Americans with Disabilities Act (ADA) Paratransit Eligibility Manual
DOT-T-93-17
September 1993
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NOTICE
This document is disseminated under the sponsorship of the
Department of Transportation in the interest of information
exchange. The United States Government assumes no liability for
its contents or use thereof.
NOTICE
The United States Government does not endorse products of
manufacturers. Trade or manufacturers' names appear herein solely
because they are considered essential to the object of this report.
Americans with
Disabilities Act (ADA)
Paratransit Eligibility
Manual
Final Report
September 1993
Prepared by
EG&G Dynatrend
24 New England Executive Park
Burlington, MA 01803
Prepared for
Federal Transit Administration
Office of Grants Management
U.S. Department of Transportation
Washington, D.C. 20590
Distributed in Cooperation with
Technology Sharing Program
U.S. Department of Transportation
Washington, D.C. 20590
DOT-T-93-17
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ADA Paratransit Eligibility Manual
Acknowledgements
This manual was prepared by EG&G Dynatrend under contract to
Battelle. Funding was Provided by the Federal Transit
Administration's Office of Grants Management through the Volpe
National Transportation Systems Center. Several individuals in
each of these organizations were involved in the development of the
manual.
Robert Stout, Nancy Solkowski, Gary DeLorme, and Irv Chor of the
Office of Grants Management, and David Spiller of the
Transportation Systems Center were instrumental in defining and
initiating the project. David Norstrom of Battelle assisted in the
preparation of the initial document outline and provided
administrative support throughout the project.
Nancy Solkowski and David Spiller also served as Project Managers
and provided valuable guidance and input on the structure and
content of the manual.
Much of the information in this report was gathered from selected
transit providers across the country. Several individuals assisted
in identifying providers with particular experience in the
development of ADA paratransit eligibility materials and processes.
Recommendations and referrals were provided by John Balog, John
Morrison, and Anne Schwarz of the Ketron Division of the Bionetics
Corporation, Nancy Coburn of Battelle, David Cyra of the University
of Wisconsin-Milwaukee, Rich Garrity of AG Planning & Management,
David Koffman of Crain & Associates, and Robbie Sarles of RLS
Associates.
This report would not have been possible without the cooperation of
the employees of each of the transit agencies contacted. Special
thanks to each of the following persons for sharing insights and
for developing and providing the materials and information
contained in this manual:
Robin Boshell, Delaware Administration for Specialized
Transportation (DAST)
Daniel Brogan, OMNITRANS, San Bernardino, California
Jan Choti, City of Durango, Colorado
Margaret Coffey, New York City Transit Authority
Lisa Darnall, Mass Transportation Administration, Baltimore,
Maryland
Richard DeRock and Chip Hazen, Los Angeles County Metropolitan
Transportation Authority
Ed Frost, Ben Franklin Transit, Richland, Washington
Gail Heald and Mary Ellen Blunt, Central Massachusetts
Regional Planning Commission, Worcester, Massachusetts
Susan Hafner and Tessie Johnston, Riverside Transit Agency,
Riverside, California
Mark Huddleston, Oshkosh Transit System, Oshkosh, Wisconsin
Robert Johnson, Waukesha Transit System, Waukesha, Wisconsin
Micki Kaplan, Lane Transit District, Eugene, Oregon
Kimberlee Kelly, Greater Bridgeport Transit District
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ADA Paratransit Eligibility Manual
Dianna Lake, San Mateo County Transit District, San Carlos,
California
Paul Laffousse, Madison Metro Transit System
Terry Lathrop, City of Charlotte, North Carolina
John Lee, City of Greeley, Colorado
Avon Makel, Washington Metropolitan Area Transit Authority
Kathy McCune, Utah Transit Authority, Salt Lake City
Tina Morris, Transit Authority of River City, Louisville,
Kentucky
Lynn Ritter Otte and Shirley Fraser, Regional Transportation
Authority, Chicago
Nancy Poultney, Seattle Metro
Jon Roth, Southeastern Pennsylvania Transportation Authority,
Philadelphia
Christopher White, Ann Arbor Transportation Authority
Cathy Williams, Port Authority of Allegheny County, Pittsburgh
Finally, several employees at EG&G Dynatrend provided input,
assistance and support. Karla Karash reviewed draft material.
Carol Schweiger and Larry Hannan provided information on the final
chapter concerning advanced technologies. Marsha Gangi provided
administrative support and assisted in document preparation.
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ADA Paratransit Eligibility Manual
Table of Contents
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Chapter 1. Understanding ADA Paratransit Eligibility . . . . . 3
Section 1. Who Must Develop an ADA Paratransit Eligibility
Determination Process and When Must it be
Implemented? . . . . . . . . . . . . . . . . . 3
Section 2. How is ADA Paratransit Eligibility Defined in
the Regulations? . . . . . . . . . . . . . . . 4
Category 1 Eligibility . . . . . . . . . . . . . . . . . 5
Category 2 Eligibility . . . . . . . . . . . . . . . . . 7
Category 3 Eligibility . . . . . . . . . . . . . . . . . 8
Companions/Personal Care Attendants. . . . . . . . . . .12
Visitors . . . . . . . . . . . . . . . . . . . . . . . .13
Temporary Disabilities . . . . . . . . . . . . . . . . .14
Section 3. Key Differences between ADA Paratransit
Eligibility and Past Paratransit Eligibility .15
ADA Paratransit Eligibility as a Civil Right . . . . . .15
Functionally-based Determinations of Eligibility . . . .16
Conditional or "Trip-by-Trip" eligibility. . . . . . . .16
Determining Eligibility Based on the Most Limiting
Factors. . . . . . . . . . . . . . . . . . . . . . . . .20
Section 4. The Importance of a Thorough Initial
Determination. . . . . . . . . . . . . . . . .21
Managing Demand. . . . . . . . . . . . . . . . . . . . .21
Documenting an Undue Financial Burden. . . . . . . . . .21
Chapter 2. Elements of an ADA Paratransit Eligibility Policy .23
Section 1. Required Elements. . . . . . . . . . . . . . .23
Strictly Limiting Eligibility. . . . . . . . . . . . . .23
Accessible formats . . . . . . . . . . . . . . . . . . .24
Processing Time/Presumptive Eligibility. . . . . . . . .25
Notice of Initial Determination. . . . . . . . . . . . .25
Documentation of Eligibility . . . . . . . . . . . . . .25
Administrative Appeal Process. . . . . . . . . . . . . .26
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ADA Paratransit Eligibility Manual
Section 2. Optional Elements. . . . . . . . . . . . . . .27
Recertification of ADA Paratransit Eligibility . . . . .27
Recertification of Other Paratransit Customers . . . . .28
No-Show Suspension Policy. . . . . . . . . . . . . . . .28
Chapter 3. Establishing an ADA Paratransit Eligibility
Determination Process . . . . . . . . . . . . . . .29
Section 1. General Considerations . . . . . . . . . . . .30
Public Participation . . . . . . . . . . . . . . . . . .30
Public Information and Marketing . . . . . . . . . . . .31
Additional Charges and Fees. . . . . . . . . . . . . . .33
Section 2. Alternative Processes. . . . . . . . . . . . .34
Self-certification with professional verification as
needed . . . . . . . . . . . . . . . . . . . . . . . . .34
Self-certification and professional verification . . . .36
In-Person Assessments. . . . . . . . . . . . . . . . . .39
Combined Approaches. . . . . . . . . . . . . . . . . . .40
Considerations for Future Recertification of Riders. . .42
Section 3. Deciding Who Will Do Initial Determinations. .48
In-House Determinations. . . . . . . . . . . . . . . . .48
Utilizing Contract Reviewers . . . . . . . . . . . . . .48
In-House Determination with Third-Party Assistance as
Needed . . . . . . . . . . . . . . . . . . . . . . . . .51
Reviewer Training. . . . . . . . . . . . . . . . . . . .52
Section 4. Developing Application Forms and Materials . .53
Accessible Formats . . . . . . . . . . . . . . . . . . .53
Terminology. . . . . . . . . . . . . . . . . . . . . . .54
Transmittal Cover Letter . . . . . . . . . . . . . . . .54
Application/Assessment Forms . . . . . . . . . . . . . .55
General Information. . . . . . . . . . . . . . . . . . .57
Questions about Mobility Aids Used . . . . . . . . . . .58
Questions about the Applicant's Disability . . . . . . .59
Questions/Functional Tests Regarding Travel Capabilities60
Travel Training Information. . . . . . . . . . . . . . .68
Other Service Information. . . . . . . . . . . . . . . .69
Administrative Information . . . . . . . . . . . . . . .69
Request for Professional Reference(s). . . . . . . . . .70
Professional Verification Form . . . . . . . . . . . . .72
ADA Paratransit Eligibility Manual
Section 5. Reviewing Applications and Making
Determinations . . . . . . . . . . . . . . . .73
Pre-Tests of Materials . . . . . . . . . . . . . . . . .73
Regulatory Review Timetable and Presumptive Eligibility.73
Establishing a Management Information System to Track
Determinations . . . . . . . . . . . . . . . . . . . . .74
Developing Reviewer Guidelines and Maintaining
Consistency in Reviews . . . . . . . . . . . . . . . . .78
Observing Privacy Rights . . . . . . . . . . . . . . . .79
Recent Certification Experiences of Selected Providers .79
Section 6. Notifying Individuals of Initial Determinations85
Section 7. Documentation of ADA Paratransit eligibility .92
Section 8. Appeals Procedures . . . . . . . . . . . . . .94
Structuring an Appeal Process. . . . . . . . . . . . . .96
Holding an Appeal Hearing. . . . . . . . . . . . . . . 102
Section 9. Refusing, Conditioning, or Suspending Service103
Circumstances Under which Service Can be Refused . . . 103
Circumstances Under which Service Can be Conditioned . 104
Circumstances Under Which Service Can be Suspended . . 104
Developing a "No-Show" Suspension Policy . . . . . . . 105
Process Issues Associated with Suspending Service. . . 111
Section 10. Visitor Policies . . . . . . . . . . . . . . 112
Chapter 4. Applying Eligibility Determinations to Daily
Operations. . . . . . . . . . . . . . . . . . . . 115
Section 1. Important Operational Information. . . . . . 115
Section 2. Trip-by-Trip Eligibility Determinations. . . 118
Review Subscription Trips. . . . . . . . . . . . . . . 119
Review Other Frequently Made Trips . . . . . . . . . . 119
Generalize Limitations of Eligibility. . . . . . . . . 119
Consideration of Easily Tracked Eligibility Conditions 120
Section 3. Using Advanced Technologies to Make Trip
Eligibility Determinations . . . . . . . . . 122
Relational Database Management Systems (RDMS). . . . . 122
Automated Client Information Systems . . . . . . . . . 122
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ADA Paratransit Eligibility Manual
Automated Routing and Scheduling Systems . . . . . . . 123
GIS and Computer Mapping Systems . . . . . . . . . . . 133
Section 4. Providing Alternatives/
Market-Based Approaches . . . . . . . . 133
References . . . . . . . . . . . . . . . . . . . . . . . . . . . 135
Index. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 137
Appendix A. 49 CFR Part 37 Sections 37.121 through 37.127 and
related sections of Appendix D
Appendix B. ADA Paratransit Eligibility Policy Checklist
Appendix C. Listing of Selected Transit Providers Contacted for
Information in the Preparation of this Manual
Appendix D. Sample Marketing and Public Information Materials
Appendix E. Sample Eligibility Material Developed by the San
Mateo County Transit District (SAMTRANS)
Appendix F. Sample Eligibility Material Developed by the Madison
Metro Transit System
Appendix G. Sample Eligibility Material Developed by the Utah
Transit Authority
Appendix H. Sample Eligibility Material Developed by the
Worcester Regional Transit Authority
Appendix I. Sample Eligibility Material Developed by the
Municipality of Metropolitan Seattle (Metro)
Appendix J. Sample Eligibility Material Developed by the
Washington Metropolitan -Area Transportation Authority
Appendix K. Sample Eligibility Material Developed by the
Delaware Administration for Specialized
Transportation (DAST)
Appendix L. Sample Eligibility Material Developed by the
Regional Transportation Authority (Chicago)
Appendix M. Sample Eligibility Material Developed by the Port
Authority of Allegheny County (PAT)
Appendix N. Information about the Applicant Tracking System used
by Seattle Metro
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ADA Paratransit Eligibility Manual
List of Tables
Table 1. Eligibility by Functional Impairment/Disability. . . . .18
Table 2. Eligibility Determination Processes Used by Selected
Transit Providers. . . . . . . . . . . . . . . . . . . .43
Table 3. Eligibility Determination Results for Selected Transit
Providers. . . . . . . . . . . . . . . . . . . . . . . .80
Table 4. Descriptions of Appeal Procedures for Selected Transit
Providers. . . . . . . . . . . . . . . . . . . . . . . .99
Table 5. Details of No-Show Suspension Policies for Selected
Transit Providers. . . . . . . . . . . . . . . . . . . 107
Table 6. Capabilities of Selected Computer Scheduling and
Dispatching Systems to Capture and Display ADA
Paratransit Eligibility Information. . . . . . . . . . 125
Table 7. Capabilities of Selected Computer Scheduling and
Dispatching Systems to Display the ADA Paratransit
Service Area and Calculate Distances to and From
Stops/Stations . . . . . . . . . . . . . . . . . . . . 127
Table 8. Capabilities of Selected Computer Scheduling and
Dispatching Systems to Track Service
Provided to Visitors . . . . . . . . . . . . . . . . . 129
Table 9. Capabilities of Selected Computer Scheduling and Dispatch
Systems to Track and Analyze Capacity Constraints and
Subscription Service . . . . . . . . . . . . . . . . . 131
List of Figures
Figure 1. Examples of Eligibility Under Category 3 . . . . . . . .11
Figure 2. Required and Optional Policy Elements. . . . . . . . . .23
Figure 3. Steps in Developing an ADA Paratransit Eligibility
Process. . . . . . . . . . . . . . . . . . . . . . . . .29
Figure 4. Examples of Types of Professionals that can Assist with
Eligibility Determinations . . . . . . . . . . . . . . .50
Figure 5. Sample Flow Chart of Eligibility Determination Process
(sheet 1 of 3) . . . . . . . . . . . . . . . . . . . . .75
Figure 6. Sample Photo ID Format for ADA Paratransit Eligibility
Documentation. . . . . . . . . . . . . . . . . . . . . .93
Figure 7. Letter Sent by SEPTA to Riders with Greatest Number of
No-Shows Each Month. . . . . . . . . . . . . . . . . . 110
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ADA Paratransit Eligibility Manual
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ADA Paratransit Eligibility Manual
Introduction
Section 223 of the Americans with Disabilities Act of 1990 (ADA)1
requires that public entities which operate non-commuter fixed
route transportation services also provide complementary
paratransit service for individuals unable to use the fixed route
system. The regulations issued by the U.S. Department of
Transportation2, which implement this portion of the law, specify
to whom and under what circumstances this service is to be
provided. In addition, the regulations require public entities
which are subject to the complementary paratransit requirements to
develop and administer a process for determining if individuals who
request service meet the regulatory criteria for eligibility.
Initial guidance on the development of complementary paratransit
plans, including the establishment of eligibility determination
processes, was provided in the ADA Paratransit Handbook3
immediately following the issuance of the regulations. Since that
time, numerous questions about the definition of eligibility and
about the determination process have been raised. The review of
initial ADA paratransit plans and first year updates also has
identified innovative approaches used by transit providers in the
development of eligibility determination programs.
This manual has been prepared to provide further guidance to
transit providers in the development and implementation of ADA
paratransit eligibility determination processes. The most common
questions raised about eligibility are addressed. Experience
gained in the first one and a half years of implementation of the
paratransit provisions is also summarized. As part of the
preparation of this manual, public entities that had particular
expertise and positive experiences with eligibility determination
were contacted and copies of the forms and procedures which they
had developed were collected. Key issues raised by these transit
providers are included in the text and copies of sample forms and
policies are provided in the appendices.
This manual is organized in three parts. The first part, which
includes Chapters I and 2, presents a thorough discussion of the
concept of ADA paratransit eligibility and describes the regulatory
requirements which apply. The second part, Chapter 3, offers
practical advice in all aspects of designing and administering an
eligibility determination process. This chapter
___________________________
1 Public Law 101-336, July 26, 1990.
2 49 CFR Parts 27, 37 and 38, "Transportation for Individuals
With Disabilities; Final Rule", published in the Federal
Register, September 6, 1991.
3 Thatcher, R.H., and Gaffhey, J.K., ADA Paratransit Handbook:
Implementing the Complementary Paratransit Service
Requirements of the Americans with Disabilities Act of 1990,
USDOT Report #UMTA-MA-06-0206-91-1, prepared for the UMTA Task
Force on the Americans with Disabilities Act, funded through
the Office of Technical Assistance and Safety, September,
1991.
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ADA Paratransit Eligibility Manual
is structured to lead the reader through the process of eligibility
determination as it would occur in actual practice. The sequence
of presentation is:
- deciding on the appropriate process;
- creating appropriate forms for the selected process;
- conducting the initial determination;
- notifying individuals about determinations;
- providing documentation of eligibility;
- establishing and conducting an appeals process;
- policies for suspending service to eligible persons; and
- providing service to visitors.
The final chapter focuses on key operational issues. It discusses
the use of eligibility information in daily operations. Possible
approaches to determining the eligibility of specific trip requests
are reviewed and advanced technologies which can assist with trip-
by-trip determinations are presented.
This manual is also intended to be a comprehensive guide to
eligibility issues. In addition to practical information and
suggestions, all regulatory information has been included. The
full text of those portions of the regulation that address
eligibility issues are reprinted in Appendix A. Applicable sections
of the appendix to the regulation which provide interpretation of
the eligibility provisions are also included. Throughout the
manual, relevant portions of the regulations and interpretive
guidance are inserted.
While this manual offers extensive guidance on the development of
application material and an eligibility process, it does not
provide a single model for eligibility determination applicable in
all cases. As noted in Chapter 3, there are many different ways
that the process can be structured. Application forms and
materials will vary depending on the approach selected. Instead,
the appendices contain several model forms and materials that apply
to all of the possible approaches. Chapter 3 also offers advice on
the types of questions and information that should be included in
eligibility materials, regardless of the approach which is
selected.
Public input is required in the design of the eligibility
determination process. The importance of involving people with
disabilities and local disability organizations in the development
of all aspects of the eligibility policy and process cannot be
overemphasized. The guidance and advice offered in this manual
should be shared with and reviewed together with these individuals
and organizations.
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ADA Paratransit Eligibility Manual
Chapter 1
Understanding ADA Paratransit Eligibility
Section 1. Who Must Develop an ADA Paratransit eligibility
Determination Process and When Must it be
Implemented?
Access to mainline, fixed route transportation services is the main
goal of the transportation provisions of the ADA. The law
recognizes, however, that some persons with disabilities are not
able to use fixed route services even if these services are fully
accessible. The law also acknowledges that many fixed route
systems are not accessible and that alternative means of
transportation are needed until full accessibility is achieved.
Complementary paratransit service is required by Section 223 of the
ADA to serve those persons whose needs cannot be met by fixed route
systems.
All public entities which operate non-commuter fixed route
transportation services for the general public are required to also
provide complementary paratransit service. This paratransit
service must be comparable to the fixed route service. Six service
criteria which define comparability are detailed in the USDOT
implementing regulations.4
Complementary paratransit service is to be provided to those
individuals determined to be ADA paratransit eligible when these
individuals are unable to use the fixed route service to meet
particular trip needs. As described in Section 2 of this Chapter,
the regulations provide detailed guidelines which define who is to
be considered ADA paratransit eligible and what trips are to be
considered eligible.
All public entities which operate complementary paratransit
services must establish a process for certifying individuals as ADA
paratransit eligible. Requests for certification must be accepted
and processed for local residents and long-term visitors.
An eligibility determination process must be established even if
the public entity operates a paratransit system with broader
eligibility requirements than the ADA. All potentially ADA
paratransit eligible persons may be covered by the broader system,
but individuals must have the opportunity to apply for and receive
documentation of ADA paratransit eligibility which can be used in
other areas.
The regulations required that the implementation of complementary
paratransit service begin on January 26, 1992. Services must be
fully implemented (i.e., must meet all of the regulatory service
criteria) by January 26, 1997 unless an "undue financial burden
waiver" is
___________________________
4 For a detailed explanation of the complementary paratransit
service requirements, see the ADA Paratransit Handbook, UMTA-
MA-06-0206-91-1, September, 1991.
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ADA Paratransit Eligibility Manual
granted by the FTA Administrator. The determination of those
persons who are eligible to receive service is a necessary first
step in this process. Therefore, an eligibility determination
process is required early in the five-year implementation period.
Regardless of local implementation schedules, all public entities
should have an eligibility determination process in place by
January 26, 1994.
Section 2. How is ADA Paratransit Defined in the Regulations?
Eligibility for complementary paratransit service is directly
related to the inability of a person with a disability to use the
existing fixed route service. A person's inability to use the
fixed route service could be related to the fact that the system
has not yet been made fully accessible. It could also result from
the nature of a person's disability. The person may not be able,
due to their disability, to get to or from the system or to board,
ride, and disembark from the vehicles even if they are fully
accessible.
While eligibility is conferred on individuals, it is conferred
based on the fact that there are certain trips that the person
cannot make on the fixed route system. For some individuals, their
disabilities may prohibit them from ever using the fixed route
service. For others, however, they may not be able to use the
fixed route service under certain circumstances. ADA paratransit
eligibility can, therefore, be considered as having two elements.
First, an individual is considered ADA paratransit eligible if
there are any circumstances under which the fixed route system
cannot be used. Second, the extent of eligibility conferred on an
individual depends on the conditions and circumstances under which
they are not able to travel on the fixed route service.
Individuals who can never use the fixed route service are
unconditionally eligible. Persons who can use fixed route service
in certain circumstances are conditionally eligible and the
limitations on their eligibility should be determined.
Because the regulations establish this concept of trip-by-trip
eligibility, it is important that the eligibility determination
process be detailed enough to identify not only eligible
individuals but to determine the conditions under which their
specific trip requests would be eligible.
The regulations describe three specific circumstances under which a
person would be considered ADA paratransit eligible. Within the
industry, these have been referred to as the three "categories" of
eligibility. The regulations also require that service be provided
to personal care attendants and companions of eligible individuals
and to visitors from outside a transit district's jurisdiction.
Following is a detailed discussion of each of the three
"categories" of eligibility and of requirements for serving
companions, personal care attendants, and visitors.
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ADA Paratransit Eligibility Manual
Category 1 Eligibility
The first category of eligibility includes those persons unable to
use fully accessible fixed route services. Included in this
category is:
"Any individual with a disability who is unable, as the result of a
physical or mental impairment (including a vision impairment), and
without the assistance of another individual (except the operator
of a wheelchair lift or other boarding assistance device), to
board, tide, or disembark from any vehicle on the system which is
readily accessible to and usable by individuals width disabilities.
" [37.123(e)(1)]
Examples of eligibility under this category would include:
- a person with a mental disability who cannot "navigate the
system". Navigating the system might involve obtaining and
understanding system information, recognizing and boarding the
correct vehicle, having available the correct fare and/or
using the fare collection system, recognizing destinations,
and understanding transfers that might have to be made;
- a person with a vision impairment who cannot "navigate the
system". Entering and traveling through a busy station or
transit center may not be possible. Recognizing and boarding
the correct vehicle, and recognizing the appropriate
destination - even though announcements are made - are also
considerations;
- a person with a physical disability who cannot stand on a
crowded bus or rail car when seats, including priority seats,
may not be available;
- a person with a physical disability who uses a wheelchair and
who cannot get on or off the lift or to or from the wheelchair
securement area without assistance.
It is important to note that eligibility under this category
depends on the complexity of the fixed route system. The type and
extent of disability that would confer eligibility in a rural area
with a one or two route bus system would be different from that in
a large urban system. Transit providers should base determinations
on the characteristics of their fixed route service and the
abilities needed to use it.
Other key issues and questions associated with this category of
eligibility are summarized below.
(1) Travel training: Many persons who cannot negotiate the entire
fixed route system can be travel trained for certain trips.
Typically, training is provided for trips that the person
makes frequently, such as to work or school. These
individuals would only be ADA paratransit eligible for trips
they have not been trained to make. As part of the
application and determination process, it should be determined
if such training has
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ADA Paratransit Eligibility Manual
been provided.
Individuals cannot, however, be required to participate in
travel training. The public entity may choose to offer
training and may encourage individuals to take advantage of
this service. Until the individual takes advantage of this
service and is adequately trained, paratransit service must be
provided.
(2) Operator assistance: Eligibility under this category is not
necessarily based on a person's ability to get on and off the
lift, up and down a ramp, to and from the securement area, or
secure their mobility device. While the regulation states
that a person is eligible for paratransit service if they
cannot independently use the fixed route system, operator
assistance is assumed. The regulations, in fact, specify the
level of assistance that must be provided by the public
entity. Section 37.165(f) of the regulations states that "the
drivers or other personnel must provide assistance with the
use of lifts, ramps, and securement devices." Beyond this
level of required assistance, however, public entities may
choose to offer additional assistance, such as assistance
getting to and from the securement area, in order to enable
persons to utilize the fixed route service. If the individual
is able to use the fixed route system with this assistance,
complementary paratransit service does not have to be
provided. Local policy concerning operator assistance should
be developed with full public participation, including the
input of persons with disabilities;
(3) Assistance of another person: With the exception of assistance
provided by the driver or other employees of the service,
eligibility under this category is based on a person's ability
to independent use the service. A person traveling with a
friend or attendant is still eligible for paratransit service
even if they would be able to use the fixed route system with
this other person's help.
(4) Accommodating mobility aids: The regulations set standards for
vehicle and station/stop accessibility. To be considered
accessible, equipment and facilities must be able to
accommodate mobility aids of a certain size and persons and
mobility aids up to a certain weight. The regulations define
a "common wheelchair" as a "wheelchair" which does not exceed
30 inches in width and 48 inches in length (measured two
inches above the ground) and which does not weigh more than
600 pounds when occupied. A "wheelchair" is defined as any
mobility aid belonging to any class of three or four-wheeled
devices, usable indoors, designed for and used by individuals
with mobility impairments, whether operated manually or
powered.
All common wheelchairs and their users are to be accommodated
on accessible fixed route and complementary paratransit
systems. The regulations do not, however, require public
entities to provide service to persons using mobility aids
that are not "common wheelchairs". An individual would not be
eligible for paratransit service under category 1 if they
could not use an accessible bus because their mobility aid is
too large or too heavy for the lift.
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ADA Paratransit Eligibility Manual
(5) Standees on lifts: The regulations require public entities to
allow persons with ambulatory disabilities who do not use
wheelchairs ( e.g., persons who use leg braces and canes) to
enter the vehicle by standing on the lift. Therefore,
individuals who cannot climb the steps to get into a bus would
not be eligible for paratransit service if they could enter
the vehicle using the lift.
Category 2 Eligibility
The second category of eligibility includes:
"Any individual with a disability who needs the assistance of a
wheelchair lift or other boarding assistance device and is able,
with such assistance, to board, tide, and disembark from any
vehicle which is readily accessible to and usable by individuals
with disabilities if the individual wants to travel on a route of
the system during the hours of operation of the system at a time,
or within a reasonable period of such time, when such a vehicle is
not being used to provide designated public transportation on the
route. " [37.123(e)(2)]
The majority of persons eligible under this category would be those
with ambulatory disabilities who could not enter an inaccessible
rail facility or would need to travel on a vehicle with a lift or
ramp and other accessibility features. This would include persons
who use wheelchairs as well as persons who use other mobility aids
such as walkers, leg braces, or canes.
Eligibility under this category depends on the accessibility of
vehicles and stations/stops. A person is eligible for paratransit
service if the fixed route on which they want to travel is not yet
accessible. Guidance on exactly what constitutes an "accessible"
fixed route is provided in the regulations and explanatory
appendix. For example:
- A person is eligible if the bus route on which they want to
travel is not 100 percent accessible. The requested trip
would be eligible if the fixed route that would otherwise be
used is only partially accessible (e.g., every other bus is
accessible).
- Similarly, a person is eligible if they need to travel on a
rapid or light rail system that is not yet accessible -
meaning that all key stations are accessible and one car per
train is accessible. An individual would be eligible in this
example even if accessible fixed route bus service is provided
in the same area.
- An individual is eligible for paratransit if a vehicle's lift
or boarding device cannot be deployed at the stop which they
want to use.
- An individual who uses a "common wheelchair" but cannot be
served by the fixed route system because the lift on the
vehicle they need to use does not meet the equipment standards
contained in Part 38 of the regulation is eligible for
paratransit service.
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ADA Paratransit Eligibility Manual
One important issue related to category 2 eligibility is the use of
on-call bus services as a way to increase the overall accessibility
of the fixed route service. Basically, on-call bus programs allow
an individual to call in advance and request that an accessible bus
be assigned to a particular route at a time when they need to
travel.5 Typically, an on-call bus program is implemented when a
significant percent of the fixed route fleet is accessible.
Successful programs have been implemented when 20-30 percent of all
peak hour vehicles are accessible.
On-call bus services do not technically make the fixed route fleet
fully accessible. Therefore, even if an on-call bus service is
offered, individuals who are eligible under category 2 must be
certified. On-call bus service is, however, considered an
acceptable form of complementary paratransit service and can be
provided in lieu of a separate van service to those who are
eligible under this category.
A second important issue is how this category of eligibility should
be treated by transit providers whose fixed route systems are fully
accessible. Clearly, individuals who could use accessible vehicles
would not be Category 2 eligible in these areas and transit
districts are not required to include questions that address this
category of eligibility in their application materials or
assessment processes if the fixed route service is 100 percent
accessible. These same individuals may not, however, be able to
use inaccessible vehicles if they travel to other transit
districts. Therefore, transit providers are encouraged to address
this category of eligibility even if it is not applicable to their
local system and to note on the eligibility documentation provided
that individuals are ADA paratransit eligible if accessible fixed
route vehicles are not available when needed.
Category 3 Eligibility
The third category of eligibility includes:
"Any individual with a disability who has a specific impairment-
related condition which prevents such individual from traveling to
a boarding location or from a disembarking location on such
system." [37.123(e)(3)]
Two important qualifiers to this category are included in the
regulations. First, environmental conditions and architectural
barriers not under the control of the public entity do not, when
considered alone, confer eligibility. If, however, travel to or
from a boarding location is prevented when these factors are
combined with the person's specific impairment related condition,
paratransit service must be provided. Examples of architectural
and environmental factors that, in combination with certain
disabilities, could prevent travel include:
___________________________
5 For more, information on on-call bus programs, see Chapter 6
of the ADA Paratransit Handbook, FTA Report #MA-06-0206-91-1,
September, 1991.
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ADA Paratransit Eligibility Manual
- a lack of curb-cuts
- the distance from the stop/station to the trip origin or
destination
- steep terrain
- snow and/or ice
- extremes in temperature (hot or cold)
- major intersections or other difficult to negotiate
architectural barriers
- temporary construction projects
- severe air pollution
Second, the specific impairment-related condition must prevent the
person from using the fixed route system. Conditions which make
getting to or from stops/stations more difficult do not confer
eligibility. A determination of whether travel is difficult rather
than "prevented" will need to be made. Appendix D of the
regulations offers the following guidance to clarify the concepts
of "prevented" travel and the relationship between architectural
and environmental conditions and a person's disability:
"For anyone, going to a bus stop and waiting for a bus is more
difficult and less comfortable than waiting for a vehicle at
one's home. This is likely to be all the more true for an
individual with a disability. But for many persons with
disabilities, in many circumstances, getting to a bus stop is
possible. If an impairment-related condition only makes the
job of accessing transit more difficult than it might
otherwise be, but does not prevent the travel, then the person
is not eligible.
For example, in many areas, there are not yet curb cuts. A
wheelchair user can often 'get around this problem by taking a
less direct route to a destination than an ambulatory person
would take. That involves more time, trouble, and effort than
for someone without a mobility impairment. But the person can
still get to the bus stop. On the basis of these
architectural barriers, the person would not be eligible.
Entities are cautioned that, particularly in cases involving
lack of curb cuts and other architectural barrier problems,
assertions of eligibility should be given tight scrutiny.
Only if it is apparent from the facts of a particular case
that an individual cannot find a reasonable alternative path
to a location should eligibility be granted.
If we add a foot of snow to the scenario, then the same person
taking the same route may be unable to get to the bus stop.
If it is not the snow alone that stops him; it is the
interaction of the snow and the fact that the individual has a
specific-impairment related condition that requires him to
push a wheelchair through the snow that prevents the travel.
Inevitably, some judgment is required to distinguish between
situations in which travel is prevented and situations in
which it is merely made more difficult. In the Department's
view, a case of "prevented travel" can be made not only where
travel is literally impossible (e.g., someone cannot find the
bus stop, someone cannot push a wheelchair through the foot of
snow or up a steep hill) but also where the difficulties
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ADA Paratransit Eligibility Manual
are so substantial that a reasonable person with the
impairment-related condition in question would be deterred
from making the trip.
The regulation makes the interaction between an impairment-
related condition and the environmental barrier (whether
distance, weather, terrain, or architectural barriers) the key
to eligibility determinations. This is an individual
determination. Depending on the specifics of their
impairment-related condition, one individual may be able to
get from his home to a bus stop under a given set of
conditions, while his next-door neighbor may not."
Given the judgement required to determine if travel is truly
prevented and the relationship between environmental conditions and
an individual's disability, making eligibility determinations based
on this third regulatory category is likely to be the most
difficult. Figure I on the following page provides additional
hypothetical examples to further define eligibility under this
category. It includes situations that would result in a person
being determined eligible as well as examples that would not confer
eligibility.
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ADA Paratransit Eligibility Manual
Figure 1. Examples of Eligibility Under Category 3
Situations that would result in category 3 eligibility:
- A person who is blind and who cannot cross a major
intersection that is not equipped with assistive devices such
as audible signals in order to get to or from a stop/station
would be eligible to receive paratransit for that trip.
- A person with a cardiac condition who is sensitive to high
temperatures and cannot wait outside for a bus during
extremely hot weather would be eligible when this
environmental condition exists.
- An individual with severe arthritis or multiple sclerosis
whose disability is aggravated by high humidity would be
eligible when this environmental condition, in combination
with the disability, prevents the use of fixed route service.
- An individual who uses a manual wheelchair, walker, or braces
and who cannot negotiate steep terrain would be eligible for
paratransit if using fixed route service for a particular trip
required crossing a hilly area.
- A person with an ambulatory disability who is unable to get to
or from stops/stations due to a lack of curb cuts.
- A person with a cognitive impairment who is unable to remember
and follow directions to get to and from a stop/station would
be eligible for trips (s)he has not or cannot be trained to
successfully make.
- A person who is frail and cannot independently travel more
than 1/4 of a mile to get to or from stops/stations and whose
particular trip is to a destination that is 1/2 mile from the
nearest fixed route.
- A person with an ambulatory disability who cannot walk or
maneuver a mobility device to or from stops/stations when
there is an accumulation of snow or ice would be eligible in
this type of weather.
- A person with a respiratory condition that is affected by high
levels of air pollution would be eligible if using fixed route
service under such environmental conditions is not advisable.
Situations that would not result in category 3 eligibility include:
- A person with a disability who prefers not to use fixed route
service due to the possibility of crime would not be eligible.
- A person who prefers not to use fixed route service when it is
raining would not be eligible unless the rain or humidity in
combination with a particular disability prevented him/her
from getting to or from a stop/station.
- An infant or child with a disability who is unable to get to
and from a stop/station and use the fixed route service not
because of the disability but because of age.
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ADA Paratransit Eligibility Manual
Companions/Personal Care Attendants
Paratransit service also must be provided to a personal care
attendant (PCA) traveling with an eligible rider. In addition to a
personal care attendant, the regulations require that service be
provided to one companion accompanying an eligible rider. Other
persons accompanying the rider are to be accommodated on a "space
available" basis. Persons are considered to be accompanying the
eligible rider if they are picked up and dropped off at the same
locations as the eligible rider. Companions must be charged the
same fare as the eligible rider and PCAs must ride free.
The following additional guidance on requirements for serving PCAs
and companions is provided in the interpretive appendix to the
regulations:
"The one individual who is guaranteed space on the vehicle can
be anyone-family member, business associate, friend, date,
etc. The provider cannot limit the eligible individual's
choice of type of companion. The transit authority may
require that the eligible individual reserve a space for the
companion when the individual reserves his or her own ride.
