to do this include: • Process Goals—Adopt process goals and develop a mission statement that reflect this approach. Possible goals could be to identify appropriate transportation options for indi- viduals who inquire about accessible services, and identify abilities of applicants to use fixed-route transit services. These goals communicate a very different message than a goal to “determine if applicants qualify for ADA paratransit service.” Make these new goals known to staff and to the public. • Public information—Develop public information about the full range of accessible transpor- tation services, rather than information that is limited to describing ADA complementary paratransit or ADA paratransit eligibility. Include information about ADA complementary paratransit as one accessible transportation option. Seattle Metro has developed a packet of material titled “Access to Metro: Public Transportation for All of Us” that is sent to anyone who inquires about ADA paratransit eligibility. The packet includes information about using accessible fixed-route transit services, the agency’s taxi script program, travel instruction, as well as ADA paratransit. Once people review this information, they can pursue ADA paratransit eligibility if it is an appropriate option for them. Or, they can contact Metro for more information on other accessible transportation options.

126 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities • Process name—Instead of labeling the process as the “ADA paratransit eligibility process,” consider a name that better reflects the broader goals. TriMet in Portland, OR, refers to their process as a “transportation assessment” and has named the facility where interviews and in-person assessments are conducted the Transportation Assessment Center. • Frame questions to stress abilities—Consider how questions are phrased in application forms and in-person interviews. Instead of starting with “Why can’t you use the bus?” start by ask- ing if they currently use the bus or have in the past. If not, ask why they don’t use the bus. If yes, ask about the conditions that make it possible to use the bus for those trips. This will solicit the same type of information about barriers that prevent fixed-route transit use, but requests this information in a way that stresses abilities rather than limitations. [Note that use of the bus for some trips does not mean a person is not eligible. It may be an indication that they are conditionally eligible.] • Letters of determination—For applicants found conditionally eligible, inform them that the review determined that they are “able to use fixed-route transit except when the following conditions exist . . .” rather than that they are “eligible for paratransit when. . . .” As part of this different focus, collect information about all travel options and make this information available as part of the eligibility determination process. If applicants are deter- mined able to use fixed-route transit some of the time, provide them with information about accessible fixed-route transit and discuss ways that the service has been made more accessible and usable. As appropriate, also have information on other transportation options available. This might include information about social service transportation, community bus services, or taxi subsidy programs that might be available in the area. Transit agencies should be careful, though, to not present this other information in a way that steers people away from pursuing ADA paratransit eligibility. ACCESS in Pittsburgh, PA, provides information about major accessible trans- portation programs and services, as appropriate, during applicant interviews. Information is provided about accessible fixed-route transit services, the Penn- sylvania 65+ Shared-Ride program, and other sponsored transportation services. Information obtained as part of the ADA paratransit application process is used to qualify individuals for these other programs when appropriate. Individuals are provided eligibility for multiple programs if they qualify. Information is also provided about travel training services. ACCESS works with local organiza- tions that provide travel training and makes referrals as appropriate. Seattle Metro has created a Transportation Resource Center at the facility where interviews and assessments are conducted. It includes information about accessible fixed-route transit services, local community bus services, taxi subsidy programs, social service transportation programs, travel training services, and volunteer driver programs. This information is shared with applicants as appropriate (Figure 9-2).

aDa paratransit eligibility Determinations 127 Strategy Option 2—Grant Conditional Eligibility and Identify When Fixed-Route Transit Can Be Used If not currently done, consider granting conditional eligibility as one of the outcomes of the determination process. Research and national experience suggests that about a third of all applicants for ADA paratransit eligibility are able to use fixed-route transit services some of the time. For these applicants, identify their independent travel abilities. Make this part of determinations by identifying the specific conditions under which they are able to use the fixed-route transit system. Even if conditions are not applied to trip requests, communicating abilities may encourage some riders to use fixed-route transit services when they are able. As noted earlier in this section, only 63% of transit agencies grant conditional ADA paratransit eligibility, and many of those only identify broad conditions such as “winter eligibility” or “summer eligibility.” Implementing this strategy may require changes to the current eligibility determination pro- cess. Making detailed determinations that identify when fixed-route transit services can be used is often not possible if the process relies mainly on a paper application. It is very difficult to gather information about all types of functional abilities needed to use fixed-route transit service, for all types of disabilities and health conditions, in a standardized paper application. To be able to thoroughly and accurately identify abilities to use fixed-route transit service, more detailed information may need to be gathered from professionals familiar with applicants. In-person interviews and functional assessments may also have to be included in the process. TCRP Synthesis 30 found that, at transit agencies that relied on paper applications, 93% or more of all applicants were granted unconditionally eligible status. (54) About 11% of applicants were found conditionally eligible, but conditions tended to be incomplete and general. Transit agencies that utilized in-person interviews and assessments found 57% to 75% of applicants unconditionally eligible, 21% to 37% conditionally eligible, and did a better job of thoroughly identifying appropriate conditions. Public Input Before making significant changes to the eligibility determination process and making condi- tional eligibility part of the outcomes, thorough public participation is strongly suggested. It is best that the concept of conditional eligibility be explained and changes to the process discussed. Figure 9-2. Seattle Metro Transportation Resource Center (courtesy of TranSystems).

128 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities Gather Useful Information from Professionals Who are Familiar with Applicants It is a best practice to seek information from a wide variety of professionals and not be prescrip- tive in the types of professionals from whom information will be accepted (e.g., only licensed physicians). Orientation and Mobility Specialists, therapists, clinical social workers, job coaches, registered nurses, independent living specialists, and many other professionals might be able to provide the best information about relevant functional abilities. Many transit agencies identify appropriate professionals through applications and/or inter- views. Follow-up is then done with these professionals to gather specific information pertinent to each applicant. Implement In-Person Interviews and Functional Assessments Many transit agencies that have successfully implemented conditional eligibility also include in-person interviews and functional assessments in the determination process. In-person inter- views allow eligibility staff to ask more specific questions that are relevant to each applicant. Properly designed assessments can provide independent and objective measures of specific functions related to the use of fixed-route transit. This can be important if applicants have never used fixed-route transit and therefore may not be sure of their abilities to use these services. Easter Seals Project ACTION has developed detailed guidance on using in-person interviews and functional assessments to make ADA paratransit eligibility determinations. Their report titled Determining ADA Paratransit Eligibility: An Approach, Guidance and Training Materials is available at no cost. (55) Transit agencies should also consider training on developing and using in-person interviews and functional assessments. The National Transit Institute (NTI) offers a free two-day course titled “Comprehensive ADA Paratransit Eligibility Determinations.” Information about the course is available at www.ntionline.com. ACCESS in Pittsburgh, PA, requires all applicants to first submit a paper application. All applicants are also asked to participate in in-person interviews, which are conducted by ACCESS staff. Physical and cognitive assessments are conducted as needed. If physical functional assessments are appropriate, they are conducted by physical therapists provided to ACCESS under a contract with Easter Seals of Western Pennsylvania. The assessments are performed at the same location immediately following interviews. Whenever possible, physical assessments are conducted in the real environment. Therapists take applicants on a walk along a designated route in downtown Pittsburgh (see Figure 9-3). Applicants with cognitive disabilities are asked, as appropriate, to participate in a cognitive functional assessment. ACCESS uses the Functional Assessment of Cognitive Transportation Skills (FACTS) tool, as appropriate, for applicants with intellectual disabilities.6 ACCESS also uses the Mini Mental Status Exam (MMSE) for applicants with certain other types of cognitive disabilities. FACTS and the MMSE are both administered by ACCESS staff (see Figure 9-4). 6The FACTS assessment was developed by Easter Seals Project ACTION and, as of the preparation of this report, was the only tool for specifically assessing transportation skills that has been validated through a rigorous scientific process.

aDa paratransit eligibility Determinations 129 Applicants with low vision, but who are not legally blind, are asked to participate in physical functional assessments. Their abilities to travel the walking course are noted. Applicants who are legally blind are not asked to participate in functional assess- ments. Eligibility decisions for these applicants is made based on information in the application forms, documentation of disability provided by applicants or identified professionals, and follow-up information obtained from professionals as needed. Determinations for applicants with psychiatric or seizure disabilities is also based on information from applicants (the application form and interview) together with verification and follow-up information from identified professionals. These applicants are not asked to participate in functional assessments unless they also have physical or cognitive disabilities. Figure 9-3. Physical functional assessment, Pittsburgh, PA (photo courtesy of ACCESS). Figure 9-4. FACTS test being administered by ACCESS staff (photo courtesy of TranSystems).

130 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities Be Specific in Identifying When Fixed-Route Transit Services Can Be Used To be meaningful, determinations of eligibility need to identify the specific conditions when fixed-route transit services can and cannot be used. For example, if an applicant is able to travel up to three blocks to get to or from bus stops or rail stations, the determination should say that she is eligible for ADA paratransit service “when you must go more than three blocks to get to or from bus stops or rail stations,” rather than “when bus stops or rail stations are too far away.” Similarly, for an applicant who is able to cross streets that have pedestrian signals, but cannot cross uncontrolled intersections, the determination should indicate he is eligible for ADA paratransit “when you must cross intersections without traffic lights and pedestrian controls,” rather than “when there are intersections you are not able to cross.” Appendix A contains lists of eligibility conditions that have been developed by Metro in Seattle, WA, and ACCESS in Pittsburgh, PA. Be Thorough and Accurate in Identifying Abilities and Setting Conditions of Eligibility If conditional eligibility is granted as one of the outcomes of the eligibility determination process, it is important to identify all conditions that prevent use of fixed-route transit service. Not including an applicable condition unfairly and inappropriately limits an applicant’s right to paratransit. For example, a person who uses a powered wheelchair might be granted eligibility “when snowy or icy conditions prevent travel to and from bus stops or rail stations.” But the transit agency may fail to include conditions when there are no sidewalks or when the bus stops or rail stations are not accessible. Only noting winter weather as the sole con- dition implies that the person is able to travel anywhere on fixed-route tran- sit as long as there is no snow or ice. This would obviously not be the case. Two helpful tools that have been developed to ensure complete and thor- ough determinations of eligibility are the Task List and Skills List presented in Appendix B. These lists were prepared by NTI for use in its training on ADA paratransit eligibility. The Task List identifies all of the things that riders must be able to do to use fixed-route transit services. The Skills List identifies the physical, cognitive, and sensory skills that persons must have to perform the identified tasks. When making determinations of eligibility, it is a best prac- tice to use these lists to be sure that all applicable issues have been considered. Identify General Conditions as Well as Specific Trips For riders who are determined conditionally eligible, a general list of conditions under which fixed-route transit service cannot be used, and when they are eligible for ADA para transit should be identified. These conditions are not related to specific trips, but define general functional ability. So, for example, conditions of eligibility related to endurance and walking distance should determine the maximum reasonable walking distance, not whether the applicant can get to the bus stop nearest their homes. The maximum reasonable walking distance is then considered and applied to specific trips that are requested. In addition to these general conditions, it may also be possible to identify specific trips that applicants indicate can be made by fixed-route transit. Information about current use of fixed- route transit might be obtained in application forms or in-person interviews. For example, an applicant with an intellectual disability might have as a general condition of eligibility that she is eligible for ADA paratransit “for any trips she has not been successfully travel trained to make on the fixed-route transit system.” During the interview, it may be learned that she has been successfully travel trained to make the trips to and from her place of employment. In addition to listing the general condition of eligibility in her determination letter, the specific trip she is able to make on the fixed-route transit system can also be listed. Note that in this example, it If conditional eligibility is granted, it is important that all conditions that prevent use of fixed-route transit service be identified and included in the determination. Leaving out applicable conditions inappropriately limits people’s right to paratransit service.

aDa paratransit eligibility Determinations 131 would be important to determine the agency that provided the training and confirm with the agency that the applicant had successfully completed training. It is also important to note that listing specific trips that can be made by fixed-route transit in determination letters should be supplemental to the identification of general conditions of eligibility. Eligibility should not be solely tied to specific trips that can or cannot be made by fixed-route transit, since the places that applicants may travel will change during the term of eligibility. General conditions that can be applied to future, unknown trips should always be listed. Specific trips can then supplement these general conditions. Effectively Communicate Conditions of Eligibility ADA paratransit eligibility is complex. The concepts of individual and trip eligibility, and unconditional, conditional, and temporary eligibility can be difficult to understand. Make an effort to craft determination letters that are understandable. This is particularly important when sending letters to persons determined conditionally eligible. A sample conditional eligi- bility letter developed by Seattle Metro is provided in Appendix C. Even with the most carefully crafted letters, some riders many be confused when they receive letters that tell them they are conditionally eligible and provide a list of conditions that define when they are able to use the fixed-route transit system and when they are eligible for ADA paratransit. Consider spending the time to call these riders to go through and explain the letters. Seattle Metro and ACCESS in Pittsburgh both have transit agency staff call riders who have been determined conditionally eligible. The specific conditions of eligi- bility are explained. Questions that riders have about their eligibility are answered. Strategy Option 3—Link the Process to Travel Training Efforts As noted in Section 6.3, providing travel training to persons with disabilities can be a very effective strategy for encouraging and facilitating the use of fixed-route transit. The research indicated that the ADA paratransit eligibility determination process can be used to increase the effectiveness of travel training programs. Following are several strategies that have been used successfully. Explain and Offer Travel Training Many transit agencies provide information about travel training as part of the eligibility determination process. This is sometimes done by including information about travel training in application packets. Agencies that conduct in-person interviews often discuss travel training services with applicants as appropriate. Identify Potential as Well as Current Abilities As noted earlier, current abilities to use fixed-route transit service indepen- dently must be used to make ADA paratransit eligibility determinations. Poten- tial to learn to use the fixed-route transit system cannot be cited as a reason for denying ADA paratransit eligibility. And travel training cannot be required. It is a good practice, however, to ask applicants if they have successfully completed travel training to use fixed-route transit services. If so, the specific trips that they have learned to make can then be identified and made part of the determination (see Strategy Option 2). Travel training can be suggested and encouraged, but cannot be required. Determinations of eligibil- ity must reflect actual abilities, not potential abilities with training.

132 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities It is also a good practice to use the ADA paratransit eligibility determination process to identify potential to learn to use the fixed-route transit system and to suggest and offer travel training. The FACTS assessment tool developed by Easter Seals Project ACTION was specifi- cally designed to do this for applicants with intellectual disabilities. The eligibility determination process might also identify some applicants who have the current ability, but little or no experience actually using fixed-route transit services. In these cases, participation in travel training might help make them more comfortable using bus or rail services. All five transit agencies that were the subjects of case studies regarding eligibility determination—ACCESS in Pittsburgh, PA, Seattle Metro, Intercity Transit in Olympia, WA, UTA in Salt Lake City, UT, and SamTrans in San Carlos, CA—use the ADA paratransit eligibility determination process to identify applicants who might benefit from travel training services. These applicants are granted temporary eligibility (typically from six months to one year) and travel training is recommended. Information about travel training services is also provided. If applicants pursue travel training, the results of training efforts are considered when temporary eligibility expires and are used to set longer-term eligibility. If applicants decide not to pursue travel training, a longer-term determination is made at the end of the temporary eligibility period and is based on current individual travel ability. Utilize Travel Trainers to Assist with Eligibility Determinations If travel trainers are on staff and travel training services are offered in-house, consider utiliz- ing this staff to assist with ADA paratransit eligibility determinations. Qualified travel trainers have an understanding of the tasks and skills needed to use fixed-route transit services inde- pendently. They may also have particular knowledge and experience working with individuals with certain disabilities, such as intellectual disabilities. Consider consulting this staff when making determinations for applicants with intellectual or other cognitive disabilities. If in-person interviews and functional assessments are used, consider having travel trainers conduct the interviews and assessments for applicants with intellectual or other cognitive disabilities. Co-locating the travel training program with ADA paratransit eligibility can make this cross- utilization of staff possible. Co-location can be useful even if travel trainers are not used to make determinations. If applicants express an interest in learning more about travel training during interviews, they can be easily referred to meet with a travel trainer to get the process started. Helpful Tip: If efforts are made to link travel training and eligibility determination pro- grams, it is important to communicate to potential applicants that participation in travel training will not result in denials of ADA paratransit eligibility. Some transit agencies have noted that applicants can be reluctant to express an interest in travel training, or to even provide information about past travel training, if they have heard that it will impact their eligibility for ADA paratransit services. Public information should stress that travel training is designed to expand travel options, not to limit use of ADA paratransit. Persons who par- ticipate in travel training and learn to use fixed-route transit for particular trips will have less

aDa paratransit eligibility Determinations 133 expensive, more flexible travel options for these trips. And using fixed-route transit for these trips will not impact ADA paratransit eligibility for other trips that they are not able to take by bus or rail. Strategy Option 4—Apply Conditions of Eligibility to Trips Requested or Made By Riders By identifying specific conditions of eligibility and making this part of eligibility determina- tions, some individuals may be encouraged to use fixed-route transit when they are able. For riders with little fixed-route transit experience who may not be inclined to begin using the system on their own, it may be necessary to proactively apply conditions of eligibility to trips that are requested or are currently being made. Applying conditions of eligibility to specific trip requests is known in the industry as “trip-by-trip eligibility.” Transit Agency Responsibility If a decision is made to do trip-by-trip eligibility, it is important to realize that the responsi- bility for determining if a particular trip can be made by fixed-route transit rests with the tran- sit agency, not the riders. It would not be appropriate to make applicants conditionally eligible, require that they identify the specific trips that they cannot make on fixed-route transit, and limit their eligibility to trips that they identify. Doing this would require individuals to attempt to make trips on the fixed-route transit system without knowing if there are barriers that will cause them to be unable to complete their trips. Instead, transit agencies ideally will review specific trips requested by riders using the condi- tions of eligibility established for those riders. If trips are reviewed and appear able to be made by fixed-route transit, this information would then be communicated to the riders. Common Concerns about Implementing Trip-by-Trip Eligibility While a significant percentage of transit agencies (63%) report that they establish conditions of eligibility as part of the determination process, the research found that very few appear to be TriMet in Portland, OR, and Valley Metro in Phoenix, AZ, house their ADA paratransit eligibility determination processes and travel training programs in the same facility. This allows them to more easily get travel training services started for applicants who express an interest in participating in the programs. Intercity Transit in Olympia, WA, uses travel trainers to conduct functional assessments. In this way, the applicant is introduced to travel training as part of the eligibility determination process, including use of mobility devices on fixed-route transit, site evaluations/barrier assessments for particular trips, and path-of-travel navigation. Inquiries and referrals for travel training also come from other sources. Some ADA paratransit eligible riders self-refer out of a desire for greater independence and spontaneity, and many individuals participate in travel training without any affiliation with Dial-A-Lift, Intercity Transit’s ADA paratransit service. Social service agencies and school transition programs also make referrals for riders and students. The tie to the eligibility determination process is, however, one important way to educate riders about travel training.

134 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities doing trip-by-trip eligibility. Fifty-eight transit agencies indicated that they apply conditions of eligibility in some way. Thirty-one of these indicated only limited application of conditions, such as setting “winter” or “summer” eligibility. Twenty-seven agencies reported that they apply conditions to trips in a broad way. Follow-up with many of these transit agencies indicated, though, that conditions are “related” to trips, but not actually applied to trip requests. Only a handful of transit agencies identified actually apply conditions of eligibility to trip requests. Possible reasons why trip-by-trip eligibility has not been implemented more broadly include: Lack of Complete and Specific Conditions Some transit agencies set general conditions of eligibility such as “distance,” or “path-of- travel barriers,” but do not make the conditions specific enough to allow trips to be evaluated. Some transit agencies also identify only a few obvious conditions, such as winter weather, but do not identify all of the barriers that might prevent travel by fixed-route transit. As a result, they are not able to use the conditions on file to actually review specific trips. Misunderstandings about How Trip-by-Trip Eligibility Should Be Performed A common misunderstanding is that trip-by-trip eligibility must be done by reservation- ists and schedulers at the time that riders are calling in to request trips. Because of a lack of national experience and direction on how to do trip eligibility, many transit agencies feel that reservationists have to determine the distance to and from stops, evaluate the paths of travel to and from bus stops, and review other types of barriers at the same time that they are trying to book rides. This misunderstanding leads to the conclusion that trip-by-trip eligibility is opera- tionally infeasible. Adequate guidance on how trip-by-trip eligibility can be implemented has not been provided. The case studies presented below attempt to dispel this misunderstanding by describing how trip eligibility has been successfully implemented in at least two locations. Misunderstandings About Data Needs Some transit agencies are under the impression that extensive data about accessibility of the service area is needed before trip eligibility can be implemented. For example, they think that an inventory of all bus stops, identifying which are accessible and which are not, is needed. Or, they think that all streets and intersections need to be surveyed for sidewalks, curb ramps, and other features, and that they must have a detailed inventory of all barriers in the service area before they can implement trip-by-trip eligibility. As the case studies below indicate, trip eligibility only requires an assessment of bus stops and the streetscape for the specific trip being reviewed. A database of accessibility can be built over time, but is not required at the outset. Case Studies of Successful Implementation of Trip Eligibility Following are several different approaches for implementing trip-by-trip eligibility that were identified by the research. The transit agencies that were found to have successfully employed these approaches are noted. Reviewing Specific Trips for Riders—Intercity Transit, Olympia, WA Intercity Transit in Olympia, WA, offers to do “barrier assessments” for riders who have been determined conditionally eligible. If riders have never made a particular trip on the fixed-route transit system and are not sure what barriers might exist, they can call Intercity Transit and ask that an assessment be done. Assessments are performed by travel trainers employed by the transit agency. The travel trainers will first review the types of barriers that affect the rider. They then go out on the street, walk from the origin to the bus stop that would be used to begin the trip, and walk from the alighting bus stop to the final destination. They make note of whether or not barriers exist along the routes. Once the assessment is completed, they contact the rider to indicate if the trip can be made by fixed-route transit.

aDa paratransit eligibility Determinations 135 This service is offered with “no strings attached.” Riders are under no obligation to make trips by fixed-route transit if the assessment indicates that there are no barriers. Intercity Tran- sit has found, though, that riders who make these requests are interested in using fixed-route transit whenever possible and just need to know if barriers exist before they attempt the trip. Intercity Transit tracks the number of barrier assessments completed, but not the number of trips that are then made by fixed-route transit. In 2012, 65 barrier assessments were conducted. Agreeing on Certain Trips That Can Be Made by Fixed-Route Transit—SamTrans, San Carlos, CA SamTrans in San Carlos, CA, uses in-person interviews and functional assessments to make ADA paratransit eligibility determinations. As part of the interviews, assessors ask about use of fixed-route transit services. This includes past as well as current use of buses and trains. If cur- rent use is indicated, assessors ask follow-up questions about the specific trips currently made by bus or train (i.e., exact locations) and make sure to verify with applicants that it is reasonable for them to be using fixed-route transit for these trips. If applicants agree that they can continue to make these trips using fixed-route transit, this information is recorded and made part of the final determination. Letters of determination first state any general conditions of eligibility and then list any trips that applicants agree can be made by fixed-route transit. Text from a sample letter provided by SamTrans is provided below. Note that SamTrans sometimes uses the phrase “trip-by-trip” as a type of conditional eligibility and has two separate paratransit services— Redi-Wheels and RediCoast—that operate in different parts of the service area. Text Excerpted From Sample SamTrans Letter of Conditional Eligibility “Dear (Applicant Name): Thank you for applying for Redi-Wheels or RediCoast paratransit with the San Mateo County Transit District (SamTrans). ADA paratransit eligibility is determined by your functional ability to use fixed-route bus service. Based on your application and interview, we determined that you can sometimes use the fixed-route bus and sometimes are prevented from using the bus. Therefore, you qualify for TRIP-BY-TRIP use of Redi-Wheels/RediCoast. You may use ADA paratransit for trips: • with a destination you cannot reach using a single bus or train. • when you must travel in hours of darkness between sunset and sunrise, due to limited vision. As part of the above restriction, you are not allowed to use ADA paratransit during hours of daylight to travel between your home and the following locations, which you indicated you are currently able to reach using fixed-route bus service: • Tanforan Mall, San Bruno • Serramonte Mall, Daly City • Your son’s school: Allen Elementary (near the San Bruno Library), San Bruno You may use paratransit for other destinations during hours of darkness, or if the destinations cannot be reached using a single bus or train.”