This one individual rides even if this means that there is
less room for other eligible individuals. Additional
individuals beyond the first companion are carried only on a
space available basis; that is, they do not displace other ADA
paratransit eligible individuals.
A personal care attendant (i.e., someone designated or
employed specifically to help the eligible individual meet his
or her personal needs) always may ride with the eligible
individual. If there is a personal care attendant on the
trip, the eligible individual may still bring a companion,
plus additional companions on a space available basis. The
entity may require that, in reserving the trip, the eligible
individual reserve the space for the attendant.
To prevent potential abuse of this provision, the rule
provides that a companion (e.g., friend or family member) does
not count as a personal care attendant unless the eligible
individual regularly makes use of a personal care attendant
and the companion is actually acting in that capacity. As
noted under 37.125, a provider may require that, as part of
the initial eligibility certification process, an individual
indicate whether he or she travels with a personal care
attendant. If someone does not indicate the use of an
attendant, then any individual accompanying him or her would
be regarded simply as a companion." [Appendix D to 49 CFR Part
37, 37.123]
As indicated above, a PCA may be an employee of the ADA paratransit
eligible rider or may be a family member or friend. Regardless of
the relationship, a PCA is clearly meant to be someone whose
services are required by the rider. In determining if eligible
individuals require PCA services, it is important to realize that
the need for a personal care attendant is not necessarily related
to travel on the paratransit service. PCAs are often needed by
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ADA Paratransit Eligibility Manual
individuals with disabilities to assist with other activities of
daily living. For example, a quadriplegic may be assisted by a PCA
in fl&g and holding papers at work or in eating meals. A blind
person may need a PCA to assist with shopping or to serve as a
reader at work. Individuals may need PCAs for these activities but
be fully capable of traveling on the paratransit service with the
assistance provided by transit personnel.
The need for PCA services can be intermittent or occasional and
still be considered Irregularly" needed. "Regular" use should be
interpreted to be consistent with the underlying need - for
example, a blind person regularly using a PCA for shopping. It is
also important to note that once a person has been certified as
needing to travel with a PCA, it should be the eligible individual,
not the transit agency, that determines if a PCA is needed for a
particular trip.
Section 4 of Chapter 3 of this manual offers guidance on questions
that can be added to the application form or assessment process to
determine if eligible individuals will need the services of PCAs
when using the paratransit program.
Visitors
The needs of visitors with disabilities who cannot use the fixed
route system also are addressed in the regulations. Complementary
paratransit service must be provided to ADA eligible individuals
who travel to areas outside of the region in which they live. If
these individuals have been certified as "ADA paratransit eligible"
by a public entity, that certification must be honored and the host
transit agency must provide up to 21 days of paratransit service.
If individuals have not been certified as eligible by another
public entity but claim that they are ADA paratransit eligible,
they are entitled to "presumptive eligibility" and must be provided
with 21 days of service. Individuals who are not certified by
another transit provider and who claim presumptive eligibility can
be requested to provide certain documentation such as their place
of residence and the nature of their disability.
Individuals are only considered "visitors" if they reside outside
of the transit provider's jurisdiction. The "jurisdiction" means
the total area within which the provider is authorized to operate,
not the sub-area designated as the ADA paratransit service area.
In joint paratransit plans, the jurisdiction is considered the
total area of all partners in the plan. The interpretive appendix
to the regulation offers the following explanation and example:
"A visitor is defined as someone who does not reside in the
jurisdiction or jurisdictions served by the public entity or
other public entities with which it coordinates paratransit
service. For example, suppose a five-county metropolitan area
provides coordinated paratransit service under a joint plan.
A resident of any of the five counties would not be regarded
as a visitor in any of them. Note that the rule talks in
terms of "jurisdiction" rather than "service area." If an
individual lives in XYZ County, but outside the fixed route
service area of that county's transit provider, the individual
is still not a visitor for purposes of paratransit in PQR
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ADA Paratransit Eligibility Manual
County, if PQR is one of the counties with which XYZ provides
coordinated paratransit service. "
Visitors from communities outside the transit agency's jurisdiction
must be served even if the community in which they reside does not
contribute financially to the transit system.
The "21 days" of service that must be provided are to be calculated
as 21 days of service over a defined period of time, not as a 21
calendar day period of time, beginning from the first day that
service is provided. For example, a person may travel to the ADA
service area two-days a week on the commuter rail system.
Eligibility should be extended in this case over the eleven week
period of time within which 21 days of paratransit service would be
required.
Visitors who require more than 21 days of service within the period
of time established can be required to apply for local eligibility.
Finally, the level of service provided to visitors must be the same
as that provided to local ADA paratransit eligible individuals who
would be traveling in the same area. This means that there can be
no difference in the area within which visitors can travel, the
times that they can travel, the fares charged, or any of the other
service criteria established in the regulations. Visitors are to
be treated exactly like eligible local customers.
Temporary Disabilities
Persons with temporary disabilities are to be considered for ADA
paratransit eligibility. This may include:
- someone with a medical condition such as a broken leg who
temporarily is unable to use the fixed route service;
- someone who has recently undergone an operation or other
medical treatment and who is unable to use the fixed route
service; or
- someone with a cognitive disability that can be expected to be
resolved over time through treatment or medication.
Temporary eligibility should be granted for the period of time that
the disabling condition is expected to last. An expiration date
should be included on the documentation provided to individuals
determined temporarily ADA paratransit eligible. Section 4 of
Chapter 3 of this manual includes a suggested approach for
determining the period of disability as part of the
application/assessment process.
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ADA Paratransit Eligibility Manual
Section 3. Key Differences between ADA Paratransit Eligibility
and Past Paratransit Eligibility
Many public transit providers offered paratransit services prior to
the enactment of the ADA. In the mid-1970's, eligibility was
determined by governing boards based on expressed local needs.
Throughout the 1980's, transit providers which opted to meet their
Section 504 obligations by offering paratransit service adopted the
general definition of eligibility provided in that regulation.
Eligibility for ADA complementary paratransit service is different
from these past notions of paratransit eligibility in four key
ways. These differences are discussed below.
ADA Paratransit Eligibility as a Civil Right
Failure to conduct a ' determination process that meets the
regulations or failure to provide complementary paratransit service
in accordance with the requirements established in the regulations
are violations of the civil rights of the affected individual.
This difference between ADA paratransit and past services has
several important implications for the eligibility determination
process. First, in designing review procedures and policies, it is
important that they adhere to all of the requirements contained in
37.123 and 37.125, described above and in Chapter 2 of this
manual. AR elements of the policy and process also should be
formally adopted by each public entity with the public
participation required in 37.137 of the regulations. Second, due
process standards must be observed in appeals, suspensions of
service, or in any other actions which affect a person's right to
the service. This is particularly true once individuals have been
determined eligible. In addressing the suspension of service for
"no-shows", the interpretive appendix states:
"Once an entity has certified someone as eligible, the
individual's eligibility takes on the coloration of a property
right. (This is not merely a theoretical statement. If one
depends on transportation one has been found eligible for to
get to a job, and the eligibility is removed, one may lose the
job. The same can be said for access to medical care or other
important services.) Consequently, before eligibility may be
removed "for cause" under this provision, the entity must
provide administrative due process to the individual."
[Appendix D to 49 CFR Part 37, Federal Register, Sept. 6,
1991, page 45747].
Finally, transit providers should maintain adequate records of
certification requests, reviews completed, notification provided,
and any appeals requested and should be prepared to demonstrate
that regulatory requirements were met in the handling of each
request for eligibility. Applications should be dated upon
receipt. Decisions made throughout the review process (e.g., the
completeness of the application, the need for more information,
reasons for determinations, requests for appeals, etc.) should be
recorded.
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ADA Paratransit Eligibility Manual
Functionally-based Determinations of Eligibility
Many policies prior to the ADA conferred paratransit eligibility
based on a particular medical condition, disability, or on the use
of a particular mobility aid. For example, persons who were
certified as paratransit eligible if they were "blind" or "legally
blind". Individuals who used wheelchairs, walkers, or leg braces
were considered eligible for paratransit. Certification from a
social service agency or a medical professional that the person
used a particular aid or had a particular disability automatically
conferred paratransit eligibility.
ADA paratransit eligibility, however, is based not just on the
presence of a disability, but on the effect that the disability has
on the person's ability to use the fixed route service. Several
factors must be considered in determining ADA paratransit
eligibility. These include:
(1) the applicant's disability;
(2) the accessibility of the fixed route system;
(3) architectural barriers that, in combination with the person's
disability, prevent use of the fixed route service; and
(4) environmental conditions that, in combination with the
person's disability, prevent use of the fixed route service.
While documentation of a particular disability or use of a mobility
aid is still important, this information alone can not be used to
make an eligibility determination. Questions about the functional
ability of the applicant to use fixed route transit must be
included in the application or assessment process. The
accessibility of the fixed route service and the effects of
environmental and architectural barriers must also be considered.
Conditional or "Trip-by-Trip" Eligibility
The paratransit eligibility processes employed by most transit
providers prior to the ADA used an "all or nothing" determination
approach. If it was determined that certain persons met the
criteria established for eligibility, they could call and request
paratransit service for any trip. If they were determined to not
be eligible, they could not request any rides. The ability to use
the fixed route system for some trips and not for others was not
considered.
Under the ADA, complementary paratransit service is only required
for trips that cannot be made on the fixed route system. Many
persons may qualify because there are certain specific conditions
which prevent them from using the fixed route service. For
example, a paraplegic wheelchair user may be able to use accessible
fixed route buses during most of the year, but may require
paratransit service when traveling on a route that is not fully
accessible or when traveling when there is a significant
accumulation of snow. Such a person would be ADA paratransit
eligible. Eligibility would be for trips that are not served by
accessible
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ADA Paratransit Eligibility Manual
fixed routes and might be limited to certain months of the year.
The documentation of ADA paratransit eligibility provided to this
individual should identify these conditions of eligibility.
While transit providers must identify whether or not applicants are
conditionally or unconditionally eligible and must include
limitations of eligibility in the documentation provided, they are
not required to conduct trip-by-trip determinations in daily
operation. If full compliance with the paratransit requirements
can be achieved within the allowed implementation period, a broader
service can be provided. If an undue financial burden waiver is
eventually requested, however, only those costs associated with the
provision of eligible trips can be used to calculate ADA
paratransit costs. An ability to distinguish between trips that
are eligible and those that are not will be needed.
Table 1 on the following pages, adapted from the ADA Paratransit
Handbook, illustrates the relationship between ADA paratransit
eligibility and selected types of disabilities/medical
conditions/functional impairments. For selected disabilities, the
applicability of eligibility conditions is indicated. The types of
conditions that should be considered are also noted. While the
table is not intended to be an exhaustive listing of disabilities
or eligibility conditions, it does illustrate the fact that
conditions of eligibility need to be considered in most cases.
There are limited instances in which it would be reasonable to
assume that paratransit service is needed "in all cases". This
would include, for example, individuals with profound mental
retardation who are unable to negotiate the fixed route system even
with travel training. It would also include persons with
disabilities that are episodic or intermittent (i.e., the extent of
disability can vary from day to day). In this latter instance, it
would probably be unrealistic to specify the condition that would
trigger an inability to use fixed route service.
17
Click HERE for graphic.
18
Click HERE for graphic.
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ADA Paratransit Eligibility Manual
Determining Eligibility Based on the Most Limiting Factors
Determinations of ADA paratransit eligibility must consider the
ability of applicants to travel to any origins and destinations in
the paratransit service area under all possible conditions.
Determinations cannot be based on a person's ability to use fixed
route service some of the time or under "typical" conditions. For
example, a person with an ambulatory disability may live only one
block from the nearest bus stop and the terrain between their home
and the stop may be level and accessible. They may not be able,
though, to independently travel more than 1/2 mile and may not be
able to negotiate steep terrain. Even though this person could get
to the fixed route system from their home, there would be possible
destinations more than 1/2 mile from fixed routes that she or he
would not be able to reach. There may be other destinations in
areas of steep terrain that would also be inaccessible.
Conditional eligibility would therefore be appropriate.
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ADA Paratransit Eligibility Manual
Section 4. The Importance of a Thorough Initial Determination
The development of a process that can accurately determine ADA
paratransit eligibility, including conditions and limitations of
eligibility, is important for several reasons. First and foremost,
as mentioned in Section 3 above, individuals who are unable to use
fixed route service have a right to receive complementary
paratransit service within the service limits established by the
regulations. Because this is a right established in national law,
the ultimate arbiter of eligibility for complementary paratransit
service is the judicial system. An applicant who feels that a
local determination of eligibility is not consistent with the
regulatory criteria can take this concern to court. It is
therefore in the interest of all involved that initial
determinations of ADA paratransit eligibility are made accurately
and in keeping with the established criteria and procedures.
In addition, an accurate determination of eligibility has important
operational and planning implications. These include:
Managing Demand
In many systems, the level of paratransit service that must be
provided to persons determined ADA paratransit eligible exceeds
that which was provided prior to the ADA. Once complementary
paratransit service is brought into full compliance, individuals
can request any and all trips for which they have been determined
eligible. Essentially, unconstrained service must be provided in
corridors served by fixed routes at all times that the service is
in operation. Unless granted an "undue financial burden waiver,"
transit providers will not be permitted to ration service, by
limiting supply or by other means, for these customers.
If the cost of providing fully compliant ADA paratransit service is
a local concern, it is important to carefully identify those
individuals who are eligible, determine when these persons can use
the fixed route system, and when paratransit is necessary. Unless
eligibility and appropriate limitations/conditions are determined
at the outset, it may not be possible to implement a trip-by-trip
scheduling system (see Chapter 4) as a way to manage paratransit
demand.
Documenting an Undue Financial Burden
In the event that providing fully compliant ADA paratransit service
presents an undue financial burden, the regulations permit transit
providers to request a waiver from the Administrator of the Federal
Transit Administration. Undue financial burden waiver requests
must document the cost of providing fully compliant service and
must detail why this cost is
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ADA Paratransit Eligibility Manual
an undue burden.6 In developing service costs, the regulations
specifically note in 37.155(b) that costs must be limited to those
"required by (the regulations) to ADA paratransit individuals" and
"attributable to ADA-mandated trips".
Transit providers requesting waivers must be able to document that
they have counted only those costs associated with eligible trips
made by persons who have been determined ADA paratransit eligible.
They must also be prepared to show that local determination of
eligible individuals and trips is consistent with the regulations.
The local eligibility determination process is, therefore, an
important concern in any decision regarding a request for an undue
financial burden waiver. If there is reason to believe that the
process has not accurately determined ADA paratransit eligibility
consistent with the regulations, the costs of ADA complementary
paratransit service included in a waiver request may be questioned.
___________________________
6 Factors which must be addressed in an undue financial burden
waiver request are detailed in 37.151 through 37.155 of the
regulations.
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ADA Paratransit Eligibility Manual
Chapter 2
Elements of an ADA Paratransit Eligibility Policy
In addition to providing a definition of ADA paratransit
eligibility, the USDOT regulations establish requirements for
several aspects of the determination process. As shown in Figure 2
below, six specific process requirements are included in 37.125 of
the regulations. Additional process issues are discussed but left
to the option of transit providers. Each of these required and
optional policy elements is described in this chapter.
Figure 2. Required and Optional Policy Elements
Required Elements: Optional Elements:
- Strictly limiting eligibility - Recertification of ADA
- Accessible formats paratransit eligibility
- Processing time - Recertification of other
- Notice of initial determinations paratransit customers
- Documentation of eligibility - No-show suspension policy
- Administrative appeal process
All transit providers should establish a written eligibility policy
as part of their ADA paratransit plan. The policy should detail
exactly how the ADA paratransit eligibility determination process
is structured. The policy must address the requirements of 37.125
and indicate how compliance with each is being achieved. It can
also address the optional elements noted above. A checklist which
can be used to ensure that all key elements are included in an ADA
eligibility policy is provided in Appendix B.
Section 1. Required Elements
Strictly Limiting Eligibility
The certification process that is established must strictly limit
ADA paratransit eligibility to the regulatory definition of
eligibility. Only those persons who meet the regulatory definition
can be given documentation indicating that they are "ADA
Paratransit Eligible". In addition, if individuals who are
determined to be ADA paratransit eligible can use fixed route
service under certain conditions, the documentation which they are
given must indicate the limitations/conditions of their
eligibility.
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ADA Paratransit Eligibility Manual
Public entities which foresee no financial difficulty fully meeting
the complementary paratransit requirements and who wish to offer a
broader service can do so. A parallel process for determining
eligibility for this broader service can be established and
documentation of eligibility for this non-ADA service can be
provided. Documentation for this broader service cannot, however,
indicate that these other customers are ADA paratransit eligible.
Entities also may develop an integrated eligibility determination
process which they use for all local paratransit services.
Questions included in the application material can be used to
determine if individuals qualify for broader services even if they
do not qualify as ADA paratransit eligible. Documentation of
eligibility must, however, distinguish between those who qualify
for the broader service and those who meet ADA paratransit
eligibility standards.
Similarly, if full compliance with the complementary paratransit
requirements poses no undue financial burden, entities may opt to
accept all trip requests, regardless of conditions and
circumstances, from individuals determined ADA paratransit
eligible. It may be too administratively burdensome to implement
trip-by-trip eligibility or may not be cost effective to attempt to
operationalize all aspect of trip eligibility. The determination
process and the documentation provided must still, however, be
designed to identify the extent of eligibility conferred on
individuals. Application or assessment forms and guidelines must
be detailed enough to allow for conditions of eligibility to be
noted where applicable. The process must also be thorough enough
to reasonably ensure that the criteria for eligibility are being
properly interpreted and applied.
As noted in Section 4 of the previous chapter, should it become
necessary to request an undue financial burden waiver, only those
costs attributable to ADA-mandated trips can be counted in the
request.
Accessible formats
Subsection (b) of 37.125 states that "All information about the
process, materials necessary to apply for eligibility, and notices
and determinations concerning eligibility shall be made available
in accessible formats upon request." Accessible formats include
large print, audio tape, braille, and computer disk.
Information does not need to be made available in the format a
requester prefers, but does have to be made available in a format
that the person can use. There is no use, for example,
giving a braille document rather than a document on tape to a
person who does not read braille.
Section 4 of Chapter 3 of this manual includes a more detailed
discussion of this requirement and suggests ways to assist
individuals with sensory impairments.
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ADA Paratransit Eligibility Manual
Processing Time/Presumptive Eligibility
Applicants are to be granted presumptive eligibility if a
determination of eligibility has not been made within 21 calendar
days of the submission of a completed application. Service must be
provided, and the applicant presumed to be eligible, until and
unless the determination is complete and the person is found to be
ineligible.
An application is considered to be complete once the person has
provided all of the information required. Subsequent
investigations or requests for additional information by the public
entity would be considered part of the review process and within
the 21 day timetable. For example, if an application process
requires that individuals complete a form which includes the name
of a professional who can be contacted for further information, the
application would be considered "complete" once the requested
information and professional contact were indicated. Follow-ups by
the public entity in getting additional professional verification
and information would be part of the 21 day review process.
Notice of Initial Determination
Applicants must be notified in writing of the initial determination
of eligibility. If the determination is that the person is not
eligible, the written notification must state the reasons for the
finding.
Appendix D to the regulations indicates that notification of
ineligibility must be specific. Information provided in the
application or obtained in the review process must be related to
the eligibility criteria (e.g., the categories of eligibility) and
to the review process which the entity has designed. Simply
indicating that the person is not ADA paratransit eligible because
it has been determined that they "are able to use the fixed route
system" is not sufficient.
Section 6 of Chapter 3 provides more information and suggestions on
the notification process.
Documentation of Eligibility
If an applicant is determined to be eligible, documentation of
eligibility must be provided. This documentation must specifically
state that the person is "ADA Paratransit Eligible". It must also
contain, at a minimum, the following information:
- the name of the eligible individual;
- the name of the transit provider providing the certification;
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ADA Paratransit Eligibility Manual
- the telephone number of the transit provider's paratransit
coordinator;
- an expiration date for eligibility (if applicable);
- any conditions or limitations on the individual's eligibility;
and
- the need for a personal care attendant.
The telephone number of the transit provider's paratransit
coordinator is meant to facilitate communication between transit
providers if additional eligibility information is needed when the
person travels to another area. The person identified (and the
phone number listed) should be the individual who has access to and
can readily provide eligibility information.
Administrative Appeal Process
Section 37.125(g) of the regulations requires that an
administrative appeal process be available to any individuals who
are determined to be ineligible for complementary paratransit
service. Because the provision of ADA complementary paratransit
service is a civil right, the denial of eligibility is a serious
matter. A fair and effective appeal process is not only required
but is in the interest of all parties.
The appeal process must be available not only to individuals who
are determined ineligible in all situations, but to persons who are
deemed conditionally eligible. Limiting eligibility is in fact
denying eligibility for certain trips.
The appeal process established must comply with the following
requirements:
- Individuals must be permitted to request an appeal within 60
days of the initial eligibility decision;
- Individuals must have an opportunity to be heard in person and
to present additional information and arguments regarding
their disability and ability to use the fixed route service;
- There must be a "separation of function" between those
involved in the initial eligibility determination and those
selected to hear appeals;
- Applicants must be notified of appeal decisions in writing, or
in accessible format if requested, and the notification must
state the reasons for the decision if eligibility is still
denied;
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ADA Paratransit Eligibility Manual
- If a decision on the appeal is not made within 30 days of the
completion of the process, individuals must be considered
"presumptively eligible" and must be provided paratransit
service until and unless a decision to deny the appeal is
issued. Paratransit service does not have to be provided,
however, during other phases of the appeal.
Section 8 of Chapter 3 offers guidance on establishing an appeal
process and includes information about the processes adopted by
several selected transit agencies.
Section 2. Optional Elements
In addition to the above items, eligibility determination policies
can include the following three additional features. These are,
not, however, required elements of the process.
Recertification of ADA Paratransit Eligibility
Transit providers can require that individuals periodically reapply
for ADA paratransit eligibility. While a person's disability may
be permanent, other factors which go into the determination of
eligibility may change. For example, the percent of accessible
vehicles in the fixed route service may increase. Improved
technologies and/or operating procedures also may be introduced
which would permit greater use of the fixed route service by
individuals with disabilities.
While the regulations do not specify the period for which
individuals should be certified as ADA paratransit eligible, some
general guidance is provided. The ADA Paratransit Handbook
suggests recertification every three to five years.7 It also notes
that the period of recertification can be flexible and can consider
the applicant's particular disability. For example, a person who
is frail and 75 years old could be determined eligible without any
expiration date while an. applicant whose disability might be
expected to change can be certified for a specific period of time.
Another important factor in setting the recertification interval is
whether or not changes in the level of fixed route accessibility
are planned. A longer interval might be appropriate in an area
where fixed route service is already 100 percent accessible versus
a system that is just beginning to make fixed route vehicles and
stations accessible.
Regardless of the policy regarding recertification, individuals
have the right to request a new determination if they believe that
there have been changes in their situation. This would
___________________________
7 ADA Paratransit Handbook, USDOT Report Number UMTA-MA-06-0201-
91-1, September, 1991, page 4-11.
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ADA Paratransit Eligibility Manual
include individuals determined ineligible as well as those whose
eligibility has been limited or conditioned.
Recertification of Other Paratransit Customers
If paratransit service was provided prior to the ADA, transit
providers may elect to require that all current riders be
recertified. Such a recertification is not, however, required by
the regulations. Current riders can continue to receive service
and can apply for ADA paratransit eligibility as they choose.
If existing riders are allowed to choose whether or not to apply
for ADA paratransit eligibility, transit providers should make
these riders aware of any potential benefits of certification.
This would include the ability to use paratransit services in other
areas and "priority service" should capacity constraints exist. It
would also provide individuals with certain rights and "due
process" protections.
A recertification of existing riders will become important,
however, if fully compliant paratransit service cannot be developed
in the five year implementation period provided by the regulation.
Any request for an undue financial burden waiver can only count
those costs associated with the provision of required paratransit
service. A recertification of existing riders will be needed to
determine which individuals and which trips are in fact required.
No-Show Suspension Policy
Finally, the regulations permit transit providers to suspend
paratransit service to those persons who establish a "pattern or
practice" of missing scheduled rides (i.e., "no-show"). Service
can be suspended for a "reasonable period of time". Allowances
must be made for missed trips that are beyond the control of the
individual. The number of no-shows considered a pattern or
practice and the period of suspension must be developed through the
public participation process required for the development and
updating of paratransit plans.
Before service can be suspended for cause under this provision,
individuals must be provided with an opportunity to appeal the
proposed suspension. A two-stage notification and appeal process
is detailed in 37.125(h) of the regulations.
Section 9 of Chapter 3 provides further guidance on no-show
policies and includes information about policies established by
selected transit agencies.
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ADA Paratransit Eligibility Manual
Chapter 3
Establishing an ADA Paratransit Eligibility Determination Process
The establishment of an appropriate eligibility determination
process involves several key decisions. Figure 3 summarizes the
basic steps that must be taken to establish a determination
process. At the outset, a decision must be made as to the process
that win be used. It is then necessary to decide who will conduct
initial determinations. An appeal process must be structured and
no-show and recertification policies considered. Application
materials and forms must then be developed. Public participation
in all of these aspects of the process is required.
A management information system for tracking reviews should be
created before the process is implemented. Training also should be
provided to those involved in the process. Consideration should be
given to pre-testing materials before they are widely distributed.
Once established and operational, administrative oversight of the
process should be maintained, particularly in the initial months.
This chapter details and provides guidance on each of these steps
and decisions. Section I discusses overall considerations,
including public participation in the development of the process
and the issue of application/assessment fees and charges. Sections
2 and 3 present alternative processes that can be used for
conducting determinations, and discuss issues
Figure 3. Steps in Developing an ADA Paratransit Eligibility
Process
1. Select the Type of Initial Determination Process to be Used
2. Determine Who will Conduct Initial Eligibility Reviews
3. Design an Appeal Process
4. Establish Recertification Requirements (Optional)
5. Establish a No-Show Policy (Optional)
6. Design Application Forms and Related Materials
7. Design a Management Information System for Tracking Reviews
and Appeals
8. Provide Appropriate Training
9. Pre-test Forms and Process
10. Implement Process
11. Monitor Process and Make Changes as Needed
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ADA Paratransit Eligibility Manual
associated with conducting determination in-house versus
contracting with an outside agency or agencies for this service.
Section 4 addresses the development of application forms and
related materials. Suggestions for the development of application
forms and other materials are presented. Issues associated with
conducting reviews, providing notification of determinations,
structuring an appeal process, and establishing details of a no-
show policy and a visitor policy are discussed in Sections 5
through 10.
Much of the information in this chapter is based on the policies,
procedures, and materials that have been developed by selected
transit providers during the first year and a half of
implementation of the complementary paratransit service
requirement. Detailed information about eligibility determination
was obtained from 25 selected transit providers across the country.
Reference is made to these systems throughout this chapter.
Appendix C provides a listing of the transit systems contacted,
addresses, phone numbers, and contact persons should additional
information be desired.
Section 1. General Considerations
Public Participation
Major elements of the process must be developed with full public
participation, including a public hearing.8 This would include
decisions on the overall initial determination process that will be
used, the structure of the appeal process, or a decision to
establish or change the specifics of a no-show policy. It would
also include major changes to the application/assessment form such
as the addition or deletion of key questions regarding travel
capabilities.
Procedural changes such as the wording of notification letters or
minor changes to the layout of forms and other materials can be
made without full public participation. Obtaining less formal
input is still, however, recommended.
The ongoing mechanism for obtaining the input of persons with
disabilities in the
development and implementation of the paratransit service should be
used throughout. Given the detail involved in developing all
aspects of a determination process, consider establishing a small
but representative working group to help in the development of
draft materials and OP
process recommendations. Make these draft materials and
recommendations available to any advisory committee or distribute
them to agencies and interested individuals for review and comment.
Finally, present the recommended process and materials at a pubic
hearing for broader comment and review. If eligibility materials
are to be revised over time, consider combining the review and
revision with the required annual ADA paratransit plan update
process.
___________________________
8 Public participation requirements are detailed in 37.137 of
the regulations.
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ADA Paratransit Eligibility Manual
Conversations with transit providers that have successfully
implemented an eligibility determination process suggest that
public involvement in the development and implementation of the
process is vital. Individuals with disabilities and agency staff
can assist with the preparation and testing of materials. They
will provide a detailed knowledge about disabilities and travel
capabilities and requirements that the transit provider staff do
not necessarily have. Involving consumers and agencies will also
allow for the development of options for outside assistance with
initial reviews and appeals.
For additional guidance on developing a public participation
process, see the ADA Public Participation Handbook. This document,
funded by FTA and prepared through Project ACTION, offers numerous
suggestions and readily adapted material for strengthening local
public participation.
Public Information and Marketing
In addition to a thorough public participation process, it is
highly recommended that a public information/marketing program be
developed to educate potential applicants and local disability
organizations about ADA paratransit eligibility. The program
should utilize a variety of media to reach persons with different
types of disabilities, and program materials should be made
available in accessible formats. It is likely that individuals and
agencies may not fully understand the functional nature of ADA
paratransit eligibility, the difference between individual and trip
eligibility, the appeal process, or other key issues.
Misunderstanding of the nature of eligibility for service can lead
to incomplete and/or inappropriate applications, as well as
political and customer relations problems.
Communicating the trip-by-trip nature of ADA paratransit
eligibility is particularly important. Several transit agencies
have reported that individuals are hesitant to use fixed route
services for fear this will make them ineligible for ADA
paratransit. The public information program should emphasize that
paratransit may still be appropriate even if fixed route service
can be used some of the time. The eligibility determination
process is intended to determine when each mode is appropriate
rather than to make an absolute distinction between those who are
to use fixed route and those who require paratransit.
Another public perception issue raised by several transit agencies
was that applicants often do not provide information about all of
the difficulties they may have using the fixed route service.
Applicants may think that, as long as the primary difficulty using
transit is noted, they will qualify for paratransit and be able to
request any trip. It is important that they understand that all
difficulties be noted so that appropriate conditions/limitations of
eligibility can be determined.
While a public information campaign is recommended in all cases, it
is particularly important in the following situations:
- If current paratransit customers are being required to reapply
and be recertified as eligible for paratransit service.
Differences between past eligibility policy and ADA
paratransit eligibility will need to be explained;
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ADA Paratransit Eligibility Manual
- If a broader paratransit service will be provided with
priority given to those determined ADA paratransit eligible.
In this situation, it is important that the benefits of
applying for and being determined ADA paratransit eligible be
communicated to all riders.
Some public information and marketing efforts to consider are
listed below.
(1) Develop a brochure that explains ADA paratransit eligibility.
It could be displayed with other service materials and mailed
to current riders. It could also be displayed at locations
which are frequented by the general public and persons with
disabilities such as public libraries, municipal buildings,
senior centers, aggregate housing locations, social service
agencies, and medical facilities. Appendix D contains copies
of brochures developed by Seattle Metro, the Regional
Transportation Authority of Chicago, and the Riverside Transit
Agency of Riverside, California that explain the ADA, ADA
paratransit, eligibility, and the appeals process.
(2) As mentioned in Section 4 of this chapter, include a summary
of ADA eligibility with certification materials that are sent
to applicants.
(3) Work with local human service agencies and disability
organizations to include information about ADA paratransit
eligibility in any publications that they may have.
Organizations such as United Cerebral Palsy councils, local
chapters of the National Easter Seal Society, commissions for
the blind and visually-impaired, commissions for the deaf and
hearing-impaired, area agencies on aging, mental health
agencies, independent living programs, and state,regional, or
local commissions on people with disabilities prepare
newsletters which are sent to members and clients.
(4) Request the opportunity to discuss eligibility issues with the
governing boards of human service agencies and disability
organizations and to make presentations at any workshops,
conferences, or consumer meetings which they may sponsor.
(5) Make a particular effort to explain the details of ADA
paratransit eligibility to the staff of local agencies.
Depending on the certification process employed, these
individuals may be asked to supplement applicant information
or may assist individuals in completing application materials.
Even if not involved in the certification process, agency
staff who are knowledgeable about eligibility issues will be
able to better advise clients.
(6) Sponsor a special public forum at which ADA paratransit
issues, including eligibility, can be discussed. Invite
current riders and other interested agencies and individuals
as well as advertising it to the general public. A notice of
such a forum, prepared by the Worcester Regional Transit
authority, is provided in Appendix D.
(7) Work with local media to develop public interest stories that
help to explain the service and eligibility. Feature a
customer who uses the fixed route service for certain trips
but has been certified for paratransit service for other
trips.
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Additional Charges and Fees
Section 37.5 of the regulations, which defines general requirements
for nondiscrimination for all aspects of transportation services
covered, states that:
"An entity shall not impose special charges, not authorized by
this part, on individuals with disabilities, including
individuals who use wheelchairs, for providing services
required by this part or otherwise necessary to accommodate
them." [37.5(d)]
For determinations of ADA paratransit eligibility, this means that
there can be no charges associated with the process, including the
filing and processing of applications, any in-person assessments
that may be requested, the documentation of eligibility that is
provided, or any other aspect of obtaining eligibility.
In particular, if the process involves obtaining information from a
professional or an in person assessment, the transit provider or
any third-party contractors acting on behalf of the transit
provider cannot impose a fee for this service. If professional
information is needed for the initial application to be considered
complete, alternatives should be made available should the
applicant not be able to obtain this information from a
professional or not be willing to incur any costs that might be
associated with obtaining this information. For example, the
transit provider should make arrangements with local professionals
to whom applicants can be referred and the transit agency should
pay any fees associated with this service. Transportation to and
from any in-person assessments or other appointment required by the
process also should be made available to applicants.
Similarly, a fee cannot be charged for the preparation of
documentation of eligibility, including photo identification cards.
A transit provider may, however, charge a nominal fee, meant to
cover the cost of production, for replacement of lost I.D. cards.
Local policy concerning such charges should be developed with full
public participation, including the input of persons with
disabilities.
In addition to prohibiting obvious direct charges, the regulations
note that the process may not impose "unreasonable administrative
burdens" on applicants.9 Repetitive and superfluous documentation,
questions, or tests must not be included.
___________________________
9 Appendix D to 49 CFR Part 37, Federal Register, September 6,
1991, page 45746.
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Section 2. Alternative Processes
There are several ways that ADA paratransit eligibility
determinations can be conducted. In general, the many approaches
that have been developed can be characterized as one of the
following:
- Self-certification with professional verification as needed;
- Self-certification and professional verification;
- In-person assessment; and
- Combined approaches.
These alternative processes can be conducted either in-house by
transit provider staff or can be contracted out and conducted by a
third-party agency. It is also possible to conduct some
determinations in-house and have third-party assistance available
as needed.
The best process and approach to conducting reviews depends on
local circumstances. Some alternatives are better suited to
smaller systems. Others are more appropriate for larger urban
systems. Whether or not a paratransit service was provided prior
to ADA complementary paratransit service is also an important
consideration in the alternative selected. Each alternative also
has its own benefits and issues that must be considered.
Regardless of the approach selected, the goal of the determination
process should be the same - to enable the public entity to
accurately determine when and under what circumstances the fixed
route service can and cannot be used by applicants. Information
collected and reviewed must be sufficient to enable the reviewer to
identify the relationship between a person's disability and their
travel capabilities given factors such as: the accessibility of the
fixed route service; the distance to and from stops/stations;
environmental factors such as snow, ice, heat, cold; and natural
and man-made architectural barriers such as steep terrain, lack of
curb-cuts, and busy roads and/or intersections.
Following is a description of each of the alternative processes
listed above. For each, general recommendations are made
concerning the applicability of the process to different types of
systems. Major considerations associated with each alternative are
also discussed.
Self-certification with professional verification as needed
This alternative involves the completion of a form by the applicant
or a person assisting the applicant. The form which the applicant
completes typically includes all of the information required for a
determination of eligibility. As part of the form, applicants are
requested to identify a professional who can be contacted if more
information is needed, and are asked to sign a release authorizing
the professional to provide the transit agency with pertinent
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ADA Paratransit Eligibility Manual
information. While the applicant chooses the professional who can
be contacted., the transit agency can request the identification of
particular type(s) of professionals. Professional verification can
be obtained under this model by phone, through the use of a second
form which is mailed to the professional by the transit provider,
or both.
While it is theoretically possible to establish a determination
process that only utilizes information provided by the applicant,
it is highly likely that at least some determinations will require
more detailed information. Verification of "hidden disabilities"
such as cardiac conditions, pulmonary conditions, cognitive
disabilities, and mental illness will be needed. It is therefore
recommended that the ADA paratransit eligibility determination
process allow for professional contact, at least as an option, in
all cases.