136 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities SamTrans’ determination letters also include other required information, such as notice of the right to appeal and how to request appeals, eligibility expiration date, telephone number for reaching the ADA paratransit program, and whether use of a PCA is authorized. The above excerpt is just the portion of the letter explaining conditions placed on eligibility. Conditions of eligibility, as well as descriptions of trips that can be made by fixed-route transit, are included in rider files in the software used to book and schedule trip requests. Res- ervationists are able to access details about conditions of eligibility for riders identified as being conditional or “trip-by-trip” eligible. SamTrans noted that they do not evaluate trips using the general conditions of eligibility, but do apply specific trip restrictions. If riders request trips that are listed in the system as being able to be made by fixed-route transit, reservationists can remind riders of the restric- tions. SamTrans does not track the number of times this happens in reservations, but reserva- tionists indicated that they do not often get requests from riders for trips that are restricted. This qualitative information suggests that riders understand the trip restrictions that have been placed on their eligibility and are fairly diligent about self-regulating their use of ADA paratransit. Applying Conditions to Frequently Made Trips—Metro Transit, Seattle, WA Metro Transit staff indicated that use of a thorough determination process, including in- person interviews and/or assessment for all applicants, has enabled them to identify specific conditions under which some riders can use fixed-route transit service. Metro has established 17 basic types of conditions and customizes these to individual riders. The types of conditions used by Metro are shown in Appendix A. Conditions of eligibility are explained to riders in determination letters. All riders granted conditional eligibility are also contacted in person after letters are sent and their conditions of eligibility are explained and discussed. Prior to 2006, riders were informed of the conditions under which they were considered able to use fixed-route transit, but all trip requests were accepted and scheduled. In 2006, Metro began to apply conditions of eligibility to rider trip requests. Before implementing eligibility conditions, Metro discussed the concept at length with its advisory committee. Some advisory committee members had concerns about applying conditions and did not fully understand how trip-by-trip eligibility determinations would work. Metro continued these discussions and provided information on the proposed process until all questions were answered and the advisory committee was on board with the approach. Metro started by doing trip eligibility reviews for the most frequently made trips. From 2006 through 2008, only trips made at least once per week were reviewed. Once these most frequent trips were identified and reviewed, Metro lowered the threshold. In 2009, trips made at least 10 times in 12 weeks were reviewed. In 2010, the threshold was lowered to trips made at least eight times in 12 weeks. In 2011, this was lowered to six trips in 12 weeks. And in 2012, at the time of the review, all trips made at least three times in 12 weeks were being reviewed. Eligibility Data Management. Metro uses scheduling software to manage the Access para- transit service. Details about rider eligibility are entered into the system. This includes applicable codes for riders granted conditional eligibility. It also includes information about individual trips that have been reviewed for eligibility. The software has been customized to use the infor- mation in the rider eligibility file to assist with trip-by-trip eligibility determinations. Eligibility Conditions. As shown in Appendix A, some eligibility conditions vary by time of day or time of year. These include things such as hot or cold temperatures, the presence of

aDa paratransit eligibility Determinations 137 snow or ice, and low or bright light. Metro has developed the following policies and procedures related to these types of conditions: • Hot temperature (HT) conditions have been standardized to mean that riders are not able to travel when the temperature exceeds 85° F. Seasonal eligibility is granted from July 1 through August 31 to riders with HT conditions. During this period, riders may request trips during the full advance reservation period (up to three days in advance). From September 1 through June 30, riders with HT conditions can only request trips one day in advance, and trips are booked only if the daytime high temperature for that area of King County is greater than 85° F for that day. From July 1 through August 31, the scheduling software is set not to limit any trip requests based on the HT condition. From September 1 through June 30, managers in the call center look at the predicted temperatures throughout the service area for the next day. If the tem- perature in any part of the area is predicted to be above 85° F, the software is set to not limit trips based on the HT condition. If no areas are predicted to have temperatures above 85° F, the software is set to apply HT conditions to any trips requested by riders who have this as part of their conditional eligibility. • Cold temperature (CO) conditions have been standardized to mean that riders are not able to travel when the temperature is below 40° F. Seasonal eligibility is granted from November 1 through February 28 to riders with CO conditions. During this period, riders may request trips during the full advance reservation period (up to three days in advance). From March 1 through October 31, riders with a CO condition can only request trips one day in advance, and trips are booked only if the daytime high temperature for that area of King County is below 40° F for that day. From November 1 through February 28, the scheduling software is set to not limit any trip requests based on the CO condition. From March 1 through October 31, managers in the call center look at the predicted temperatures throughout the service area for the next day. If the temperature in any part of the area is predicted to be below 40° F, the software is set to not limit any trip requests based on the CO condition. If no areas are predicted to have tempera- tures below 40° F, the software is set to apply CO conditions to any trips requested by riders who have this as part of their conditional eligibility. • Snow/ice (SNI) conditions apply when there is actually snow or ice on the ground that would prevent travel. Riders with this condition must call one day in advance to book trips. Dur- ing non-winter months, the software is set to apply the SNI condition to any trip requests by riders who have this as part of their eligibility conditions. Throughout the winter months, managers in the call center review the predicted weather throughout the service area and adjust the software setting appropriately. If snow or ice is predicted anywhere in the ser- vice area, the software is set to not limit trip requests based on this condition. If there is no snow or ice predicted in the service area, the software is set to apply this condition to trips requested by riders who have this as one of their conditions. • Darkness (NT) conditions apply to riders who have vision disabilities and cannot travel dur- ing times of low light. These riders may book trips that involve travel from sunset to sunrise. The scheduling software is programmed to apply or not apply this condition using time set- tings each month. The time settings are based on the longest hours of darkness each month rounded to the nearest five minutes (rather than being set each day). • Extreme Light (LT) conditions apply to riders who cannot travel during times of bright light. Metro’s policy is to allow riders with this condition to use Access during any daylight hours. Daylight hours are set each month based on the longest hours of daylight for that month rounded to the nearest five minutes.

138 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities “Pathway” conditions must be evaluated by Mobility Specialists for the specific trips requested. These include things such as maximum walking distances, steep hills, inaccessible bus stops, difficult intersections or street crossings, uneven terrain, or the lack of sidewalks or curb ramps. Since 2008, Metro has used three Mobility Specialists, provided by their call center contractor, to assist with pathway reviews. Mobility Specialists regularly generate lists of riders and trips meeting the review threshold (currently at least three times in 12 weeks). Trips that have not yet been evaluated are then assigned for review. Mobility Specialists start by identifying the specific conditions that would prevent riders from using fixed-route transit service. If riders have “Pathway” conditions, the Mobility Specialists use Metro’s fixed-route trip planner to determine how the trips could be made by bus or train. The fixed-route transit stops that would need to be used are identified and maps are generated showing the streets and paths of travel that would be used to get from the origin to the boarding stop and from the alighting stop to the destination. On-street reviews are then conducted along these paths of travel to determine if any barriers exist. Metro has developed an automated data collection process to assist in recording observa- tions and storing information about pathways. Mobility Specialists use handheld computers to record observations (see Figure 9-5). Maps of the street networks at both the origin and destination are loaded onto the handheld units. Observations about the accessibility of each street segment are then entered directly into the units and linked to the street segments or inter- sections on the maps. Graphic attributes (such as the location of curb ramps, the steepness of the street segments, or uneven surfaces) are then used to display accessibility features on the maps (see Figures 9-6 and 9-7). All physical barriers, whether or not they apply to the rider in question, are evaluated so that the information for those street segments can be stored and used in the evaluation of other trips in those areas. Results of the on-street reviews are then used to determine if there are any pathway barri- ers that would prevent the trips being evaluated from being made by fixed-route transit. This information is entered into a trip spreadsheet for each conditionally eligible rider. Each row in the spreadsheet represents a trip that has been evaluated. If no barriers are identified, trips are tagged in the spreadsheet with a NQ (Not Qualified) coding, meaning there are no pathway Figure 9-5. Mobility specialist recording data on a handheld computer (photo courtesy of Metro).

ADA Paratransit Eligibility Determinations 139 Figure 9-6. Map showing street segments with graphic attributes (screenprint courtesy of Metro). Figure 9-7. Attributes and attribute icons used on trip review maps (screenprint courtesy of Metro).

140 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities barriers that qualify them for Access paratransit service. Information in rider trip spreadsheets is then uploaded into the rider eligibility file in the scheduling software. If pathway reviews indicate that there are no travel barriers, riders are contacted in person by Metro’s Mobility Planner. They are informed of the reviews and told that there do not appear to be any barriers that would prevent the use of fixed-route transit. Detailed information about how to make the trips by fixed-route transit is also prepared and sent to riders. If riders are not comfortable attempting the trips alone, travel training services are offered to assist them with the transition. This in-person contact is made before information is uploaded into the schedul- ing software rider eligibility file, so riders do not first learn that trips are no longer eligible when they call to book the trips. Documentation of Travel Training. If riders have been successfully travel trained to make cer- tain trips by fixed-route transit, this information is also added to their eligibility file. The origin and destination addresses for these trips are entered and these trips are given the code “BTT” (Bus Travel Trained). As trips are requested, the software will search to see if the origins and destinations of the trips being requested match any BTT trips in the riders’ file. If so, the software generates a “pop-up” box alerting the reservationist that this is a trip for which the rider has been travel trained. Metro’s policy is to still book the trip, but reservationists record these trips and notify travel trainers that riders have requests the trips by paratransit. Travel trainers then follow up with individuals to determine why they decided to make these trips by Access paratransit. Metro only considers riders to have been successfully travel trained if they completed train- ing provided by Metro. Information provided by applicants about training received from others is not considered. Staff noted that this policy has been adopted so that Metro can be sure of the quality and results of the training. Transit Trips That Require Transfers. Another condition that is considered is whether trips can be made directly on fixed-route transit, that is, without a transfer, or whether one or more transfers are required. Some riders can only use fixed-route transit for direct trips. Riders with this type of condition have a “BX” coding in their eligibility file. Mobility Specialists consider this issue when doing reviews of frequently made trips. If trips can be made directly, the trip is given an NQ code in the rider’s trip spreadsheet. If there are no other conditions or barriers and the trip can be made by fixed-route transit, riders are contacted in person by the Mobility Planner and options for using the bus or train are explained. Two conditions depend on the effects of the disability on the day of service. These are “Life- Sustaining Medical” (LSM) and “Good Day/Bad Day” (GBD) conditions. The software is not programmed to limit trip requests based on these conditions. Trip requests from riders with these conditions are simply accepted, but these riders must book trips no more than one day in advance. Customized Trip Scheduling Software. The software used by Metro to accept and schedule trip requests has been customized to consider all of the above information. If a trip is being sched- uled for a conditionally eligible rider, the software will examine the rider’s trip eligibility file to see if there are any trips coded as NQ that match the origin and destination of the trip being requested. If the trip is found to be in the file and coded NQ, the software will also consider whether any other conditions apply for that rider that would prevent use of fixed-route transit. This includes conditions related to weather and time of day. The system will only generate a pop-up window and alert reservationists that the trip is not eligible and can be made by fixed- route transit if all conditions in the file for the rider are satisfied. The pop-up windows are also designed to provide relevant information that reservationists can relay to riders. For example, if a rider only has a cold temperature condition (CO), and the predicted weather does not prevent travel by fixed-route transit, the pop-up screen will indicate the rider is only eligible to ride from November 1 through February 28, or when the temperature if below 40° F.

aDa paratransit eligibility Determinations 141 While riders can challenge trip eligibility decisions, it was noted that this rarely happens. Metro staff attributed this to (1) telephone follow-up with all riders to explain their conditions of eligibility, (2) personal contact by phone if trip reviews indicate no barriers and the possibil- ity of making trips by fixed-route transit, and (3) sending riders detailed information about how to make trips by fixed-route transit when reviews identify this as an option. Applying Established Conditions to All Trip Requests—ACCESS, Pittsburgh, PA ACCESS is considered a pioneer in applying conditional and trip-by-trip eligibility. The agency began providing conditional eligibility to riders who could sometimes use fixed-route transit services in 1995. Conditions of eligibility have been applied and trip-by-trip eligibility decisions made since July 1, 2003. ACCESS has applied conditions of eligibility to all trips, not just subscription or frequently made trips, since 2003. There is no standard list of conditions that apply to eligibility. The conditions are established based on individual rider abilities. Public Input and Support. A significant public input process was undertaken before trip- by-trip eligibility determinations were implemented. This included several large community informational meetings, as well as small group meetings with riders to explain how the process would work. ACCESS also has a regular newsletter. Information about conditional and trip- by-trip eligibility was the focus of several newsletters during the time the process was being discussed. Initially, some riders were not pleased with the idea of trip eligibility. In the end, though, key advocates in the community, who supported the idea of integrated transportation and maxi- mizing use of the fixed-route transit service, convinced others in the community to support the policy. The community did request that ACCESS not implement trip eligibility until all Port Authority of Allegheny County (PAT) fixed-route transit services were 100% accessible. This way, trip eligibility would be applied fairly to all riders, regardless of the type of disability. The community also requested that trip eligibility be applied to all trips, rather than just subscrip- tion trips or the most frequently made trips—again for fairness reasons. In total, the policy was debated over a two year period, and ACCESS waited until 2003, when all PAT services became fully accessible, to implement the process. Convenience Fare. Another key to gaining public support was the introduction of a “con- venience fare.” Riders argued that even though trips might be able to be made on fixed-route transit, there may be important reasons why they might prefer to make trips by paratransit. They recognized, though, that these would not be ADA eligible trips. So, it was agreed that these trips would be subject to a higher fare. This convenience fare was set with community input at twice the regular ADA paratransit fare (currently $6.30 rather than $3.15). ACCESS and PAT agreed to hold the convenience fare at this price subject to available funding. It was agreed that the fare would be increased if demand for convenience rides was too high and could not be funded. Since its adoption in 2003, riders have been responsible in using the convenience fare option. In FY 2012, a total of 558,332 ADA paratransit eligible trips were provided. Only 32,837 convenience fare rides have been requested, about 5.6% of the total ADA plus convenience trips. Trip Reviews. From 2003 to 2007, ACCESS implemented trip-by-trip eligibility determina- tions without any special software or technology. As trips by conditionally eligible riders were requested, the origins, destinations, and names of the riders were recorded and added to a list of trips that needed to be reviewed. Customer service staff took one trip at a time, looked up the rider’s specific conditions, and conducted a review to determine if the trip requested could be made by fixed-route transit. Until trips were reviewed and decisions about their eli- gibility made, the trips were considered presumptively eligible. Once trips were reviewed, the decisions about eligibility were recorded for each conditionally eligible rider. If it was found that trips could be made by fixed-route transit, riders were contacted by phone by customer