In addition to contacting the identified professional when
additional information is needed, some transit providers will
randomly contact named professionals to verify the information
provided by applicants. Verification can also be done following
certification if there is cause to believe that the information
provided by the applicant is not correct.
Applicability
Self-certification with professional verification as needed is used
extensively by smaller fixed route operators in small urban and
rural areas. It is most appropriate in areas where the size of the
system allows transit providers to be familiar with paratransit
riders. It is also appropriate in cases where the transit agency
offered paratransit services prior to the implementation of ADA
service. In these instances, it is likely that the provider
already has information about riders, possibly including
professional verifications, on file. An ADA paratransit
eligibility determination process which does not require
professional verification can be used to reduce unnecessary
duplication of existing eligibility information.
Considerations
This certification process is perhaps the least burdensome on
applicants. Appointments with professionals to have forms
completed or to have personal assessments conducted are not
required. Greater burden is placed on reviewers, however, as
follow-up may be needed if sufficiently detailed information is not
provided in the initial application.
If this alternative is selected, particular attention should be
given to the 21 day timetable allowed by the regulations for
reviewing applications and presumptive eligibility beyond this
time. Applications must be considered complete if applicants
complete all items on the form and name a professional contact as
requested. Any follow-up by reviewers to obtain professional
verification would be part of the 21 day review timetable. An
initial review and decision whether or not professional information
is needed should be made within the first few days after receipt of
the application.
Another important issue associated with this approach is getting
information from the most appropriate professional. Depending on
the nature of an applicant's disability, different types
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ADA Paratransit Eligibility Manual
of professional verification are desirable. For example, for
someone with a physical disability, information from a physical
therapist or occupational therapist may be most helpful. For an
applicant with a vision-impairment, information from an
opthomologist which can provide the degree of sight which the
applicant has may be helpful. It is not always possible, however,
to control the type of professional named by the applicant. If
allowed, many applicants may provide the name of a personal
physician with a knowledge of the person's disability but with
little understanding of their ability to travel on the fixed route
service.
If possible, applicants should be directed to identify
professionals most appropriate to their disability or medical
condition. Section 4 of Chapter 3 of this manual suggests wording
that can be added to the application form to direct applicants to
identify an appropriate professional. It is also possible under
this approach to request that a different professional be
identified if the person originally listed cannot provide adequate
information.
Finally, because this process relies on information provided by the
applicant and/or a professional, it is important that they
understand the nature of ADA paratransit eligibility. A ma or
issue encountered by transit providers using this form of
certification is that applicants/professionals will identify a
primary disability or travel limitation but may not detail all
problems that may be encountered using the fixed route service.
This may be due to the fact that applicants feel they only need to
qualify and that they will then receive service as needed.
Professionals also may have a tendency to provide cryptic medical
information. The introductory section of the form should describe
ADA paratransit eligibility in detail. The notion of trip-by-trip
eligibility also needs to be made clear so that the applicant and
professional understands that detailed information is required in
order to identify appropriate eligibility conditions/limitations.
Self-certification and professional verification
In this eligibility determination process, the initial application
form contains two parts - one part completed by the applicant (or
his/her representative) and the other part to be completed by a
professional familiar with the applicant's condition. The
information from the professional is requested as part of the
initial submission and the application is not considered complete
without it. As with the first alternative described above, each
applicant selects the professional from which they request
additional information. Transit providers can, however, specify
the types of professionals that can provide this information.
The professional verification portion of the application is
typically designed in one of two ways. In some cases, the
questions asked of both the applicant and the professional are very
similar and the separate responses are compared for accuracy and
consistency by the reviewer. In other cases, the applicant is
asked only general information and more detailed information about
travel capabilities and the nature of the person's disabilities is
included in the professional verification section of the form.
While information is requested from both applicants and
professionals under this process,
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ADA Paratransit Eligibility Manual
follow-up may still be required. Contact with the applicant may be
needed if a different professional, with a better understanding of
the person's functional abilities, is needed. Follow-up with
professionals may be necessary if the information provided is not
sufficiently detailed to allow a determination to be completed.
Applicability
This process is often used by larger transit providers who, because
of the expected volume of certification requests, may find it
administratively difficult to do the necessary professional follow-
up within the required processing timetable. The inclusion of
professional information as part of all applications received can
help to facilitate the review process.
It may also be applicable if past eligibility for paratransit
service was not functionally based or if information that may be on
file as part of past determinations needs to be updated.
Considerations
If this approach to certification is used, transit providers must
allow for those instances when applicants are not able to easily
obtain information from professionals. While systems report that
most individuals are able to obtain the needed information from a
professional, there will be some individuals who will not have an
ongoing relationship with a professional or may have to pay for
this information to be provided.
In order for the process to be consistent with the regulatory
prohibition against special charges and unreasonable administrative
burdens, professional verification should be requested. Applicants
should be instructed to contact the transit provider if
professional verification cannot be obtained. A fist of
appropriate professionals to whom applicants can be referred should
be maintained and the cost associated with any required
appointments should be paid by the transit provider.
As with "self-certification with professional verification as
needed", it is important that an effort be made to obtain
information from the most appropriate professional. Applicants can
be instructed to provide verification from particular professionals
or can be directed to contact a professional appropriate to their
disability.
Paratransit eligibility determination prior to the ADA often
specified that this type of professional verification be provided
by a personal physician. Under the ADA, the use of physicians may
not be appropriate in many cases. While personal physicians may be
the professionals most readily available to applicants, they may
not understand the applicants functional capabilities as well as
other professionals. The interpretive appendix to the regulation
offers the following advice concerning the use of information from
physicians:
"The substantive eligibility process is not aimed at making a
medical or diagnostic determination. While evaluation by a
physician (or professionals in rehabilitation or other
relevant fields) may be used as part of the process, a
diagnosis of a disability is not
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ADA Paratransit Eligibility Manual
dispositive. What is needed is a determination of whether, as
a practical matter, the individual can use fixed route transit
in his or her own circumstances. That is a transportation
decision primarily, not a medical decision." [Appendix D to 49
CFR Part 37, Federal Register, September 6, 1991, page 45746]
In certain instances, information from a physician will be
appropriate. Verification of a cardiac condition or the degree of
vision impairment may, for example, be needed. Transit providers
should consider allowing applicants to obtain information from
several different types of professionals, including physicians.
Direction should also be provided encouraging applicants to obtain
information from a professional most appropriate to their
particular disability.
It is also important that professionals understand that the
verification which they provide is not considered a determination.
Eligibility determinations are to be made by transit providers or
contractors hired to conduct eligibility determinations.
Professionals must understand that they are simply providing
information to the reviewers and that they are not being asked to
make the determination. This should be made clear on the forms
provided. Avoid having professionals answer broad questions which
ask them if they think that the person is ADA paratransit eligible.
They should not be asked to make a final judgement. This will only
cause problems and possible confrontations if the final
determination differs from their professional opinion.
Many systems also indicate that information provided by
professionals is cryptic and general in nature. Transit providers
should make questions concise and explain on the form that detailed
information is needed. The concept of trip-by-trip eligibility
should be explained and professionals should be informed that the
information needs to be of sufficient detail to allow the reviewer
to not only determine that paratransit service is needed but to
decide when and under what circumstances, paratransit service is
needed.
In some cases, transit providers will allow human service agencies
to provide professional verification for their clients. Such
agencies may have conducted assessments of clients to determine
their eligibility for other programs. They often will have
detailed functional information on file which can be of assistance
in the process. Because of the obvious benefit to these agencies
of having clients certified for paratransit service, it is
recommended that consideration be given to the extent of this type
of agency involvement in the process. If the staff of human
service agencies are to be used for professional information and
verification, transit providers may want to consider limiting the
types of agency verifications accepted to those agencies that
promote independent living. It is important that agencies
authorized to provide verifying information be concerned not just
with obtaining a convenient service for their clients but with
mainstreaming them. Independent living centers, certain agencies
for persons with vision-impairments, and rehabilitation centers are
examples of such agencies. As with other types of professional
verification, it is important that information provided by these
agencies be one factor in the determination rather than being used
as a final eligibility decision.
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ADA Paratransit Eligibility Manual
If reviewers used by the transit provider are skilled in
interpreting standard human service assessments, another option
available under this model would be to request copies of any
functional tests which these agencies may have on file.
In-Person Assessments
Under this model, all applicants are required to meet with a
reviewer selected by the transit provider. At this assessment
meeting, the reviewer will typically ask the applicant a series of
questions, similar to those contained in an application form, meant
to determine the person's disability and ability to use fixed route
service. Often, the reviewer will also elaborate on standard
questions to get more detailed information as appropriate. In
addition to a face-to-face interview, in-person assessments may
also involve the administration of functional tests. These may
include physical tests such as the ability to board and disembark
from an inaccessible bus, use a wheelchair-lift, or see and read
signs or other visual information. It may also involve
administering standard cognitive tests to determine the applicants
ability to perform tasks such as asking for and following
directions.
Because of the skill required to administer and interpret detailed
tests and draw immediate conclusions from such assessments,
determinations under this process are typically performed by third-
party agencies under contract to the transit provider. Transit
providers may also work with contractors to develop testing centers
containing equipment needed to simulate travel on the fixed route
system. The Transit Authority of River City (TARC) in Louisville,
Kentucky, for example, has created a testing center at a local
rehabilitation center that is equipped with a specially constructed
bus stop and a spare bus. The site also contains sidewalks with
varying terrain and varying surfaces. For applicants with visual
impairments, the site includes typical transit signage and symbols
and can simulate varying degrees of light and darkness. For
applicants with mental disabilities, a cognitive and orientation
assessment is conducted by a clinical psychologist.
In addition to information collected by the reviewer, the process
may require applicants to complete a general information form and
sign necessary releases/certifications.
Applicability
In-person assessments may be particularly applicable in larger
urban systems with complex fixed route services. The in-person
process is able, in these circumstances, to obtain detailed
information about using various parts of the system that may be
difficult or complex to collect on standard application forms.
This approach may also be more appropriate in areas that did not
provide paratransit service prior to the ADA. While transit
providers with established paratransit services and longstanding
customers may not deem it necessary to require all riders to
undergo an in person assessment, new systems will have no past
record of riders to rely on. New riders may also be more amenable
to an in-person assessment process.
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ADA Paratransit Eligibility Manual
Considerations
The use of in-person assessments has many advantages. It allows
eligibility determination to be done by a limited number of
professional who can be trained by the transit provider. Obtaining
information from an appropriate professional, which is a major
concern in self-certification/professional verification models, is
eliminated. In-person assessments also are not bound by standard
application questions. The process can be more personalized to the
person's particular disability. Even though standard
questionnaires are used to guide the process, reviewers can ask
follow-up questions as needed.
This process also allows reviewers to explain ADA paratransit
eligibility in-person and to answer questions about eligibility
which the applicant may have. The applicant also has an
opportunity to request clarification of questions before providing
an answer. The information received is therefore more likely to be
complete and accurate.
Because of the degree of flexibility which reviewers may have, it
is important that efforts be made to maintain consistency in the
process. Transit providers should consider establishing standards
for the types of professionals who are used as reviewers. Detailed
training of reviewers is also vital.
Perhaps the greatest drawback to requiring in-person reviews in all
cases is that many applicants may have disabilities which do not
require such elaborate assessments. To many applicants, such a
required process may seem an unnecessary and burdensome procedure.
Another issue with this type of process is assessing disabilities
that are intermittent or episodic. A single visit and review may
not generate the same level of information about a person's
capabilities that may be available to a professional who has worked
with the individual for years. Consideration should be given, in
such cases, to obtaining supplemental information from a
professional identified by the applicant.
Similarly, an assessment of cognitive ability based on a single
visit or series of tests may not be as complete as information
which can be obtained from the person's social worker or mental
health counselor.
Finally, it may be difficult to simulate all environmental
conditions which may affect a person's ability to use fixed route
service. The limitations of certain physical tests need to be
considered and the applicability of these tests to the process
carefully weighed against the cost of their administration and
inconvenience to the applicant. Regardless of the sophistication
of the tests administered, information obtained in the personal
interview is likely to still be an important part of the
determination.
Combined Approaches
In addition to the basic approaches described above, eligibility
determination can also be conducted by combining the features of
each of these processes. Table 2, presented at the
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ADA Paratransit Eligibility Manual
end of this section, includes information about the processes used
by several selected transit providers across the country. As can
be seen, many different combined models are possible.
Perhaps the combined model that is most widely used combines self-
certification/professional verification with in-person assessments
as needed. For example, the Madison Metro Transit System in
Madison, Wisconsin relies primarily on a self-certification process
which asks applicants to identify a professional that can be
contacted for verification and additional information. Metro's in-
house reviewers will seek verification as needed. Metro also
reserves the right to ask applicants to appear in-person for an
assessment by a local rehabilitation center.
Several providers, including Lane Transit District, Baltimore's
MTA, Seattle METRO, and the Utah Transit Authority obtain
information from both the applicant and a professional ("self-
certification and professional certification"). In addition, they
will refer applicants for an in-person assessment if a final
determination is still not possible.
The Riverside Transit Agency (RTA) requires an in-person assessment
in most cases. They will, however, accept professional
verification from applicants with severe mental retardation. An
in-person assessment is not required if a psychological evaluation
is provided which indicates severe mental retardation and has been
signed by 4 or more professionals of the regional mental health
program. It is also interesting to note that the RTA has arranged
for in-person assessments to be conducted either at the local
clinic or at the applicant's home.
The Regional Transportation Authority of Chicago, which will be
administering eligibility determinations for CTA and PACE, combines
self-certification with in-person assessments as needed. A similar
process is being established by the New York City Transit
Authority.
It is interesting to note that in systems that employ "combined"
processes using both self-certification/professional verification
and in-person assessments, relatively few in-person reviews are
necessary. As shown in Table 2, 90 percent of all determinations
can typically be completed based on the information supplied by the
applicant and/or the named professional. Seattle Metro, for
example, has found it necessary to refer only 5 percent of all
applicants for an in-person assessment. The Utah Transit Authority
relies on in-person reviews in 7 percent of all cases. The Lane
Transit District, located in a medium sized urban area, finds in-
person assessments necessary in only 1 percent of all
determinations.
As transit providers complete recertification efforts and begin
doing determinations of new riders, in-person assessments may
become more important. Madison Metro reports, for example, that
during the process of recertifying existing riders, only 10 percent
of all determinations of existing riders required in-person
reviews. Following the recertification of existing riders, in-
person assessments have been deemed necessary in 25-30 percent of
all determinations.
Another model developed by the Port Authority of Allegheny County's
ACCESS Program in
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ADA Paratransit Eligibility Manual
Pittsburgh combines in-person assessment with professional
verification. An in-person assessment is required in all
determinations. In addition, applicants who receive services from
a local human service agency are also encouraged to bring
verification information from that agency to the assessment. PAT
provides a "Professional Verification" form to applicants for this
purpose.
Finally, the Oshkosh Transit System in Oshkosh, Wisconsin uses a
self-certification with professional verification as needed process
but also relies heavily on two local human service agencies for
verification of eligibility. The Oshkosh Transit System recently
consolidated local paratransit services and assumed operating
responsibility from the local Red Cross and the County Committee on
Aging. As the past operators of service, these two agencies were
familiar with existing riders. The Oshkosh Transit System
therefore accepts professional verification from these two agencies
for all existing riders seeking ADA paratransit eligibility.
Applicability and Considerations
Combined models may be appropriate in any number of situations.
The use of in-person assessments as needed or professional
verification to supplement an in-person review process may be
needed to strengthen the original process. As experience is gained
with the eligibility determination process, transit providers and
their reviewers may discover that these additional steps are needed
to ensure the accuracy and consistency of determinations.
Depending on the features combined, the issues noted above for each
of the basic processes would apply.
Considerations for Future Recertification of Riders
As noted in Chapter 2 of this manual, the regulations permit
transit providers to require periodic recertification of riders.
It is possible that the process used for this recertification will
be different from that used in the initial determination or to
certify new riders.
For example, if a self-certification/professional verification
process was used for initial determinations, it may be possible to
forward the information that was originally provided by the
applicant and request that they indicate whether this information
is still current and correct. Updating of the original form may
also be supplemented by a limited number of new questions.
Applicants could be asked if the professional who provided the
initial verification is still the appropriate person to contact and
new verification could be sought only in.those cases where
significant changes in capabilities are noted.
Transit providers using an in-person assessment process for all
initial determinations could opt to not require another detailed
review but instead could use a self-certification type of form that
asks if the persons disability or ability to use the fixed route
service has changed. In-person assessments may be limited to those
recertifications where significant changes are noted.
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ADA Paratransit Eligibility Manual
Section 3. Deciding Who Will Do Initial Determinations
A second major decision that must be made when designing an
eligibility determination process is who will actually review
application materials or conduct in-person screenings. The basic
choice is to either conduct initial determinations in-house, using
staff of the public entity, or to contract with a third-party to
perform this service. It is also possible to involve staff in part
of the process and utilize outside help for specific functions as
needed. Issues related to each of these options are discussed
below. The approach taken by selected transit providers is also
presented in Table 2 in the previous section.
In House Determinations
If eligibility decisions are to be made by in-house staff, it is
important to be sure that this staff has the capabilities and
qualifications to make accurate and consistent determinations.
While ADA paratransit eligibility is a functional transportation-
related decision, it also involves relating specific types of
disabilities to reported functional capabilities. A knowledge of
various types of disabilities and the likely functional
capabilities of persons with such disabilities is, therefore,
important.
Public entities which operated paratransit services prior to the
ADA and have been conducting eligibility determinations may already
have staff with such capabilities, Others may elect to hire new
staff or train existing staff to handle this job. Consideration
should also be given to combining the task of doing ADA paratransit
eligibility determinations with other similar in-house tasks. For
example, it may be possible to combine the job of ADA eligibility
determinations with the review of applications for reduced fare
cards. If an in house travel training program is developed, staff
in this program could also assist with determinations of
eligibility. A medical officer hired to work on drug and alcohol
testing might also be a good person to involve in the eligibility
determination process.
In-house determinations are more common among providers that have
elected to use either a self-certification with professional
verification as needed or a self-certification with required
professional verification system. It is also common among smaller
providers and providers which offered paratransit services to
persons with disabilities prior to the ADA.
Contract Reviewers .
It is likely, that there are a variety of local organizations in
the area that could be hired to either do or assist in initial
eligibility determinations. This might include a clinic that
employs occupational or physical therapists, a rehabilitation
center, an independent living center or program, a rehabilitation
center, or a visiting nurses program. If it is determined that in-
house staff capabilities are not adequate, or if the impartiality
of having an organization other than the transit provider is an
important consideration, contracting with
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ADA Paratransit Eligibility Manual
one of these organizations may be appropriate.
When selecting a third-party contractor for eligibility reviews,
consider both the capabilities of the employees of the agency as
well as the general philosophy and mission of the agency. Figure 4
on the following page identifies several types of professionals
that can assist in the process. Certain professionals will have
the skills necessary to perform determinations of functional
capabilities. Others will be most helpful in verifying the nature
and extent of particular disabilities. Note in particular the
capabilities of physiatrists. Doctors of physiatry specialize in
the mobility and travel capabilities of persons with disabilities -
skills ideally suited to ADA paratransit certification. Physiatry
is a narrow specialty, however, and such doctors may not be
available in many areas. If there are physiatrist(s) in the area,
consideration should be given to involving them in the process -
either to assist with development of the process or to assist with
actual determinations. Doctors of physiatry may be particularly
well suited to assisting with appeals, for example. Occupational
therapists are also well suited to determine capabilities
associated with activities of daily living.
In addition to considering the type of professional to be used,
transit providers may want to develop specific applications for
reviewers who may be proposed or used by third-party contractors.
As noted in Table 2, for example, the Los Angeles County
Metropolitan Transportation Authority includes certified nurses in
the list of professional that can be "Certification Analysts" but
requires persons in this profession to have at least two years of
experience.
When involving human service agencies in the process, consider any
conflicts or biases which may exist - particularly with agency
clients. Organizations which support the concept of independent
living and mainstreaming of persons with disabilities are also more
likely to make determinations which strictly limit eligibility to
those who are unable to use the fixed route system.
Third-party contractors can be particularly appropriate if a large
number of existing paratransit riders are to be recertified as part
of the,implementation of the program. Conducting a large-scale
recertification process in-house may require several reviewers who
would only be used for a limited period of time. The scope of a
third-party contract, on the other hand, could be adjusted to meet
the particular demand.
Third-party review contractors also should be considered if it is
decided that the determinations will be done through in-person
assessments. Correctly interpreting responses to questions and/or
the results of specific tests may require skills not available in-
house. Both of the, transit providers contacted as part of the
preparation of this manual which require in-person assessment in
all cases utilized third-party reviewers. The Port Authority of
Allegheny County's ACCESS Program utilizes the local chapter of the
Easter Seal Society, a local neuropsychology agency, and a network
of orientation and mobility specialists for persons with vision-
impairments. Los Angeles has developed a network of "Certification
Analysts" representing various professions.
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ADA Paratransit Eligibility Manual
Figure 4. Examples of Types of Professionals that can Assist with
Eligibility Determinations
Examples of types of professionals who can assess the functional
capabilities of individuals to use fired route transit services
include:
Clinical Social Workers: Persons who provide psychiatric social
work assistance to mentally or emotionally disturbed patients of
hospitals, clinics, or other medical centers, and to their
families. Will investigate case situations and present information
to a psychiatrists. Help patients to respond constructively to
treatment and assist in adjustment leading to and following
treatment. Serve as link between patients, psychiatric agency, and
community. Usually required to have knowledge and skill in
casework methods acquired through degree program at school of
social work.
Independent Living Specialists: Individuals who work with
independent living programs or centers to provide special education
and training to persons with disabilities in the performance of all
or most activities of daily living.
Occupational Therapists: Persons who use purposeful activity to
treat individuals who are limited by physical injury or illness,
psychosocial dysfunction, developmental or learning disabilities,
poverty and cultural differences, or the aging process to maximize
independence, prevent disability, and maintain health.
Physiatrists: Physicians who test the physical functioning of a
person and supervise the person's rehabilitation program.
Physical Therapists: A person who is licensed to assist in the
examination, testing, and treatment of persons with disabilities
through the use of special exercise, or other techniques.
Rehabilitation Specialists: Persons who assist individuals in
regaining normal or near normal functional capabilities after a
disabling disease, injury, addiction, or incarceration.
Examples of professionals that can assist in verifying the nature
and extent of disabilities include:
Audiologists: Persons who specialize in the physiology, anatomy,
and pathology of the ear and the diagnosis and treatment of
disorders of the ear.
Opthomologists: Physicians who specialize in the physiology,
anatomy, and pathology of the eye and the diagnosis and treatment
of disorders of the eye.
Physicians: Health professionals who have earned a degree of
Doctor of Medicine (M.D.) after completing an approved course of
study at an approved medical school. Physicians can be trained in
general medical practice, or in specialized areas of medicine.
Psychologists: Persons who specialize in the study of the structure
and function of the brain and related mental processes. A Clinical
Psychologist is one who is qualified by graduate degree in
psychology and training in clinical psychology and who provides
testing and counseling services to patients with mental and
emotional disorders.
Registered Nurses: A professional nurse who has completed a course
of study at a state approved school of nursing and passed the
National Council Licensure Examination.
Sources: Mosby's Medical, Nursing, and Allied Health Dictionary,
the C. V. Mosby Company, 1990; and, Dictionary of Occupational
Titles, Volume 1, Fourth Edition, U.S. Department of Labor, 1991.
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ADA Paratransit Eligibility Manual
In House Determination with Third-Party Assistance as Needed
It is also possible to combine an in-house staff review with the
option to obtain third-party assistance as needed. A significant
percentage of the reviews of eligibility may be relatively
straightforward. In-house staff may be able to easily make
determinations in these cases. Other applications or assessments
may be more difficult. In these cases, the application material
can be forwarded to a contract reviewer for further review and
recommendation. If information forwarded by the applicant or the
named professional is not sufficient to make a determination, it
may be desirable to request that the person appear in person for a
more in depth assessment. Such assessments can then be contracted
out.
Many of the transit providers contacted as part of the preparation
of this manual used third-party reviewers as needed. The Utah
Transit Authority utilizes a self-certification with professional
verification as needed process. In-house staff have been able to
determine eligibility in 93 percent of the cases using information
initially submitted and follow-up information obtained from named
professionals. In the remaining instances, applicants have been
requested to participate in in-person assessments conducted by
several local organizations. The assessment is done by an agency
familiar with the particular disability of the applicant. The UTA
utilizes the Spine Rehabilitation Center of the University of Utah,
the State Services for Visually Impaired, and local Associations
for Retarded Citizens to conduct assessments. Seattle Metro, which
utilizes a self-certification with required professional
verification process, works with the occupational and physical
therapists at a local medical center when in-person assessments are
required. Metro reports that 5 percent of all applicants are
referred to the Center for in-depth assessments.
One consideration in using third-party review contractors, either
as needed or in all cases, is the cost of these services. The cost
of contracting out for this service must be compared to the costs
that would be incurred if in-house staff performed this function.
Current availability of qualified staff, training costs, and long-
term employment issues must all be considered. Table 2, included
in the previous section of this manual provides a summary of cost
information obtained from providers who utilize third-party review
contractors. As can be seen, costs range from about $18 to $164
per review, depending on the type of review performed. In person
assessments contracted by Lane Transit, Los Angeles, Madison Metro,
Seattle Metro, Riverside Transit, and the Utah Transit Authority
range from $25 to $164. It appears that assessments done only as
needed (implying a lower volume) may be more expensive while
assessments of all riders in Pittsburgh and Los Angeles are
considerably less expensive ($20 - $30). The transit provider that
contracts for the review of self-certification forms, Worcester
Regional Transit Authority, reported that this service costs
approximately $18 per review.
It may also be possible to lower the cost of needed assessments by
working with other available public agencies. The Utah Transit
Authority, for example, refers individuals with vision impairments
to the State Services for the Visually-Impaired. This state agency
has agreed to conduct assessments free of charge.
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ADA Paratransit Eligibility Manual
Reviewer
Regardless of whether determinations are conducted in-house or by a
third-party, it is important that those involved in the
determination are adequately trained. As noted above, in-house
staff may have an adequate knowledge of the existing transit system
but may need training regarding types of disabilities and their
functional characteristics. Such could be provided by local
organizations. Sensitivity training materials, such as that
developed by the Rural Transportation Assistance Program, may also
be helpful.
Third-party staff may need a more complete understanding of the
services offered on the fixed route system. They may not be aware,
for example, of the extent of accessibility and driver assistance
that is now offered. They may also not be aware that individuals
with ambulatory impairments are permitted to enter the vehicle by
standing on the lift.
Both in-house and third-party staff should also be given thorough
instruction about ADA complementary paratransit and ADA paratransit
eligibility. A complete understanding of the concepts discussed in
Chapter 1 of this manual will be needed.
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ADA Paratransit Eligibility Manual
Section 4. Developing Application Forms and Materials
Once decisions have been made concerning the process to be used and
the persons or agencies that will actually conduct reviews, the
next step in the process is to develop application/assessment forms
and related materials. This section discusses the development of
this material.
Before addressing the development of application material, it is
important to note two general considerations - accessible formats
and terminology - that apply to all forms and materials. These are
discussed below.
Accessible Formats
As noted in Chapter 1, the regulations require that all information
about the eligibility determination process, including materials
necessary to apply, notifications of determinations, and other
related correspondence be made available in accessible format upon
request. This could include large print, audio tape, braille, or
computer disk. The requested format does not always have to be
provided, but the format provided must be usable and appropriate
for the purpose.
While all materials must be available in accessible formats upon
request, transit providers can require that application be made in
a standard format. Making information available in accessible
formats does not mean that applications and information must be
accepted on tape or in braille.
Even though individuals may be asked to complete a standard form,
providing the form and related information available in an
accessible format is important. It allows individuals to study the
information and questions. This allows for a better understanding
of ADA eligibility and the process for applying than could be
obtained by having the information read over the phone.
As part of the application process, transit providers should
determine if applicants would like to have future correspondence
sent in an accessible format. The application should also ask if
another person assisted in the completion of the form(s). The
determination letter and other correspondence could then be sent to
this other person as well.
In some cases, it may be necessary to provide documentation of ADA
paratransit eligibility in a standard as well as an accessible
format. A standard letter or pass would be needed as proof to
present to other transit agencies if the person traveled to another
area. Providing the same information in an accessible format would
be important if the person needed to periodically refer to the
exact conditions associated with their eligibility.
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ADA Paratransit Eligibility Manual
Terminology
Several of the transit providers contacted reported that many of
the modifications made to original materials related to
terminology. Applicants had difficulty understanding the questions
being asked. Much of this difficulty was due to the inclusion of
industry jargon in the application or other materials.
Particular attention should be given to using terminology that can
be easily understood by the general riding public. For example,
applicants and professionals providing verification may not
understand what a "paratransit" service is or even what the fixed
route system is. Use terms such as the "regular city buses" or "van
service" and refer to services by their public names such as
"ACCESS-A-RIDE" or "OMNITRANS". The public also may not fully
understand what an "accessible" bus is. Provide more detail on the
features of the vehicle or use terms such as "wheelchair-lift-
equipped".
Transmittal/Cover Letter
If the process selected involves sending application forms to
individuals and/or professionals for completion, it is strongly
recommended that a detailed transmittal letter explaining the
material and ADA paratransit eligibility be developed and included.
The transmittal letter should include:
- a summary and description of the material attached and
instructions for completing and submitting the forms;
- A concise and clear description of ADA paratransit
eligibility; and
- A description of the fixed route transportation services
provided, particularly policies designed to facilitate use by
persons with disabilities.
Particular attention should be given to explaining the trip-by-trip
nature of ADA paratransit eligibility. It is important that
individuals and professionals realize that the process is intended
to determine not only if they require paratransit service but when
and under what conditions they require paratransit service. It
should be stressed that in order to make a complete and accurate
decision, detailed information about their travel capabilities is
needed.
Information about the fixed route service should include the latest
changes made to improve accessibility. Describe the level of
accessibility in the fleet, improvements in sinage, recent driver
training efforts, new policies such as the standee policy and the
bus stop announcement policy. Also describe available services such
as route identifier or destination card systems that are available.
Many applicants may have a preconceived notion about the service or
may have attempted to use the service when there was a low level of
accessibility and/or operational problems with the service.
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ADA Paratransit Eligibility Manual
APPENDIX TRANSIT PROVIDER TYPE OF PROCESS
San Mateo County Transit Self-certification with
E District (SAMTRANS) professional verification as
San Carlos, CA needed
Madison Metro Transit System Self-certification with
F Madison, Wisconsin professional verification and
in-person assessments as needed
G Utah Transit Authority Self-certification with
Salt Lake City, Utah in-person assessment as needed
Worcester Regional Transit Self-certification and
H Authority professional verification
Worcester, Massachusetts
Municipality of Metropolitan Self-certification and
Seattle (Metro) professional verification with
Seattle, Washington in-person assessment as needed
Washington Metropolitan Area
Transportation Authority Self-certification and
(WMATA) professional verification
Washington, D.C., Northern
Virginia, and Suburban Maryland
Delaware Administration for Self-certification and
K Specialize Transportation (DAST) professional verification
Dover, DE
L Regional Transportation Authority Self-certification with in-
(for CTA and PACE) person assessment as needed
Chicago, IL
Port Authority of Allegheny In-person assessment and
County (PAT) professional verification
Pittsburgh, Pennsylvania
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ADA Paratransit Eligibility Manual
Application/Assessment Forms
Once a decision has been made about the type of process to be used
and the person(s) who will conduct determinations, a form or forms
will have to be developed for obtaining information, either by mail
or in person, from individuals requesting ADA paratransit
eligibility certification. This form or set of forms can be
completed by the applicant, a professional verifying the
applicant's disability and capabilities, an evaluator conducting an
in-person assessment, or a combination of these people. The
information obtained will then be used to determine whether or not
the person is ADA paratransit eligible and under what conditions
they require complementary paratransit service.
Regardless of the type of determination process selected, the same
basic information should be collected. This includes:
- General information about the applicant;
- The nature of the person's disability or disabilities;
- The person's ability to use the fixed route service;
- Information which may be needed for operations; and
- Administrative information needed to complete the
determination.
How the form(s) and questions are organized depends on the type of
review process used. In a "self-certification with professional
verification as needed" process, the form completed by the
applicant is typically comprehensive. All of the basic information
needed is requested of the applicant. In a " self-certification
and professional verification" process, the. applicant is often
only asked for general information and some basic information about
their disability and travel capabilities. The professional is then
asked more detailed questions about the exact nature of the
person's disability and functional capabilities. In "in-person
assessment" processes, the applicant may be requested to file a
form with general information. The professional(s) conducting the
assessment then complete the more detailed form based on their
discussion with the applicant and/or functional tests that are
administered.
The type of questions used can also vary. Some forms use open-
ended questions that rely on applicants to clearly detail their
situation and capabilities. Other forms are more detailed and use
multiple choice answers to guide the applicant in providing
information in the required level of detail. The approach used
will depend on local needs and circumstances. It is important,
however, that if open-ended questions are used, applicants and/or
professionals are clearly instructed to provide enough detail to
describe all of the factors that affect their use of the fixed
route service. Similarly, if directed, multiple-choice questions
are used, the possible answers suggested must be comprehensive.
Several sample forms, developed by transit providers which use
various determination processes, are included in the appendices to
this manual. A summary of the sample forms included and the type
of process within which they are used is provided on the following
page.
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Following is a summary of the type of information that can be
collected in each of the basic sections of the
application/assessment form. Sample questions are also provided.
General Information
The first part of the form should request information about the
applicant. Following is the type of information that is commonly
requested in this first part of the application form.
- the applicant's name
- street address, apartment number, city/town, state, and zip
code
- mailing address (if different)
- telephone number, including home and work number, and TDD
number (if applicable)
- Social Security Number (optional)10
- date of birth
- the name and phone number of a person to be contacted in an
emergency and the relationship of this person to the applicant
To assist in communicating with the applicant in the future, many
forms also ask if applicants would like communications to be sent
in an accessible format. For example, the following question could
be included:
Do you need written information given to you in a different way?
____ Yes (specify below):
____ Large print
____ Braille
____ Audio tape
____ Other:
____ NO
You can also call (agency phone number) if you need assistance
completing this form.
A question such as the following can also be included to determine
if communication in another language would be helpful. This
question should be tailored to include the
___________________________
10 The federal privacy act of 1974 requires that individuals be
notified that disclosure of their social security number is
voluntary.
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languages, other than English, that are common to the area.
Language Ability (please check all that apply)
____ English ____ Spanish
____ Other (specify)
Questions about Mobility Aids Used
Application/assessment forms also should include a section which
requests information about the types of mobility aids used by the
applicant following the "General Information" section. This
information is not only useful in the eligibility determination
process but is important information that will be needed in daily
operations should the applicant be determined eligible for service.
As shown in the sample question below, information about mechanical
aids, life support, as well as service animals should be requested.
It may also be helpful to request detailed information about the
type, size, and weight of wheelchairs to determine if the applicant
uses a "common wheelchair"11. Some forms indicate prior to this
question that the information is needed to ensure that appropriate
paratransit service is provided.
Which of the following mobility aids do you use? (please check all
that apply)
__ Cane __ Manual wheelchair __ Service animal
__ White cane __ Powered wheelchair __ Picture board
__ Walker __ Powered scooter/cart __ Alphabet board
__ Crutches __ Boarding chair __ Portable oxygen
__ Prosthesis __ Transfer board __ None of these
__ Other (please describe)
If you use a manual or powered wheelchair or scooter, what make and
type is it?
If you use a manual or powered wheelchair or scooter, is it more
than 30 inches wide, more than 48 inches long, or does it, when in
use, weigh more than 600 pounds?
Yes _____ No
___________________________
11 Section 37.165(b) of the USDOT regulations require transit
providers to transport all 'common wheelchairs'. A common
wheelchair is defined as a device which does not exceed 30
inches in width and 48 inches in length measured two inches
above the ground, and does not weigh more than 600 pounds when
occupied. Wheelchairs which exceed these dimensions and
weight do not have to be transported.
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Information can also be requested in this section about the
applicant's need for a personal care attendant (PCA). When asking
about the need for a PCA, it is important to note that assistance
may be needed at the final destination, not just in transit. It is
also important to consider that some applicants, particularly frail
elders, may not consider those who assist them to be "PCAS" or
"attendants". General language, as shown below, may be
appropriate.
Do you need to travel with someone who assists you?