142 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities service staff. Detailed instructions for making the trip by fixed-route transit were provided. Applicable bus schedules and instructions were also prepared and mailed to riders. ACCESS also offered riders the option of having a staff person go with them on the first trip. This personal contact was made before trip eligibility decisions started to be made in reservations. This way, riders knew the eligibility of trips even before they called to request rides. As noted above, they could still request rides under the convenience fare option, but they knew in advance which trips qualify as ADA eligible at the lower fare and which would require paying the higher convenience fare. In some cases, the review could be conducted by simply looking up readily available infor- mation about the trip. For example, if a rider’s only condition was that he/she could not make a trip by fixed-route transit if it involved a transfer, the staff person only needed to consult the PAT trip planner to see if the trip could be made by fixed-route transit without a transfer. Or, if the only condition was that the rider could only walk three blocks to get to or from fixed-route transit stops, the staff person could again consult the trip planner as well as a computer map- ping program to see how far the origin and destination were from stops that would be used to make the trip. Other reviews took more effort. If the rider’s conditions included path-of-travel issues, such as steep terrain, a lack of curb cuts, a lack of sidewalk, or uneven surfaces, the staff person needed to go out on the street and evaluate the path of travel to and from stops firsthand. Weather and time of day conditions were handled in reservations. These included heat and cold, snow and ice, and dusk to dawn conditions. ACCESS provided information about predicted weather to each service provider. Each provider was required to post the predicted weather in their reservations area. Reservationists then considered these predicted conditions when trip requests were received from riders with conditional eligibility. ACCESS worked with riders and its advisory board to establish a policy for handling these types of conditions. Riders with weather and time of day conditions were asked to call one day in advance to place trip requests. It was agreed that the National Weather Service (NWS) would be used, since it was readily available by phone, online, and on the radio and was updated several times each day. If the NWS predicted a 30% or greater chance that the particular weather condition would exist, the ride was made eligible. If that weather condition did not materialize, the ride was still provided. And if a trip was not approved and the weather turned out to be worse than predicted, riders with weather conditions were allowed to call and request same-day rides. ACCESS staff reported that the NWS proved to be surprisingly reliable and that weather related conditions of eligibility turned out to be some of the easiest to apply. The number of same-day trips that needed to be provided because of incorrect NWS forecasts were very small and very manageable. Same-day trips because of unpredicted snow and ice proved to be easy to accommodate since many other riders tended to cancel trips on those days, creating slack time in the schedules. Good Day/Bad Day Conditions. Trip requests by riders with “good day/bad day” conditions, meaning their abilities to use fixed-route transit could change each day, were not reviewed. Riders were simply allowed to place trip requests and these requests were booked. Manual Record Keeping. In the initial years of implementation, ACCESS created manual recordkeeping systems to manage trip eligibility information. This included street information binders for various sections of the service area, which were used to record the accessibility of street segments. It also included a catalog of conditionally eligible riders, with decisions about their prior trip requests. In the first few years of implementation, ACCESS indicated that about 0.5 FTE of customer service staff time was spent reviewing trip eligibility and accompanying riders the first time they used fixed-route transit. Over time, the amount of staff effort required decreased as many

aDa paratransit eligibility Determinations 143 of the trips made by conditionally eligible riders were already reviewed. As records of path-of- travel barriers were developed, staff could also consult these records rather than going out to review street segments that had not yet been evaluated. Once the path-of-travel from a rider’s home to the nearest bus stop was reviewed, decisions about future trips that originated at the home only required an evaluation of the path of travel from the alighting stop to the destination. In 2012, few new trips by existing conditional riders needed to be reviewed. Most of the time was spent reviewing trips requested by newly certified conditional riders. ACCESS managers were estimated that only about 1.5 hours per day was spent by customer service staff in 2012 to review trip requests from conditionally eligible riders. While it was possible to do trip-by-trip eligibility with manual records, ACCESS staff indi- cated that there were some problems. Initially, riders complained that not enough information was provided when trips were determined able to be made by fixed-route transit. This was addressed by stressing the need for better communications about trip decisions. The decen- tralized service delivery design also presented challenges. With eight different providers and reservations centers, there were inconsistencies in the application of trip eligibility proce- dures. ACCESS had to regularly audit trip bookings by conditionally eligible riders to improve consistency. Software for Trip Eligibility. In 2007, ACCESS developed software to assist with trip-by-trip eligibility determinations. The software, known as ACCESS Infinity, was developed with a local information technology company, and also includes reservations, scheduling and dispatch capabilities. The software has been adopted by all of ACCESS’s dedicated service providers. A trip eligibility file is set up for all riders who are conditionally eligible. The file contains detailed information about their conditions of eligibility. It also notes the fixed-route bus stop nearest the home and whether the rider is able to get to that stop—determined through inter- views and on-street assessments as needed. Knowing whether riders can get to and from the nearest bus stop is then helpful for doing trip eligibility reviews for any trips that start or end at the home. The eligibility file also includes the results of trip reviews. Riders indicate in the ADA para- transit application form their three most common trips. These are reviewed as part of the initial eligibility determination and riders are informed in determination letters, as well as through personal phone contacts, whether these trips can be made by fixed-route transit. The results of the review of these three most common trips are also entered into the trip file. As additional trips are requested and reviewed, they are also added to the file. The lower ADA paratransit fare is linked to trips that are determined not possible by fixed-route transit. The higher conve- nience fare is linked to trips that are determined able to be made by fixed-route transit. A screen print of a sample ACCESS Infinity trip eligibility file is show as Figure 9-8. When riders call and request trips, the Infinity system compares the origin and destination of the trip being requested to trips in the rider’s eligibility file. If the information in the file indicates that the trip is ADA paratransit eligible, the system populates the fare field on the trip booking screen with the ADA paratransit fare. This lets the reservationists know that the trip is paratransit eligible. The system also tags the trip with the code for why the trip cannot be made by fixed-route transit using standardized conditional trip eligibility codes (e.g., “8 – Route Not Accessible”). If the trip eligibility file indicates that the trip can be made by fixed-route transit, the system enters the convenience fare into the fare field in the trip booking screen, letting the reservationist know that the trip is not ADA paratransit eligible but can still be taken if the rider elects to pay the higher fare. If the trip being requested is not in the trip eligibility file (a new request or a trip that has not yet been evaluated), the system considers the trip presumptively ADA paratransit eligible.

Figure 9-8. Screenprint of sample infinity trip eligibility file (courtesy of ACCESS).

aDa paratransit eligibility Determinations 145 Weather and Time of Day Conditions. With the new software system, ACCESS handles weather and time of day issues as follows: At the time of trip bookings, the Infinity software does not consider weather or time of day issues. Trip requests by riders with these types of con- ditions are booked only considering other types of possible barriers. One day before the day of service, ACCESS staff reviews all trips that are booked with weather or time of day eligibility codes. If the predicted weather or time of day will not prevent travel, riders are contacted and informed the trip can either be taken on fixed-route transit or on paratransit at the convenience fare. ACCESS staff noted that very few calls typically have to be made. Weather and time of day issues are often not the only conditions that affect travel. ACCESS is considering upgrades to the Infinity system to avoid call-backs, though. In the future, ACCESS plans to have the Infinity system link to the NWS so that predicted weather can be considered during the trip booking process. Adding information about hours of dawn and dusk is also being considered so that this issue can be automatically considered. ACCESS tracks trips provided to conditionally eligible riders. Trips are categorized based on the primary barrier that prevents use of fixed-route transit. For example, if a rider’s use of fixed-route transit is affected by the lack of sidewalks as well as by hot temperatures, and there are no sidewalks from her origin to the closest bus stops, the trip would be placed under the “Route Not Accessible” category since she would always be prevented from making this trip, regardless of the temperature. When applicable, this information is used to inform local officials about the need for acces- sibility in the community. For example, ACCESS can identify the trips prevented from being made on fixed-route transit due to a lack of intersection controls, or the lack of sidewalks or curb ramps. This information can then be provided to local communities and can be used to advocate for accessibility improvements. Similarly, ACCESS can identify trips that cannot be made because of inaccessible bus stops and can provide this information to PAT. 9.4 Outcomes, Costs, and Benefits The literature contains some information about the outcomes and costs associated with more thorough determination processes that can identify conditions of ADA paratransit eligi- bility. Very limited information exists, however, about the outcomes, costs and benefits of doing trip-by-trip eligibility determinations. As part of this study, additional outcome data was collected from the five case studies con- ducted on conditional and trip-by-trip eligibility determinations. Cost and benefit information associated with trip-by-trip eligibility determinations was collected from two of the case study sites—Metro Transit in Seattle and ACCESS in Pittsburgh. This section first summarizes the outcomes, costs and benefits associated with more thorough ADA paratransit eligibility determinations. It then provides a detailed analysis of the outcomes, costs and benefits of trip-by-trip eligibility determinations at Metro Transit in Seattle and ACCESS in Pittsburgh. More Thorough Eligibility Determinations Outcomes TCRP Synthesis 30 (54), the first national review of ADA paratransit eligibility processes and outcomes, provides information about typical outcomes reported by transit agencies using various types of determination processes. Transit agencies that relied on self-certification and

146 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities verification of disability from professionals reported that 88% of applicants were determined unconditionally eligible, 11% were found to be conditionally eligible, 1% were given tempo- rary eligibility, and 7% were found not eligible. Agencies that included in-person interviews and functional assessments in the process reported much different results. Depending on how interviews and functional assessments were used, they reported that between 57% and 75% were unconditionally eligible, 18–37% were conditionally eligible, 4–10% were eligible on a temporary basis, and 9–23% were not eligible. In 2009, the National Transit Institute (NTI) collected eligibility determination outcome data from three transit agencies that were considered to have thorough processes. The data are included in NTI’s participant workbook for its course on Comprehensive ADA Paratransit Eligibility. (58) The three transit agencies reported finding between 48% and 70% of applicants unconditionally eligible, 28–31% conditionally eligible, 4–11% eligible on a temporary basis, and 2–9% not eligible. A study conducted for the Regional Transportation Authority (RTA) in Chicago also provides outcome information collected from five transit agen- cies that were considered to have thorough processes. (59) All five required applicants to participate in interviews and performed functional assess- ments as needed. Reported outcomes were: 38–70% unconditional; 25–54% conditional; 2–13% temporary; and 1–11% not eligible. Outcome data were also collected from five transit agencies that served as case studies for this research. Four of the agencies (Metro Transit, ACCESS, UTA, and SamTrans) require all applicants to participate in in-person inter- views. Functional assessments are then conducted as needed. Intercity Tran- sit uses in-person interviews and functional assessments only as needed and typically asks about 12% of applicants to appear in-person. Reported out- comes were as follows: 53–70% unconditional; 8–30% conditional; 7–17% temporary; and 1–15% not eligible. Table 9-3 summarizes outcome information from all of the above sources. The table shows outcomes for transit agencies that only use paper applications as well as outcomes from agencies that use in-person interviews and functional assessments. Outcomes for transit agencies that use only paper applications are based on TCRP Synthesis 30. Outcomes shown for agencies that use in-person interviews and functional assessments are averages, as well as ranges, based on all of the sources detailed above. On average, studies have found that transit agencies that rely on paper applications find 88% of applicants unconditionally eligible, 11% conditionally eligible, and 1% eligible on a temporary basis. Transit agencies that include in-person interviews and functional assessments in the process find, on average, about 63% of applicants uncondition- ally eligible, 28% conditionally eligible, and 9% eligible on a temporary basis. The research suggests that a thorough and accurate ADA para- transit eligibility process does not result in significantly increased denials of eligibility. Instead, it does a better job of identifying when some applicants are able to use fixed-route transit, which results in more applicants being conditionally eligible rather than unconditionally eligible. Type of Process Determination Outcomes Unconditional Conditional Temporary Not Eligible Paper Applications with Professional Verification* 88% 11% 1% 7% In-Person Interviews and Functional Assessments** 63% Range: 38-75% 28% Range: 8-54% 9% Range: 2-17% 7% Range: 1-23% *Source: (54). Note: Report provides averages. Ranges not indicated. **Sources: (47, 54, 58, 59), Case Studies. Table 9-3. Reported ADA paratransit eligibility determination outcomes for paper versus in-person determination processes.