____ Always ____ Sometimes ____ No
If you travel with someone who assists you, does this person assist
you in:
____ Getting to or from bus stops/rail stations
____ Getting on or off the bus
____ To help me when I get where I am going
____ Other (describe)
Additional information about the need for attendants can be
requested if there is particular concern about this issue. The
Port Authority of Allegheny County, for example, requires
applicants to complete and sign a "Personal Assistance
Certification" (see Appendix M).
Questions about the Applicants Disability
Complementary paratransit service is required if trips cannot be
made on the fixed route system due to a person's disability. In
order to verify that a person's inability to use the fixed route
service is due to a disability, the application/assessment form
should include a question or questions requesting information about
the nature and extent of the applicant's disability. This could
include a functional description of the disability (e.g.,
"Difficulty Walking", or "Vision Impairment"), a medical diagnosis
(e.g., "Cerebral Palsy"., or "Glaucoma"), or both. For sensory
impairments and hidden disabilities, it may also be helpful to
obtain information about the extent of the disability (e.g., the
degree of vision loss or the mental/cognitive disability).
Questions that determine if the disability is temporary or if it is
episodic (the effects vary over time) can also be included here.
If the process selected involves getting information from the
applicant as well as from a professional, general information
(functional descriptions) can be obtained from applicants and more
detailed information (degree of impairment, diagnosis, etc.) can be
obtained from the professional.
The type of information requested should also match the expertise
of those responsible for conducting reviews. If non-medical, in-
house transportation staff will be reviewing application forms,
request applicants and/or professionals to describe the disability
in nonclinical terms.
It is important to realize that many applicants may have multiple
disabilities that affect their
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ability to use fixed route service. Questions should be structured
to encourage applicants to list all applicable conditions.
Information can be obtained using general open-ended questions or
detailed multiple-choice questions. For example, many forms begin
this section by asking:
What is the health condition or disability which prevents you from
using the regular bus service? (Please list all applicable
conditions/disabilities) ________________________________
___________________________________________________________
Is this condition/disability temporary?
____No ____Yes
If Yes, what is the expected duration of this
condition/disability?________________months
Does your condition/disability change from day-to-day in ways
that affect your ability to use the regular bus (rail, subway)
service?
____No ____Yes (Please explain) ____________
_________________________________________________________________
Information on the type of disability can also be obtained by
providing applicants with detailed lists of various
conditions/disabilities and asking them to check all that apply.
The application form used by Seattle Metro (see Appendix 1)
includes such a comprehensive list.
Questions/Functional Tests Regarding Travel Capabilities
Perhaps the most critical part of the application/assessment form
is the section that requests information about the person's
functional capabilities as they relate to using the fixed route
service. Questions in this section should be designed to reflect
the functional capabilities needed to use the local transit system.
They also should allow applicants to explain how environmental and
architectural barriers affect their ability to travel. Finally, it
is important that questions be detailed enough to enable reviewers
to determine not only if the person is ADA paratransit eligible but
under what conditions they need to use paratransit.
As in previous sections, information can be obtained using general
questions, detailed lists, or both. For example, the following
general question could follow one regarding the nature of the
person's disability:
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Please explain how your disability prevents you from
using regular bus (rail) service?
_____________________________________________________
_____________________________________________________
This general question could then be followed by more detailed
questions that ask specific questions-about the capabilities
associated with using the fixed route service. These questions can
be organized around the regulatory categories of eligibility or the
four "tests" detailed in Chapter 4 of the ADA Paratransit Handbook.
When structuring this section, simulate the decisions that must be
made and actions that must be taken to make trips on the fixed
route system and consider the environmental and physical barriers
that might prevent a person with a disability from making a trip.
In order to identify conditions under which travel is and is not
possible, ask not only if applicants are or are not able to perform
certain functions, but allow for a "Sometimes" response and follow
this with a request for an explanation of barriers that can prevent
travel.
The types of questions asked in this section will vary somewhat
depending on the local transit system. Transit providers that
operate rail as well as bus services should consider questions
about climbing flights of stairs in addition to getting on and off
of vehicles. Assessing an applicant's capability to learn the
system and make complex connections and transfers will also be
important.
Depending on the type of process used, some questions can be asked
of applicants and other may be more appropriate for professionals
asked to provide an assessment of the applicant's abilities.
Certain questions about cognitive ability, in particular, may be
more appropriately addressed to a professional.
The general categories of capabilities that should be considered
and sample questions that could be used are presented below. In
several categories, two sample questions are provided - an open-
ended question and one that is more structured.
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The ability to obtain information about the fixed route service and
to understand and "negotiate" the system:
Questions under this category should address issues such as the
ability to read and understand schedules, to call for information
about the service, and to understand and follow directions. As
noted above, if professional verification is part of the process,
this information may be more appropriately included on a
verification form. Specific questions that might be asked are
shown on the following page.
In-person assessment processes can utilize accepted tests to obtain
this information or to augment information from these questions.
For example, Behavior Neuropsychology Associates, Inc., under
contract to the ACCESS Program in Pittsburgh, uses sections of the
following standardized tests to determine the applicant's cognitive
ability:
- the Mini-Mental State Examination (MMSE)
- the Weschler Adults Intelligence Scale (WAIS-R)
- the Communicative Abilities in Daily Living (CADL)
- the Cognitive Competency Test (CCT)
- the River Mead Behavioral Memory Test
Trail Making
A description of the various tests performed, along with the forms
used, is included in Appendix M.
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Sample Questions Regarding Ability to "Negotiate" the Fixed Route
System
Can you (or can the applicant) use a telephone to make calls and
get information about bus (rail) service?
____Yes ____No ____Sometimes
If No or Sometimes, please explain: ________________________
____________________________________________________________
Are you (is the applicant) able to ask for, understand, and follow
written or spoken directions either independently or with help of
an aid (such as a letter board or bus ID card)?.
____Yes ____No ____Sometimes
If No or Sometimes, please explain: ________________________
____________________________________________________________
Are you (is the applicant) able to deal with unexpected situations
and unexpected changes in routine?
____Yes ____No ____Sometimes
If No or Sometimes, please explain: ________________________
____________________________________________________________
Can you (can the applicant) recognize landmarks and travel on the
transit system independently?
____Yes ____No ____Sometimes
If No or Sometimes, please explain: ________________________
____________________________________________________________
Can you (can the applicant) safely travel through crowded and/or
complex transit stations?
____Yes ____No ____Sometimes
If No or Sometimes, please explain: ________________________
____________________________________________________________
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The ability to get to and from bus stops/stations within the ADA
Paratransit service area:
This section should ask/assess the applicant's ability to travel
certain distances to get to and from stops/station. The effects of
environmental conditions and architectural barriers on the distance
that can be traveled should also be determined.
Because eligibility must be based on the most limiting condition
(see Section 3 of Chapter I of this manual), information obtained
in this part of the form/assessment should not be limited to travel
to and from specific stops/stations. For operational reasons, it
may be helpful to know if applicants can get to the stop/station
closest to their home, but this information cannot be used to
determine overall eligibility. An individual should be provided
paratransit service if there are any trips that they cannot make
within the entire service area.
When asking about maximum distances that can be traveled, consider
a measure that will be most easily understood by applicants in the
area. In urban settings, it may be appropriate to ask about the
number of blocks that can be traveled. In general, nine city
blocks are approximately 3/4 of a mile in length. In non-urban
areas, measures could include fractions of a mile, feet, or yards.
For example, the following questions could be asked to determine
how far applicants are able to independently travel:
Using a mobility aid or on your own, how far are you able to
travel without the assistance of another person?
__ less than 200 feet __ 1/4 mile (3 blocks) __ 1/2 mile (6 blocks)
__ 3/4 mile (9 blocks) __ more than 3/4 mile (9 blocks)
The effects of environmental conditions and/or architectural
barriers on applicants' ability to travel these distances could be
determined by asking:
Is your ability to independently travel this distance affected
by snow, ice, steep hills, or other barriers?
____ No ____ Yes
If yes, please explain_________________________________________
_______________________________________________________________
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or, a specific list of environmental/architectural barriers could
be provided as follows:
Are you unable to get to or from bus stops (transit stations)
without the assistance of another person for any of the
following reasons (check all that apply)?
____I cannot travel up or down steep hills
____I cannot travel through deep snow or when there is ice
____I cannot cross busy intersections
____I cannot travel in areas without curb-cuts or sidewalks
____I cannot travel at night due to night blindness
____Very cold weather is dangerous to my health
____Very hot weather is dangerous to my health
____High air pollution (smog, etc.) is dangerous to my health
____Other. Explain:____________________________
The ability to wait at a stop or station:
Questions in this section should determine if applicants are able
to wait for a bus or train. This can be determined by asking for
the maximum time that applicants can wait or by asking if they can
wait more than a predetermined time (e.g., 10 minutes or 30
minutes). If a predetermined time is used, it should relate to
typical headways and expected wait times on the fixed route service
in question. As with travel distance, conditions that might affect
applicants' ability to wait at a stop or station should be
determined as well.
Possible questions regarding this ability could include:
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ADA Paratransit Eligibility Manual
Are you able to wait for a bus at a bus stop (or a train at a
station)?
_____ Yes _____ Sometimes _____ No
If no or sometimes, please check all of the following statements
that apply to you:
_____ I can wait only if there is a bench
_____ I can wait only if there is a shelter
_____ Waiting outside in very hot weather is dangerous to my health
_____ Waiting outside in very cold weather is dangerous to my
health
_____ I can wait only if it is not longer than minutes
The person's ability to board, ride, and disembark from accessible
and non-accessible vehicles or in and out of transit stations:
Questions in this section should address applicants' ability to use
bus or rail services once at the stop or station. Abilities that
need to be determined include: climbing the steps of a vehicle or a
flight of stairs at a subway stop; getting on and off a lift;
getting to and from a seat or securement area; paying fares; riding
on the bus or rail car if a seat is not available; and recognizing
when to get off the bus/rail car.
Some forms include a direct question about the ability to
use fixed route service, such as:
What best describes your ability to use the regular city
buses?
I can use with little or no difficulty
I can only use with great difficulty
I can use only those buses that have lifts or ramps
I cannot use at all
The response to this question can then be compared to answers to
more detailed questions about use of fixed route service. If the
fixed route service in question is fully accessible, a
determination of applicants' ability to use non-accessible services
is not required. As mentioned in Section 2 of Chapter 1 of this
manual, it may be beneficial to include questions about using non-
accessible services, however, to assist riders who may travel to
areas where the fixed route service is not yet fully accessible.
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Possible questions that should be considered in this part of the
form could include:
Are you able to get on and off a bus that does not have a lift
or a ramp?
_____ Yes _____ No
Are you able to get on and off a bus that has a "kneeler" to
lower the first step?
_____ Yes _____ No
Are you able to get on and off a bus that has a Eft (Please
note that persons who do not use wheelchairs but who cannot
climb the bus steps are permitted to enter the bus by standing
on the lift)?
_____ Yes _____ No
Once inside, can you get to a seat or wheelchair position
without assistance?
_____ Yes _____ No
Can you climb a flight of 7 inch steps? (rail services)
____Yes ____ No
Are you able to hold a handhold or a pole on a bus or a
subway?
____Yes ____ No
Are you able to balance yourself when standing on a bus or
subway using a handhold or pole?
_____ Yes _____ No
_____ Not applicable (use wheelchair)
_____ Don't Know
Do you know where to get off the bus or subway or can you
find out?
_____ Yes _____ No
Are there any other reasons why you cannot get on or ride
the bus or subway?
_____ Yes _____ No
If yes, please explain: _________________________________
_________________________________________________________
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Travel Training Information
While transit providers cannot require that applicants undergo
travel t g, complementary paratransit service does not have to be
provided if individuals have been travel trained and are able to
use part of the fixed route service. The application form should,
therefore, include a question that asks if the person has received
travel training. For example:
Have you ever had to use the regular buses (or the subway)?
_____ No _____ Yes _____ In process
If yes or in process, from which agency?
_____________________________________________________________
If you completed this training and are able to use certain bus
routes (subway lines), please list them below:
1. ______________________________
2. ______________________________
3. ______________________________
4. ______________________________
The eligibility determination process provides an excellent
opportunity to determine if applicants could benefit from travel
training, to make them aware that training is available (or may be
made available), and to ask if they would be interested in
receiving training. Consider adding a question that describes what
training is available and asks if the applicant would be interested
in learning more about the program. For example:
The (name of transit provider) has available a program that
can provide you, free of charge, with professional training on
how to use the bus (subway) system. If you are interested in
learning more about this program, please indicate this below
or call (phone #) .
_____ Yes, I would be interested in learning more about
the travel training program
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If travel is an important part of the overall strategy to serve
persons with disabilities, it may be useful to obtain information
about the possible benefits of travel throughout the form.
Examples of how questions on travel training can be integrated in
several parts of the form/assessment, see the material developed by
Seattle Metro (Appendix I) and the forms developed by the Regional
Transportation Authority of Chicago (Appendix
Other Service Information
The application process also provides an opportunity to get
important travel information for later use in daily operations.
For example, questions can be added to determine:
- If the-person is able to use a standard taxi. This could be
important if part of the service is provided through a
contract with a local taxi company;
- If the person currently uses the fixed route service or if
they used it in the past. If the person tried to use the
service but stopped, it may be useful to determine why. There
may have been equipment issues or policies that did not meet
their needs. They may not be aware that current service can
meet their travel needs.
- If the person can travel from their place of residence to the
nearest stop/station. A large percentage of a person's trips
originate and end at the home. Determining if applicants can
get to and from the fixed route service from their place of
residence can help in making trip-by-trip eligibility
determinations.
- The most frequent destinations to which the applicant travels.
Again, this information can be helpful in making trip
eligibility determinations.
Administrative Information
Finally, the form may need to include reference(s) for
professional(s( that can be contacted for additional information, a
release to request this information, and other administrative
items.
At the end of any form completed by the applicant, space should be
provided for the applicant's signature. A statement should proceed
the signature indicating that the person has provided true and
accurate information and noting any consequences that may be
associated with the provision of false information. Following is
an example of language that could be used for this purpose:
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I hereby certify that the information given above is true and
correct. I expressly acknowledge that the (transit provider) will
rely upon the information contained herein in making a
determination as to my eligibility to participate in the program.
I agree that if any of the information given to the (transit
provider) is materially false or misleading, the (transit provider)
shall have the right to reconsider my right to participate in the
paratransit program, m addition to pursuing any other right or
remedy which the (transit provider) may have under the
circumstances.
Signature __________________________________________
Date___/___/___
If the form or a part of it must be completed by the applicant, it
is also important to determine if another person assisted the
applicant with the completion of the form. This other person can
then be notified, in addition to the applicant, about the final
determination or if additional information is needed. For example,
the following question can be included:
If this application form has been completed by someone other than
the person requesting certification, that person must complete the
following:
Name: _____________________________________________
Address: __________________________________________
City: _____________________________
State: __________ Zip code: __________
Phone: ________________________
Relationship to Applicant: __________________________
Request for Professional Reference(s)
If a "self-certification with professional verification as needed"
process is used to determine eligibility, the application form must
include a request for the name of a professional who can be
contacted for additional information about the person's disability
and travel capabilities. As noted in Section 2 of this Chapter, it
may be helpful to direct applicants to identify professionals who
are familiar with their ability to use the fixed route service.
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Following is an example of the type of language that could be
included in this section of the application to direct the
identification of professionals:
In order to allow the (name of transit provider) to evaluate
your request for ADA paratransit eligibility certification, it
may be necessary to contact a health care or rehabilitation
professional for additional information about your disability
and ability to use regular bus service. Please complete and
sign the following authorization.
Note: It is important that, if possible, you identify a
professional who is familiar not only with your particular
disability but who also understands your ability or inability
to travel on the public transit system. This could include:
____ a rehabilitation specialist
____ an occupational or physical therapist
____ an independent living counsellor
____ a vocational rehabilitation counselor
____ a social worker
____ a physician or registered nurse
____ a psychologist
____ a mental health counselor
I authorize the following professional to release to the (name of
transit provider) information about my disability and its affect on
my ability to travel which may be needed in connection with my
request for ADA paratransit eligibility certification. It is my
understanding that the information released will be used solely to
determine my ADA paratransit eligibility. I understand that I may
revoke this authorization at any time. Unless earlier revoked this
form will permit the professional listed to release the information
described until 60 days after the date appealing below.
Name of Professional: ____________________________
Street Address: __________________________________
City/Town: _______________________________________
State: __________ Zip code: ____________
Telephone Number: ________________________
Applicant's Name: ________________________________
(PLEASE PRINT)
Applicant's Signature: ____________________________
Date: ____________________
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Professional Verification Form
If the eligibility determination process selected includes
obtaining information from a professional, a "Professional
Verification Form" will need to be developed. As noted in Section
2 of this chapter, professional verification can be obtained as
needed or can be requested as part of the initial application. It
is also possible to contact identified professionals by phone
rather than in writing. Even if contact is by phone, it is
recommended that a standard form be prepared for use by staff or
contractors collecting the information.
If the professional verification form is sent separate from the
standard application material, it should include basic information
about ADA paratransit eligibility and the purpose of the request.-
This introductory information should also indicate that the
applicant has authorized the release of records pertaining to their
disability and functional capabilities. A copy of the release form
signed by the applicant can also be included. If the professional
verification is part of the application form, this information
should be provided for both the applicant and the professional.
As noted in Section 2 of this chapter, verification forms should
not be used solely to request a definitive opinion as to the
applicants eligibility. It should be clear that the information
requested will be one element in the determination made by the
transit provider's staff or contractor. Instead, professionals
should be asked to verify the disability claimed by the applicant,
the extent of this disability, and for functional assessments as to
the applicant's ability to perform activities related to using
fixed route transit service. If a general opinion is requested, it
should be supplemented by more specific questions about the
applicant's disability and capabilities.
Professional verification will be particularly important in cases
where applicants have claimed a "hidden" disability or a medical
condition such as a cardiac or pulmonary condition, mental illness,
or a joint disease. Verification will also assist in determining
the extent of a sensory impairment (e.g., level of vision or visual
acuity) or the degree of cognitive capability.
Several sample professional verification forms are contained in the
appendices to this manual. A verification form used by the
Delaware Administration for Specialized Transportation (DAST) which
is part of the initial application (a "self-certification and
professional verification" process) is provided in Appendix K. A
verification form used by the Worcester Regional Transit Authority
which is sent by the WRTA separate from the initial application is
provided in Appendix H.
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Section 5. Reviewing Applications and Making Determinations
Pre-Tests of Materials
Before formally initiating the eligibility process or broadly
distributing application materials, it is strongly recommended that
a pre-test be conducted using draft materials. Request the
assistance of members of the advisory committee who have not been
closely involved in the development of materials. Ask local human
service agencies if they would be willing to have clients complete
a few forms. Be sure to have draft materials completed by persons
with different types of disabilities. Requesting the assistance of
a local independent living program may be an effective way to
obtain information from a full cross-section of the population.
Collect the completed test materials and have the staff or third-
party agency that will be responsible for reviews go through the
process of making determinations. Have them note if they are
getting adequate information to make thorough determinations. Also
talk with individuals and professionals who have completed the
draft forms to see if they fully understood the directions and
questions.
Such a pre-test can provide valuable insights and result in
important revisions to materials before full-scale certification or
recertification is undertaken.
Regulatory Review Timetable and Presumptive Eligibility
Determinations of eligibility should be made within 21 calendar
days of the submission of a completed application form. If a
determination is not made by the 21st day, the applicant must be
treated as eligible and paratransit service provided on a
presumption of eligibility until the review is completed.
Unconditional service must be provided during this period of
presumed eligibility unless the applicant has specifically
requested conditional eligibility.12
In the case of a self-certification with professional verification
as needed process, the calculation of the 21 day period would
commence when the applicant submits requested information including
the name of a professional who can be contacted. Follow-up
information requested by the transit provider and provided from the
professional would be considered part of the 21 decision period.
In the case of self-certification with required professional
verification, an application would be considered complete only if
all
___________________________
12 If the application includes a question or questions that
enable the public entity to determine that the applicant can
use the fixed route system (for example, the person can use
accessible vehicles), then presumptive eligibility can be
conditioned based on this information. If such a partial
determination is made, the applicant must be notified in
writing of the conditions of their presumptive eligibility and
must be given an opportunity to appeal.
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information, including information required of a professional, is
provided. For processes that involve in-person assessment, the 21
day period would begin when the person fulfills established
requirements for requesting that an assessment be conducted. This
could be a telephone request or could involve the completion of a
brief request for determination form.
Establishing a Management Information System to Track
Determinations
To ensure that reviews are handled expeditiously and that they are
referred to the appropriate person or agency as needed, transit
providers should establish a management information system to track
applications as they go through the process.
The first step in establishing this system is to determine all
possible actions that could be required given the determination
process selected. To do this, work back from the regulatory limit
of 21 days to determine when each of these actions would need to be
completed in order to complete the review in the required time.
Develop a flow chart or outline that summarizes the timing of
required actions for use by all staff involved in tracking or
reviewing applications. Figure 5 provides an example of such a
chart developed by the Commonwealth of Virginia in their guide on
ADA paratransit eligibility.13
A system for tracking each application, according to the
established timetable, should then be established. This could be
accomplished by attaching a cover "tracking" sheet, which includes
the date of receipt and the subsequent date of each required
action, to each application. The date which is 21 days from the
date of receipt should be added to the tracking sheet to alert
reviewers to the target completion day. The tracking sheet should
also include information and dates which pertain to the appeal
process.
A master file should then be maintained which includes critical
dates from each individual tracking sheet. This file will provide
information on overall progress as well as indicate which reviews
have exceeded the maximum allowed determination times (21 days for
initial reviews and 30 days for appeals). Information about the
applicants who will then need to be treated as eligible can then be
transmitted to the service operator(s).
In larger transit systems, it may be necessary to utilize a
computerized database system or other automated tracking system.
One alternative is to use software developed for the human resource
field to log and track job applications. Seattle Metro has
customized software developed by Sigma to track ADA applications
and determinations. In addition to accurately tracking progress in
making determinations, the software allows Metro to print reports
that include key information such as the number of applications
received, the number in each stage of review, and a breakdown of
determinations by type of finding (e.g., conditionally eligible,
Unconditionally eligible, ineligible, etc.). Information about the
Seattle tracking system is contained in Appendix N.
___________________________
13 CGA Consulting Services, Inc., EG&G Dynatrend, Katherine
McGuinness and Associates, Inc., ADA Paratransit Eligibility:
A Guide for Virginia Transit Systems for Complying with the
Americans with Disabilities Act of 1990, prepared for the
Virginia Department of Rail and Public Transportation, July 1,
1992.
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Developing Reviewer Guidelines and Maintaining Consistency in
Reviews
Transit providers should develop reviewer guidelines and final
evaluation forms to assist reviewers in properly interpreting
answers and information provided by applicants and/or
professionals. Guidelines and forms can also help to ensure
consistency in the determination process. As mentioned in Section
3 of this chapter, reviewer training is also recommended. Ensuring
consistency in the review process is particularly important if
determinations will be conducted by several different individuals.
A number of transit agencies have developed evaluation forms which
are correlated with the information requested in the application
forms. These evaluation forms ask the reviewer to draw conclusions
from answers provided by applicants and/or professionals to
particular questions. Depending on the responses provided, certain
eligibility findings are suggested. For example, if an applicant
indicates that she/he can usually travel independently up to half a
mile but cannot negotiate in snow and ice, conditional eligibility
based on distance from stops/stations and times of the year could
be granted. Similarly, applicants who note that they use
wheelchairs would automatically be eligible when they travelled on
routes not yet fully accessible.
Several examples of this type of summary evaluation form are
contained in the appendices to this manual. Of particular note are
forms developed by the Washington Metropolitan Area Transit
Authority (see Appendix J), the Worcester Regional Transit
Authority (see Appendix H), and San Mateo County (see Appendix E).
Applications which use closed/multiple-choice type questions, such
as the WMATA application, can be more directly correlated to
particular types of eligibility. More open ended questions will
require the reviewer to draw a conclusion from the information
provided.
Other suggestions for ensuring consistency and for building
important checks into the determination process include:
- Consider having reviewers double-check with supervisors or
other review staff if a determination of ineligibility or
conditional eligibility is being recommended. This type of
confirmation and reinforcement may help reduce inappropriate
findings and will be helpful if an appeal is requested.
- If several individuals are involved in making determinations,
have them periodically exchange applications and compare
findings. If there are differences in the recommendations
that would be made, encourage general discussion on key issues
and incorporate the results of this discussion in updated
reviewer guidelines.
- Conduct random post-determination checks of findings. This
may be particularly important if third-party contractors are
utilized for determinations. Have staff who are
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familiar with ADA paratransit eligibility review the complete
file, including,the application form and related information
and the final eligibility determination. Such administrative
reviews will be an important part of the management of the
determination process and will provide valuable insight needed
to revise existing materials or strengthen reviewer training
programs.
Observing Privacy Rights
The medical information that may be gathered as part of the ADA
paratransit eligibility certification process should not be shared
with any other party. This would include specific diagnosis
provided by professionals and information about the nature of
disabilities provided by the applicant. Access to eligibility
files should be limited and those with access to these files should
be informed and instructed to respect the privacy of applicants.
This should include 'M-house staff as well as any third-party
contractors used in the determination process.
Information regarding a person's functional ability to use fixed
route service, derived from the determination process can, however,
be shared with other transit providers. Other entities may call to
obtain more detailed information about a person's ability to travel
if that person has requested service in another area as a visitor.
Recent Certification Experiences of Selected Providers
Table 3 on the following pages provides general information about
the outcome of determinations conducted by selected transit
providers to date. Information about the percent of applicants that
have been determined ineligible, the percent determined
conditionally eligible, and the number or percent of appeals of
determinations is given.
As shown, the general experience to date has been that relatively
few applications are denied outright. Approximately half of the
systems which had this information reported a denial rate of less
than 3 percent. Several systems reported denials of between 7 and
15 percent. In general, it was the opinion of these transit
providers that very few individuals were attempting to obtain
certification inappropriately. It was reported by several
providers that a significant number of those persons determined
ineligible had misunderstood the nature of ADA paratransit
eligibility. This general sense is supported by the fact that,
typically, very few appeals are requested. Many individuals
verbally question the final decision but are satisfied with the
explanation given once they better understand the nature of the
determination.
Some of the variance may also be explained by differences in pre-
ADA eligibility policy. Transit providers which previously used a
functional eligibility criteria close to that established in the
ADA have had relatively few ineligible determinations as most
existing riders were eligible. This was noted by both the Ann
Arbor Transportation Authority and
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___________________________
14 The ann Arbor Transportation Authority noted that the low
percentage of applicants determined ineligible was due mainly
to the fact that, prior to the ADA, they had used a
functionally-based eligibility criteria that was similar to
what is now used.
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ADA Paratransit Eligibility Manual
Ben Franklin Transit. Agencies which had broader criteria in the
past might expect a higher rate of ineligible determinations.
There appears to be greater variance in the percentage of
applicants being granted conditional rather than unconditional
eligibility. Several systems reported that their initial
determinations have not focused on conditions of eligibility.
There is even a considerable range among those systems that are
doing a more detailed identification of limitations/conditions of
eligibility. The percent of applicants certified as eligible under
particular conditions ranges between 20 percent and 75 percent.
Some of this variance is probably attributed to whether or not the
transit agencies intend to rely on trip-by-trip eligibility
determinations to manage demand.
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Section 6. Notifying Individuals of Initial Determinations
Applicants must be notified of initial eligibility determinations
in writing. Efforts must also be made to provide this notification
in a format that the individual is able to use and in a way that
ensures effective notice. For example, as noted in Section 4 of
this chapter, consider including a question in the application form
which identifies whether the applicant needs to have information
and correspondence provided in accessible formats. If so, notice
of the initial finding should be provided in the requested format.
Also, include a question in the application which identifies
whether the form has been completed by someone acting on behalf of
the applicant. If so, send the notice of initial determination to
this person as well as to the applicant.
If the initial determination finds that the applicant is
ineligible, specific reasons for this finding must be included in
the notification letter. Simply including a general statement that
the person "is able to use the fixed route service" and is
therefore not eligible for paratransit service is not acceptable.
Reasons cited should relate directly to information contained in
the application, obtained as part of the professional verification
process, or derived through an assessment of the individual. For
example, specific reasons for a finding that a person is not
eligible might be stated as follows:
- "The particular reason included in the application for why you
could not use regular bus service was that you are unable to
independently travel distances greater than 1/2 mile to get to
or from bus stops. Your diagnosis of disability, provided by
the professional named in the application, did not, however,
indicate a disability that limits your ability to
independently travel throughout the full service area."
- "Your application indicated that you do not feel safe
traveling on the regular bus and subway system. While the
possibility of an incident occurring while traveling may be a
factor in your decision to use available public transit
service, it is not a reason, in and of itself, which requires
that separate van service be provided.
Similarly, if the initial determination is that the applicant is
eligible for paratransit services under certain conditions, the
reasons for limiting eligibility should be explained in the
notification letter. For example, a person may be determined
eligible but may have indicated that they have been travel trained
for daily trips that they make to work. The letter of notification
should, therefore, state that the person is ADA paratransit
eligible with the following limitation:
- "Trips to your current work site from your current place of
residence are not ADA paratransit eligible as you indicated in
the in-person assessment that you have received instruction in
the use of the regular bus service to make this particular
trip."
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If strict control of travel with personal care attendants is an
important consideration, consider noting any limitation on travel
with PCAs directly in the notification letter. For example, if the
application or assessment includes a specific question about the
need for a PCA, a condition of eligibility that should be noted for
all applicants that PCAs are not required could be:
- "As stated in the application (noted in the assessment),
travel with a personal care attendant is not required."
The notification letter should also contain information about the
appeal process that is available if the initial determination is
that the person is not eligible or if limitations are placed on the
person's eligibility. Individuals must be able to question
limitations of eligibility as well as findings of ineligibility in
general. A copy of the appeal policy, noting the procedure for
requesting appeals, the number of days within which appeals must be
requested, and other aspects of the policy should be attached to
the letter.
Individuals determined ineligible or eligible with certain
condition(s) should also be apprised of the fact that they can
reapply should their situation or disability change.
As noted in Section 7 below, many transit providers also use the
notification letter as formal documentation of ADA paratransit
eligibility. Others use it as an opportunity to promote specific
incentive programs that encourage use of the fixed route service.
In Los Angeles, for example, persons who are determined
conditionally eligible are informed that their ADA paratransit
eligibility documentation also serves as an identification card for
a reduced fixed route fare.
As part of the development of the eligibility determination
process, several form letters should be developed. Separate
letters should be developed for those determined unconditionally
eligible, conditionally eligible, ineligible, and temporarily
eligible. Additional letters may be needed if you combine ADA
paratransit eligibility determination with other processes such as
eligibility for other paratransit services. Sample letters of
determination are provided on the following pages.15
___________________________
15 Letters are adapted from ADA Paratransit Eligibility: A Guide
for Virginia Transit Systems for Complying with the Americans
with Disabilities Act of 1990, prepared for the Virginia
Department of Rail and Public Transportation by CGA Consulting
Services, Inc. in association with EG&G Dynatrend and
Katherine McGuinness and Associates.
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SAMPLE DETERMINATION LETTER - UNCONDITIONAL ELIGIBILITY
DATE
NAME
ADDRESS
CITY, STATE ZIP
Dear
Based upon a review of your application for certification of ADA
paratransit eligibility, the (name of Transit agency) - has
determined that you are eligible for ADA paratransit service for
any trip in our service area. This determination also enables you
to use similar paratransit services nationwide.
This certification of eligibility is valid until. (expiration date)
. You will automatically receive a recertification form in the
mail so that you can reapply at that time.
Attached is your identification card. Please carry it with you at
all times. The identification number contains important
information regarding your functional capabilities and requirements
and must be given whenever you make a trip request.
Also attached is a Rider's Manual which provides important
information about the ADA paratransit service. It also describes
how to use the service. Please read it carefully.
If you have any questions about the service, or need any other
assistance, please feel free to call the paratransit service office
at (phone)___________ (TDD)____________ (FAX) _____________.
Sincerely,
Enclosures: ADA paratransit eligibility ID Paratransit Rider's
Manual
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SAMPLE DETERMINATION LETTER - CONDITIONAL ELIGIBILITY
DATE
NAME
ADDRESS
CITY, STATE ZIP
Dear
Based upon a review of your application for certification of ADA
paratransit eligibility, the (name of Transit agency) has
determined that you are eligible for ADA paratransit service when
one or more of the following conditions exist:
(1)
(2)
(3)
This determination also enables you to use similar paratransit
services nationwide.
The above conditions may be used by (name of transit agency) to
determine if and when you may be able to use the regular bus/rail
service. If you can use these services, federal law does not
require that paratransit service be provided. You are encouraged
to use the regular bus/rail service whenever possible.
If you do not agree with the limitations that have been placed on
your eligibility, you have the right to appeal this determination.
Any request for an appeal must be made in writing and must be
mailed within 60 days of the date of this letter. The enclosed
description of the appeal policy provides additional information
about the process.
This certification of eligibility is valid until (expiration date)
You will automatically receive a recertification form in the mail
so that you can reapply at that time. Please note that you may
also reapply at any time if you feel that changes in your ability
to use the regular bus/rail service could affect this
determination.
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NAME
DATE
PAGE -2-
Attached is your identification card. Please carry it with you at
all times. The identification number contains important
information regarding your functional capabilities and requirements
and must be given whenever you make a trip request. Also enclosed
is a Rider's Manual which provides important information about the
paratransit service. Please review it carefully.
If you have any -questions about the service, or need any other
assistance, please feel free to call the paratransit service office
at (phone) (TDD) (FAX)
Sincerely,
Enclosures: ADA paratransit eligibility ID Paratransit Rider's
Manual Description of appeal policy
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SAMPLE DETERMINATION LETTER - INELIGIBLE
DATE
NAME
ADDRESS
CITY, STATE ZIP
Dear
Based upon a review of your application for certification of ADA
paratransit eligibility, the (name of Transit agency) has
determined that you are not eligible for ADA paratransit service.
This determination is based on the following factors:
(1)
(2)
(3)
Federal law restricts eligibility for ADA paratransit service to
persons who cannot, due to a disability, utilize fixed route
transit service (regular bus/rail service). This determination
applies only to your eligibility for ADA paratransit service
offered by (name of transit agency).
We would encourage you to use the fixed route service and hope you
will become a regular customer. For that reason, we have enclosed
information about the bus/rail service and a complementary monthly
pass to encourage you to find out just how convenient our services
really are. You can also call our customer information office for
assistance in planning trips. That Number is (phone)_____________
(TDD) _____________. We hope to have you as a customer often.
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NAME
DATE
PAGE -2-
If you do not agree with the decision that has been made, you have
the right to appeal this determination. Any request for an appeal
must be made in writing and must be mailed within 60 days of the
date of this letter. The enclosed description of the appeal policy
provides additional information about the process. Please also
note that if there is any change in your ability to use the fixed
route service in the future, you may submit a new application.
Sincerely,
Enclosures: Complementary monthly pass Regular bus/rail service
information Description of appeal policy
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Section 7. Documentation of ADA Paratransit Eligibility
ALL persons determined eligible must be provided with documentation
stating that they are "ADA Paratransit Eligible". The following
information is required by the regulations to be part of the
documentation provided:
- the name of the eligible individual
- the name of the transit provider making the determination
- the telephone number of the transit provider's paratransit
coordinator
- an Expiration date for eligibility (if applicable)
- any conditions or limitations on the individual's eligibility
including the use of a personal care attendant.
As indicated, an expiration date is necessary if recertification
will be required at some future date. The regulations allow such a
recertification at "reasonable intervals". For a more complete
discussion of recertification, see Section 2 of Chapter 2 of this
manual.
The "telephone number of the transit provider's paratransit
coordinator" should be the number at which eligibility can be
confirmed and specific information about the individual's
functional ability to travel and any limitations or conditions of
eligibility can be obtained. This requirement is meant to
facilitate the exchange of specific eligibility information between
transit providers. The number listed could be for the office which
oversees determinations and maintains eligibility files, the system
broker, or the service operator, depending on where this
information is kept and is most readily available.
Documentation can be provided in the form of an identification
card, as part of the notification letter, on standard paper, or in
other forms as long as the information required is included. It is
also possible to provide detailed documentation in a letter or on
standard paper and to supplement this with an I.D. card that
contains more cryptic information. For example, the detailed
documentation may describe conditions of eligibility and the
reasons for such conditions as detailed in Section 6 above. The
I.D. card, for obvious reasons of space, may include concise
statements of limitations such as "can use accessible vehicles", to
"seasonal eligibility May through September" or "Requires PCA?