aDa paratransit eligibility Determinations 147 It is interesting to note that using in-person interviews and functional assessments does not appear to increase the percent of applicants found not eligible. For both types of processes, about 7% of applicants were determined not eligible. More thorough processes that use in- person interviews and functional assessments find more applicants conditionally eligible or eligible on a temporary basis, and fewer applicants unconditionally eligible. Costs Three types of costs are incurred to make in-person interviews and functional assessments part of the ADA paratransit eligibility determination process. These are costs associated with conducting interviews and assessments, facility and equipment costs for setting up assessment centers, and transportation costs for getting applicants to and from assessment centers. Interview and Functional Assessment Costs Limited information is available in the literature on the cost of in-person interviews and functional assessments. The information available, though, suggests that costs can vary sig- nificantly depending on how the process is structured, what parts of the process are performed by transit agency staff versus contractors, and the qualifications of individuals performing functional assessments. Material for NTI’s Comprehensive ADA Paratransit Eligibility course provides cost informa- tion for two transit agencies that contract to have licensed physical or occupational therapists conduct functional assessments. (58) Costs (in 2009) ranged from $105 to $155 per interview/ assessment. Assuming 2% inflation per year, this would suggest 2013 costs of $114 to $168 per interview/assessment. A study conducted for Valley Metro of Phoenix includes 2008 cost information from two transit agencies that contract to have other types of professionals perform interviews and func- tional assessments. (47) Costs ranged from $78 to $93 per interview and assessment. This would be about $86 to $103 in 2013 dollars. The case study of Metro Transit in Seattle, conducted as part of this study, found similar costs. In 2011, Metro Transit paid $799,085 to a regional medical center to have 4,694 interviews and functional assessments performed by occupational or physical therapists. On average, interviews and assessments cost $170. In 2013 dollars, this would be about $177 per interview/ assessment. The case study of ACCESS in Pittsburgh, PA, indicated that it is possible to incorporate in-person interviews and functional assessment into the eligibility determination process at a lower cost by working cooperatively with local disability organizations. ACCESS has a con- tract with Easter Seals of Western Pennsylvania (ESWP) under which ESWP provides the ser- vices of physical therapist at a rate of $50 per hour. ACCESS then schedules assessments as needed. ACCESS estimates that each functional assessment requires about one hour of time, which includes the assessment as well as paperwork. Each functional assessment therefore costs ACCESS about $50. Facility and Equipment Costs Facility and equipment costs also can vary significantly depending on how assessments are conducted. Some agencies have built elaborate indoor assessment centers with ramps of vari- ous slopes, paths of travel with various types of surfaces, mock-ups of buses and bus stops, and mock-ups of street crossings. All assessments are conducted in a simulated travel environment in these facilities. Other transit agencies conduct assessments in the real environment whenever possible and have minimal props and equipment in an indoor facility that are used only when going outdoors is not appropriate.

148 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities Facility costs can also vary based on the number of assessment centers that are set up. Typi- cally, unless the service area is very large, transit agencies conduct interviews and assessment in one central facility. This not only reduces cost, but can help ensure more consistent outcomes. The research team is aware of only a few transit agencies that have set up multiple assessment centers—New Jersey Transit, which operates statewide; the RTA in Chicago, which has an ADA paratransit service area roughly the size of Connecticut; and New York City MTA, which has multiple contractors (due in part to the volume of applications received) who conduct interview assessments at their various locations in each of the city’s boroughs. • Access Services, Inc. (ASI) in Los Angeles is an example of a transit agency that built an assessment center and conducts all assessments in this facility. The facility is 19,500 sq. ft. in size and cost $17,000 in rent per month in 2009. A large facility is needed to accommodate the 150–160 assessments done each weekday and to allow multiple assessments to be conducted at one time. Modifications to the facility and equipment for conducting assessments cost about $310,000 in 2005. (58) • SamTrans in San Carlos, CA, also conducts all assessments indoors in a specially built facility. The facility is smaller, though, and is designed for much lower volume—about 10 to 11 applicants per day. The facility is about 3,000 sq. ft. in size. As part of the case study conducted for this research, SamTrans indicated that initial modifications to the rented space, as well as props and equipment, cost about $70,000. Subsequent changes were made to the facility costing about $10–15,000. Total facility build-out and equipment cost therefore was about $80–85,000. • ACCESS in Pittsburgh is an example of an agency that conducts outdoor assessments when- ever possible. Assessments are conducted along an outdoor course located in the neighbor- hood around the main ACCESS offices. Two conference-sized rooms have been set aside for interviews and assessments. Minimal props, including a mock-up of a curb and curb ramp, and a mock-up of a bus lift have been built. Total cost incurred for indoor props and equip- ment was estimated by ACCESS staff at about $10–15,000. • DART in Dallas also conducts assessments in the real environment whenever possible. The assessment center is housed in DART’s main administrative building in downtown Dallas. Assessments are conducted along a set route in the area of the center. The center is located at a light rail station, which allows assessments to include short trips on the light rail as appropri- ate. The assessment center is composed of four offices where interviews are conducted and a common area connecting the offices where some basic assessment props are located. In total, the center is about 1,000 sq. ft. in size. If outdoor assessments are not appropriate because of extreme weather, assessors walk with applicants along corridors in the building. The cost for props and equipment was minimal. Transportation Costs U.S.DOT ADA regulations require that there can be no cost associated with applying for ADA paratransit eligibility. FTA has indicated that this means that transit agencies must pro- vide transportation, if needed by applicants, to and from any required in-person interviews or assessments. Typically, when interviews and functional assessments are being scheduled, eligibility deter- mination staff ask if applicants need transportation to and from the assessment center. If trans- portation is needed, it is either arranged on the transit agency’s ADA paratransit service (at no fare), or provided through a separate contract or fleet of vehicles (also at no fare). Costs for providing transportation to and from interviews/assessments vary based on local circumstances. Higher per trip costs can be expected in areas with large ADA paratransit ser- vice areas with long average trip lengths. Higher costs can also be expected if the assessment

aDa paratransit eligibility Determinations 149 center is not located near accessible public transportation, as a higher percentage of applicants will need assistance with transportation. In general, transit agencies should expect to pay something close to the average ADA para- transit per trip cost for transportation to and from interviews and assessments. Depending on the location of the assessment center and the quality of fixed-route public transit services, agencies should also expect 70–80% of applicants to request assistance with transportation. Summary of Costs Table 9-4 provides a summary of the likely costs associated with including in-person inter- views and functional assessments in the ADA paratransit eligibility determination process. The added cost of performing interviews and functional assessments is typically $100–$150 per applicant. This can range from as low as $50 to as much as $200 per applicant. Factors that further define the cost are the required qualifications of the staff that perform assessments (e.g., whether licensed physical or occupational therapists are used), and if the transit agency is able to work with local disability or public service organizations that provide in-kind contributions to the process. The cost of setting up an assessment center is typically about $50,000 to $100,000. Facility set-up costs can vary significantly, from a low of about $15,000 to as much as $350,000. Set-up and build-out cost depends on the size of the facility needed and whether extensive testing is done indoors versus in the real environment. Ongoing facility costs depend on the size of the facility, local commercial rents, and whether a new facility is needed. An average assessment center is in the range of 2,000 sq. ft. Ongoing facility costs can be minimal if assessments are conducted mainly in the real environment and interviews are conducted in existing, available administrative offices. Ongoing costs can be higher, though, if a large assessment center is created. Centers of 15,000 sq. ft. and greater have been set up by some agencies. Transportation costs can be expected to be about the same as the average local ADA para- transit costs. The majority of applicants (perhaps 70–80%) can be expected to need assistance with transportation. The percent of applicants needing transportation will depend on the loca- tion of the assessment center and on its proximity to accessible fixed-route transit services. Table 9-4. Summary of costs for incorporating in-person interviews and functional assessments into the eligibility determination process. Cost Typical Cost Range and Factors Interview and Functional Assessment Costs $100-$150 per interview/assessment $50-$200 (depending on required qualifications of assessors and cost- reduction assistance received from working with local disability agencies) Facility and Equipment Costs—Set-Up $50,000-$100,000 $15,000-$350,000 (depending on the role of the indoor facility in the process and number of applicants per day) Ongoing Facility Cost Rent for 2,000-3,000 sq. ft. space From minimal (share of rent in current agency facility) to rent for 15,000 sq. ft facility. Depends on size of desired assessment center Transportation Costs Approx. the average local ADA paratransit cost per trip, with 70-80% of applicants requiring assistance with transportation Actual cost depends on typical local trip distances and on proximity of the assessment center to accessible fixed-route transit services

150 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities Benefits The main benefit of more thorough eligibility determination is that more applicants are found able to use fixed-route transit services for some of their trips. If implemented in a holistic way, riders are provided with information about how to make some trips by fixed-route transit. This can increase independence and allow people to travel more spontaneously. Finding more applicants able to use fixed-route transit, at least for some trips, also reduces the demand for and cost of ADA paratransit service. The impacts of more rigorous eligibil- ity determinations on ADA paratransit demand was first studied and documented in TCRP Report 119. (60) An aggregate statistical model based on data from 28 “representative” agencies was developed to improve the estimation of ADA paratransit demand. This model suggested a demand elasticity of -0.29 for the percent of applicants found conditionally eligible (i.e., a 1% higher percent of applicants found conditionally eligible compared to the mean value of 21% corresponds to a 0.29% decrease in demand). So, for example, a process that does not grant conditional eligibility, but grants unconditional eligibility to all persons found eligible, can expect to have about 6% higher demand than an agency that finds 21% of applicants condition- ally eligible (the mean value in the model), all else being equal. And an agency that finds 30% of applicants to be conditionally eligible can expect 3% less demand for service than an agency that finds only 21% of applicants conditionally eligible. Trip-by-Trip Eligibility Determination Outcomes, Costs, and Benefits Very limited information about the benefits of implementing trip-by-trip eligibility is pro- vided in the literature. Only one report was found, TCRP Report 119, which included estimates. (60) The model developed as part of that study predicts that transit agencies that do trip-by-trip eligibility screening experience 48% lower ADA paratransit demand than systems that do not do trip screening. To supplement this limited information from the literature, detailed analysis of the out- comes, costs and benefits of trip-by-trip eligibility programs at Metro in Seattle, WA, and ACCESS in Pittsburgh, PA, was conducted. This analysis is presented below. Costs and Benefits, Metro Transit, Seattle, WA Table 9-5 provides information about trip-by-trip eligibility reviews from 2008 through 2011. This includes the number of unique trips screened by Mobility Specialists, the number of unique trips found not eligible, estimates of the number of trips per year affected by these decisions, estimates of annual operating cost savings, the annual costs of reviewing trips, and estimates of the net savings per year. Metro keeps statistics related to trip reviews conducted by Mobility Specialists, including the total number of trips reviewed and the number found not eligible. In 2008, when trips made at least once each month were evaluated, Mobility Specialists reviewed a total of 2,245 unique trips. Each leg of a trip is counted separately, so this represents one-way trips reviewed. Of these, 624 (or 28%) were found to have no pathway or navigational barriers that would prevent use of fixed-route transit. In 2009, when trips made at least 10 times in 12 weeks were considered, 2,937 unique trips were reviewed and 1,459 (or 50%) were found to have no barriers.7 In 2010, trips made at least eight times in 12 weeks were evaluated. A total of 3,062 trips were reviewed 7The increase in trips able to be made by fixed route in 2009 is due to a backlog of reviews conducted in 2008 but not com- municated to riders until 2009. Metro does not record trips as being able to be made by fixed route until notice is provided to riders. While the data are presented based on the way it is recorded by Metro by year, an averaging of data for 2008 and 2009 would provide a more accurate picture of the percent of trips found able to be made by fixed-route transit in those years.

aDa paratransit eligibility Determinations 151 and 640 (21%) were found to have no barriers. And in 2011, when trips made at least six times in 12 weeks were considered, a total of 3,318 trips were reviewed and 655 (or 20%) were found to have no barriers. To estimate the total number of trips affected each year, an average number of trips per year per unique trip reviewed was assumed. In 2008, when the review threshold was that trips must be made at least one time per week, it was assumed that the average trip was made twice each week (104 times per year). This is likely a conservative estimate since riders using the service to go to work or work training make the same trips five times per week. It was also assumed that the trip reviews were spread evenly throughout the year, so about half of the trips reviewed would be affected that year. The esti- mate of trips affected in 2008 is therefore 16,224 (624 unique trips × 52 trips per year × 0.5). In 2009, it was assumed that most trips made at least once each week would have already been reviewed, and that the reviews that year would have focused on trips made from 10 times in 12 weeks to once each week. It was conservatively estimated that the average trip reviewed that year would have been made 10 times in 12 weeks, or about 43 times each year. During that year, reviews would have therefore affected about 31,368 trips (1,459 unique trips × 43 trips per year × 0.5). It was also assumed that the trips affected by reviews in 2008 would still exist, and that Table 9-5. Metro transit trip eligibility review statistics and costs, 2008–2011. 2008 2009 2010 2011 Unique Trips Reviewed 2,245 2,937 3,062 3,318 Unique Trips Able to Be Made by Fixed- Route Transit 624 (28%) 1,459 (50%)(1) 640 (21%) 655 (20%) Est. Trips Per Year Able to Be Made by Fixed-Route Transit 32,448 (2) 31,368 (3) 11,200 (4) 8,515 (5) Est. Cumulative Trips Able to Be Made by Fixed- Route Transit (6) 32,448 96,264 138,832 158,547 Est. Operating Cost Savings (7) $1,114,264 $3,408,708 $5,067,368 $5,966,124 Cost to Do Trip Screenings (8) $293,396 $302,470 $311,825 $320,384 Est. Net Savings $820,868 $3,106,238 $4,755,543 $5,645,740 (1) The increase in trips able to be made by fixed-route transit in 2009 is due to a backlog of reviews conducted in 2008 but not communicated to riders until 2009. Metro does not record trips as being able to be made by fixed-route transit until notice is provided to riders. (2) Assumes average trip reviewed was made twice each week (104 trips per year) and that reviews were evenly distributed throughout year so that about 52 trips were affected on average. (3) Assumes average trip was made 10 times in 12 weeks (43 times a year) and that reviews were evenly distributed throughout year. (4) Assumes average trips were made eight times in 12 weeks (35 times per year) and that reviews were evenly distributed throughout year. (5) Assumes average trips were made six times in 12 weeks (26 times per year) and that reviews were evenly distributed throughout year. (6) Assumes trips each year continue to be made in subsequent years. (7) Average 2011 paratransit operating cost was $42.11 per trip, paratransit fare was $1.25, fixed-route transit operating cost was $3.98 per trip, and fixed-route transit (reduced) fare was $0.75. Savings per trip in 2011 therefore estimated at $37.63 (($42.11-$1.25)-($3.98-$0.75)). Savings were considered to be 3% less each subsequent year ($36.50 in 2010; $35.41 in 2009; and $34.34 in 2008). (8) Actual costs for 2010 and 2011 were calculated. Costs for 2008 were assumed to be 3% less than 2010. Costs for 2008 were assumed to be 3% less than 2009.

152 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities a full year of trips reviewed in 2008 would still be affected (or 64,896 trips). The cumulative number of trips affected by reviews in 2008 and 2009 would therefore be 96,264 (64,896 trips from 2008, plus 31,368 trips affected in 2009). Similar calculations for trips affected each year and the cumulative number of trips affected were made for 2010 and 2011. In 2010, it was conservatively estimated that each trip found to have no barriers was made 8 times in 12 weeks (35 times per year), which was the review thresh- old for that year. In 2011, it was conservatively estimated that each trip found to have no barriers was made 6 times in 12 weeks (26 times per year), which was the review threshold for that year. The calculations of cumulative trips affected in 2010 and 2011 are as follows: • For 2010: 64,896 continuing trips affected by 2008 reviews, plus 62,736 continuing trips affected by 2009 reviews, plus 11,200 trips affected in 2010, or 138,832 total trips affected. • For 2011: 64,896 continuing trips affected by 2008 reviews, plus 62,736 continuing trips affected by 2009 reviews, plus 22,400 continuing trips affected by 2010 reviews, plus 8,515 trips affected in 2011, or 158,547 total trips affected. To estimate the savings in operating costs, the average costs for Access paratransit and fixed- route transit trips, and the fares for each mode, were considered. In 2011, the average operating cost per Access paratransit trip was $42.11, the paratransit fare was $1.25, the average fixed- route transit cost was $3.98, and the reduced fare on fixed-route transit was $0.75. The savings per trip for trips made by fixed-route transit rather than Access paratransit was therefore $37.63 (($42.11 - $1.25) - ($3.98 - $0.75)). It was assumed that savings for each subsequent year would be 3% less than this amount, or $36.50 in 2010, $35.41 in 2009, and $34.34 in 2008. Applying these average per trip savings to the cumulative number of trips affected each year suggests total operating cost savings of $1,114,264 in 2008, $3,106,238 in 2009, $4,755,543 in 2010, and $5,645,740 in 2011. Finally, the cost to conduct trip reviews and make trip eligibility determinations was con- sidered. In 2011, Metro estimated that program costs included the full-time Mobility Planner ($103,658), 30% of the time of the CERT Administrator (or $37,658), three Mobility Specialists at $45,605 each (or $136,815), 25% time for a dispatch manager to adjust software settings (or $16,760), and 16.6% overhead and profit on contractor provided positions (or $25,493). Total costs for 2011 were therefore estimated to be $320,384. Similar calculations were done for 2010. These calculations yielded a cost estimate of $311,825 for 2010, or about 3% less than the costs for 2011. For 2009, it was assumed that costs were 3% less than 2010 (or $302,470). For 2008, costs were assumed to be 3% less than 2009 estimates (or $293,396). Subtracting program costs from operating cost savings, it was estimated that trip-by-trip eligibility saved a net amount of $820,868 in 2008, $3,106,238 in 2009, $4,755,543 in 2010, and $5,645,740 in 2011. A large part of these savings is based on the assumption that trips reviewed in past years would likely continue to be made and requested in subsequent years. However, even if only a portion of prior year trips continue to be made, the amount of the savings would still be sig- nificant and much greater than annual program costs. The estimates in Table 9-5 also do not include the effects of trip reviews conducted between 2006 and 2008. While Metro continued to use three full-time Mobility Specialists in 2012 to do on-street path- way reviews, it was noted that fewer trips were likely need to be reviewed each year. Program costs were expected to decrease each year once the most frequent trips have already been reviewed. ADA Paratransit Ridership Trends Figure 9-9 and Table 9-6 show Access ADA paratransit ridership (boardings) from calendar years 2001 through 2012. Table 9-7 identifies significant eligibility or service changes by year.

aDa paratransit eligibility Determinations 153 500,000 600,000 700,000 800,000 900,000 1,000,000 1,100,000 1,200,000 1,300,000 1,400,000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 B oa rd in gs P er Y ea r Access ADA Boardings Trend Based on 2001-2006 Figure 9-9. Access ADA paratransit ridership, 2001–2012. Calendar Year ADA Paratransit Boardings % Change Est. Boardings (2001-2006 Trend) 2001 976,707 NA 976,707 2002 991,464 2% 991,464 2003 1,024,491 3% 1,024,491 2004 1,062,092 4% 1,062,092 2005 1,104,480 4% 1,104,480 2006 1,128,496 2% 1,128,496 2007 1,118,400 -1% 1,163,479 2008 1,121,776 0% 1,199,547 2009 1,119,927 0% 1,236,733 2010 1,120,990 0% 1,275,072 2011 1,099,954 -2% 1,314,599 2012 1,084,041 -1% 1,355,352 Table 9-6. Access ADA paratransit ridership, 2001–2012. Table 9-7. Significant eligibility and service changes by year. Year Changes 2003 First Hyde Shuttle implemented 2006 Increased use of in-person interviews/assessments (from 40% of applicants to 100% of applicants). Started trip eligibility determinations 2007 Implemented Transportation Resource Center 2007-2012 Expanded Hyde Shuttles and community buses 2008 Access fare increased from $0.75 to $1.00 2010 Access fare increased from $1.00 to $1.25

154 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities From 2001 through 2006, ridership increased from 976,707 to 1,128,496, or about 3.1% per year. During this period, the Access paratransit fare was $0.75 and the first local demand response service (Hyde Shuttle) was implemented (2003). Starting in 2006, Metro began requiring that all applicants for ADA paratransit eligibility participate in interviews and functional assessments. Trip eligibility was also implemented in 2006. The growth in ridership slowed from 4% in 2005 to 2% in 2006. Ridership then declined 1% in 2007. A number of changes were made between 2007 and 2012. The Transportation Resource Cen- ter was created and began to be used by Evaluators at Harborview Medical Center in July of 2007. The Access paratransit fare was increased twice—first from $0.75 to $1.00 in 2008, and then from $1.00 to $1.25 in 2010. And the Hyde Shuttle and community bus programs were steadily expanded from 2007 through 2012. After the 1% decrease in 2007, Access paratransit ridership remained essentially unchanged from 2008 through 2010. In 2011, ridership declined 2%. And in 2012, it declined by 1%. The many eligibility and service changes between 2006 and 2012 appear to have had an impact on the use of Access paratransit. If the trend experienced from 2001 through 2006 had continued, the expected ridership in 2012 would have been 1,355,352. The actual ridership of 1,084,041 in 2012 is about 20% less than this projection. The impacts of conditional and trip-by-trip eligibility determinations appear to be signifi- cant. Prior to implementing conditions of eligibility, Access paratransit ridership was increas- ing by about 3.1% each year. In each of the six years following implementation of trip-by-trip eligibility, as well as other service changes, ridership has remained constant or has decreased slightly. Access paratransit ridership in 2012 appears to be about 20% less than it would have been if trip-by-trip eligibility and other service changes had not been made. Conditional and trip-by-trip eligibility have not been the only changes that have encouraged greater use of other transit modes, but appear to have played a significant role, in combination with travel training and the development of other accessible transportation options. Costs and Benefits, ACCESS, Pittsburgh, PA All trips requested by conditionally eligible riders are screened by ACCESS staff using the Infinity system. If trips are determined able to be made by fixed-route transit, riders can choose to still book the trip at the higher convenience fare. If riders elect not to pay the convenience fare, trips are not scheduled on ADA paratransit. Riders then must make the trip by fixed-route transit or by some other means. ACCESS tracks the number of trips made by conditionally eligible riders at the regular fare (trips determined ADA paratransit eligible) as well as the number of trips taken at the conve- nience fare (trips determined not ADA paratransit eligible). However, ACCESS does not track the number of trips requested by conditionally eligible riders who decide not to pay the higher fare and therefore do not make the trips by ADA paratransit. Table 9-8 shows ADA paratransit trips for FY 2012 by type of rider eligibility. Detail on the number of trips taken by conditionally eligible riders, both at the regular fare and at the con- venience fare, is also provided. As shown, a total of 77,476 trips were provided to riders who were conditionally eligible for ADA paratransit service. All of these trips were reviewed for eligibility. The reviews found 44,639 trips requested by conditionally eligible riders were eligible, and these trips were provided at the regular fare. The reviews found that 32,837 trips requested by conditionally eligible riders could be made by fixed-route transit, so these trips were provided at the higher convenience fare.

aDa paratransit eligibility Determinations 155 The data in Table 9-8 suggests that ACCESS staff used the Infinity system to review at least 77,476 trips requested by conditionally eligible riders in FY 2012. Of these, 32,837 (about 42%) were found able to be made by fixed-route transit but still provided at the higher convenience fare. Not all of these trips required staff review in FY 2012. The large majority had been reviewed by staff in prior years and the Infinity system continued to apply the prior review determina- tions as trips were requested in FY 2012. While the data suggests that at least 77,476 trip requests were reviewed for eligibility in FY 2012, this does not represent the total number of trips reviewed. Some trips requested by conditionally eligible riders were determined able to be made by fixed route and the riders, when apprised of the higher fare, chose not to make the trips by ADA paratransit. These cancelled requests are not tracked by the ACCESS Infinity system. The 77,476 trips provided to conditionally eligible riders in FY 2012 also does not reflect the trips that these riders chose to make on fixed-route transit without requesting ADA paratransit. ACCESS staff noted that when some riders are informed about fixed-route transit options, and in some cases accompanied on the first trip, they simply continue to make those trips by fixed- route transit and do not request ADA paratransit. To estimate the number of trips that were not requested by conditionally eligible riders and made by fixed-route transit or other modes, the trip-making rates of riders were examined. Table 9-9 shows the number of riders by eligibility type (unconditional, conditional, tempo- rary) as well as the number of trips taken in FY 2012 by riders in each category. The trip-making rates of riders are then calculated and included in the table. As shown, there were 4,397 registered ADA eligible riders in the ACCESS system in early 2012. Unconditionally eligible riders made up 62.5% of the total, conditionally eligible riders were 32% of the total, and 5.5% of registered riders had temporary eligibility. Unconditionally eligible riders took 75.3% of the PAT-ADA paratransit trips provided in FY 2012. On average, these riders made 88.3 trips in FY 2012 on ADA paratransit. Conditionally eligible riders took 24% of the trips and had an average trip-making rate of 55.1 trips per rider per year. Riders with temporary eligibility took only 0.7% of all ADA paratransit trips, for an average trip-making rate of only 8.7 trips per person per year. Table 9-8. Paratransit trips by rider eligibility and fare type, FY 2012. Rider Eligibility One-Way Trips % of Total Unconditional 242,630 75.3% Conditional 77,476 24.0% Regular Fare 44,639 13.8% Convenience Fare 32,837 10.2% Temporary 2,114 0.7% Totals 322,220 100% Table 9-9. Riders and trips by eligibility type, FY 2012. Note: PAT-ADA Conditional Trips in FY 2012 excludes Base Plus Trips and Out of Town Visitors # of PAT-ADA Convenience Total Tripmaking Eligibility Registered % of Trips Trips Trips % of Rate Type Riders Riders (FY 2012) (FY 2012) (FY 2012) Trips (trips/pers/yr) Unconditional 2,748 62.5% 242,630 0 242,630 75.3% 88.3 Conditional 1,407 32.0% 44,639 32,837 77,476 24.0% 55.1 Temporary 242 5.5% 2,114 0 2,114 0.7% 8.7 Totals 4,397 100.0% 289,383 32,837 322,220 100.0% 152.1