__X__ Yes _____ No"
When deciding on the type of documentation to be provided, take
into consideration the ease of use by persons with disabilities.
An I.D. card may be more durable and easier to carry by persons who
will be traveling frequently to other transit districts. If the
standard form of documentation provided is a letter, consider also
offering a laminated I.D. which can be obtained by those who desire
it.
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Also consider current and possible future uses of the documentation
that is provided. For example, if ADA paratransit eligibility
documentation will also be used to provide reduced fare access to
fixed route services, an I.D. card should be considered.
Similarly, if a user side subsidy program is used to provide
service or to supplement basic paratransit service, and I.D. card
may be required.
If the documentation will have a cash value (e.g., will be used for
fare discounts, etc.) consideration should also be given to
security and fraud issues. Typically, a photo I.D. is used and a
"security seal" is incorporated. Figure 6 below offers a sample
format for a photo I.D.
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Section 8. Appeals Procedures
Individuals who are determined to be either ineligible or
conditionally eligible must have an opportunity to appeal the
initial decision. As noted in Section 1 of Chapter 2 of this
manual, the regulations include a number of specific requirements
related to this appeal process. These are:
- An individuals must be able to request an appeal for within 60
calendar days of the denial of their initial application;
- An individual must have an opportunity to be heard in person
to present information and arguments;
- There must be a "separation of function" between those
involved in the initial determination and those deciding
appeals;
- Written notification of the appeal decision, stating the
reasons for the finding, must be provided; and
- Presumptive eligibility must be granted to the individual if a
decision is not made within 30 days of the completion of the
appeal process.
As indicated in Section 6 of this chapter, written notification to
applicants determined eligible or conditionally eligible should
include information about the appeal process. This information
should indicate how to file an appeal and what they can expect if
they request an appeal. One way to provide complete information
would be to enclose a copy of the full appeal policy with the
notification letter.
Transit providers can require that appeals be requested in writing.
Accommodation should be made, however, for individuals with vision
impairments who may not be able to independently communicate in
written form. Providers may also request that reasons for
requesting an appeal be detailed by individuals. Some transit
providers have people with different knowledge and specialties hear
appeals depending on the individual's particular type of
disability. Information about the reason(s) for the appeal may be
helpful in structuring the process. The absence of such detailed
information cannot, however, be used to preclude the scheduling of
an appeal hearing. Individuals must still be given the opportunity
to be heard in person, even if they decide not to provide written
arguments in advance.
As noted above, appeals must be able to be requested within 60
calendar days of the denial (or the limiting) of an individual's
request to be determined ADA paratransit eligible. This 60 day
period should be calculated from the time that the person is
notified of the initial decision. There are several ways to
administer the process to ensure that a full 60 days have been
allowed for appeal. These include:
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(1) Sending notice of initial determinations by registered mail
and then calculating the time between certified receipt and
the date that the appeal request is received;
(2) Adopting a policy that allows appeals to be filed for a period
somewhat longer than 60 days from the date of the notification
letter (e.g., 65 days) to account for time in the mail;
(3) Calculating the period of time based on the date stamp on both
the notification letter and the appeal request.
Once a request for an appeal has been made, a hearing date should
be established and the applicant should be provided with adequate
written notice (in accessible formats if appropriate). The notice
should ask what accommodations may be needed (such as an
interpreter) and could request that adequate notice of the need for
these accommodations be provided. In many areas, one or two weeks
may be needed to arrange for interpreter services.
A critical factor in ensuring that the individual is afforded "due
process" is the separation of function between those involved in
the initial determination and those hearing appeals. To the extent
practicable, appeals should not be heard by individuals in the same
office as those responsible for initial determinations. Similarly,
if practicable, appeals should not be heard by subordinates or
supervisors of staff responsible for initial decisions. Such a
daily working relationship could bias those hearing appeals.
If appeals are heard by a committee rather than an individual,
person(s) involved in the initial decision should not sit as voting
members on the committee - even if they do not constitute a
majority of the committee members. It may be desirable to have
those involved in initial determinations available at hearings to
provide information and reasons for the initial finding, but they
should not have a formal say in any appeal decision.
The regulations recognize that the degree of separation of function
may be less in smaller transit systems. With limited staff, all
employees may have a daily working relationship. In these cases,
if the appeal process is kept in-house, efforts should be made to
ensure that the person(s) hearing appeals have not been involved in
the original decision in any way and do not discuss appeals with
initial decision makers prior to the hearing. It is also
recommended that there be an elevation of authority between the
initial decision and the appeal. Supervisors should hear appeals
rather than subordinates to avoid the obvious influence that
superiors hold over those they manage. To establish a clear
"separation of function", transit providers both small and large
should consider involving individuals from outside the agency in
the process.
Those responsible for making the appeal decision must be present at
the hearing. It would not be acceptable, for example, to have a
person appear before an advisory committee that makes a
recommendation to the transit provider. Having the decision
maker(s) hear firsthand the issues and the person's argument is an
inherent part of the right to be heard "in-person".
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The appeal must be more than an administrative review of the
initial determination. In addition to ensuring that the approved
policy was followed, the appeal must also review the judgement(s)
made regarding the individual's eligibility in the initial
determination. The appeal should be based on additional
information provided prior to or during the hearing as well as on
information contained in the original application. For this
reason, the process should allow those involved in deciding appeals
to have access to all pertinent information and adequate time to
review file documentation.
As with the initial notification, the appeal finding must be
communicated in writing and must include specific reasons for the
decision. A simple statement that the person can use fixed route
service or a statement that there was agreement with the original
decision is not sufficient. The written decision should relate to
the additional information provided (or lack thereof) and why these
additional facts, combined with the information in the initial
application, support the finding made.
While the regulations establish a maximum time for deliberation on
an appeal before presumptive eligibility must be granted, they do
not set a maximum time for the holding of a hearing following the
receipt of an appeal request. The amount of time that is required
to bring appeals to a hearing will depend on the number of appeals
received and the appeal structure selected. In keeping with the
general principle of due process, transit providers should schedule
and conduct hearings as soon as is administratively possible within
the constraints of the established process. The public, including
persons with disabilities, are required to have input into the
appeal policy that is established. The expeditious handling of
appeals should be one factor considered in the creation of the
policy. Hearings that involve a large independent appeal panel, or
a panel that relies solely on volunteers, may be more difficult to
schedule or may be able to meet less frequently.
Structuring an Appeal Process
Appeals can be heard by single individuals or by panels comprised
of several persons. Within the basic requirements for a
"separation of function" detailed above, appeals can be decided by
persons from other offices or divisions within the agency, by
persons from other agencies, by rehabilitation or medical
professionals, by consumers, or by a panel comprised of persons
from several of these groups.
Regardless of the size or make-up of the appeal "panel", several
factors should be considered when structuring the process. First,
it is vital that the process not only is but is perceived as being
objective and unbiased by individuals with disabilities and the
agencies representing them. The regulations require that the
process and policy be established with full public participation.
Suggestions made in this process should be carefully considered.
If there appears to be general distrust with an in-house process
(i.e., both initial decisions and appeals are decided by transit
provider staff or representatives), serious consideration should be
given to outside, independent representation in the process.
Transit providers should avoid the temptation to want to "control"
the process, the decision makers involved, or the
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findings made. Public trust in the objectivity of the process will
help to avoid costly legal action and equally costly public
skepticism.
Second, individual(s) involved in appeal decisions should possess,
either individually or collectively, certain knowledge and skills.
Among these are:
- a working knowledge of the ADA complementary paratransit
regulations, particularly the regulatory definition of ADA
paratransit eligibility and the appeal process;
- an understanding of different types of disabilities and the
functional capabilities characteristic of each;
- a knowledge of the fixed route system and the skills needed to
understand and use it; and
- an understanding of the complementary paratransit service and
the policies and procedures related to the service.
Not all individuals need to be expert in all areas listed above.
Many transit providers have structured their appeal panels to
include several persons, each with particular knowledge. Training
should be provided to appeal decision makers to augment the
knowledge that they bring to the process. Individuals from outside
the transit agency will need to be educated on the specifics of the
ADA and the fixed route and paratransit services that are provided.
Information on existing services should include the latest policies
and equipment used (such as the level of operator assistance
provided, allowing standees on lifts, mobility aid restraints, and
lift specifications) as these will affect their understanding of
the capabilities needed to use the service. Individuals
representing the transit agency, on the other hand, may need
training on types of disabilities and their effect on travel.
Transit providers may also want to consider utilizing different
appeal decision makers depending on the disability of the
applicant. A pool of available panel members with different
specialties could be created. Panel members could then be called
to attend a hearing if the applicant has reported a disability
similar to their area of expertise. Professionals specializing in
mental retardation, vision impairments, physical disabilities, etc.
would be included in the process as needed.
Third, the ability of the structure selected to handle the expected
number of appeals in an expeditious manner should be considered.
Large panels may provide representation but may be difficult to
schedule on a frequent basis. In addition to the ease of
administration, consideration should also be given to the level of
effort being requested from panel members, particularly if they are
expected to volunteer their time. If a large number of appeals is
expected, consideration should be given to creating a pool of
available panel members and establishing a rotating schedule.
Finally, regardless of the structure selected, consider the
liability which individuals may be incurring by participating in
the appeals process - particularly if they are consumers or
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volunteers who may not be covered by insurance which a contractor
or medical professional may have. Consider providing professional
liability insurance to these individuals, either through a separate
policy or by adding them to a policy which may already exist.
Table 4 on the following pages provides information about the
appeal processes used by selected transit providers across the
country. As can be seen, a wide variety of structures are used.
In a number of instances, appeals are heard by employees of the
transit agency who are not involved in the initial decision.
Seattle Metro, which uses a third-party contractor for the initial
review, uses other employees at this organization for appeals. The
LACMTA in Los Angeles, which also uses third-party contract
reviewers, uses a higher level professional for the appeal. For
example, if an occupational therapist conducted the initial
assessment, a physiatrist may hear the appeal.
Several transit providers utilize appeal panels of between three
and seven members. In some cases, panel members are selected based
on their familiarity with the applicant's particular disability.
In other cases, panels are structured to have members who are each
familiar with a specific type of disability.
Ben Franklin Transit works with the applicant to select panel
members that are mutually agreed upon by both parties. The
Regional Transportation Authority of Chicago has established a
three-person Eligibility Review Board. One standing member is
selected by the RTA and the other by its consumer advisory group.
The third member is chosen by these standing members. SEPTA in
Philadelphia has established a panel of three members plus one
alternate who each serve two-year staggered terms. SEPTA and its
consumer advisory committee share in the selection of these
members. TARC, in Louisville, has established eight appeal panels
so that appeal hearing responsibilities can be shared and will not
become burdensome on any one panel.
It is also interesting to note that several transit providers have
established more than one level of appeal. A number of the
agencies contacted use an informal review process if applicants
verbally request an explanation of the decision. A more formal
appeal is available if the applicant desires. Six of the agencies
contacted have more than one level of formal appeals. OMNITRANS
works with a private, non-profit mediation board and offers
applicants an opportunity to obtain a non-binding recommendation
from this board at any time during the process. The formal appeals
process is also available.
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Table 4. Descriptions of Appeal Procedures for Selected Transit
Providers
Name of Transit Provider Person or Panel that Hears Appeals
Ann Arbor Transportation 1 st : Paratransit Coordinator
Authority 2nd Appeal: Executive Director
Ann Arbor, NH
Ben Franklin Transit (BFT) Panel of three people mutually agreed
Richland, WA upon by the applicant and BFT.
Panel to consist of two people
from the community familiar with the
applicant's disability and one person
from BFT.
City of Charlotte Three person panel (Independent
Charlotte, NC Living Center staff person, Transit
Agency staff person, and one person
from the City Manager's office)
City of Durango, CO Transit Advisory Board
Delaware Administration for 1st: Paratransit Administrator
Specialized Transportation 2nd Appeal: Paratransit Advisory
(DAST) Committee Dover, DE (comprised of
consumers and disability
organizations)
Greater Bridgeport Consumer Advisory Committee
Transit District (20 people)
Bridgeport, CT
Greeley, CO General Services Manager of City DPW
Lane Transit District Informal Review: If verbal questions
Eugene, OR by applicant, informal review by
paratransit coordinator. Formal
Appeal: If formal appeal Committee (5
person: Director of group homes; two
persons with disabilities; transit
district representative; ad hoc
person selected by applicant).
Los Angeles County Higher level professionals
Metropolitan appropriate to the type
Transportation Authority of disability (such as physiatrists,
Los Angeles, CA doctors, psychiatrists) under
contract to the Authority. Cost is
$60/appeal review.
Madison Metro Transit System 1st Appeal: To general manager
Madison, WI 2nd Appeal: Four person panel
(paratransit/fixed route user with a
disability; city council
representative; city disability
commission representative; ADA
paratransit eligible senior.
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Table 4 continued
Name of Transit Provider Person or Panel that Hears Appeals
Municipality of Metropolitan Another professional staff person of
Seattle (METRO) the eligibility review contractor
Seattle, WA (Evergreen Medical Center) not
involved in the initial
determination.
New York City Transit Three person appeal board (medical
Authority professional familiar with
New York, NY applicant's disability; NYCTA staff;
consumer).
OMNITRANS Informal review: If applicant
San Bernardino, CA verbally questions the initial
decision, the determination is
reviewed by other OMNITRANS staff
person.
Formal Appeal: If appeal is formally
requested, it is heard by OMNITRANS
Board of Directors.
Supplemental Review: Third-party
mediation is available at any time
upon request of the applicant. The
recommendation, by the non-profit In-
land Mediation Board, is non-binding.
Oshkosh Transit System 1st Appeal: City transit director.
Oshkosh, WI 2nd Appeal: County Coordinating
Committee of Elderly and Handicapped
Transportation.
Port Authority of Allegheny 1st Appeal: Nine person panel
County (PAT); (orientation and mobility specialist
ACCESS Program for visually-impaired; mobility
Pittsburgh, PA specialist for mentally retarded;
consumer advisory committee member;
physical therapist; specialist in
cognitive disabilities; local
advocacy agency representative;
representative of area agency on
aging; two consumers).
2nd Appeal : Paratransit Director or
Assistant Director Regional
Transportation Authority
Informal Review: Voluntary informal
meeting.
Regional Transportation Informal Review : with RTA staff
Authority within 30 days of the initial
Chicago, IL determination.
Formal Appeal : Heard by a three-
person Eligibility Review Board. The
Board consists of two permanent
members, one selected by the RTA and
the other approved by the RTA's
consumer advisory group. The third
member is chosen for an individual
hearing by the two standing members
(from a list of persons with
expertise in the type(s) of
disability(ies) of the applicants.
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Table 4 continued
Name of Transit Provider Person or Panel that Hears Appeals
Riverside Transit Agency Another professional not involved in
Riverside, CA the initial decision at the medical
clinic which does initial
determinations.
San Mateo County Transit Three person panel (one person from
District (SAMTRANS) the ADA Technical Advisory
San Carlos, CA Committee, one health professional
from the community, and one SAMTRANS
representative)
Southeastern Pennsylvania Four people are selected (two by
Transportation Authority SEPTA and two by the consumer
(SEPTA) advisory committee) to serve on
Philadelphia, PA an appeal panel. All serve a two-year
term and terms are rotating. Three
panel members hear the appeal and one
serves as an alternate.
Transit Authority of Eight panels have been established to hear
River City (TARC) appeals. Each panel has three
Louisville, KY members; one with a visual impairment, one
with a physical disability, and one from
an agency representing persons with mental
impairments.
Utah Transit Authority 1st Appeal: Advisory Review Board (2 or 3
Salt Lake City, UT representatives from larger consumer
advisory committee.
2nd Appeal: Transportation Disabled
Advisory Committee (2 authority board
members, 2 local operator staff, 1-2
consumers).
Waukesha Transit System Transit System Board of Directors.
Waukesha, WI
Worcester Regional Transit Three person panel (occupational
Authority therapist; paratransit customer;
Worcester, MA independent living center
representative).
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Holding an Appeal Hearing
It is recommended that transit providers develop written guidelines
for conducting appeal hearings. These guidelines will provide
structure to the hearing and will ensure that the process is
consistent from one review to the next. Guidelines should indicate
the basic agenda and when and how the final decision will be
reached. For example, they could indicate that the hearing will
include:
(1) an introduction of panel members (if appropriate);
(2) an explanation of the appeal policy and the applicant's rights
to ensure that there is a clear understanding of process;
(3) a brief overview of eligibility policy to ensure that the
applicant has a clear understanding of key issues such as the
functional nature and trip-by-trip nature of ADA paratransit
eligibility;
(4) a summary of initial determination findings;
(5) an opportunity for the applicant and/or her representative to
provide additional information or dispute the initial
determination findings;
(6) an opportunity for the hearing officer or panel members to ask
the applicant or her representative questions; and
(7) the restatement of policy concerning a decision on the appeal
so that the applicant clearly understands what will happen
following the hearing.
In addition to the basic agenda, the guidelines might indicate who
will preside over the hearing (if a panel is involved) and who will
be responsible for making presentations at certain stages. If
large panels are involved, it may also be useful to specify in what
order questions will be asked or who will be primarily responsible
for responding to any questions asked by the applicant.
The issue of conflict of interest should also be addressed should
an applicant have a professional or personal relationship with a
decision maker. The basis on which decisions will be reached
(e.g., majority vote, etc.) also should be stated in the
guidelines.
Finally, because ADA paratransit eligibility can become the subject
of a civil rights complaint and ultimately be reviewed by the
courts, it is important that there be documentation of the
proceedings. It is not required or necessary to have hearings
transcribed, but documentation should be complete enough to capture
the essential issues raised and note that the established process
was followed.
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Section 9. Refusing, Conditioning, or Suspending Service
The regulations provide for the refusal, conditioning, or
suspension of complementary paratransit service only under
specific, defined conditions. These are described below. Local
policies regarding the refusal, conditioning, or suspension of
service should be developed with full public participation,
including the input of persons with disabilities.
Circumstances Under which Service Can be Refused
Section 37.5(h) of the regulations allows public entities to refuse
to provide fixed route or paratransit service to persons with
disabilities if they engage in "violent, seriously disruptive, or
illegal conduct. " This may include a person who assaults a driver
or another passenger, who smokes or drinks on the vehicle in
violation of established laws, or who engages in conduct that is so
severe that the delivery of service is seriously disrupted.
Conduct which is related to a person's disability and which annoys
or offends is not to be considered "seriously disruptive". The
interpretive appendix to the regulation uses the example of a
person with Tourette's syndrome who may make involuntary profane
statements. Such behavior would not be grounds to refuse service.
Similarly, service cannot be refused based on an unfounded fear of
a particular disability. For example, a person with I-UV disease
cannot be refused service because drivers or passengers are afraid
of being near and being exposed to the condition. On the other
hand, a person who refuses to use a seat belt and has a habit of
not staying seated during transport could distract the driver and
seriously disrupt service. Refusing service or requiring that the
individual ride with an attendant might be appropriate in such a
case. Similarly, customers are responsible for the behavior of
service animals. Service can be refused or conditioned if a
service animal is seriously disruptive.
In determining what constitutes "seriously disruptive" or "violent"
behavior, transit providers may want to rely on local ordinances.
Most communities have established laws and standards that define
unacceptable public behavior.
Accurate and correct information about various disabilities and
medical conditions is vital to ensuring that passengers are not
subjected to discrimination. For example, it may be necessary to
determine if a passenger's disability causes annoying behavior or
if (s)he is prone to violence. As suggested in Section 4 of this
chapter, information can be requested in the application form or
from a professional that will assist with making these decisions.
Follow-up with a professional identified by the passenger might
also be necessary to request further guidance on actual incidents.
This information should be available to operators of the service so
that they can respond appropriately to the person's disability.
The policies used in paratransit operation should also be
consistent with those established for
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the fixed route service. Policies should not be adopted solely for
the paratransit service unless the issue is unique to that mode.
If particular issues arise in paratransit operation, examine the
current general service policy and revise it for all types of
service if necessary. For example, an agency or parent may request
that paratransit service be provided to an infant or child with a
disability. If the transit provider had a policy for the fixed
route service that requires children under a certain age to be
accompanied by a parent or guardian, the same policy could be
applied to the paratransit service. Determination of the child's
ability to use the fixed route system could then assume the
assistance of a parent/guardian.
The period for which service is refused should also be consistent
between modes of service. For example, riders may be refused
service for a particular trip on the fixed route service if they do
not pay the fare. Similarly, paratransit service can be refused if
the fare is not paid. It would not be acceptable, however, to not
accept future trip requests on the paratransit service for a
previous lack of payment if this is also not the policy on the
fixed route system.
Circumstances Under which Service Can be Conditioned
In certain circumstances, it may be possible to mitigate the
effects of a person's conduct by requiring that they meet certain
conditions (e.g., use the service with an attendant). While the
regulation does not allow transit agencies to require attendants in
other cases, such a condition of use is permitted if the rider
would otherwise be refused service. In other words, transit
providers may place conditions on the use of service if they
otherwise would have the right to refuse service.
For example, a rider with mental retardation may have a tendency to
move around the paratransit vehicle and accost other passengers.
The behavior may be able to be controlled by the presence of an
attendant. Because such conduct would be seriously disruptive to
the service, the transit provider would have the right to refuse
service. They could also, therefore, require that the person
travel with an attendant.
Circumstances Under Which Service Can be Suspended
In addition to permitting service to be refused or conditioned as
described above, the regulations also specify one additional
circumstance under which paratransit service may be suspended.
Section 37.125(h) of the regulations allows paratransit service to
be suspended, for a "reasonable period of time," for individuals
who establish a "pattern or practice" of missing scheduled trips.
This provision is included in the regulations to allow transit
providers to respond to chronic "no-shows".
This provision does not apply to trips that are beyond the rider's
control. For example, a rider could not be considered a "no-show"
if:
- the vehicle arrived at the pickup location early or late and
the person was not ready or
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had left to call or make other arrangements;
- a sudden family emergency caused the person to change plans
and did not allow time to notify the dispatcher of this
change;
- the person had made a reasonable effort to notify the operator
that service would no longer be needed but experienced an
unreasonable delay getting through on the phone;
- a sudden turn for the worse in someone with a variable
condition causes them to miss the trip.
It is important to note that "no-shows" are different than
cancellations and that the regulations do not specify that service
can be suspended for a pattern or practice of cancellations. A
major cause of cancellations is the advance notice required for use
of paratransit service - a policy that does not exist for fixed
route service. Sanctions cannot be imposed on individuals whose
schedules change frequently and who are therefore required to
change or cancel their scheduled paratransit trips.
Developing a "No-Show" Suspension Policy
Before service can be suspended, a "no-show" suspension policy must
be developed. Because the policy is part of the overall eligibility
policy, it therefore must be developed with full public
participation as specified in 37.137 of the regulations. This
includes consultation with persons with disabilities (following an
outreach effort to identify interested and affected persons), a
public comment period, and a public hearing.
The no-show policy should address the following items:
- the amount of notice that riders must give if they want to
cancel a scheduled trip;
- the frequency of no-shows that will constitute a "pattern or
practice"; and
- the length of time for which service will be suspended.
Notice required for canceling a trip cannot exceed the amount of
advance notice required to make a trip reservation. For example,
riders cannot be asked to give 24 hours notice of a trip
cancellation if "next day" service is provided.
Suspension of service for no-shows must be based on a "pattern or
practice " of such activity rather than infrequent, one-time
incidents. The frequency of no-shows that will be considered a
pattern or practice can be either an absolute measure or a relative
measure. An absolute measure would establish a specific number of
no-shows in a given period of time that would be considered
excessive. For example, such a policy could set three no-shows in
a three-month period as a "pattern or practice". A relative
measure would set a percentage
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of no-shows to total trip requests. For example, it would be
considered a pattern or practice if three percent of a person's
trip requests in any three-month period resulted in no-shows.
The advantage of an absolute measure is that it is easier to
measure and easier for riders to understand. It also lends itself
to progressive action (e.g., a call after one no-show, a letter
after two, and suspension after three). The primary disadvantage
is that it does not account for differences in the number of trips
made by riders. For example, three no-shows in a three-month
period for someone who makes four one-way trips per week would mean
that the person no-shows six percent of the time. A person who
uses the service five days a week for work and makes 20 trips per
week would be no-showing one percent of the time.
Regardless of the method used, the measure should be able to be
defended as a pattern or practice. One way to do this is to
compare the measure that is considered excessive to the system wide
average for no-shows. For example, if there is a one percent no-
show rate for the entire system, establishing a standard that would
equal a three percent rate, even for frequent users of the service,
would be defensible.
The regulations do not provide guidance on what would constitute a
"pattern or practice" of no-shows or what would be a reasonable
period of suspension. Table 5 provides the no-show policy details
of selected transit providers. As shown, most providers use an
absolute standard. Many also have a standard that will lead to an
escalation of actions (e.g., a number that will trigger a letter
and a number that will result in suspension). The Southeastern
Pennsylvania Transportation Authority has established a sliding
scale that allows a different number of no-shows depending on the
frequency with which the customer uses the service. Before
suspending service, Ben Franklin Transit and the Port Authority of
Allegheny County consider each situation on a case-by-ease basis.
In general, the period of suspension should be long enough to be a
deterrent but should not cause undue hardship. As shown in Table
5, a period of suspension of one month appears to be typical for a
first violation. A number of providers increase the period of
suspension for subsequent violations of the policy.
Other approaches, incentives, and disincentives can also be used to
reduce the incidence of no-shows. The suspension policy and the
reason for it should be known by riders. Include this information
in brochures and rider manuals. DAST keeps notices about the no-
show policy posted on vans. SEPTA develops a list each month of
the twenty riders with the greatest number of no-shows and sends
each a letter noting the effect of no-shows on the overall service.
A copy of the letter sent by SEPTA is provided as Figure 7.
In addition to contacting riders, efforts should be made to
determine the cause of the problem. Identify and address any
operational problems that may be leading to no-shows. Many of the
systems contacted for policy details indicated that they contact
riders who no show a first time to explain the importance of
canceling in advance and to make sure that the person is aware of
the service suspension policy. Extenuating circumstances and
operational problems can also be noted and/or resolved at this
time. Some systems also indicated that
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Figure 7. Letter Sent by SEPTA to Riders with Greatest Number of
No-Shows Each Month
ParaTRANSIT
June 9, 1993
Dear
SEPTA ParaTransit is an advance scheduled shared-ride service.
Space is very limited and costly to provide. Each month we print
out a list of individuals who have more late cancellations (less
than two hours notice) and/or no-shows than are allowed by SEPTA's
generous policy. A review of the list indicates you are one of
twenty-five people with the greatest number of late cancellations
and/or no shows.
It would be appreciated if you could provide SEPTA more notice
so we can offer your scheduled ride to someone else that needs
service. Over $17,000 was spent on providing transportation that
was not used in May.
If you are having difficulties with our service or have
questions about our policy, please call Customer Service at 580-
7145.
Thank you for your cooperation.
Cordially,
Jon H. Roth
Acting Administrative/
Customer Service Supervisor
Southeastern Pennsylvania Transportation Authority
714 Market Street Suite 500 - Philadelphia, PA 19106-2385 -
(215) 580-7000 - Fax (215) 580-3709
Copyright SEPTA 1992 8-92-09962
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they will still charge the fare or will charge the sponsoring
agency the full cost of the trip. The Ann Arbor Transportation
Authority indicated that, as an alternative to suspending service,
customers may be assessed a $10 charge per no-show.
Another effective approach used by some providers is to leave a
notice at the person's home indicating that the vehicle arrived and
that they were recorded as a no-show, The no-show policy and the
importance of canceling trips is also included in the notice.
Subscription service privileges can also be revoked if individuals
regularly miss trips. For a period of time they can be required to
call for each trip.
Many times, no-shows will also be caused by guardians or human
service agency staff who assist the rider in making and keeping
scheduled appointments. Follow-up with these individuals and/or
contact with supervisors or program directors may be an effective
approach.
Excessive no-show and cancellation rates can also be caused by
inconvenient advance reservation and trip confirmation practices.
In general, no-shows and cancellations will decrease as the
"response time" is reduced. Confirming trip requests as they are
placed also will reduce the number of cancellations.
Process Issues Associated with Suspending Service
Suspending a person's right to paratransit service is a serious
matter. This is so not only because of the legal ramifications but
because many riders may have few other or no transportation
alternatives and may rely on services for employment, medical, and
other essential services. Transit providers should have clear
documentation of all missed trips and should be prepared to show
that all aspects of the policy have been followed.
The regulations also require that before a suspension of services
is imposed, administrative due process must be extended to the
individual. A two-stage process is required, including initial
notification and an opportunity for an informal hearing followed by
a second notice and an opportunity to appeal. The exact process
that must be used is explained in Appendix D to the regulations as
follows:
"If the entity proposes to impose sanctions on someone, it
must first notify the individual in writing (using accessible
formats where necessary). The notice must specify the basis
of the, proposed action (e.g., Mr. Smith scheduled trips for 8
a.m. on May 15, 2 p.m. on June 3, 9 a.m. on June 21, and 9:20
p.m. on July 10, and on each occasion the vehicle appeared at
the scheduled time and Mr. Smith was nowhere to be found) and
set forth the proposed sanction (e.g., Mr. Smith would not
receive service for 15 days).
The entity would provide the individuals an opportunity to be
heard (i.e., an in-person informal hearing before a decision
maker) as well as to present written and oral
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information and arguments. All relevant entity records and
personnel would be made available to the individual, and other
persons could testify. It is likely that, in many cases, an
important factual issue would be whether a missed trip was the
responsibility of the provider or the passenger, and the
testimony of other persons and the provider's records or
personnel are likely to be relevant in deciding this issue.
While the hearing is intended to be informal, the individual
could bring a representative (e.g., someone from an advocacy
organization, an attorney).
The individual may waive the hearing and proceed on the basis
of written presentations. If the individual does not respond
to the notice within a reasonable time, the entity may make,
in effect, a default finding and impose sanctions. If there
is a hearing, and the individual needs paratransit service to
attend the hearing, the entity must provide it.
The entity must notify the individual in writing about the
decision, the reasons for it, and the sanctions imposed, if
any. Again, this information would be made available in
accessible formats. In the case of a decision adverse to the
individual, the administrative appeals process (detailed in
37.125 of the regulations) would apply." [Federal Register,
September 6, 1991, page 45747]
All of the process issues associated with appeals of initial
eligibility determinations, described in Section 8 of this chapter
must be followed in the final appeal noted above. This would
include a separation of function, allowing 60 days for the appeal
to be requested, making a determination within 30 days of the
hearing, and providing interpreters if needed. The same
individuals who hear appeals of initial eligibility determinations
do not, however, have to hear appeals of proposed service
suspensions.
Finally, it is important to note that service must continue to be
provided throughout the process. The transit provider cannot
suspend service while any part of the process is pending.
Section 10. Visitor Policies
Section 2 of Chapter I of this manual describes the regulatory
requirements concerning the provision of service to visitors.
Basically, the regulations require that:
- ADA paratransit eligible visitors to an area must be provided
21 days of service;
- Eligibility determinations provided by other public entities
are to be honored for this period of time;
- Individuals who do not have certification from another public
entity are to be served if they claim to be ADA paratransit
eligible. These individuals can be requested to provide
documentation of place of residence and/or disability;
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- The service provided to visitors must be the same as that
provided to local residents traveling in the same area; and
- Visitors needing more than 21 days of service can be required
to apply for local eligibility certification.
Transit providers should establish, as part of their visitor
policy, the period of time within which the 21 days of service can
be made. For example, a policy may state that visitor service will
be provided "for 21 days in any six month period". The time frame
should be established as part of the planning process and must be
set with full public participation.
Manual or automated rider and trip records can be coded to identify
visitors, can display the period for which visitor travel will be
provided, and can record the number of trips provided to date. -To
avoid a lapse in service, transit providers should inquire whether
or not a visitor will be needing more than 21 days of service
during the established period of time when they call for their
first ride. Certain parts of the application process may need to
be completed before the visitor leaves their place of residence.
For example, if the process requests professional verification as
part of the initial application, the individual may need to have
this portion of the form completed by a local professional before
they leave. Form(s) that the person and/or a professional may need
to complete should be sent or faxed in advance so that the person
can bring these with them or return them in advance. This will
enable the process to be completed and an eligibility determination
to be made before the person's eligibility as a visitor runs out.
This is particularly important for travellers who will need 21
consecutive or nearly consecutive days of service.
As noted above, visitors who have not been certified by another
public entity and who claim to be eligible can be requested to
provide certain documentation. Documentation of place of residence
may be desired to ensure that the individual is from outside the
transit providers jurisdiction or the combined jurisdiction of
several transit agencies which may be providing coordinated, joint
paratransit service. A picture ID would obviously be preferred,
but it is important to note that many ADA paratransit eligible
individuals may not have a drivers license or other form of photo
identification. Several alternative forms of proof of residence
should be considered. These might include a copy of a telephone
bill that would provide an address and would list the visitor's
phone number (which could be called to provide some form of
verification). It may also include identification which the
individual may have been provided by another service agency.
Documentation of disability may not be necessary in all cases. It
will be particularly important if the person claims to have a
"hidden disability" such as a heart condition, mental illness or
other disability that is not obvious. Types of acceptable
documentation might include proof of eligibility for other services
based on disability such as documentation from a veterans
organization, Social Security, a rehabilitation agency, independent
living program, or other agency. Such forms of documentation
probably will not be detailed enough to
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definitively verify ADA paratransit eligibility and transit
providers should not require such definitive proof They will,
however, be able to indicate that the person does in fact have a
disability that would likely qualify them for paratransit service.
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Chapter 4 Applying Eligibility Determinations to Daily Operations
As explained in Chapter 1 of this manual, eligibility for
complementary paratransit service is based on trips that cannot be
made on the fixed route transit system by individuals with
disabilities. For this reason, the determination of ADA
paratransit eligibility is not solely an administrative function
performed separate from daily operations. While basic information
about applicants' functional capabilities and need for paratransit
service is developed in the initial eligibility certification
process, the eligibility of specific trip requests made by
individuals who are ADA paratransit eligible will be determined in
daily operations. The availability and accessibility of fixed
route service will need to be considered along with applicable
environmental and architectural conditions to determine whether
paratransit service is required or if travel on the fixed route
service is an appropriate alternative.
This chapter addresses the determination of trip eligibility in
daily operations. Section 1 reviews key information that will need
to be available to operations personnel. Section 2 discusses trip-
by-trip determination and suggests several practical approaches
that can be applied in most operations. Section 3 notes some
advanced technologies and recent developments in commercially
available software that can assist in the operation of ADA
paratransit services. Finally, Section 4 offers suggestions for
encouraging conditionally eligible individuals to use fixed route
service and for providing additional transportation alternatives.
Although the regulations do require that transit providers strictly
limit eligibility and identify limitations and conditions of
eligibility, it is important to note that they do not require that
trip-by-trip determinations be conducted in daily operations.
Transit providers can opt to offer broader service to ADA
paratransit eligible individuals if it is decided that determining
the eligibility of each trip is too difficult, not cost-effective,
or not necessary to fully implement required paratransit service.
Some level of trip-by trip eligibility determination should be
considered, however, if full implementation of the paratransit
service requirements could become a financial burden. Only those
costs associated with the provision of eligible trips can be
included in any request of an undue financial burden waiver
request.
Section 1. Important Operational Information
Much of the information obtained or developed in the eligibility
determination process will be needed by schedulers, drivers, and
other operations personnel to provide appropriate, effective
paratransit service. Paratransit services typically maintain
customer files with much of this information. The determination of
ADA paratransit trip eligibility may, however, require these
records to be expanded and enhanced.
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In addition to name, address, and other general personal
information, a customer record maintained by the operations
department or contract operator will need to include:
- Information about the person's disability In order to
appropriately responding to a customer's needs and provide any
necessary assistance, operations personnel will need basic
information about the person's disability. For example, the
customer record may indicate that the rider is blind, is
moderately retarded, or has cerebral palsy and uses a
wheelchair.
Certain medical information should be released only if it is
vital to the effective and safe operation of the service. For
example, the customer record may show that a person suffers
from chronic fatigue but would not indicate that the
individual has been exposed to the HIV virus. Certain medical
information, if deemed vital, can also be released only to
limited personnel such as managers or supervisors.
Operators will also need to have information about the
particular effects of the disability. For example, it would
be important to note if the individual is prone to seizures or
certain types of behavior. It would also be helpful to
provide suggestions for communicating with or otherwise
assisting the individual that may have been noted in the
application.
- Mobility aids used. This would include aids such as
wheelchairs, walkers, braces, canes, and portable life
support. It would also include information on service animals
and/or the need for personal care attendants.