156 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities Table 9-10 provides information about the cost of making trip eligibility decisions, and includes estimates of possible savings in FY 2012 as a result of trip-by-trip eligibility screening. First, as noted above, a total of 32,837 trips were determined able to be made by fixed-route transit, but still provided as non-ADA trips at the higher convenience fare. The savings in oper- ating cost for these trips is the difference between the $4.50 convenience fare and the standard $2.25 ADA paratransit fare (the fares in FY 2012). For the 32,837 convenience fare trips, the cost savings was $73,883. Second, as shown in Table 9-8, riders with conditional eligibility make far fewer trips by ADA paratransit than riders with unconditional eligibility. If it is assumed that the overall trip-making rates of conditionally and unconditionally eligible riders are similar, but that conditionally eligible riders are requesting fewer ADA paratransit trips and making more trips by fixed-route transit or other modes, an additional savings for these other trips on fixed-route transit can be estimated. Applying the trip-making of unconditionally eligible riders (88.3 trips per person per year) to the number of conditionally eligible riders (1,407) suggests that conditionally eligible riders took a total of 124,238 trips in FY 2012, but only 77,476 on ADA paratransit. This suggests that 46,762 trips were made on fixed-route transit or other modes. Assuming that these trips were taken on fixed-route transit, the per trip savings in operating costs would be the difference between the net ADA para- transit per trip operating costs and the net fixed-route transit per trip operating costs. ACCESS’s average paratransit operating cost was $23.90 per trip in FY 2012, and the regular ADA paratransit fare was $2.25. The net ADA paratransit cost per trip was therefore $21.65. The average fixed-route transit cost was $5.41 per trip and the reduced fare for riders with disabilities is $1.25, for a net cost of $4.16 per trip. The savings is therefore $17.49 per trip ($21.65 - $4.16). Multiplying this net per trip savings by the estimated number of other trips taken on fixed-route transit by conditionally eligible riders (46,762) resulted in an additional estimated operating cost savings of $817,867 in FY 2012. Together with the $73,883 savings in cost for trips taken at the convenience fare suggests a total operating cost savings in FY 2012 of $891,750. ACCESS staff estimated that about 1.5 hours are spent each day screening trips requested by conditionally eligible riders. The staff doing these screenings is paid $18.50 per hour. Adding 71% overhead and 10% fee to this hourly rate, the total cost per hour for staff to screen trips is $34.80. For 1.5 hours per day, 325 days per year, the estimated cost is $16,965 per year. # of Convenience Fare Trips 32,837 trips Convenience Fare Net Operating Cost Savings $73,883 (1) Est. of Other Trips by Fixed-Route Transit 46,762 trips (2) Operating Cost Savings per Trip $17.49 (3) Est. Cost Savings for Other Trips by Fixed-Route Transit $817,867 (4) Est. Total Operating Cost Savings $891,750 (5) FY 2012 ACCESS Trip Screening Costs $16,965 (6) Est. Net Operating Cost Savings $874,785 (7) (1) Difference in FY 2012 regular versus convenience paratransit fare ($4.50-$2.25) times number of convenience fare trips. (2) Difference between total trips by conditionally eligible riders (assuming the same trip-making rate as unconditionally eligible riders) and the actual trips taken on ADA paratransit (124,238 – 77,476). (3) Difference between net paratransit cost per trip and net fixed-route transit cost per trip: (($23.90 - $2.25) – ($5.41 - $1.25)) = $17.49. (4) $17.49 times 139,531 trips. (5) Savings from convenience fare trips plus other trips by fixed-route transit. (6) 1.5 hours of staff time per day at $34.80 per hour with overhead, for 325 days per year. per year. (7) Total estimated operating cost savings per year minus trip screening costs Table 9-10. Trip eligibility estimated costs and savings, FY 2012.

aDa paratransit eligibility Determinations 157 ACCESS managers noted that when trip eligibility screening was started back in 2003, it required about four hours of staff time each day. Over time, as the trips of current riders were reviewed and recorded in the Infinity system, less time was required. In 2012, only new trips by current riders or trips by new conditionally eligible riders had to be reviewed. And, given that many street segments, intersections, and bus stops have already been visited and their acces- sibility noted, these reviews often can be performed using existing records. With an estimated operating cost savings of $891,750 in FY 2012, and a total screening cost of only $16,965, a net operating cost savings of $874,785 is estimated. Given that the PAT total operating cost for ADA paratransit service was about $7.7 million in FY 2012, this represents about a 10% savings in ADA paratransit costs. ADA Paratransit Ridership Trends Figure 9-10 and Table 9-11 show ADA paratransit and convenience fare ridership from FY 2001 through FY 2012. Table 9-12 lists significant ADA paratransit service changes through- out this period. Figure 9-10. PAT/ACCESS ADA paratransit ridership, FY2001–FY2012. 0 100,000 200,000 300,000 400,000 500,000 600,000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 O ne -W ay E lig ib le R id er T rip s ADA-PAT ADA-OID Convenience Fare Total ADA Conven. Total ADA & ADA-PAT ADA-OID Total ADA Fare Conven. Fare 2001 2002 539,992 539,992 2003 534,055 534,055 2004 541,483 541,483 2005 530,457 530,457 2006 536,041 536,041 2007 321,973 189,959 511,932 26,249 538,181 2008 316,615 202,423 519,038 26,643 545,681 2009 305,238 220,732 525,970 27,794 553,764 2010 286,878 229,329 516,207 28,915 545,122 2011 295,809 242,049 537,858 31,794 569,652 2012 304,563 253,769 558,332 32,486 590,818 Year One-Way Eligible Rider Trips Table 9-11. PAT/ACCESS ADA paratransit ridership, FY2001–FY2012.

158 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities As noted in Table 9-11, few service changes were made from FY 2001 through FY 2012. Trip- by-trip eligibility was introduced in FY 2003. There was a fare increase from $2.00 to $2.25 in FY 2008. Also, ACCESS staff noted that on-time performance continually increased from 2001 through 2012. In 2001, about 90% of trips were performed on-time. In 2012, on-time performance was about 96%. There have been other, very recent service changes. The ADA paratransit service area was reduced to the minimum ¾-mile corridor requirement (and the Connection service introduced). And the ADA paratransit fare was increased from $2.25 to $3.15. Both of these changes occurred at the start of FY 2013, though, and are not reflected in the ridership through FY 2012. Also, it should be noted that ACCESS tracked total ADA paratransit ridership through FY 2006. ADA service for PAT was separated out from ADA trips sponsored by the Office of Intel- lectual Disabilities (OID) starting in FY 2007. Convenience fare trips also began to be included in standard reports in FY 2007. As shown, total ADA paratransit ridership has remained about the same throughout this 12-year period. It has fluctuated by only a few percentage points, both up and down, each year. ADA-PAT ridership, trips supported by the transit agency, decreased from 2007 through 2010, from 321,973 in 2007 to 286,878 in 2010. In 2011 and 2012, ADA-PAT ridership increased slightly, but still below 2007 levels. Most of the increase in ridership in recent years has been in ADA-OID trips: trips to ADA paratransit eligible riders going to OID work training programs and to supported and competi- tive employment. Most public transit agencies report increases in ADA paratransit ridership over the past decade. Nationally, FTA reports that ADA paratransit ridership increased from about 45 mil- lion one-way trips in NTD reporting year 2000 to 75 million trips in reporting year 2008 (a 67% increase). ACCESS’s use of conditional and trip-by-trip eligibility appears to have encouraged greater use of fixed-route transit service and less reliance on ADA paratransit ser- vice over a similar period of time. Summary of Trip Eligibility Case Study Findings Table 9-13 provides a summary of the costs and benefits findings for trip-by-trip eligibility determinations for the two case studies presented above. As noted in the case study descrip- tions, the two programs are at different stages of implementing trip-by-trip eligibility. Seat- tle Metro began doing trip-by-trip eligibility in 2006 and was still at a stage where they were reviewing the most frequent trips made by conditionally eligible riders. ACCESS in Pittsburgh implemented trip eligibility in 2003 and frequently made trips by registered riders, as well as infrequent trips by current riders, had already been reviewed. ACCESS was at the point in implementation where they were mainly checking prior records to make trip determinations, with some occasional new reviews of trips not previously requested. ACCESS also had devel- oped a fairly extensive database of community barriers that allowed many new trip reviews to be conducted by simply consulting these records of community accessibility. Table 9-12. ADA paratransit service changes, FY 2001–FY 2012. Year Service Change 2003 Trip-by-trip eligibility started 2008 ADA paratransit fare increase from $2.00 to $2.25 2001-2012 Continuous on-time performance improvements, from 90% in 2001 to 96% in 2012

aDa paratransit eligibility Determinations 159 Metro tracked the number of reviews performed for unique trip requests. These were one- time reviews that then applied to these trips in the future. The number of reviews per year varied from 2,245 to 3,318 between 2008 and 2011. ACCESS reviewed all trip requests made by conditionally eligible riders each time they were made and did not track how many unique (non-repeat) trips this included. In 2012, ACCESS staff reviewed 77,476 trip requests by condi- tionally eligible riders. Metro had three Mobility Specialists that conducted pathway reviews to determine trip eli- gibility, as they were still in the process of reviewing a large number of frequently made trips by existing riders with conditional eligibility. The estimated cost per year for these on-street reviews ranged from $293,396 in 2008 to $320,384 in 2011. The average cost for conducting on-street reviews of unique trip requests averaged between $96.56 and $130.69 between 2008 and 2011. ACCESS reported only spending about 1.5 hours of staff time per day to review the eligibility of trips requested by conditionally eligible riders, which average about 250 per day. This was done mainly by a desk review using a database of information of past reviews as well as infor- mation on community accessibility developed over time. Most of the trip reviews only require Table 9-13. Summary of cost and benefit findings, Metro (Seattle, WA) and ACCESS (Pittsburgh, PA). Cost/Benefit Metro, Seattle (2008–2011) ACCESS, Pittsburgh (2012) Number of unique (non-repeat) trips reviewed each year 2008 – 2,245 2009 – 2,937 2010 – 3,062 2011 – 3,318 NA Total number of trips reviewed each year NA 77,476 Annual cost to review trip eligibility 2008 – $293,396 2009 – $302,470 2010 – $311,825 2011 - $320,384 $16,965 Avg. cost to review unique (non- repeat) trip 2008 – $130.69 2009 – $102.99 2010 – $101.84 2011 - $96.56 NA Avg. cost per trip to review all trips by conditionally eligible riders NA $0.22 % of trips reviewed found able to be made on fixed-route transit 2008 – 28% 2009 – 50% 2010 – 21% 2011 – 20% 42% No. of total trips requested by conditionally eligible riders on paratransit and found able to be made on fixed-route transit each year 2008 – 32,448 2009 – 31,368 2010 – 11,200 2011 – 8,515 32,837 Est. of number of trips conditionally eligible riders made on fixed-route transit by choice NA 46,762 Total annual ADA paratransit ridership 2008 – 1,121,776 2009 – 1,119,927 2010 – 1,120,990 2011 – 1,099,954 304,563 % of total trips made by fixed-route transit 2008 – 2.9% 2009 – 5.7% 2010 – 6.7% 2011 – 7.5% 15% Est. Annual net operating cost savings per year 2008 – $820,868 2009 – $3,106,238 2010 – $4,755,543 2011 - $5,645,740 $874,785