Detailed information on the size and weight of wheelchairs win
be important for determining if the lifts available can
accommodate the rider or if vehicles with particular
accessibility features (e.g., a certain securement system)
will be needed.
- Functional Disabilities. In addition to basic information
about the nature of the person's disability, operations staff
will need to know the functional capabilities of customers.
This could include the person's ability to board an accessible
vehicle, to negotiate steep terrain, or to travel under
certain environmental conditions. It may also include
information about travel training that the rider has received
and specific fixed routes which they can independently use.
Information provided to operations staff should be consistent
with the information provided to the applicant. The level of
detail provided should be determined by the degree of trip
eligibility determination that will be conducted. For
example, the specific temperature sensitivity of a rider
(e.g., temperatures above 85 degrees Fahrenheit) would not be
needed if trip determinations are going to be seasonally-based
(e.g., the rider is eligible during hot weather months).
- Frequent travel information. If questions about common trips
are included in the application, they can also be useful in
determining the person's need for paratransit for
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frequently made trips. This information can also help in
predicting travel demand and structuring future subscription
service or daily routes.
In addition to information obtained through the eligibility
determination process, paratransit operations staff will also
need information about fixed route services. They will also
need certain geographic and architectural data in order to
determine if there are conditions that could prevent customers
with disabilities from getting to or from stops/stations.
Again, the level of detail of this information depends on the
degree of trip-by-trip determination that is done in
operations. Additional information that should be considered
includes:
- Fixed routes and schedules. Paratransit schedulers should
have access to the latest fixed route information. A simple
map that displays the routes overlaid on the ADA paratransit
service area is one approach. In larger systems, giving
schedulers access to computer programs used by public
information staff that can show best routes given a particular
origin and destination should be considered.
Knowledge of accessibility features of the fixed route system
is also important. Accessible routes should be highlighted.
If an "on-call" lift bus service16 is utilized, consideration
should be given to combining this program with the paratransit
operation or closely linking the two. It would be beneficial
to be able to directly arrange for on-call lift bus service
for individuals calling for paratransit who could use
accessible fixed route service.
- Location of accessible bus stops/rail stations. Information
about stations and stops that are accessible can also be made
available to paratransit schedulers. A survey of bus stops
can be conducted to identify those areas where the geography
or street conditions may prevent individuals from boarding and
disembarking.17
Paratransit operators asked to do trip-by-trip eligibility
determination will also need current information about system
access such as the latest information on elevator outages.
- Map of the ADA-service area. Maps used in scheduling should
delineate the ADA paratransit service area. This is
particularly important if the service area is limited to 3/4
mile corridors specified in the regulations.
___________________________
16 For information about on-call bus service, also known as
"call-a-lift-bus', see Chapter 6 of the ADA Paratransit
Handbook, UMTA-MA-06-0206-91-1, September, 1991.
17 The Virginia Department of Rail and Public Transportation has
developed a Bus Stop Checklist guide which is intended to
assist operators with such surveys.
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It may also be helpful to display other distance lines, such
as a 1/4 mile or 1/2 mile distance from fixed routes. This
will be helpful in determining if paratransit is required for
individuals who can independently travel distances less than
3/4 of a mile and are conditionally eligible based on the
distance to and from stops/stations.
- Areas of steep terrain. The map of the service area should
also highlight areas of steep terrain that could prevent
individuals with ambulatory disabilities from getting to or
from stops/stations. While it may not be practical to
highlight all areas which exceed the regulatory definition of
an accessible grade, it may be useful to display extreme
terrain that is a definite barriers to travel.
- Location of curb cuts and sidewalks. The location of curb
cuts within the service area can also be displayed. Cites and
towns are required by the Department of Justice's ADA
regulations to include in their ADA transition plans a
schedule for building curb cuts.18 Maps showing the location
of existing and planned curb cuts may be available from local
city engineering offices.
Areas that lack sidewalks can also prevent independent travel to
transit stops/stations. Local public works offices may also be
able to assist in the collection of this information.
- Major intersections and other barriers. Finally, it may be
helpful for schedulers to know the location of other manmade
or natural features that could act as barriers to travel by
individuals with disabilities. This might include highways,
busy intersections, railroad tracks, waterways, or other
similar features. It may also include streets and sidewalks
that are under construction. This information will need to be
regularly updated with the help of local planning and public
works agencies.
The above information can be developed and displayed manually. As
discussed in Section 3 of this chapter, it can also be developed
with the aid of certain advanced technologies.
Section 2. Trip-by-Trip Eligibility Determination
The consideration of all factors that may affect trip eligibility
is a difficult undertaking at best. Even with detailed information
about the fixed route service and extensive environmental,
geographic, and architectural information, it may still not be
possible to determine if certain conditions, when combined with a
person's disability prevent use of the fixed route service. For
example, in advanced reservation operation, it is not be possible
to know in advance the environmental conditions such as
temperature, humidity, snow, ice, or air pollution that may exist
at the time of travel. The effects of certain types of
disabilities,
___________________________
18 For more information on transition planning requirements or
city/town responsibility for building curb cuts, see 28 CFR
Part 35, "Nondiscrimination on the Basis of Disability in
State and Local Government Services; Final Rule", Section
35.150(d)(2), Federal Register, July 26, 1991, page 35720.
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such as multiple sclerosis and mental illnesses also can change
from day to day. Transit providers will need to rely on the
personal assessments of travel capabilities made by individuals
with these disabilities.
While it may be impractical or impossible to take into
consideration all of the factors associated with trip eligibility,
there are certain approaches that can be taken that can allow a
significant portion of all trips provided to be reviewed, at some
level, for eligibility. These approaches are described below.
Review Subscription Trips
Many paratransit programs permit riders to obtain reservations for
repeat trips by calling only periodically. For example, a rider
may have a standing reservation for daily travel to work which only
needs to be reconfirmed once a month or every three months. These
"subscription" trips have the same origin and are made to the same
destination. In many systems, subscription trips can account for
40-50 percent of all trips provided.
A detailed analysis of each subscription rider's ability to make
this one repeat trip can be conducted using information obtained in
the application for ADA paratransit eligibility. Additional
information about exact travel distances involved or
geographic/architectural features that might prevent travel can be
obtained by a site review or by speaking to the rider. A single
review can impact many future trips. Determining that ten current
paratransit riders could use fixed route service for daily travel
to work, for example, could reduce paratransit trip demand by about
5,200 trips per year.
Review Other Frequently Made Trips
Non-subscription trips are also often made from the same origin to
the same destination. For example, individuals will often grocery
shop at the same store or may be members of a particular civic
organization. A review of possible use of fixed route service to
meet these common travel needs can be done. As with subscription
service, such reviews will impact many potential paratransit trip
requests.
As noted in Section 4 of Chapter 3 of this manual, information
about common trips can be included in the initial eligibility
application form. Commonly made trips can also be generated from
trip records by sorting trips by rider and by origin and
destination.
Generalize Limitations of Eligibility
Another approach to simplifying trip eligibility determinations is
to generalize the conditions that have been placed on an
individual's ADA paratransit eligibility. By broadening the
condition, it may then become practical to consider the condition
when reviewing a particular trip request.
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For example, a rider may not be able to use fixed route service
when there is snow or ice. Instead of taking current weather
conditions into consideration in the scheduling process, the rider
could be considered eligible during those times of the year when
snow and ice are present. Similarly, a person with a sensitivity
to high temperatures and/or humidity could be granted eligibility
during hot weather months. This person would be expected to use
fixed route service at other times.
These generalized conditions of eligibility could be included in
the customer record file. Schedulers could then easily determine
if the trip request should be accommodated.
Consideration of Easily Tracked Eligibility Conditions
Other conditions of eligibility may also be easily identified using
information from the application review process. This information
can then be prominently displayed on computer scheduling screens
(or can be noted on rider record cards) to allow schedulers to
determine if the use of fixed route service might be a reasonable
alternative for a particular trip that is being requested.
Individuals determined to be unconditionally eligible would be
identified as such and no further consideration of their trip
request would be necessary as long as both the origin and
destination were within the ADA paratransit service area. Persons
determined conditionally eligible would have key information about
their eligibility indicated. Examples of conditions that can be
easily identified and tracked and which may be practical to
consider in the scheduling process include:
- whether the person has received travel training for certain
trips;
- whether the person is able to use accessible fixed route
services;
- whether eligibility is based on an inability to negotiate
transfers and complex fixed route trips;
- the ability of the person to independently travel certain
distances;
- whether travel is prevented at certain times of day (e.g.,
night blindness); or
- whether travel is prevented in certain seasons (e.g., winter
due to snow/ice, or summer due to heat).
Using basic information such as that listed above, schedulers may
sometimes be able to definitively determine if paratransit is
required. For example, a request for a trip for which the
individual has been trained could be quickly assessed. A decision
on a midday trip request by an individual determined eligible on
the basis of night blindness could be easily made. Similarly, a
determination on a trip request that involves the use of only one
route could be made if eligibility is based on the person's
inability to negotiate complex trips.
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In other cases, it may not be possible to arrive at a definitive
determination of eligibility, but use of the fixed route service
may be a distinct possibility. For example, the customer record of
a wheelchair-user may show that he/she can use accessible vehicles
and can travel up to 1/2 mile to and from bus stops. The origin
and destination may both be close to an accessible route and the
request may be at a time of the year when weather is not a factor.
Without detailed information about curb cuts and terrain, it is not
possible to make a final decision but there would seem to be a good
chance that the person could use the fixed route service. In this
case, the call-taker or scheduler may want to ask the person "Are
you aware that Bus XYZ is now lift-equipped and is only 3 blocks
from you?" or a stronger suggestion such as "Our records indicate
that you are able to use accessible buses. Bus XYZ is lift
equipped and can be used for this trip" could be made. The
customer may decide that this fixed route alternative can be used
or may point out that other barriers exist. Under this approach,
transit providers would rely on customers to note difficult to
track issues such as a lack of curb cuts and/or steep terrain.
More accurate determinations would obviously be possible if
schedulers were given easy access to other eligibility conditions
and had detailed service area and environmental information.
Examples of other factors that would be slightly more difficult to
utilize in daily operation but which could be considered include:
- whether eligibility is based on an inability to travel in
areas of steep terrain (combined with detailed knowledge of
the terrain in the area);
- whether eligibility is based on a lack of curb cuts (combined
with a map of curb cuts in the area);
- whether eligibility is based on an inability to cross busy
streets and intersections (combined with information about
busy roadways and difficult intersections in the area).
As can be seen, trip-by-trip eligibility determinations can be
considered at many levels of complexity. There is a clear benefit
to using some of the simpler approaches outlined above. A careful
analysis of the costs and benefits of maintaining more detailed
data and asking operators to spend the additional time making trip
determinations should be considered before more involved approaches
are used in daily operation.
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Section 3. Using Advanced Technologies to Make Trip Eligibility
Determinations
A number of advanced technologies are available that can assist in
maintaining and using ADA eligibility information. Following is a
brief description of each and a discussion of possible applications
to the eligibility process.
Relational Database Management Systems (RDMS)
Relational database management systems are "off-the-shelf" software
packages that can be used to create and manage data files.
Separate files can be created (e.g., customer files and trip files)
and this information can then be "related" by using a common
identifier (e.g., a customer ID). RDMS software is inexpensive and
can be programmed by users with basic to moderate computer skills.
Data files and reports can be customized to address the particular
need.
RDMS software could be used by smaller operators to store detailed
eligibility information, including specific conditions/limitation
of eligibility. As trip requests are received, call takers or
schedulers could recall information on the rider and use this data
in making trip eligibility decisions. RDMS software could also
keep trip records for individuals being served as visitors and
assist schedulers in knowing when to request that these persons
apply for local eligibility.
In addition to assisting with ADA paratransit eligibility, RDMS
software can be applied to many other paratransit operations needs
such as general client information, trip records, reporting, and
billing. For more information on RDMS, see:
Commercial Software Applications for Paratransit, USDOT Report
#DOT-1- 84-5 1, available through the USDOT Technology Sharing
Program.
Automated Client Information Systems
Several software packages are also available that are designed
specifically to allow for the storage and retrieval of detailed
information on clients/customers. In many cases, these systems
have been developed from standard RDMS. While they serve the same
basic purpose as RDMS, the main advantage of these customized
packages is that they include special screen displays and menus
that make information storage and retrieval quicker and easier for
the user.
Often, these systems are one piece of larger computer scheduling
and dispatching programs.
It is possible, however, to purchase client information system
modules separate from the
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larger programs. Typically, these modules cost less than $5,000.
Automated client information systems are also used extensively by
human service agencies.
Information about several available automated client information
systems is included in:
Pcs in Transportation Software Directory, a catalog available
through PC-TRANS at the University of Kansas Transportation
Center. PC-TRANS phone number is (913)864-5655.
Automated Routing and Scheduling Systems
Many of the commercially-available routing and scheduling programs
developed for the paratransit industry have recently been upgraded
to include features that address ADA information needs and
requirements. As noted above, these packages typically include
client information modules as well as trip fees, scheduling
algorithms, reporting routines, and other functions designed to
offer full support in all aspects of paratransit operation.
Some of the common features that have been developed for ADA
paratransit operation include:
ADA Paratransit Eligible Customer Information: Individuals who
are determined ADA paratransit eligible can be distinguished
from other riders. Conditions and limitations of eligibility
and/or the regulatory categories under which riders are
eligible can be displayed. If ADA paratransit eligible
persons are also eligible under other programs, this multiple
eligibility information can also be displayed.
To be of immediate use to schedulers, the above client
information can be displayed in "real-time", meaning that it
can be immediately accessed as part of a scheduling routine.
Relationship of Desired Trip to the Fixed Route System: The
ADA regulations require transit providers to offer
complementary paratransit service to eligible individuals in
an area defined by corridors 3/4 of a mile to each side of
fixed routes plus to other areas within a "core service area".
In determining if a requested trip is eligible, transit
providers will need to check the geographic relationship of
the origin and destination to the fixed route service. In
addition, customers may be able to get to and from bus stops
up to a certain distance (e.g., up to 1/4 of a mile) but are
eligible for paratransit when they would need to travel a
greater distance to and from bus stops.
Several scheduling systems are now capable of incorporating
geographic information about the fixed route system. ADA
paratransit service corridors can be displayed and
calculations of distances from origin or destination to the
closest fixed route.can be made. More accurate systems will
develop these calculations by using exact latitude/longitude
coordinates or street centerlines. Trip eligibility can then
be determined using this information.
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Visitors Information: As noted in Chapter 1 of this manual,
the regulations require that ADA paratransit systems
accommodate visitors to the area. Visitors are to be provided
with 21 days of service over a reasonable period of time if
they have been determined eligible by another transit agency
or if they claim to be eligible. After 21 days of service,
the person can be required to go through the local eligibility
determination process.
Several paratransit scheduling programs are able to process
visitor requests, track the days of service provided to a
visitor, and display this information as part of the
scheduling routine.
Documenting Compliance: In addition to assisting with
determining individual and trip eligibility, these systems are
also capable of providing data and developing reports that can
assist in assuring compliance with the regulations. For
example, the ADA regulations require that complementary
paratransit service, when fully implemented, cannot have
capacity constraints. Examples of capacity constraints are an
excessive number of trip denials, late pick-ups, and long
trips. Trip requests are to be considered denials if they
cannot be scheduled within one hour of the requested pick-up
time. Additionally, the regulations limit subscription trips
("standing orders") to no more than 50 percent of total trips
when capacity constraints exist.
Several software systems allow users to track and analyze
capacity constraints and subscription trips.
As part of the preparation of this manual, information about the
availability of the above features was requested from 30 of the
leading paratransit software companies. Twelve companies responded
and indicated that one or more of these features was either
currently available or in development. The tables on the following
pages summarize this information. Table 6 summarizes client
information features. Table 7 presents information about
displaying the ADA paratransit service area and calculating
distances to and from stops. Table 8 addresses features included
to accommodate visitor requirements. Table 9 notes capabilities
for collecting and analyzing capacity constraint and subscription
information.
For more information on the capabilities of automated routing and
scheduling systems, see:
Assessment of Computer Dispatch Technology in the Paratransit
Industry, USDOT Report #DOT-T-92-23, available through the
USDOT Technology Sharing Program.
Advanced Public Transportation Systems: The State-of-the-Art
Update '92, USDOT Report #DOT-VNTSC-FTA-92-3, available
through the National Technical Information Service,
Springfield, Virginia, 22161.
124
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125
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126
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127
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128
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129
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130
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131
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GIS and Computer Mapping Systems
Geographic information systems (GIS) provide database management
capabilities for the display of spatial data, and provide users
with the ability to perform analysis of geographic features. Many
of the scheduling and dispatching systems discussed above utilize
GIS to code the location of origins, destinations, and fixed route
services. This then allows distances from stops/stations to be
calculated.
In addition to assisting with the calculation of required travel
distances, GIS can be used to locate and store information on other
geographic features. This could include curb cuts, areas of steep
terrain, or other manmade or natural barriers to travel. Such
displays and information can then be incorporated into complex
scheduling systems. GIS can also be used independent of scheduling
programs to display the ADA paratransit service area, origins,
destinations, and other key geographic information that can then be
considered in the scheduling process.
For more information on GIS, see:
Current Use of Geographic Information Systems in Transit
Planning, USDOT Report #DOT-T-92-02, available through the
USDOT Technology Sharing Program.
Section 4. Providing Alternatives/Market-Based Approaches
Appropriate use of ADA paratransit service can also be achieved by
encouraging eligible individuals to use fixed route service and by
providing attractive alternatives to the paratransit service. Such
approaches can supplement efforts to do trip-by-trip determinations
as part of paratransit operations.
Fare policies for fixed route and paratransit services will
obviously impact rider choice. Individuals who are conditionally
ADA paratransit eligible (i.e., they can use fixed route service
for some trips) can be encouraged to utilize mainline service by
maintaining a lower fare for this service. This can be achieved by
pricing paratransit service higher than fixed route service (the
regulations permit a paratransit fare that is a maximum of twice
the base fixed route fare for a comparable trip) or by offering
fixed route fare discounts and special promotions. Because a
higher paratransit fare will also impact those who must use
paratransit service (unconditionally ADA paratransit eligible
persons), consideration of the latter approach may be preferable.
Transit providers presently must offer persons with disabilities a
50 percent fare discount during off-peak hours. Consideration
should be given to expanding this discount to an hours. ADA
paratransit eligibility documentation could then be used as
identification to qualify individuals for this discount. The Los
Angeles County Metropolitan Transportation Authority presently has
such a program for individuals who are conditionally ADA
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paratransit eligible. This encourages these eligible individuals
to use the fixed route service when they are able.
Also consider special promotions that allow persons with
disabilities to use fixed route service free or at a discount for a
limited time. Conditionally eligible persons could be mailed a
monthly pass when they are notified of their eligibility
determination. The notification letter could encourage use of the
fixed route system and offer training, special instruction, trip
planning services, or other assistance.
Another alternative would be to encourage local private taxi
companies to begin offering accessible taxi service. Initial
capital and/or assistance could be considered to demonstrate the
feasibility of the service. An ongoing accessible taxi program
could also be funded to supplement ADA paratransit service. This
program could provide a lower level of subsidy to riders than is
provided on the standard paratransit system. Individuals may opt
to pay a higher fare for immediate response taxi service rather
than make arrangements for ADA paratransit service a day in
advance.
Utilizing these approaches will encourage ADA paratransit eligible
persons to utilize fixed route services and will expand travel
alternatives available to them. More decisions about the
appropriate use of paratransit service will be made by riders which
will ease requirements for trip-by-trip determinations in daily
operation.
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References
Americans with Disabilities Act of 1990, Public Law 101-336, July
26, 1990
CFR 49 Parts 27, 37 and 38, "Transportation for Individuals With
Disabilities; Final Rule", Federal Register, September 6, 1991.
Thatcher, R. H., Gaffney, J. K., ADA Paratransit Handbook.
Implementing the Complementary Paratransit Service Requirements of
the Americans with Disabilities Act of 1990, US DOT Report #UMTA-
MA-06-0206-91-1, prepared for the UMTA Task Force on the Americans
with Disabilities Act, funded through the Office of Technical
Assistance and Safety, September 1991.
Balog, John N., Schwarz, Anne N., Rimmer, Jennifer E., and Hood,
Mark M., ADA Public Participation Handbook, prepared for Project
ACTION, funded by the Federal Transit Administration, September,
1993.
C.V. Mosby Company, Mosby's Medical, Nursing, and Allied Health
Dictionary, Third Edition, 1990.
U.S. Department of Labor, Dictionary of Occupational titles, Volume
1, Fourth Edition, Revised 1991.
DeAlba, M., Evolution of Functional Eligibility and Certification
for Paratransit Service: the Chicago Experience, Transportation
Research Record 1338.
Hazen, C., ADA Implementation Evaluating Disabled Individuals for
ADA Paratransit Eligibility, prepared for the University of
Wisconsin - Milwaukee, April 27, 1993.
CGA Consulting Services, Inc., EG&G Dynatrend, Katherine McGuinness
& Associates, Inc., ADA Paratransit Eligibility: A Guide for
Virginia Transit Systems for Complying with the Americans with
Disabilities Act of 1990, prepared for the Virginia Department of
Rail and Public Transportation, July 1, 1992.
Coburn, N., Martin, C., Thompson, R., Norstrom, D., Guidelines for
Improvements to Transit Accessibility for People with Disabilities,
Technical Report #DOT-T-93-04, prepared for the Office of Technical
Assistance and Safety, Federal Transit Administration, September
1992.
Schwarz, A.N., Trip by Trip Eligibility: Can it Really Be Done?
presented at Solving ADA Paratransit Problems: How to Cope with
Reality, Phoenix, AZ, May 27-29, 1993.
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ADA Paratransit Eligibility Manual
Cutler, M.R., Cabrera, A., Monahan, P.A., Harman, L.J., Commercial
Software Applications for Paratransit, US DOT Report #DOT-I-84-5 1,
prepared for the Office of Methods and Support UMTA, funded through
the U.S. Department of Transportation, July, 1984.
University of Kansas Transportation Center, PC's in Transportation
Software Directory, March 1991.
Stone, J.R., Gorman, G., Nalevanko, A., Assessment of Computer
Dispatch Technology in the Paratransit Industry, US DOT Report
#DOT-T-92-23, prepared for Federal Transit Administration Office of
Technical Assistance & Safety, March 1992.
Labell, L.N., Schweiger, C.P., Kihl, M., Advanced Public
Transportation Systems: The State of the Art, Update 1992, US DOT-
VNTSC-FTA-92-3, April 1992.
Schweiger, C.L., Current Use of Geographic Information Systems in
Transit Planning, US DOT Report #DOT-T-92-02, prepared for the
Office of Grants Management UMTA, August 1991.
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ADA Paratransit Eligibility Manual
Index
Accessible formats
types of, 24
identifying the need for, 57
application materials, 53
regulatory requirement for, 24
Accessible taxi programs, 134
Appeals
required process, 26-27
of initial determination, 26-27
of proposed suspension of service, 28, 111-112
alternative approaches, 94-101
hearings, 102
separation of function in, 26, 95
Application forms
accessible formats, 53
suggested contents, 54-72
pre-test of, 73
use of appropriate terminology in, 54
Architectural barriers
application questions concerning, 64-65
construction, 9
curb-cuts, 9
data needs in daily operation, 117-118, 121
effects on eligibility, 8, 9, 16
major intersections, 9
Audiologist, 50
Category 1 eligibility
examples of, 5
factors which affect, 5-7
suggested application questions, 62-63, 66-67
regulatory definition of, 5
Category 2 eligibility
examples of, 7
factors which affect, 8
suggested application questions, 66-67
regulatory definition of, 7
Category 3 eligibility
examples of, 11
factors which affect, 8
"prevented" travel, 9-10
regulatory definition of, 8
Clinical social worker, 50
Common wheelchair
definition of, 6
suggested application question, 58
Companions, 12
Conditional eligibility
defined, 4
examples of, 16-19
recent experience concerning, 79-84
sample determination letter for, 88-89
Conditioning service, 104
Curb-cuts
application questions concerning, 64-65
data needs in daily operation, 118, 121
effects on eligibility, 9
Determinations of eligibility
contracted vs. in-house, 48-52
maintaining consistency of, 78-79
recent experiences with, 79-83
selecting appropriate third-party reviewers, 48-49
Disability
relationship to eligibility, 4, 16, 17-19
episodic and intermittent, 17, 59-60
suggested application questions, 59-60
Distance from fixed routes
data needs in daily operation, 117-118
determining with advanced technology, the effects on
eligibility, 9, 11, 18-19, 20
suggested application questions, 64
137
ADA Paratransit Eligibility Manual
Documentation
costs associated with, 33
requested from visitors, 13, 113-114
limiting to those eligible, 23-24
of appeals hearings, 15, 102
of eligibility, 25, 92-93
of the process, 15, 74
sample ID, 93
Environmental conditions
air pollution, 9, 11
suggested application questions, 64-66
data needs in daily operation, 118, 119-121
humidity, 11
ice, 9, 11
rain, 9, 11
snow, 9, 11
temperature, 9, 11
terrain, 9, 11
Fare incentives, 93, 133-134
Fees, application and process
regulatory language concerning, 33
for applications/determinations, 33
for professional verification, 37
for documentation, 33
Functional ability
relationship to eligibility, 16-19
suggested application questions, 60-67
tests to determine, 39, 62
Functionally-based determinations, 16
Independent living specialist, 50
Independent travel
relationship to eligibility, 6
Infants/Children
eligibility of, 11, 104
In-person assessment
as part of determination process, 39-42
cost of, 51
questions and functional tests, 39, 62
Language ability
obtaining information regarding, 58
Management information system
example of automated system, 74
suggestions for, 74
Marketing (see "Public information")
Mobility aids
"common wheelchair' definition, 6
effects on eligibility, 6
requirements for accommodating, 6
suggested application questions, 58-59
Most limiting factors
determining eligibility based on, 20
No-shows
considerations in developing a policy, 105-111
regulatory requirements, 28
sample policies of selected providers, 106-109
suggested approaches to reduce, 106-111
Notice, providing
of initial determination, 25, 85-91
of appeals decision, 26, 96
of service suspension, 28, 111-112
sample determination letters, 87-91
Occupational therapists, 35, 49-50
On-call accessible fixed route bus service, 8
Operator assistance
effects on eligibility, 6
regulatory requirements for, 6
Opthomologists, 35, 50
Personal care attendants
definition of, 12
requirements for serving, 12-13
suggested application questions, 59
Physiatrists, 49-50
Physical therapists, 35, 50
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ADA Paratransit Eligibility Manual
Physicians
appropriate use of, 37-38
definition of, 50
Presumptive eligibility
during initial determination, 24, 35, 74
during appeals, 26, 74, 94
for visitors, 13-14, 112-114
Privacy rights of applicants and customers, 79, 116
Process, establishing an eligibility
alternative processes, 34-42
examples of selected processes, 43-47
general considerations in, 30-33
suggested 'steps", 29
Process requirements
required implementation date, 4
required elements of a policy, 23-27
who must establish eligibility processes, 3
Professional verification
as needed, 34-36
forms for obtaining, 72
obtaining appropriate, 35, 37
questions in application concerning, 70-71
requested in all cases, 36-39
Psychologist, 50
Public information
importance of, 31-32
suggestions for, 32
Public participation
guidance on, 31
importance of, 30
regulatory requirements for, 30
Recertification
future process considerations, 42
of ADA paratransit eligibility, 27, 92
of current paratransit customers, 27-28
Refusing service, 103-104
Registered nurses, 50
Rehabilitation specialists, 50
Reviewer guidelines, 78-79
Self-certification
as part of determination process, 34-38
Separation of function (see "Appeals")
Service animals, 58, 103
Standees on lifts
noting in application material, 54, 67
regulatory requirements, 7
Strictly limiting eligibility, 23-24
Subscription service
checking trip eligibility of, 119
documenting compliance, 124
Suspending service
circumstances permitting, 104-105
process issues concerning, 111-112
Temporary eligibility
regulatory requirements, 14
suggested application questions, 60
Training
reviewer training, 40, 52
travel training for customers, 5, 68-69, 116
Travel training
combining with eligibility process, 48
data needs in daily operation, 116, 120
effects on eligibility, 5
suggested application questions, 68-69
Trip-by-trip scheduling
data needs for, 115-118
practical approaches to, 118-121
technology to assist with, 122-124
Trip eligibility, 4, 16-17
139
ADA Paratransit Eligibility Manual
Unconditional eligibility
defined, 4
examples of, 17-19
sample determination letter, 87
Undue financial burden waiver, 17, 21-22, 115
Vehicle/system accessibility
data needed for trip-by-trip scheduling, 117
effects on eligibility, 7, 8, 16
Visitors
data needs in daily operations, 124
documentation that can be requested, 113-114
regulatory definition, 13-14
requirements for serving, 13-14
suggestions for serving, 112-114
140
ADA Paratransit Eligibility Manual
Appendix A
49 CFR Part 37 Sections 37.121 through 37.127
and related sections of Appendix D
45634 Federal Register / Vol. 56, No. 173 / Friday, September 6,
1991 / Rules and Regulations
Subpart F-Paratransit as a Complement to Fixed Route Service
37.121 Requirement for comparable Complimentary paratransit
service.
(a) Except as provided in paragraph (c) of this section, each
public entity operating a fixed route system shall provide
paratransit or other special service to individuals with-
disabilities that is comparable to the level of service provided to
individuals without disabilities who use the fixed route system.
(b) To be deemed comparable to fixed route service, a
complementary paratransit system shall meet the requirements of
37.123-37.133 of this subpart. The requirement to comply with
37.131 may be modified in accordance with the provisions of this
subpart relating to undue financial burden.
(c) Requirements for complementary paratransit do not apply to
commuter bus, commuter,rail, or intercity rail systems.
37.123 ADA paratransit eligibility Standards.
(a) Public entities required by 37.121 of this subpart to
provide complementary paratransit service shall provide the service
to the ADA paratransit eligible individuals described in paragraph
(e) of this section.
(b) If an individual meets the eligibility criteria of this
section 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.
(c) Individuals may be ADA paratransit eligible on the basis
of a permanent or temporary disability.
(d) Public entities may provide complementary paratransit
service to persons other than ADA paratransit eligible individuals.
However, only the cost of service to ADA paratransit eligible
individuals may be considered in a public entity's request for an
undue financial burden waiver under 37.151-37.155 of this part.
(e) The following individuals are AD paratransit eligible:
(1) Any individual with a disability who is unable, as the
result of a physical or mental impairment (including a vision
impairment), and without the assistance of another individual
(except the operator of a wheelchair lift or other boarding
assistance device). to board, ride, or disembark from any vehicle
on the system which is readily accessible to and usable individuals
with disabilities.
(2) Any individual with a disability who needs the assistance-
of a wheelchair lift or other boarding, assistance device and is
able, with such assistance, to board, ride and disembark from any
vehicle which is readily accessible to,and usable by individuals
with disabilities if the individual wants to travel on a route on
the system during the hours of operation of the system at a time,.
or within a reasonable period of such time, when such a vehicle is
not being used to provide designated public transportation on the
route.
(i) An individual is eligible under this paragraph with
respect to travel on an otherwise accessible route on which the
boarding or disembarking location which the individual would use is
one at which boarding or disembarking from the vehicle is precluded
as provided 'm 37.167(g) of this part.
(ii) An individual using a common wheelchair is eligible under
this paragraph if the individual's wheelchair cannot be
accommodated on an existing vehicle (e.g., because the vehicle's
lift does not meet the standards of part 38 of this title), even if
that vehicle is accessible to other individuals with disabilities
and their mobility wheelchairs.
(iii) With respect to rail systems, an individual is eligible
under this paragraph if the individual could use an accessible rail
system, but-
(A) there is not yet one accessible car per train on the
system; or
(B) key stations have not yet been made accessible.
(3) Any individual with a disability who has a specific
impairment-related condition which prevents such individual from
traveling to a boarding location or from a disembarking location on
such system.
(i) Only a specific impairment-related condition which
prevents the individual from traveling to a boarding location or
from a disembarking location is a basis for eligibility under this
paragraph. A condition which makes traveling to boarding location
or from a disembarking location more difficult for a person with a
specific impairment related condition than for an individual who
does not have the condition. but does not prevent the travel, is
not a basis for eligibility under this paragraph.
(ii) Architectural barriers not under the control of the
public entity providing fixed route service and environmental
barriers (e.g., distance, terrain, weather) do not, standing alone,
form a basis for eligibility under this paragraph. The interaction
of such barriers with an individual's specific impairment-related
condition may form a basis for eligibility under this paragraph, if
the effect is to prevent the individual from traveling to a
boarding location or from a disembarking location.
(f) Individuals accompanying an ADA paratransit eligible
individual shall be provided service as follows:
(1) One other individual a accompanying the ADA paratransit
eligible individual shall be provided service-
(i)If the ADA paratransit eligible individual is traveling
with a personal care attendant the entity shall provide service to
one other individual in addition to the attendant who is
accompanying the eligible individual;
(ii) 4 family member or friend is regarded as a person
accompanying the eligible individual, and not as a personal care
attendant, unless the family member or friend registered is acting
in the capacity of a personal care attendant;
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Rules and Regulations 45635
(2) Additional individuals accompanying the ADA paratransit
eligible individual shall be provided service, provided that -space
is available for them on the paratransit vehicle carrying the ADA
paratransit eligible individual and that-transportation of the
additional-individuals will not result in a denial of service to
ADA paratransit eligible individuals;
(3)-In order to be considered as accompanying" the eligible
individual for purposes of this paragraph (O. the other
individual(s) shall have the same origin and destination as the
eligible individual.
37.123 ADA paratransit eligibility: Process
Each public entity required to provide complementary
paratransit service by 37.121 of this part shall establish a
process for determining ADA paratransit eligibility.
(a) The process shall strictly limit ADA paratransit
eligibility to individuals specified in 37.123 of this part.
(b) All information about the process, materials necessary to
apply for eligibility, and notices and determinations concerning
eligibility shall be made available in accessible formats, upon
request.
(c) If. by a date 21 days following the submission of a
complete application, the entity has not made a determination of
eligibility, the applicant shall be treated as eligible and
provided service until and unless the entity denies the
application.
(d) The entity's determination concerning eligibility shall be
in writing. If the determination is that the individual is
ineligible, the determination shall state the reasons for the
finding.
(e) The public entity shall provide documentation to each
eligible individual stating that he or she is "ADA Paratransit
Eligible." The documentation shall include the name of the eligible
individual, the name of the transit provider, the telephone number
of the entity's paratransit coordinator, an expiration date for
eligibility, and any conditions or limitations on the individual's
eligibility including the use of a personal care attendant.
(f) The entity may require recertification of the eligibility
of ADA paratransit eligible individuals at reasonable intervals.
(g) The entity shall establish an administrative appeal
process through which:individuals who are denied eligibility can
obtain review of the denial.
(1) The entity may require that an appeal be filed within 60.
days of the denial of an individual's application.
(2) The process shall include an opportunity to be heard and
to present information and arguments, separation of functions (ie..
a decision by a person not involved with the initial decision to
deny eligibility), and written notification of the decision, and -
the reasons for it.
(3) The entity is not required to provide paratransit service
to the individual pending the determination on appeal. However, if
the entity has not made a decision within 30 days of the completion
of the appeal process, the entity shall provide paratransit service
from that time until and unless a decision to deny the appeal 'is
issued.
(h) The entity may establish an administrative process to
suspend, for a reasonable period of time, the provision of
complementary paratransit service to ADA eligible individuals who
establish a pattern or practice of missing scheduled trips.
(1) Trips missed by the individual for reasons beyond his or
her control (including, but not limited to, trips which are missed
due to operator error) shall not be a basis for determining that
such a pattern or practice exists.
(2) Before suspending service, the entity shall take the
following steps:
(i) Notify the individual in writing that me entity proposes
to suspend service, citing with specificity the basis of the
proposed suspension and setting forth the proposed sanction.
(ii) Provide the individual an opportunity to be heard and to
present information and arguments;
(iii) Provide the individual with written notification of the
decision and the reasons for it.
(3) The appeals process of paragraph (g) of this section is
available to an individual on whom sanctions have been imposed
under this paragraph. The sanction is stayed pending the outcome
of the appeal.
(1) In applications for ADA paratransit eligibility, the
entity may require the applicant to indicate whether or not he or
she travels with a personal care attendant.
37.127 Complementary paratransit for visitors
(a) Each public entity required to provide- complementary
paratransit service under 37-121 of this part shall make the
service -available.to visitors as provided in this section.
(b) For purposes of this section, a visitor is an individual
with disabilities who does not reside in the jurisdiction (a)-
served by the public entity or other entities -with which the
public entity provides coordinated complementary paratransit
service within a region.
(c) Each public entity shall treat as eligible for its
complementary paratransit service all visitors; who present
documentation that they are ADA paratransit eligible, under the
criteria of 1 37.t25 of this part, in the jurisdiction in which
they reside.
(d) With respect to visitors with disabilities who do not
present such documentation, the public entity may require the
documentation of the individual's place of residence and, if the
individual's disability is not apparent, of his or her disability.
The entity shall provide paratransit service to individuals with
disabilities who qualify as visitors under paragraph (b) of this
section. The entity shall accept a certification by such
individuals that they are unable to use fixed route transit.
(e) A public entity is not required to provide service to a
visitor for more than 21 days from the date of the first
paratransit trip used by the visitor. The entity may require that
such an individual, in order to receive service beyond this period,
apply for eligibility under the process provided for in 37.125 of
this part.
45744 Federal Register
Appendix D to Part 37 Construction and Interpretation of Provisions
of 49 CFR part 37
This appendix explains the Department's construction and
interpretation of provisions of 49 CFR part 37. It is intended to
be used as definitive guidance concerning the meaning and
implementation of these provisions. The Appendix is organized on a
section-by-section basis. Some sections of the rule are not
discussed in the Appendix, because they are self-explanatory or we
do not currently have interpretive material to provide concerning
them.
The Department also provides guidance by other means, such as
manuals and letters. The Department intends to update this
Appendix periodically to include guidance, provided in response to
inquiries about specific situations, that is of general relevance
or interest.
Section 37.123 ADA Paratransit
Eligibility-standards
General Provisions
This section sets forth the minimum requirement for eligibility for
Federal Register / Vol. 56, No. 173 / Friday, September 6, 1991 /
Rules and Regulations 45745
complementary paratransit service. All fixed route operators
providing complementary paratransit must make service available at
least to individuals meeting these standards. The ADA does not
prohibit providing paratransit service to anyone, entities may
provide service to additional persons as well. Since only service
to ADA eligible persons is required by the rule. however, only the
costs of this service can be counted in the context of a request
for an undue financial burden waiver.
When the rule says that ADA paratransit eligibility shall be
strictly limited to persons in the eligible categories, then, it is
not saying that entities are in any way precluded from serving
other people, it is saying that the persons who must be provided
service, and counting the costs of providing them service, in
context of an undue burden waiver, are limited to the regulatory
categories.
Temporary Disabilities
Eligibility may be based on a temporary as well as a permanent
disability. The individual must meet one of the three eligibility
criteria in any case, but can do so for a limited period of time.
For example, if an individual breaks both legs and is in two casts
for several weeks, becomes a wheelchair user for the duration, and
the bus route that would normally take him to work is not
accessible. the individual could be eligible under the second
eligibility category. In granting eligibility to such a person,
the entity should establish an expiration date for eligibility
consistent with the expected end of the period disability.
Trip-by-Trip Eligibility
A person may be ADA paratransit eligible for some trips but not
others. Eligibility does not inhere in the individual or his or
her disability. as such, but in meeting the functional criteria of
inability to use the fixed route system established by the ADA.
This inability is likely to change with differing circumstances.
For example, someone whose impairment related condition is a severe
sensitivity to temperatures below 20 degrees is not prevented from
using fixed route transit when the temperature is 75 degrees.
Someone whose impairment-related condition is an inability to
maneuver a wheelchair through snow is not prevented from using
fixed route transit when there is no snow on the ground. Someone
with a cognitive disability may have learned to take the same bus
route to a supported employment job every day. This individual is
able to navigate the system for work purposes and therefore would
not be eligible for paratransit for work trips. But the individual
may be unable to get to other destinations on the bus system
without getting lost and would be eligible for paratransit for non-
work trips. Someone who normally drives his own car to a rail
system park and ride lot may have a specific impairment related
condition preventing him from getting to the station when his car
is in the shop. A person who can use accessible fixed route
service can go to one destination on an accessible route; another
destination would require the use of an inaccessible route. The
individual would be eligible for the latter but not the former.
In many cases. though the person is eligible for some trips
but not others, eligibility determinations would not have to be
made literally on a trip-by-trip basis. It may often be possible
to establish the conditions on eligibility as part of the initial
eligibility determination process. Someone with a temperature
sensitivity might be granted seasonal eligibility. Somebody who is
able to navigate the system for work but not nonwork trips could
have this fact noted in his or her eligibility documentation.
Likewise, someone with a variable condition (e.g., multiple
sclerosis, HIV disease, need for kidney dialysis) could have their
eligibility based on the underlying condition, with paratransit
need for a particular trip dependent on self-assessment or a set of
medical standards (eg., trip within a certain amount of time after
a dialysis session). On the other hand, persons in the second
eligibility category (people who can use accessible fixed route
service where it exists would to be given service on the basis of
the particular route they would use for a given trip.
Because entities are not precluded from providing service
beyond that required by the rule, an entity that believes it is too
difficult to administer a program of trip-by-trip eligibility is
not required to do so. Nothing prevents an entity from providing
all requested trips to a person whom the ADA requires to receive
service for only some trips. In this case. if the entity intends
to request an undue financial burden waiver, the entity, as
provided in the undue burden provisions of this rule, must
estimate, by a statistically valid technique, the percentage of its
paratransit trips that are mandated by the ADA. Only that
percentage of its total costs will be counted in considering the
undue burden waiver request.
Category 1 Eligibility
The first eligibility category includes, among others, persons
with mental or visual impairments who, as a result, cannot
.,navigate the system." This eligibility category includes people
who cannot board, ride, or disembark from an accessible vehicles
"without the assistance of another individual." This means that, if
an individual needs an attendant to board, ride, or disembark from
an accessible fixed route vehicles (including "navigating the
system"), the individual is eligible for paratransit. One
implication of this language is that an individual does not lose
paratransit eligibility based on "inability to navigate the system"
because the individual chooses to travel with a friend on the
paratransit system (even if the friend could help the person
navigate the fixed route system). Eligibility in this category is
based on ability to board, ride, and disembark independently.
Mobility training (e.g.. of persons with mental or visual
impairments) may help to improve the ability of persons to navigate
the system or to get to a bus stop. Someone who is successfully
mobility trained to use the fixed 'route system for all or some
trips need not be provided paratransit service for those trips.
The Department encourages entities to sponsor such training as a
means of assisting individuals to use fixed route rather than
paratransit.
Category 2 Eligibility
The second eligibility criterion is the broadest, with respect
to persons with mobility impairments, but its impact should be
reduced over time as transit systems become more accessible. This
category applies to persons who could use accessible fixed route
transportation, but accessible transportation is not being used at
the time and on the route, the persons would travel This concept is
route based, not system based.
Speaking first of bus systems. if a person traveling from
Point A to Point B on route and route 1 is accessible, the person
is n eligible for paratransit for the trip. This is true even
though other portions of the system are still inaccessible. If the
person is traveling from Point A to Point C on route 2, which is
not accessible, the person is eligible for trip. If the person is
traveling from point A to Point B on accessible route 1, with a
transfer at B to go on inaccessible route 3 to Point D then the
person is eligible for the second leg of the trip. (The entity
could choose to provide a paratransit trip from A to D or
paratransit or on-call bus trip from B to D For purposes of this
standard.
We view routes as accessible when all buses scheduled on the
route are accessible. Otherwise, it is unlikely that an accessible
vehicle could be provided "within a reasonable period of time" when
the individual wants to travel, as the provision requires. We
recognize that some systems' operations may not be organized in a
way that permits determining whether a given route is accessible,
even though a route-by-route determination appears to be
contemplated by the statute such cases, it may be that category 2
eligibility would persist until the entire system was eligible.
With respect to a rail system, an individual is eligible under
this standard if on the rail or line he or she wants to use, there
is not one car per train accessible or if key stations are not yet
accessible. This eligibility remains even if bus systems covering
the area served by the rail system have become 100 percent
accessible. This is necessary because people use rail systems for
different kinds of trip than bus systems. It would often take much
more in the way of time, trouble, and transfers for a person to go
on the buses of one or more transit authorities than to have a
direct trip provided by the rail operator. Since bus route systems
are often designed to feed rail systems rather than duplicate them,
it may often be true that " you can't get there from here" relying
entirely on bus routes or the paratransit service area that
parallels them.
If the lift on a vehicle cannot be deployed at a particular
stop, an individual is eligible for paratransit under this category
with respect to the service to the inaccessible stop. If on
otherwise accessible route 1, an individual wants to travel from
Point A to Point E and the lift cannot be deployed at E, the
individual is eligible for paratransit for the trip. (On-call bus
would not work as a mode of providing this trip, since a bus lift
will not deploy at the stop.) This in true even though service from
Point A to all other points on the line is fully accessible. In
this
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6, 1991 / Rules and Regulations
circumstance, the entity should probably think seriously about
working with the local government involved to have the stop moved
or made accessible.
When we say that a lift cannot be deployed, we mean literally
that the mechanism will not work at the location to permit a
wheelchair user or other person with a disability to disembark or
that the lift will be damaged if it is used there. It is not
consistent with the rule for a transit provider to declare a stop
off-limits to someone who uses the lift while allowing other
passengers to use the stop. However, if temporary conditions not
under the operator's control (e.g., construction, an accident, a
landslide) make it so hazardous for anyone to disembark that the
stop is temporarily out of service for all passengers may the
operator refuse to allow a passenger to disembark using the lift.
Category 3 Eligibility
The third eligibility criterion concerns individuals who have
a specific impairment related condition which prevents them from
getting to or from a stop or station. As noted in the legislative
history of the ADA, this is intended to be a "very narrow
exception" to the general rule that difficulty in traveling to or
from boarding or disembarking locations is not a basis for
eligibility.
What is a specific impairment-related condition? The
legislative history mentions four examples: Chronic fatigue,
blindness, a lack of cognitive ability to remember and follow
directions, or a special sensitivity to temperature. Impaired
mobility, severe communications disabilities (e.g., a combination
of serious vision and hearing impairments), cardiopulmonary
conditions, or various other serious health problems may have
similar effects. The Department does not believe that it is
appropriate, or even possible. to create an exhaustive list.
What the rule uses as an eligibility criterion is not just the
existence of a specific impairment-related condition. To be a
basis for eligibility, the condition must prevent the individual
from traveling to a boarding location or from a disembarking
location. The word "prevent" is very important. For anyone, going
to a bus stop and waiting for a bus is more difficult and less
comfortable than waiting for a vehicle at one's home. This is
likely to be all the more true for an individual with a disability.
But for many persons with disabilities, in many circumstances,
getting to a bus stop is possible. If an impairment related
condition only makes the job of accessing transit more difficult
than it might otherwise be, but does not prevent the travel, then
the person is not eligible.
For example, in many areas, there are not yet curb cuts. A
wheelchair user can often get around this problem by taking a less
direct route to a destination than an ambulatory person would take.
That involves more time, trouble, and effort than for someone
without mobility impairment. But the person can get to the bus
stop. On the basis of these architectural barriers, the person
would not a eligible.
Entities are cautioned that, particularly in involving lack of
curb cuts and other architectural barrier problems, assertions of
eligibility should be given tight scrutiny. Only if it is apparent
from the facts of a particular case that an individual cannot find
a reasonable alternative path to a location should eligibility be
granted.
If we add a foot of snow to the scenario, then the same person
taking the same route may be unable to get to the bus stop. If is
not the snow alone that stops him; it is the interaction of the
snow and the fact that the individual has a specific-impairment
related condition that requires him to push a wheelchair through
the snow that prevents the travel.
Inevitably, some judgment is required to distinguish between
situations in which travel is prevented and situations in which it
is merely made more difficult. In the Department's view, a case of
"prevented travel" can be made not only where travel is literally
impossible (e.g., someone cannot find the bus stop, someone cannot
push a wheelchair through the foot of snow or up a steep hill) but
also where the difficulties are so substantial that a reasonable
person with the impairment-related condition in question would be
deterred from making the trip.
The regulation makes the interaction between an impairment-
related condition an the environmental barrier (whether distance,
weather, terrain, or architectural barriers) the key to eligibility
determinations. This is an individual determination. Depending on
the specifics of their impairment-related condition, one individual
may be able to get from his home to a bus stop under a given se of
conditions, while his next-door neighbor may not.
Companions
The ADA requires entities to provide paratransit to one person
accompanying the eligible individual, with others served on a
space-available basis. The one individual who is guaranteed space
on the vehicle can be anyone - family member, business associate,
friend, date, etc. The provider cannot limit the eligible
individual's choice to type of companion. The transit authority
may require that the eligible individual reserve a space for the
companion when the individual reserves his or her own ride. This
one individual rides even if this means that there is less room for
other eligible individuals. Additional individuals beyond the
first companion are carried only on a space available basis; that
is, they do not displace other ADA paratransit eligible
individuals.
A personal care attendant (i.e., someone designated or
employed specifically to help the eligible individual meet his or
her personal needs) always may ride with the eligible individual.
If there is a personal care attendant on the trip, the eligible
individual may still bring a companion, plus additional companions
on a space available basis. The entity may require that, in
reserving the trip, the eligible individual reserve the space for
the attendant.
To prevent potential abuse of this provision, the rule
provides that a companion (e.g., friend or family member) does not
count as a personal care attendant unless the eligible individual
regularly makes use of a personal care attendant and the companion-
is actually acting in that capacity. As noted under 1 37.125, a
provider may require that as part of the initial eligibility
certification process, an individual indicate whether he or she
travels with a personal care attendant. If someone does not
indicate the use of an attendant then any individual accompanying
him or her would be regarded simply as a companion. To be viewed as
"accompanying" the eligible individual, a companion must have the
same origin and destination points as the eligible individual. In
appropriate circumstances, entities may also wish to provide
service to a companion who has either an origin or destination, but
not both, with the eligible individual (e.g., the individual's date
is dropped off at her own residence on the return trip from a
concert).
Section 37.125 ADA Paratransit Eligibility Process
This section requires an eligibility process to be established
by each operator of complementary paratransit. The details of the
process are to be devised through the planning and public
participation process of this subpart. The process may not impose
unreasonable administrative burdens on applicants, and, since it is
part of the entity's nondiscrimination obligations, may not involve
"user fees" or application fees to the applicant.
The process may include functional criteria related to the
substantive eligibility criteria of 37.123 and, where
appropriate. functional evaluation or testing of applicants. The
substantive eligibility process is not aimed at making a medical or
diagnostic determination. While evaluation by a physician for
professionals in rehabilitation or other relevant fields) may be
used as part of the process, a diagnosis of a disability is not
dispositive. What is needed is a determination of whether, as a
practical matter, the individual can use fixed route transit in his
or her own circumstances. That is a transportation decision
primarily, not a medical decision.
The goal of the process is to ensure that only people who meet
the regulatory criteria. strictly applied, are regarded as ADA
paratransit eligible. The Department recognizes that transit
entities may wish to provide service to other persons, which is not
prohibited by this rule. However, the eligibility process should
clearly distinguish those persons who are ADA eligible from those
who are provided service on other grounds. For example,
eligibility documentation must clearly state whether someone is ADA
paratransit eligible or eligible on some other basis.
Often, people tend to think of paratransit exclusively
in.terms of people with mobility impairments. Under the ADA, this
is not accurate. Persons with visual impairments may be eligible
under either the first or third eligibility categories. To
accommodate them, all documents concerning eligibility must be made
available in one or more accessible formats. on request.
Accessible formats include computer disks, braille documents. audio
cassettes, 'and large print documents. A document does not
necessarily need to be made available in that format a requester
prefers, but it does have to be made available,
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Federal Register / Friday September 6, 1991 / Rules and Regulations
45747
in a format the person can use. There Is no use giving a computer
disk to someone who does not have a computer, for instance, or a
braille document to a person who does not read-braille.
When a person applies for eligibility, the entity will provide
all the needed forms and and instructions. These forms and
instructions may include a declaration of whether the individual
travels with a personal care attendant. The entity may make further
inquiries concerning such a declaration (e.g.. with respect to the
individual's actual need for a personal care attendant).
When the application process is complete-all necessary actions
by the applicant taken-the entity should process the application in
21 days. If it is unable to do so, it must begin to provide
service to the applicant on the 22nd day, as if the application had
been granted. Service may be terminated only if and when the
entity denies the application. All determinations shall be
writing; in the case of a denial, reasons must be specified. The
reasons must specifically relate the evidence in the matter to the
eligibility criteria of this rule and of the entity's process. A
mere recital that the applicant can use fixed route transit is not
sufficient.
For people granted eligibility, the documentation of
eligibility shall include at least the following information:
- The individual's name
- The name of the transit provider
- The telephone number of the entity's paratransit coordinator
- An expiration date for eligibility
- Any conditions or limitations on the individual's eligibility,
including the use of a personal care attendant.
The last point refers to the situation in which a person is
eligible for some trips but not others. Or if the traveler is
authorized to have a personal care attendant ride free of charge.
For example, the documentation may say that the individual is
eligible only when the temperature falls below a certain point. or
when the individual is going to a destination not on an accessible
bus route, or for-non work trips. etc.
As the mention of an expiration date implies, certification is
not forever. The entity may recertify eligibility at reasonable
intervals to make sure that changed circumstances have not
invalidated or changed the individual's eligibility. In the
Department's view, a reasonable interval for recertification is
probably between one and three years. Less than one year would
probably be too burdensome for consumers; over three years would
begin to lose the point of doing recertifications. The
recertification interval should be stated in the entity's plan. Of
course, a user of the service can apply to modify conditions on his
or her eligibility at any time.
The administrative appeal process is intended to givve
applicants who have been denied eligibility the opportunity to have
their cases heard by an official other than the one who turned them
down in the first place. In order to have the appropriate
seperation of functions-a key element of administrative due
process-not only must the same person not decide the case on
appeal, but that person, to the extent practicable, should not have
been involved in the first decision (e.g., as a member of the same
office, or a supervisor or subordinate of the original decision
maker). When, as in the case of a small transit operator, this
degree of separation is not feasible, the second decision maker
should at least be "bubbled" with respect to the original decision
(i.e.. not have participated in the original decision or discussed
it with the original decision maker). In addition, there must be
an opportunity to be heard in person as well as the chance to
present written evidence and arguments. All appeals decisions must
be in writing, state the reasons for the decision. To prevent the
filing of stale claims, the entity may establish a 60 day "statute
of limitations" on filing of appeals, the time starting to run on
the date the individual is notified on the negative initial
decision. After the appeals process has been completed (ie., the
hearing and/or written submission completed). the entity should
make a decision within 30 days. If it does not, the individual
must be provided service beginning the 31st day, until and unless
an adverse decision is rendered on his or her appeal.
Under the eligibility criteria of the rule, an individual has
a right to paratransit if he or she meets the eligibility criteria.
As noted in the discussion of the nondiscrimination section, an
entity may refuse service to individual with a disability who
engages in violent, seriously disruptive, or illegal conduct, using
the same standards for exclusion that would apply to any other
person who acted in such an inappropriate way.
The rule also allows an entity to establish a process to
suspend, for a reasonable period of time, the provision of
paratransit service to an ADA eligible person who establishes a
pattern or practice of missing scheduled trips. The purpose. of
this process would be to deter or deal with chronic "no-shows." The
sanction system-articulated criteria for the imposition of
sanctions, length of suspension periods, details of the
administrative process, etc.-would be developed through the public
planning and participation process for the entity's paratransit
plan, and the result reflected in the plan submission to UMTA.
It is very important to note that sanctions could be imposed
only for a "pattern or practice" of missed trips. A pattern or
practice involves intentional, repeated or regular actions, not
isolated. accidental, or singular incidents. Moreover, only
actions within the control of the individual count as part of a
pattern or practice. Missed trips due to operator error are not
attributable to the individual passenger for this purpose. If the
vehicle arrives substantially after the scheduled pickup time, and
the passenger has given up on the vehicle and taken a taxi or gone
down the street to talk to a neighbor, that is not a missed trip
attributable to the passenger. If the vehicle does not arrive at
all, or is sent to the wrong address, or to the wrong entrance of a
building, that is not a missed trip attributable to the passenger.
There may be other circumstances beyond the individual's control
(e.g., a sudden turn for the-worse in someone with a variable
condition; a sudden family emergency) that make it impracticable
for the individual to travel at the scheduled time and also for the
individual to notify the entity in time to cancel the trip before
the vehicle comes. Such circumstances also would not form part of
a sanctionable pattern or practice.
Once an entity has certified someone as eligible, the
individual's eligibility takes on the coloration of a property
right. (This is not merely a theoretical statement. If one depends
on transportation one has been found eligible for to get to a job,
and the eligibility is removed. one may lose the job. The same can
be said for access to medical care or other important services.)
Consequently, before eligibility may be removed "for cause"
under this provision, the entity must provide administrative due
process to the individual.
If the entity proposes to impose sanctions on someone, it must
first notify the individual in writing (using accessible formats
where necessary). The notice must specify the basis of the
proposed action (e.g., Mr. Smith scheduled trips for 9 a.m. on May
15, 2 p.m. on June 3, 9 a.m. on June 21, and 9:20 p.m. on July 10.
and on each occasion the vehicle appeared at the scheduled time and
Mr. Smith was nowhere to be found) and set forth the proposed
sanction (e.g., Mr. Smith would not receive service for 15 days).
The entity would provide the individual an opportunity to be
heard (i.e., an in-person informal hearing before a decision maker)
as well as to present written and oral information and arguments.
All relevant entity records and personnel would be made available
to the individual and other persons could testify. It is likely
that, in many cases, an important factual issue would be whether a
missed trip was the responsibility of the provider or the
passenger, and the testimony of other persons and the provider's
records or personnel are likely to be relevant in deciding this
issue. While the hearing is intended to be informal, the
individual could bring a representative (e.g., someone from an
advocacy organization, an attorney).
The individual may waive the hearing and proceed on the basis
of written presentations. If the individual does not respond to
the notice within a reasonable time, the entity may make, in
effect, a default finding and impose sanctions. If there is a
hearing, and the individual needs paratransit service to attend the
hearing, the entity must provide it. We would emphasize that,
prior to a finding against the individual after this due process
procedure, the individual must continue to receive service. The
entity cannot suspend service while the matter is pending.
The entity must notify the individual in writing about the
decision, the reasons for it, and the sanctions imposed. if any.
Again this information would be made available in accessible
formats. In the case of a decision adverse to the individual. the
administrative appeals process of this section would apply. The
sanction would be stayed pending an appeal.
There are means other than sanctions. however; by-which a
transit provider can deal with a "no show" problem in its system.
Providers who use "real time scheduling" report that this technique
is very effectiive in
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45748 Federal- Register / Vol. 56, No. 173 / Friday, September
6, 1991 / Rules and Regulations
reducing no-shows and cancellations, and increasing the mix of real
time scheduling in a system can probably be of benefit this areas.
Calling the customer to reconfirm a reasonable time before pickup
can head-off some problems, as can educating consumers to call with
cancellations ahead of time. Training of dispatch and operator
personnel can help to avoid miscommunications that lead to missed
trips.
Section 37.127. Complementary Paratransit for Visitors:
This section requires each entity having a complementary
paratransit system. to provide service to visitors from out of town
oh the same basis as it is provided to local residents. By "on the
same basis," we mean under a] I the same conditions, service
criteria, etc., without distinction. For the period of a visit the
visitor is treated exactly like an eligible local user, without any
higher priority being given to either.
A visitor in defined as someone who does not reside in the
jurisdiction or jurisdictions served by the public entity or other
public entities with which it coordinates paratransit service. For
example, suppose a five-county metropolitan area provides
coordinated paratransit service under a joint plan. A resident of
any of the five counties would not be regarded as a visitor in any
of them. Note that the rule talks in terms of "jurisdiction"
rather than "service area." If an individual lives in PQR County,
but outside the fixed route service area of that county's transit
provider, the individual is still not a visitor for uses of
paratransit in PQR County, if PQR is in one of the counties with
which XYZ provides coordinated paratransit service.
A visitor can become eligible in one of two ways. The first
is to present documentation from his or her "home" jurisdiction's
paratransit system. The local provider will give "full faith and
credit" to the ID card or other documentation from the other
entity. if the individual has no such documentation, the local
provider may require the provision of proof of visitor status
(i.e., proof of residence somewhere else) and, if the individual's
disability is not apparent. proof of the disability (e.g., a letter
from a doctor or rehabilitation professional). Once this
documentation is presented and is considered satisfactory, the
local provider will make service available on the basis of the
individual's statement that he or she is unable to use the fixed
route transit system.
The local provider need serve someone based on visitor
eligibility for no more than 21 days. After that, the individual
is treated the same as a local-person for eligibility, purposes.
This is true whether the 21 days are consecutive or parceled out
over several shorter visits. The local provider may require the
erstwhile visitor to apply for eligibility in the usual local
manner. A visitor who expects to be around longer than 21 days
should apply for regular eligibility as mm as he arrives. The same
approach may be used for a service of requested visits totaling 21
days or more in a relating compact period of time. Preferably.
this application process should be arranged before the visitor
arrives. by letter, telephone or fax, so that a complete
application can be processed expeditiously.
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ADA Paratransit Eligibility Manual
Appendix B
ADA Paratransit Eligibility Policy Checklist
ADA Paratransit Eligibility Manual
ADA Paratransit Eligibility Policy Checklist
Following is a list of required and recommended elements of an ADA
paratransit eligibility policy. Those in bold are required by the
regulations and must be included in the policy.
- Is the definition of ADA paratransit eligibility included in
the policy consistent with the regulatory definition of
eligibility?
- Does the definition of eligibility allow for one companion and
a personal care attendant in all cases and additional
companions on a space available basis?
- Does the definition of eligibility address the policy for
visitors, note that service will be provided to those who have
been determined eligible by another public entity as well as
those who claim to be eligible?
- Does the visitor portion of the policy indicate the period of
time, from the date of the first trip, over which 21 days of
service will be provided?
- Does the visitor portion of the policy indicate what
documentation of residence and disability will be accepted and
when this will be required?
- Is the eligibility process and application material used
detailed enough to identify not only who is eligible but under
what conditions and circumstances they are eligible?
- Have arrangements been made to produce information about the
process, materials needed to apply, notifications of
eligibility, and other materials in accessible formats upon
request?
- Does the policy provide for other assistance, such as a phone
number to call or staff to provide individual assistance, that
individuals may need to understand the process and complete
application forms?
- Does the policy describe marketing and public information
efforts to inform riders, potential riders, and other
individuals and organizations about ADA paratransit
eligibility?
- Does the policy describe the process that is used to make
initial determinations?
- Does the policy indicate who will make initial determinations?
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ADA Paratransit Eligibility Manual-
ADA Paratransit Eligibility Policy Checklist, Page 2-
- Does the policy indicate that applicants will be notified in
writing, and other accessible formats as required, of the
initial decision regarding their eligibility?
- Does the policy note that applicants determined ineligible or
conditionally eligible will be given the specific reasons for
the reasoning when they receive their notification of the
initial determination and that these reasons will specifically
relate to the ADA paratransit eligibility criteria?
- Does the policy state that individuals will be provided
service on a presumption -of eligibility if an initial
determination is not made within 21 days of the receipt of a
completed application?
- Does the policy indicate the form of documentation that will
be provided to individuals determined ADA Paratransit Eligible
and include each of the following items in this documentation?
- the name of the eligible individual
- the name of the transit provider providing the
certification the telephone number of the transit
provider's paratransit coordinator
- an expiration date for eligibility (if applicable)
- any conditions or limitations on the individual's
eligibility
- the need for a personal care attendant
- Does the policy note that individuals determined ineligible or
conditionally eligible will be notified of the process to
appeal the decision?
- Is the appeal process and the person or persons who will hear
and decide appeals described and is there a "separation of
function" between those hearing appeals and those involved in
initial determinations?
- Does the appeal process note that appeals will be accepted
within 60 days of the initial eligibility decision?
- Does the appeal process offer the individual an opportunity to
be heard in person to present additional information and
arguments?
- Does the policy include details for providing accommodations
that the person may need at the appeal hearing and note how
the need for accommodations will be determined?
- Does the policy indicate that appeal decisions will be made in
writing, and in accessible formats as appropriate, and will
detail any reasons for a continued reason of ineligibility or
conditional eligibility?
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ADA Paratransit Eligibility Manual
ADA Paratransit Eligibility Policy Checklist, Page 3
- Is it noted that applicants will be provided paratransit
service on a presumption of eligibility if a decision on their
appeal is not made within 30 days of the completion of the
appeal process?
- Does the policy indicate the period of time for which ADA
paratransit eligibility will be granted and specify
recertification requirements for those found eligible?
- Does the policy address requirements for existing riders to be
recertified?
- Does the policy indicate under what circumstances service may
be refused, suspended, or conditioned?
- If included, does the no-show suspension policy include the
number/frequency of no shows that will be considered a
"pattern or practice" and the period of suspension'.)
- If included, does the no-show suspension policy provide for
notification of the proposed suspension, an opportunity for an
informal hearing, and an opportunity for a formal appeal?
- Have all aspects of the ADA paratransit eligibility policy
been developed with fun public participation as required in
37.137 of the regulations?
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ADA Paratransit Eligibility Manual
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ADA Paratransit Eligibility Manual
Appendix C
Listing of Selected Transit Providers Contacted
for Information in the Preparation of this Manual
ADA Paratransit Eligibility Manual
Selected Transit Providers Contacted
for Information in the Preparation of this Manual
Name of Transit Provider Contact Person Phone
Ann Arbor Transportation Authority Mr. Christopher White
Ann Arbor, NE (313) 677-3922
Ben Franklin Transit Mr. Ed Frost
Richland, WA (509) 735-4131
City of Charlotte Mr. Terry Lathrop
Charlotte, NC (704) 336-2261
Delaware Administration for
Specialized Ms. Robin Boshell
Transportation (DASI) (302) 739-3278
Dover, DE
City of Durango Ms. Jan Choti
-Durango, CO (303) 385-2880
Greater Bridgeport Transit District Ms. Kimberlee Kelly
Bridgeport, CT (203) 366-7070
City of Greeley Mr. John Lee
Greeley, CO (303) 350-9280
Lane Transit District Ms. Micki Kaplan
Eugene, OR (503) 741-6100
Los Angeles County Metropolitan Mr. Richard DeRock
Transportation Authority (213) 244-6524
Los Angeles, CA.
Madison Metro Transit System Mr. Paul Larrousse
Madison, WI (608) 267-8777
Mass Transit Administration (MTA) Ms. Lisa Darnall
Baltimore, MD (410) 333-3328
Municipality of Metropolitan Seattle Ms. Nancy Poultney
(METRO) (206) 689-3107
Seattle,.WA
New York City Transit Authority Ms. Margaret Coffey
New York, NY (718) 694-3414
OMNITRANS Mr. Daniel Brogan
San Bernardino, CA (909) 889-0811
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ADA Paratransit Eligibility Manual
Name of Transit Provider Contact Person Phone
Oshkosh Transit System Mr. Mark Huddleston
Oshkosh, WI (414) 236-5280
Port Authority of Allegheny County (PAT) Ms. Cathy Williams
Pittsburgh, PA (412) 237-7335
Regional Transportation Authority Ms. Shirley Fraser
Chicago, IL (312) 917-1426
Riverside Transit Agency Ms. Susan Hafner
Riverside, CA (909) 684-0850
San Mateo County Transit District Ms. Dianna Lake
(SAMTRANS) (415) 508-6241
San Carlos, CA
Southeastern Pennsylvania Transportation Mr. Jon Roth
Authority (SEPTA) (215) 580-7711
Philadelphia, PA
Transit Authority of River City (TARC) Ms. Tina Morris
Louisville, KY (502) 561-5100
Utah Transit Authority Ms. Kathy McCune
Salt Lake City, UT (801) 262-5626
Washington Metropolitan Area Mr. Avon Makel
Transportation Authority (WMATA) (202) 962-1100
Washington, DC
Waukesha Transit System Mr. Robert Johnson
Waukesha, WI (414) 524-3594
Worcester Regional Transit Authority Ms. Gail Heald
Worcester, MA (508) 756-7717
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ADA Paratransit Eligibility Manual
Appendix D,
Sample Marketing and Public information Materials
Materials included:
- "Paratransit Services on the Move with ADA" developed by
Seattle Metro.
- "Eligibility Appeals Process" developed by Seattle Metro.
- "Special Services Certification" developed by the
Regional Transportation Authority of Chicago.
- "The Americans with Disabilities Act: What is the ADA and
how does it affect me?" prepared by the Riverside Transit
Agency.
- Notice of public forum to discuss ADA issues developed by
the Worcester Regional Transit Authority.
Copies of this brochure are available in large print, In Braille or
on audiotape by calling 689-3113 (voice) or 689-3116 (TDD).
Metro's Current Programs For People With Disabilities
- Regional Reduced Fare Permit
A card that allows people who have a disability or who are 65
or older to pay a lower fare on 8 bus systems throughout the Puget
Sound Region.
- Special Transportation Service Program (STSP)
A sticker that allows low-income people with Regional Reduced
Fare Permits to use Reserve-A-Ride and Taxi Scrip:
- Reserve-A-Ride is a door-to-door van service provided for
Metro by North/East King County VanGo, Seattle Personal
Transit, Neighborhood House, Transia and South King
County VanGo.
- Taxi Scrip is discounted taxi fare scrip; users may buy
up to four $5 books per month. Each $5 book is worth $10
in taxi fares.
For more information on Metro's Regional Reduced Fare Permits,
Reserve-A-Ride or Taxi Scrip programs, call 553-3060.
Click HERE for graphic.
D-1
All Aboard
Everyone should be able to use public transportation to get
where they need to go. Since 1979, Metro has provided accessible
bus service for people with disabilities, plus door-to-door van
services for those unable to use the bus.
Beginning in late 1993. Metro's new ADA (Americans with
Disabilities Act) Paratransit Services will make it easier for
people With disabilities to use public transportation, no matter
what their income level.
Here is information on important changes that affect people
with disabilities - including instructions for. getting the
identification card you will need to participate in the new ADA
Paratransit Services.
Good News For People With Disabilities
- New ADA Paratransit Services
If you have a disability which prevents you from using Metro's
regular bus service, you may be eligible for the new ADA
Paratransit Services.
The service will begin in late 1993. It features brand new
specially-equipped vans that take you to and from any location in
King County, and will be available Monday through Saturday, 5:00
a.m. to 10:00 P.M.
- Qualifying for ADA Paratransit Services
There are three levels of eligibility for the new ADA
Paratransit Services:
- Regular - if your disability prevents you from using the
bus at all times..
- Conditional - if your disability prevents you from using
the bus only under certain conditions, such as snow.
- Temporary - if your disability prevents you from using
the bus for a limited period of time.
- All ADA Paratransit Services users will need a special Iden-
ification card. Even users of Metro's current Special
Transportation Service Program, such as the Reserve-A-Ride and
Taxi Scrip programs, will need to fill out an application.
There is no low-income requirement.
Although ADA Paratransit Services do not begin until later in
1993, it's a good idea to apply for the identification card now.
Simply fill out an application form and mail it to Metro. It you
need an application, call Metro at 689-3113 (voice) or 689-3116
(TDD).
- Uninterrupted Service
By applying now, you will be ready when Metro begins the new
ADA Paratransit Services. Until then, there will be no change in
the Reserve-A-Ride or Taxi Scrip programs.
- Plus - More Accessible Buses and Routes
By 1995, all Metro buses and routes will be accessible for
people with disabilities. Today 80% of Metro's 1200 buses are
equipped with wheelchair lifts, and 75% of
D-2
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Metro has received your application for ADA Paratransit Service.
Based on the information you have provided, we have determined that
you are either NOT ELIGIBLE, or CONDITIONALLY ELIGIBLE.
if you disagree with this decision, you have the right to appeal.
Here's what you need to do: I
- within sixty days after you get your eligibility determination
letter, write a brief letter telling us why you disagree.
- send the letter to:
Paratransit Eligibility Appeals
METRO,, MS 134
821 Second Avenue
Seattle,, WA 98104-1598
- participate in an evaluation of your ability to use the bus.
If you have already done this, you do not need to do it again.
- either attend an appeal meeting, OR send written information
for that meeting.
- The Appeal Meeting
By law, your appeal must be handled by an independent party. So,
Evergreen Hospital will arrange for a qualified professional to
serve as an appeal officer and make a final eligibility
determination.
If you have not already had an evaluation of your ability to use
the regular bus, Evergreen Hospital will arrange that, too.
And, if you need it, Evergreen Hospital will also arrange
transportation for both the evaluation and the appeal meeting.