160 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities a glance at the record to see whether the trip has been determined eligible or not. ACCESS estimated that the staff time cost only about $16,965 per year including wages and benefits. The average cost per trip to review the 77,476 trips requested by conditionally eligible riders was therefore only about 22 cents. Metro’s records indicated that between 20% and 50% of the unique trip requests reviewed each year were found able to be made by fixed-route transit. The percentage was higher in 2008 and 2009 and lower in 2010 and 2011. ACCESS records indicated that 42% of the trips requested by conditionally eligible riders were found able to be made by fixed-route transit. This higher percent was due to ACCESS’s “convenience fare” program which allows conditionally eligible riders to still request trips on paratransit and to then pay a higher fare if the trips could other- wise be made by fixed-route transit. Metro estimated that the review of unique trips resulted in 32,448 trips by conditionally eli- gible riders being made by fixed-route transit rather than ADA paratransit in 2008; 31,368 trips in 2009; 11,200 trips in 2010; and 8,515 trips in 2011. The lower number each year reflects the fact that less frequently made trips were being reviewed in the latter years. This included only those trips where ADA paratransit trip requests were made by conditionally eligible riders. The analysis of Metro did not estimate the number of trips that conditionally eligible riders made by fixed-route transit by choice (didn’t call and request an ADA paratransit ride). The analysis of trip-making rates by ADA paratransit eligible riders in Pittsburgh indicated that riders who were conditionally eligible were requesting ADA paratransit service far less fre- quently than those who were unconditionally eligible. It was estimated that about 46,762 trips were being made each year on fixed-route transit by choice by riders with conditional eligibility. This appears to reflect the fact that trip eligibility is well established in Pittsburgh and condi- tionally eligible riders have transitioned many of their trips to the fixed-route transit systems. The analysis of Metro suggested that the number of trips by conditionally eligible riders found able to be made by fixed-route transit amounted to about 2.9% of total ADA paratransit ridership in 2008. Assuming that these trips continued to be made on fixed- route transit and that additional trips were found able to be made by fixed- route transit each year, this increased to 5.7% of all ADA paratransit trips in 2009, 6.7% of all ADA paratransit trips in 2010, and 7.5% of all ADA para- transit trips in 2011. In Pittsburgh, with a more longstanding and established process, it was estimated that the number of trips being made on fixed-route transit by conditionally eligible riders amounted to about 15% of the total annual ADA paratransit ridership. Net operating cost savings estimated for Metro in 2008 was $820,868. Assuming that trips found able to be made by fixed-route transit continued to be made by fixed-route transit in subsequent years, and that each year additional, ongoing trips were able to be made by bus or train, the estimate of savings increases to about $3.1 million in 2009, about $4.8 million in 2010, and about $5.6 million in 2011. Net operating cost savings in Pittsburgh for one year (2012) were estimated to be $874,785. 9.5 Implementation Issues, Lessons Learned The research indicates that doing thorough ADA paratransit eligibility can assist riders with disabilities in identifying travel options beyond ADA paratransit. The research also suggests that thorough eligibility determinations and implementation of trip-by-trip eligibility can help transit agencies serve riders with disabilities in a more cost-effective way. In Seattle, implementation of trip eligibility enabled 7.5% of trips by conditionally eligible riders to be made on fixed-route transit rather than ADA paratransit by the fourth year of the program. In Pittsburgh, trip eligibility has enabled about 15% of trips by conditionally eligible riders to be made on fixed-route transit rather than on ADA paratransit.

aDa paratransit eligibility Determinations 161 Implementing a more thorough eligibility determination process and trip-by-trip eligibility determinations can, however, be costly and require considerable work. Extensive community input is needed when changing the eligibility determination process. Creating transportation assessment centers and including in-person interviews and functional assessments as part of the process can also be costly and require a significant initial investment. Implementing a trip eligibility process and conducting trip eligibility reviews can also be complicated and somewhat costly to implement. • On-street reviews of pathway accessibility must be conducted. • Software must be customized or created to store trip eligibility decisions so that ADA para- transit reservationists and schedulers have the information they need to quickly determine if trips that are requested should be scheduled. • Procedures need to be developed and implemented to allow reservationists and schedulers to easily make decisions related to factors that vary from day to day (such as the weather or time of day) and cannot be pre-determined. Over time, though, once frequently made trips by current riders are reviewed, if a database of past decisions is created, and if procedures for addressing day-to-day issues are developed, making trip eligibility decisions can be relatively inexpensive. This is demonstrated by the costs reported by ACCESS in Pittsburgh, the agency that has ventured the farthest into trip- by-trip eligibility determinations. If done correctly and with public input, more thorough eligibility deter- minations and trip-by-trip eligibility can have significant benefits that out- weigh these initial and ongoing costs. More thorough processes reinforce the idea within the community that fixed-route transit should be used whenever possible and that ADA paratransit is to be used only when travel by bus and train is not possible. If an accessible and usable fixed-route transit service is in place, it also enables and promotes more flexible and spontaneous travel. Achieving this change in mindset within the disability community can be a significant step in making ADA paratransit sustainable. Transit agencies that have successfully implemented more thorough ADA paratransit eligi- bility determination processes noted several important implementation issues. These include: • Developing a range of accessible transportation services and options for riders with dis - abilities. • Holding extensive discussions with the community to obtain support prior to implementation. • Stressing that the application process is not just about eligibility for the ADA paratransit service, but is also to identify all of the accessible transportation options that can assist indi- viduals with meeting their travel needs. • Taking every opportunity throughout the process to inform individuals about all acces- sible transportation services, including sending this information with application materials, telephone follow up when applications are received, and discussing transportation options during in-person interviews. • Including in-person interviews and functional assessments in the process so that conditions of eligibility can be accurately and thoroughly determined. • Setting measurable and specific conditions of eligibility so that they can be applied to trip requests. • Not relying on determination letters to communicate conditions of eligibility, but following up by phone with individuals determined conditionally eligible to explain their conditions and to answer any questions they may have. Implementing trip eligibility requires an initial investment in a more thorough ADA paratransit eligibility determination process and individual trip reviews. The benefits can be significant, though, including reinforcement of the idea that fixed-route transit should be used whenever possible and ADA paratransit should be used only when travel by fixed-route transit is not possible.

162 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities • Conducting detailed on-street assessments to identify path-of-travel barriers when making trip eligibility decisions. • Developing and using technology to record pathway and trip eligibility information. • Customizing existing software, or developing supplemental software that can record the results of trip eligibility reviews and automatically apply the results to rider requests so that decisions about trip accessibility do not have to be made by reservationists. • Developing a database of community accessibility as on-street pathway and trip eligibility reviews are completed, and using this to more easily make other trip eligibility decisions in similar areas. • Contacting people in person if a trip is possible on fixed-route transit rather than having them find out when the trip is not accepted by a reservationist. • Offering to accompany riders on initial fixed-route trips to facilitate a transition from ADA paratransit-to-fixed-route transit. • Having a travel training program that can assist riders with the transition to fixed-route service. • Adopting a “convenience fare” that allows riders to still use paratransit at a higher, non-ADA fare when trips are determined able to be made by fixed-route transit. 9.6 Evaluating Eligibility Efforts If a more thorough ADA paratransit eligibility determinations process and trip-by-trip eligibility program are implemented, it is important to track outcomes, costs, and benefits to assess the effectiveness of the efforts. Possible methodologies for assessing general eligibility improvements efforts, as well as trip-by-trip eligibility programs, are presented in Appendix D. Following is a summary of the suggested approaches. Evaluating General Eligibility Determination Improvements This chapter presents several strategies for making general improvements to the ADA para- transit eligibility determination process. These include better explaining ADA paratransit eli- gibility to potential applicants, developing public information that better communicates ADA paratransit eligibility, and making more thorough determinations through the use of in-person interviews and functional assessments. Communicating ADA Paratransit Eligibility The effectiveness of communicating the nature of ADA paratransit eligibility can be evalu- ated in several ways, including: • Recording the number of general information calls received requesting information about ADA paratransit eligibility. Recording the number of application packets sent to callers. Also noting the number of callers that “self-select” out and choose not to apply. This information can indicate the effectiveness of call-taking staff in explaining ADA paratransit eligibility. • Tracking the number of application packets sent to prospective applicants. Also recording the number of applications returned. This can help indicate the effectiveness of the information in the packet in explaining ADA paratransit eligibility. Note that this analysis will not be pos- sible if application packets are widely distributed through outlets in the community or online. Making More Accurate and Thorough Determinations of Eligibility The accuracy and thoroughness of the ADA paratransit eligibility determination process can be evaluated in several ways, including: • Comparing outcomes (percent of applicants determined unconditionally eligible, condi- tionally eligible, temporarily eligible, not eligible) to the national experience of agencies

aDa paratransit eligibility Determinations 163 considered to have good processes. The data in Table 9-3 can help with this comparison. Information should also be considered from any future reports on ADA paratransit eligibil- ity determination outcomes. • Using the number of individuals determined ADA paratransit eligible and the population of the service area, calculate the proportion of the area population that has been determined ADA paratransit eligible. Compare this information to the national experience or peer sys- tems. TCRP Synthesis 30 and TCRP Report 119 contain national experience information. (54, 60) • Dividing the number of annual ADA paratransit trips provided by the service area popula- tion to get a measure of trips per capita. Compare this information to national experience and peer systems. • Tracking the number of eligibility determinations that are appealed and the appeal out- comes. A high percentage of determinations overturned on appeal could indicate issues with the accuracy of the initial determination process (note that it could also, though, indicate issues with the appeal process). Also use the individual findings from appeals where deci- sions are changed to evaluate the accuracy and thoroughness of initial determinations. • Analyzing trends in ADA paratransit ridership before and after any changes are made to the eligibility determination process. Note other changes to ADA paratransit eligibility during this period (see analysis done in Section 9.4). The above approaches, particularly the ridership trend analysis and the comparison of trips per capita, can then be used to estimate the impact of more thorough ADA paratransit eligibil- ity determinations on ADA paratransit ridership. Estimated reductions in ADA paratransit ridership can be used to calculate operating cost savings. Finally, the costs associated with implementing a more thorough eligibility determination process can be subtracted from the estimated savings to determine the net cost-benefit of efforts. Note that beyond the cost savings, other qualitative benefits to riders and the community, such as increased travel options and more flexible and spontaneous travel by fixed-route transit also need to be considered. Evaluating Trip-by-Trip Eligibility Efforts Two different approaches for evaluating the effectiveness of trip-by-trip eligibility efforts are detailed in Appendix D. The first considers the individual trip decisions that are made and the costs of making these decisions. The second considers broader impacts of trip-by-trip eligibility determinations on the trip-making patterns of riders. Individual Trip Reviews and Decisions This evaluation methodology involves tracking the costs and outcomes associated with indi- vidual trip decisions. It is the approach used in Section 9.4 to evaluate the trip eligibility efforts at Metro in Seattle. Costs for making trip decisions need to be recorded. This includes the cost of staff used to conduct trip reviews, equipment required to assist in the reviews, and computer software needed to record the decisions. The number of trips reviewed and the number found able to be made on fixed-route transit should also be tracked. The frequency of each trip found able to be made on fixed-route tran- sit should be noted so that an estimate of the total number of trips able to be made on fixed- route transit can be estimated. Using the average operating cost per ADA paratransit trip, and the average fare, calculate the net cost for each ADA paratransit trip. Subtract the net operating cost per fixed-route trip (aver- age operating cost per trip minus average fare) to get the net savings for each trip that is made

164 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities by fixed-route transit rather than ADA paratransit. Multiply this by the estimated number of trips determined able to be made on fixed-route transit to get the estimated net operating cost savings. To consider multiple year impacts, it will be necessary to make an assumption about the like- lihood that trips will continue to be made on fixed-route transit rather than ADA paratransit in future years. This evaluation methodology is appropriate for a new trip eligibility program. Trip-Making by Conditionally Eligible Riders For a trip eligibility determination program that has been in place for a number of years, it will also be important to assess impacts on trip-making decisions by riders who are condition- ally eligible. Over time, as the eligibility of trips by ADA paratransit is reviewed, riders are likely to begin making decisions to use fixed-route transit without first requesting ADA paratransit service. To consider impacts on trip-making decisions, compare the trip-making rates on ADA para- transit of riders who have conditional eligibility to riders who have unconditional eligibility. To do this will require the capability to identify trips by type of rider. If this is not possible, a sample of riders who are conditional versus unconditional might be identified and trips for each group totaled and compared. The differences in trip-making rates can be used to estimate the number of trips that condi- tionally eligible riders might be making by fixed-route transit rather than by ADA paratransit. This approach was used in Section 9.4 to analyze trip eligibility efforts by ACCESS in Pitts- burgh. Note that this analysis assumes that riders with different types of eligibility make, on average, the same number of total trips. Ideally, trip-making rates before and after the imple- mentation of trip eligibility should be analyzed to account for any differences in travel by these two groups. Again, the above analysis focuses on the cost effectiveness of trip eligibility efforts. Other qualitative benefits should also be considered and factored into any decisions about the utility of programs and efforts. Qualitative benefits include assisting people with disabilities to iden- tify travel options that are more flexible and spontaneous and that provide for a greater degree of personal independence.