The appeal meeting will be held within 30 days after we get your
letter. -You do not need to attend the meeting. Instead, you may
send information to the appeal officer. If you do decide to
attend, you may bring another person with you.
Aids and services related to your disability (such as Brailled
material, voice amplification, sign language-interpreter) will be
provided if you request them at least a week before the meeting.
There will be NO COST TO YOU for any of these services.
You will be notified of the appeal officer's final eligibility
determination-within 30 days after Metro gets your appeal letter.
Once this final determination has been made, the eligibility
appeals process is completed.
It at any time in the future you feel your condition has changed,
you may reapply for ADA Paratransit Service.
- Questions?
For more information about .eligibility for Metro's ADA Paratransit
Service, please call 689-3113 (voice) or 689-3116 (TDD).
Copies of this brochure are available in large print, in braille,
or on audio tape.
Accessible Services Section,
METRO, MS 134
821 Second Avenue
Seattle, WA 98104-1598.
D-4
Click HERE for graphic.
D-5
Click HERE for graphic.
MAY I HAVE THE ENVELOPE PLEASE?
The RTA is changing to meet the challenges of the Americans
with Disabilities Act. To bring our public transportation system
to ADA compliance, the Regional Transportation Authority will
certify users of CTA and Pace Special Services and ensure mainline
access for everyone.
The first step of certification for users of Special Services
will arrive in the form of a RED ENVELOPE through the mail,
beginning this summer. You will be asked to fill out and return
the questionnaire. Certification will be based on each person's
functional ability to use public transportation.
WHERE TO TURN FOR HELP
If you need assistance in filling out the application, or have
any questions on the process, contact the RTA's Certification
Hotline at 312-917-HELP or at our TTY number, 312-917-1338.
AND THE WINNER IS...
You, our riders. These changes will ultimately mean better
service for everyone. We will continue to provide Special Services
for those who need it. And for those who do have the functional
ability, training will be provided on how to use buses and trains
in our region.
Were changing to meet the challenges of ADA.
The RTA. Making Transit work for everyone.
D-6
Questions most often asked...
Click HERE for graphic.
Question: What is the new certification for Special Services?
Answer: The Americans with Disabilities Act (ADA) requires some
changes to Special Services at CTA and Pace. One change is the way
it is determined who can use Special Services. Everyone must go
through the new certification. The ADA requires that the new
certification be based on a person's functional ability to take
transit.
Question: What is a "functional" certification?
Answer: A functional certification determines whether a person
has the ability to use bus and rapid transit service. The new
certification will NOT look at the type of disability you have.
Instead, the new certification determines if you are able to do
such things as travel to a bus stop or rapid transit station, board
a vehicle, and pay a fare.
Question: Why is the ADA changing the way people are certified to
ride Special Services?
Answer: The ADA wants you to have better access to the community.
The new certification will encourage people to use bus and rapid
transit if they can. The new certification will assure that
Special Services rides are used only by persons who really need the
service.
Question: Who can be certified for Special Services under the new
ADA rules?
Answer: There are three ways you can be eligible for Special
Services: 1) If you cannot use bus or rapid transit, even when it
is accessible. 2) If you are able to use bus or rapid transit, but
the equipment or station is not yet accessible. Or, 3) if your
disability prevents you from getting to or from the bus stop or
rapid transit station.
An example of the third way you can be eligible might be: You are
normally able to ride buses and rapid transit, except that your
disability prevents you from walking outside in very cold weather.
In this case, you would be certified to ride Special Services
during the winter months.
Question: If I am currently registered for Special Services, can I
continue to ride Special Services under the new ADA rules?
Answer: No. You must apply for the new certification.
Question: When does the new certification happen?
Answer: if you are now registered for Special Services, you can
continue to ride for about another year, until the summer of 1994.
At that time, you will need the new certification to continue to
ride.
D-7
...And the Answers You Need
Question: How do I apply for the new certification?
Answer: if you are currently registered for Special Services, you
will receive a red envelope in the mail, containing a new
certification application, sometime in the next year. You will
have plenty of time to Pill it out. If you are a new rider, call
the Certification Hotline at 312/917-HELP for more information.
Question: What if I need help filling out the new certification
application?
Answer: Help is available at many locations in the Chicago area.
Call the Certification Hotline at 312/917-HELP for the location
nearest you. if you need the application in large print, in
Braille, in Spanish, or on an audio tape,
call us at 312/917-HELP.
Question: What if under the new ADA rules I am no longer certified
to ride Special Services?
Answer: You will Find that buses and rapid transit give you better
access to the Chicago area, since you do not have to call in
advance to plan your trip. Because of the new ADA rules, more and
more buses, rapid transit cars, and stations will become accessible
in the next few years. For those who will no longer be certified
for Special Services, there will be training available to learn how
to use buses and rapid transit.
For the most convenient service,
consider making your trek on mainline
You don't have to call ahead ... you'll never be turned away,
and... you can ride anytime - day or night - on CTA rail cars and
buses, Pace suburban buses, or METRO commuter rail.
If you are functionally able to ride the RTA system, and would like
route information, call the Travel Information Center at 836-7000,
city or suburbs.
To be trained on taking mainline, call the ADA Certification
Hotline at 312-917-HELP.
For 24-hour service and complete flexibility, make it on mainline.
Click HERE for graphic.
D-8
THE AMERICANS WITH DISABILITIES ACT
What is the ADA and how does it affect me?
Click HERE for graphic.
Answers to your questions on ADA and how it impacts public
transit services.
Prepared by the
Riverside Transit Agency
(909) 682-1234
1 (800) 800- RTA1
TDD
1 (800) 800-7825
RTA
RIVERSIDE TRANSIT AGENCY
WHAT IS THE AMERICANS WITH DISABILITIES ACT (ADA)?
ADA is a Federal law that guarantees specially certified disabled
Americans full and equal access to the same services and
accommodations that are available to people without disabilities.
WHAT IS RTA REQUIRED TO DO UNDER ADA?
The Riverside Transit Agency (RTA) must make its regular bus system
completely accessible for use by people with disabilities. This
includes maintaining wheelchair lifts on buses and adding features
for people with hearing and vision impairments. RTA currently
operates a 100% wheelchair accessible service.
If a person is unable to use RTA's regular bus system because of
his/her disability, RTA must provide ADA priority van service that
is comparable to the fixed route service.
Click HERE for graphic.
for information regarding ADA priority van service,
call RTA at 1(800)800-RTA1 OR TDD: 1(800)800-7825
WHAT IS ADA PRIORITY VAN SERVICE?
ADA priority van service's comparable to the level of fixed route
bus service provided by RTA. This means that ADA priority service
is provided wherever the regular bus service operates and during
the same days and hours. In addition, ADA priority van service
meets the following requirements for those who are eligible:
- A person can call the day before a ride is needed to request a
trip.
- Trips can be requested up to 14 days in advance.
- Subscription service is available, but restrictions may apply
- Fares can be no more than twice the RTA mixed route base fare
for the same trip.
- Trips can be requested for any purpose.
- An eligible person's access to van service cannot be limited
by patterns of refUsals, unusually long trips, late pick ups,
or other Such factors.
WHEN WILL ADA PRIORITY VAN SERVICE BEGIN?
- ADA priority service will be phased in over the next 5 years.
- Once certified, an individual may request ADA Priority
Service.
- The ADA certification process began in October 1992.
D-9
RTA Riverside Transit Agency
1825 Third Street
Riverside, CA 92507-3484
This pamphlet is designed to introduce you to the ADA and to
explain the impact it will have on service provided by the
Riverside Transit Agency (RTA). If you have any unanswered
questions, or if you need an ADA registration form, please call
(909) 684-0850
WHO IS ELIGIBLE FOR ADA LEVEL VAN SERVICE?
The intent of ADA is to insure that persons with specific
disabilities have equal access to public transportation.
RTA expects that many disabled individuals will be able to use the
regular bus service. However, ADA priority van service will act as
a "safety net" for individuals whose disabilities Prevent them from
using the buses. Examples of individuals who can use the priority
van service under ADA are as follows:
- Certified Individuals who cannot use the RTA bus service
because of their inability to get around on their own.
- A personal assistant accompanying an ADA eligible individual.
Such an assistant is considered a mobility aid.
- One traveling companion accompanying the ADA eligible rider.
Additional traveling companions are permitted only if space is
available without displacing a disabled rider. Companions pay
the same fare and must have the same pick up point and
destination point as the ADA eligible rider.
- ADA eligible riders from anywhere in the United States may
ride the service when they are visiting in the RTA area.
DO CURRENT DIAL-A-RIDE USERS WITH DISABILITIES HAVE TO REGISTER FOR
ADA LEVEL SERVICE?
YES, but only if they require ADA level service. Others do not
have to register to keep using Dial-A-Ride (see below).
ADA priority service will be available only to those who go through
the ADA certification process. If an individual applies for ADA
priority service and is refused, he/she can call the RTA office at
684-0850 for information on the appeal process.
WILL DIAL-A-RIDE SERVICE STILL BE AVAILABLE FOR SENIORS AND PERSONS
WITH DISABILITIES WHO ARE NOT ADA ELIGIBLE?
YES! RTA will maintain existing levels of service for non-ADA
eligible riders subject to funding availability. However, ADA
eligible riders will receive priority over non-ADA eligible riders.
IF A PERSON CAN'T ARRANGE A VAN RIDE, HOW CAN HE/SHE ACCESS PUBLIC
TRANSPORTATION?
Travel training is available for disabled individuals of all ages
and elderly individuals without disabilities. This special
training can give people the skills and experience to feel
comfortable riding the regular bus system. Please call the RTA
office at (909) 684-0850 for information on travel training
D-10
TPAG MEETING/FORUM
WHEN: TUESDAY, SEPTEMBER 14,1993
TIME: 7:00 P.M.
PLACE: WORCESTER REGIONAL TRANSIT AUTHORITY ADVISORY BOARD ROOM
287 GROVE STREET WORCESTER, MA
SUBJECT: AMERICANS with DISABILITIES ACT (ADA) OVERVIEW
Since the Americans with Disabilities Act (ADA) was passed,
there have been a number of questions raised by both the elderly
and disabled community. This Forum will help answer any questions
regarding the act and how the act effects consumers with their
transportation needs.
The forum will be set-up with a Moderator and a panel of (4)
Speakers who will discuss the various aspects of ADA. After their
presentations, there will be a Question & Answer period for anyone
who may have additional questions.
This forum is being done in conjunction with the TPAG Meeting.
The TPAG Meeting will take place at 7:00 p.m. and the Forum will
begin at approximately 7:30 p.m.
As always, free transportation is available by calling the
Worcester Area Van Express (WAVE) at 756 - 7149.
We look forward to seeing you at the Forum!
D-11
ADA Paratransit Eligibility Manual
Appendix E
Sample Eligibility Material Developed by:
San Mateo County Transit District (SAMTRANS)
Materials included:
- Cover Letter to Applicants
- Application Form
- Eligibility Review Guidelines
samTrans
BOARD OF DIRECTORS
JOHN R. ASMUS
JERROLD D. BUCK. Chairman
FRANK T. CANNIZZARO
MADALYN T. FITZPATRICK
ARTHUR L. LLOYD. Vice Chair
TOM NOLAN
WILLIAM J. SCHUMACHER
WILLIAM J. STANGEL
ALBERT M. TEGLIA
GERALD T. HAUGH
General Manager
To Redi-Wheels Applicant:
Thank you for your interest in Redi-Wheels, SamTrans' paratransit
service for people with disabilities. Redi-Wheels' service area
includes most of San Mateo County with the exception-of the coast
and parts of Pacifica.
To enable us to determine your eligibility, please complete the
enclosed application explaining how your disability prevents you
from riding regular SamTrans fixed route buses. You may complete
the form yourself or have it filled out by a qualified professional
familiar with your condition. If you fill the form out yourself,
you must complete the bottom of Page 5 which provides permission
for SamTrans to contact a qualified professional to verify your
condition. A large-type application form is available on request.
Return the completed application to:
Redi-Wheels
P.O. Box 3006
San Carlos CA 94070-1306
If you qualify for Redi-Wheels transportation, you will be mailed
your Redi-Wheels membership card and ride-reservation information
within one week of the date your application is received. The
membership card is valid for three years from the date of issue.
If you do not qualify for Redi-Wheels, a letter will be mailed to
you explaining the reason and advising you of procedures to follow
if you wish to appeal.
If for any reason, you are not contacted within 21 days of
applying, you will be entitled to receive Redi-Wheels service at
least until you receive a definite decision on your application.
If you have any questions about the Redi-Wheels program, or if you
need help filling out the application, please call the Elderly and
Disabled Program Assistant at 508-6241.
SAN MATEO COUNTY TRANSIT DISTRICT
1250 San Carlos Avenue - P.O. Box 3006
San Carlos, California 94070-1306 (415) 508-6200
E-1
Exp. Date: _________
Aide Type: __________
Attendant: __________
REDI-WHEELS APPLICATION
(Please print or type)
All questions must be answered
1. Name: ______________________________________________________
2. Street Address: ____________________________________________
City: _____________________ Zip:__________________________
3. Home telephone: __________ 4. Date of birth: __________
Work telephone: __________
5. Emergency Contact person: __________________________________
Phone number: __________
6. If this application is being filled out by someone other than
the person requesting certification, please complete the
following:
Name: ______________________________________________________
Relationship to Applicant: _________________________________
Daytime Phone ________________
7. Describe your disability and explain in detail how it prevents
you from using SamTrans' bus service some of the time or all
of the time.
______________________________________________________________
______________________________________________________________
______________________________________________________________
8. Is your condition...
_____ Permanent? _____ Temporary? Expected duration: ________
E-2
9. Are there any other effects of your disability of which we
need to be aware?
______________________________________________________________
______________________________________________________________
10. Do you use any of the following mobility aids? (Check all that
apply)
_____ Manual Wheelchair _____ Crutches _____ Dog Guide
_____ Electric Wheelchair _____ Cane _____ Walker
_____ Three-Wheeled Scooter/Wheelchair _____ Braces
11. Do you need someone to accompany you to travel outside the
home, for example, a personal care attendant?
_____ Yes _____ No _____ Sometimes
12. PLEASE ANSWER ALL OF THE FOLLOWING QUESTIONS.
a. Are you able to board and disembark from a standard transit
bus with a wheelchair lift?
_____ Yes _____ No. Please explain:_________________
___________________________________________________________________
b. Are you able to travel to the nearest bus stop?
_____ Yes _____ No. Please explain:_________________
__________________________________________________________________
c. Are you able to wait at the bus stop:7.
_____ Yes _____ No. Please explain: _______________
__________________________________________________________________
-2-
E-3
d. Are you able to identify the correct bus?
_____ Yes _____ No. Please explain: _____________________
___________________________________________________________________
e. Are you able to handle/grasp coins (pay fare), tickets,
railings, handles.)
_____ Yes _____ No. Please explain: _____________________
___________________________________________________________________
f. Are you able to keep balance while seated on a moving vehicle?
_____ Yes _____ No. Please explain: _____________________
___________________________________________________________________
9. Are you able to read, hear, understand and/or process
information, schedules, or directions which are needed to make
necessary decisions during a trip.7
13. If you can use a lift-equipped bus, are you unable to ride
because . . .
_____ One or more routes you want to ride do not have lift-
equipped buses?
_____ The lift cannot be operated at stops where you need to
board?
_____ Your wheelchair can't be accommodated on a transit
vehicle?
_____ Other?
Please explain (include routes, stop locations, and the type,
size, securement devices, dimensions and weight of your
wheelchair):
______________________________________________________________
______________________________________________________________
______________________________________________________________
______________________________________________________________
-3-
E-4
14. Are you prevented from travelling to or from a boarding
location for one or more of the following reasons?
_____ Inability to negotiate hilly terrain
_____ Extreme sensitivity to climatic conditions
_____ Allergic/environmental sensitivities
_____ Hyper-fatigue, frailty
_____ Night-blindness
Inability to cross busy intersections Other reasons.
Please explain:
______________________________________________________________
______________________________________________________________
IF THE APPLICANT HAS A COGNITIVE DISABILITY, THE FOLLOWING QUESTION
MUST BE ANSWERED BY A QUALIFIED PROFESSIONAL FAMILIAR WITH THE
APPLICANT'S ABILITIES.
15. Is the applicant able to perform the following functions
without supervision?
a. Find his/her way between familiar locations?
_____ Yes _____ No _____ Yes, with training
b. Signal the bus driver to get off at a familiar bus stop and
get off the bus there? (Assume the driver announces all major
stops.)
_____ Yes _____ No _____ Yes, with training
c. At a bus stop served by more than one bus route, distinguish
the correct bus to board and indicate intention to board?
_____ Yes _____ No _____ Yes, with training
-4-
E-5
16. 1 hereby certify that the information given in this
application is correct.
Signature: _________________________________ Date: __________
Applicant
Signature of other person completing this form:
____________________________________________ Date: __________
Print name: ________________________________
I hereby authorize _______________________________ to release to
name and phone number of professional
San Mateo County Transit District certain information about my
disability in order to verify my eligibility for a Redi-Wheels
membership card. The information released will be used solely to
determine my eligibility for Redi-Wheels.
I realize that I have the right to receive a copy of this
authorization.
I understand that I may revoke this authorization at any time.
Unless earlier revoked, this form will permit the health
professional who is certifying my disability to release the
information described until 60 days after the date appearing below.
___________________________________ _________________________
name of applicant (please print) date signed
___________________________________
signature of applicant
-5-
E-6
Click HERE for graphic.
E-7
ADA Paratransit Eligibility Manual
Appendix F
Sample Eligibility Material Developed by:
Madison Metro Transit System
Materials included:
- Instructions with Detailed Explanation of Eligibility
- Application Form
MADISON METRO+PLUS TRANSIT SYSTEM
APPLICATION FORM
Please review this application form carefully. Read the
description of the various disabilities which is based on the
Americans with Disabilities Act of 1990.
This application will be reviewed and eligibility will be
determined by Metro+Plus staff. Staff may consult the appropriate
professional expert regarding your eligibility at any stage of the
certification process if it is deemed necessary. It is extremely
important that the form is filled out completely. Any incomplete
applications will be returned without being processed. Within 21
days of receipt of a completed application, an eligibility
determination will be made. The submission of this application
does not guarantee eligibility. Metro+Plus' determination will be
in writing, and will inform the applicant of the acceptance or
denial of eligibility, and in the case of a denial, the reason(s)
for such. In the event eligibility is made conditional or denied,
a fun description of the appeals process shall be included with the
written determination.
Disabilities are described in the following three categories:
1. Mental impairment, including development disabilities
a. Is attributable to a mental or physical impairment or a
combination of mental and physical impairments;
b. Is likely to continue indefinitely;
c. Results in substantial functional limitations in any of the
following areas of major life activities: self-direction,
learning, mobility, economic self-sufficiency, self-care,
capacity for independent living and receptive and expressive
language;
d. Causes the substantial diminished level of functioning in the
primary aspects of daily living and an inability to cope with
the ordinary demands of life, attention impairment, cognition
impairment, language impairment, memory impairment, conduct
disorder, or motor disorder.
2. Physical impairment
a. Persons having a physical condition resulting from injury,
disease, or congenital deficiency which significantly
interferes with or limits one or more major life activities
and affects one or more of the following body systems:
anatomical, musculoskeletal, neurological, respiratory
including speech organs, cardiovascular, reproductive,
digestive, genito-urinary, hemic and lymphatic, skin and
endocrine.
b. The term physical impairment includes, but is not limited to,
such contagious or noncontagious diseases and conditions as
orthopedic, visual, speech, and hearing impairments; cerebral
palsy, epilepsy, muscular dystrophy, multiple sclerosis,
cancer, heart disease, diabetes, mental retardation, emotional
illness, specific learning disabilities, HIV disease and
tuberculosis.
PLEASE SAVE THIS FOR FUTURE REFERENCE
F-1
3. Major life activities
a. Activities relating to the performance of
self-care and engaging in leisure or play activities. Self-care
includes grooming, mobility, object manipulation, and ambulation.
b. Activities relating to the ability to walk, see hear, breathe
or communicate.
c. Activities relating to moving about in one's community for
purposes that include accessing and participating in
vocational, educational, recreational, and social activities
in the community with other members of the community.
Eligibility standards are as follows:
1. Any individual with a disability (as defined above), who is
unable to board, ride or disembark from any accessible vehicle on
the fixed-route system without the assistance of another individual
(excluding the operator of a wheelchair lift or other boarding
assistance device).
2. Any individual with a disability who needs the assistance of a
wheelchair lift or other boarding device and is able, with operator
assistance, to board, ride, and disembark from any vehicle which is
readily accessible and usable by individuals with disabilities if
the individual wants to travel on a route on the system during the
hours of operation of the system at a time, or within a reasonable
period of such time, when an accessible vehicle is not being used
to provide designated public service on that route.
This category addresses the fact that until the fixed-route
system is capable of providing accessible service to persons with
disabilities, they will be granted temporary ADA eligible status.
As the fixed route system becomes accessible, any person found
eligible under this paragraph will be expected to utilize the
system to the fullest extent possible.
3. An individual with a disability who has a specific impairment-
related condition which prevents the individual from traveling to
or from a fixed-route bus stop. A condition which makes traveling
to or from a bus stop more difficult for a person with a specific
impairment-related condition than for an individual who does not
have the condition, but does not prevent the travel, is not a basis
for eligibility under this paragraph.
a. The specific impairment-related condition must prevent the
person from using the fixed-route system. Conditions which make
getting to or from a bus stop more difficult or less comfortable do
not confer eligibility.
b. Architectural barriers not under the control of the transit
provider to remove, e.g., curb cuts, and environmental barriers,
e.g., distance terrain and weather, do not, when considered alone,
confer eligibility. If, however, travel to or from a bus stop is
impossible when combined with the person's specific impairment-
related condition, paratransit service must be provided.
If you feel that your disability may fit into one of the
previously described categories, please continue with the following
five pages of this application form. If you do not meet the
criteria defined herein, please contact the Madison Metro Transit
Information Center at 266-4466 (TDD 267-1143) for information on
the fixed-route system. If you would like a copy of the
eligibility criteria as defined in the Federal Register, please
contact the Metro+Plus Office at 267-8787 (TDD 267-8789).
F-2
Please Type or Print Clearly/Must Be Complete
Applicant Information:
Last Name:_________________ First Name: __________ M.I.:_______
Address: __________________________________________________________
City: ______________________ State: _____ Zip Code: __________
Name of Residence (if appropriate): _______________________________
Phone Numbers/ Home: __________ Business: _________ Extension:_____
Date of Birth/Month: __________ Day: __________ Year: __________
Mailing Address, if different from above:
Address: __________________________________________________________
City: ______________________ State: _____ Zip Code: __________
Contact Person's Name (if applicable): _________________________
Please list the names of two people and/or an agency, that we may
contact in the event of an emergency:
Name: ______________________ Telephone Number(s): __________
Address: ____________________________________________________
City: _________________ State: _______ Zip Code: __________
Name: ______________________ Telephone Number(s): __________
Address: ____________________________________________________
City: _________________ State: _______ Zip Code: __________
Agency: _____________________ Telephone Number(s): __________
Address: ____________________________________________________
City: _________________ State: _______ Zip Code: __________
Please list the names of two professionals, which may include
physicians, agencies or others familiar with your disability, who
may be contacted by Metro+Plus staff if verification of information
is required:
Name: ______________________ Telephone Number(s): __________
Address: ____________________________________________________
City: _________________ State: _______ Zip Code: __________
Name: ______________________ Telephone Number(s): __________
Address: ____________________________________________________
City: _________________ State: _______ Zip Code: __________
F-3
Please Type or Print Clearly/Must Be Complete
1. What is your disability? (Disability is defined as a physical
or mental impairment that substantially limits one or more
life activities)
Reason for Disability Disability
EXAMPLE: Glaucoma Blindness
EXAMPLE: Spinal Cord Injury Paraplegia
1. _______________ ________________
2. _______________ ________________
3. _______________ ________________
4. _______________ ________________
5. _______________ ________________
6. _______________ ________________
7. _______________ ________________
8. _______________ ________________
Other comments:
______________________________________________________________
______________________________________________________________
______________________________________________________________
2. Please mark all of the categories below as they relate to your
disability.
a. Medically defined cold/heat sensitivity?
_____ Yes _____ No ____ Sometimes
b. Distance to fixed route stop is too far?
_____ Yes _____ No ____ Sometimes
c. Recognize destinations/bus stops or landmarks?
_____ Yes _____ No ____ Sometimes
d. Able to travel or walk the physical terrain to or from bus
stop?
_____ Yes _____ No ____ Sometimes
e. Adversely affected by certain types of weather?
_____ Yes _____ No ____ Sometimes
If yes, what type and how does it affect you?
______________________________________________________________
______________________________________________________________
f. Able to cross streets at busy intersections.
_____ Yes _____ No ____ Sometimes
If no, name those which are troublesome.
______________________________________________________________
______________________________________________________________
F-4
g. Able to receive or exchange printed information?
_____ Yes _____ No ____ Sometimes
h. Able to receive or give spoken words or auditory information?
_____ Yes _____ No ____ Sometimes
i. Give addresses and telephone numbers upon request?
_____ Yes _____ No ____ Sometimes
j. Deal with unexpected situations or changes in routine?
(example: bus detours)
_____ Yes _____ No ____ Sometimes
k. Ask for, understand and follow directions?
_____ Yes _____ No ____ Sometimes
l. Safely and effectively travel through crowded and/or complex
facilities?
_____ Yes _____ No ____ Sometimes
m. Able to detect curbs and other drop offs?
_____ Yes _____ No ____ Sometimes
n. Ability to travel streets without c control lights?
_____ Yes _____ No ____ Sometimes
o. Ability to travel streets with traffic control lights?
_____ Yes _____ No ____ Sometimes
p. Able to see at night?
_____ Yes _____ No ____ Sometimes
q. Does weather affect your vision?
_____ Yes _____ No ____ Sometimes
r. Are you legally blind? (Legally blind is defined as: The
visual acuity in your best eye with best correction is no
better than 20/200, or the visual field of the best eye is
constricted to less than 20 degrees.)
_____ Yes _____ No ____ Sometimes
s. Do you have limited vision?
_____ Yes _____ No ____ Sometimes
t. Other comments or situations relating to your disability.
______________________________________________________________
______________________________________________________________
______________________________________________________________
F-5
3. Will you be requiring Metro+Plus service:
___Permanently ___Temporarily ___Until fixed route buses have lifts
If temporarily, for how long? ______ months
4. Do you travel with an attendant?
_____ Yes _____ No ____ Sometimes
If sometimes, when: __________
(In order for your attendant to ride with you at no charge,
you must inform the office staff that you will be accompanied
by an attendant when making your ride request. The attendant
is then responsible for assisting you, not Metro+Plus.)
5. Approximately how many city blocks can you travel
independently? Do not include distances covered in cars or
buses.
Blocks _______
6. Can you walk up and down or climb steps independently?
_____ Yes _____ No ____ Sometimes
If yes, or sometimes, how many steps in succession? _____ Steps
7. Do you use a mobility assistance device when travelling?
(Examples include a wheelchair, cane, crutches, service animal and
walker)
_____ Yes _____ No ____ Sometimes
Please specify the type of device: ___________________________
8. If you use a wheelchair, what type is it?
_____ Manual _____ Power
Make/model of chair _____________________
Physical dimensions of chair, including foot or head
extensions; In inches _____ Wide_____ High
9. If you use a wheelchair, are you able to transfer into a taxi
cab seat?
_____ Yes _____ No ____ Sometimes
10. Do you have a communication disability which necessitates the
use of some type of communication aide? (Examples include a
lapboard and telecommunication device for the deal)
_____ Yes _____ No ____ Sometimes
If yes or sometimes, what aid: __________
11. In what format would you prefer your response to this
application?
____ Written
____ Braille
____ Audio (tape)
F-6
Release of Information
I, the applicant, understand that the purpose of this
application form is to determine my eligibility to use the Madison
Metro+Plus Transit System. I agree to release the information
requested to Metro+Plus and any eligibility review panel, and
understand that the information contained herein will be treated
confidentially. I understand that Metro+Plus reserves the right to
request additional information at its discretion.
___________________________________________________________________
Signature of Applicant Date
_______________________________________________
Printed Name of Applicant
___________________________________________________________________
Signature of Preparer (if other than applicant) Date
_______________________________________________
Printed Name of Preparer
_______________________________________________
If preparer represents an agency, please print the agency name
here.
___________________________________________________________________
Signature of Parent or Legal Guardian Date
_______________________________________________
Printed Name of Parent or Legal Guardian
Thank you for completing this application form. Please return it
to:
Madison Metro+Plus
1101 East Washington Avenue
Madison, WI 53703.
For Metro+Plus Office Use Only
Date Application Received: _________
_____ Approved _____ Denied Date: _________________
Eligibility Category ____ 1 ____ 2 ____ 3
Mailed Response (date): __________ By Whom: __________________
Client Code: __________ Conditional Eligibility: _________________
Nearest Major Intersection: _______________________________________
Nearest Bus Stop: _________________________________________________
Approximate Distance to Nearest Stop: __________
Extenuating Conditions:
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
F-7
ADA Paratransit Eligibility Manual
Appendix G
Sample Eligibility Material Developed by:
Utah Transit Authority
Materials included:
- "Eligibility Information Sheet"
- Application Form
ADA PARATRANSIT SERVICE
Eligibility Information Sheet
The Americans with Disabilities Act (ADA) requires that
complementary paratransit (curb-to-curb) service be available to
persons who, because of a disability, are unable to use the regular
bus system.
The Utah Transit Authority either operates or provides funding
to operate this service in Salt Lake, Weber, and Davis Counties and
northern Utah and Tooele Counties.
Eligibility
Eligibility for paratransit service is based upon a person's
functional inability to use regular UTA bus service. Three
categories of persons who are eligible for paratransit are
established by the ADA.
Category 1
Any person who is unable, because of a disability, to
independently board, ride, and/or disembark from a lift equipped
bus. This includes persons who are unable to "navigate" the UTA
system without the assistance of another person.
For example, individual is unable to:
- board or disembark from an accessible vehicle without
assistance
- maintain balance while seated on a moving bus
- identify correct bus or stop
- understand transfer directions needed to complete the trip
Category 2
Any person with a disability who is able to use a lift or ramp
equipped bus, but for whom any desired trip cannot be made because
the fixed route he/she wants to ride is not operated by a lift
equipped bus.
This is a transitional category. When all UTA buses are
accessible, persons in this category will no longer be eligible for
paratransit service
THIS INFORMATION IS AVAILABLE IN BRAILLE OR LARGE PRINT
G-1
Category 3
Any person with a disability who has a specific impairment-
related condition which prevents him or her from traveling to or
from a boarding or disembarking location.
A. Only a specific impairment-related condition which
prevents the individual from traveling to or from a bus
stop is a basis for eligibility under this category. A
condition which makes traveling to or from a bus stop
difficult, but does not prevent the travel, is not a
basis for eligibility under this paragraph.
B. Architectural barriers not under the control of UTA and
environmental barriers (e.g., distance, terrain, weather)
do not alone form a basis for eligibility. However, the
interaction of such barriers with an individual's
impairment-related condition may form a basis for
eligibility if the effect is to prevent the individual
from traveling to or from a bus stop.
Eligibility under Category 3 may be situational under the
following conditions:
- extreme weather conditions interact with an impairment-related
condition
- variations in the health/functional ability of the individual
- visual, cognitive or developmental disability prevents travel
to or from a stop for exceptional trips
Conditional Eligibility
Some people with disabilities may be able to use regular UTA
bus service under certain conditions, but not under others.
Eligibility for paratransit for some individuals will be determined
on a trip-by-trip basis. Examples of conditional eligibility under
each eligibility category are as follow:
Category 1: A person with mental retardation or blindness may
have received mobility training which allows him/her to travel
independently to a work site, but is not able to "navigate"
the system to travel to other locations. This person will be
eligible for paratransit only for trips other than work.
Category 2: A person who requires the lift or ramp to board
the bus and whose desired destination is served by accessible
service is not eligible for paratransit for that particular
trip. However, if that person desires to travel to a
destination that is not served by accessible buses, he/she
will be eligible
G-2
for paratransit.
Category 3: A person who uses a wheelchair who can travel to
the bus stop in good weather, but is unable to maneuver with
snow on the ground, would be eligible only on days of severe
weather conditions.
Temporary Eligibility
A person with a temporary disability will be eligible for
paratransit service if the disability results in his/her functional
inability to use the UTA bus system as described in the three
eligibility categories.
Personal Care Attendants
A personal care attendant who is accompanying a passenger who
requires assistance may travel free. The attendant must complete
and submit a registration form.
Visitors
Persons visiting the UTA service area who provide
documentation of ADA paratransit eligibility from another area will
automatically be eligible for paratransit service. Persons who do
not possess documentation, but claim their disability prevents them
from using the UTA bus system, will be considered "presumptively'
eligible for a period not to exceed 21 days. If the individual
plans to remain in the area longer, he/she must go through the
eligibility process which has been established for residents.
In-Person Evaluation
It may be necessary for some paratransit applicants to
participate in an in person evaluation to determine eligibility for
paratransit services. Notification will be given if this will be
required.
Right to Appeal
Persons who are denied eligibility for paratransit services
have the right to appeal the decision. A request for appeal must
be filed in writing within 60 days of the denial of the
application. The appeal will be heard by: 1) a professional
consultant; 2) a disabled advisory committee; 3) UTA's
transportation disabled advisory committee; 4) the UTA Board of
Directors.
A copy of the appeals process is available for public
inspection from Kathy McCune during regular business hours at the
UTA offices, 3600 South 700 West, Salt Lake City.
G-3
Application for Determination
of Eligibility
If you believe that you have a disability which prevents you
from using the UTA bus system, please complete this form and mail
it in the envelope provided. Your disability must prevent you from
using the UTA bus. Please read the ADA Paratransit Info Sheet
carefully for further clarification.
An in-person evaluation of your inability to use the UTA bus may be
necessary. You may be found eligible for it (curb-to-curb)* service
for all of your trips, for some of your trips or capable of using
the UTA bus.
It is important that all parts of this form are completed. If
not, it will be returned to you for-completion. all information
will be kept confidential.
Please use the envelope provided or return to:
ADA Certification Committee
Utah Transit Authority
P.O. Box 30810
Salt Lake City, Utah 84130-0810
PLEASE PRINT
Last Name ___________________ FWA ___________________ Initial ____
____ Mr. ____ Mrs. ____ Ms. ____ Miss
Address ________________________ City ______________ Zip _________
Phone (daytime) ___________________ (evening) ____________________
Date of Birth (month/day/year) ____________________
In case of emergency, notify:
Name ___________________________________ Phone ___________________
Operators will assist you on and off vehicles, but will not go into
residences or buildings.
G-5
2
Disability Information
A. The disability that prevents me from using UTA buses places me
in the following category (see information sheet for further
clarification).
_____ 1. I am unable to ride the UTA bus without the assistance of
someone else.
_____ 2. I need a lift or ramp to board the bus.
_____ 3. My disability prevents me from getting to the bus stop.
_____ 4. My disability does not prevent me from riding the UTA
bus.
B. Disabling Condition(s)
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
C. Please explain how your disability prevents you from using the
UTA bus system. Be specific. (Attach separate sheets, if
necessary.)
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
Mobility Information
D. Which Of these mobility aids or equipment do you use to help
you get where you need to go?
____ Cane ____ Manual Wheelchair ____ Bus ID cards
____ Walker ____ Power wheel
____ Crutches ____ Powered scooter/cart ____ None of these
Other
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
G-6
3
E. Using a mobility aid or on your own, how many blocks can you
travel?
______ blocks.
F. Do you require an attendant to accompany you when you travel
by public transit? (either UTA buses or paratransit)
_____ Yes _____ No
If yes, please complete the following
please identify your personal care attendant:
Name: _____________________________________________________________
Address:___________________________________________________________
City: ____________________________________ Zip Code _____________
Telephone Number: (Home) _________________ (Work) ________________
G. Have you ever had any training to learn how to use a regular
bus?
_____ No
_____ Yes. The training was at: _____________________________
H. Is your health condition or disability temporary?
_____ I don't know
_____ No.
_____ Yes. How long do you expect it to last? _______________
I. Does your disability or health condition change from time to
time in ways which affect your ability to use the UTA bus
system?
_____ No
_____ Yes. Please describe __________________________________
G-7
4
J. Are there any other conditions which limit your ability to use
the UTA bus?
_____ No
_____ Yes. Please explain.
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
K. Are you eligible for any transportation subsidies?
_____ Medicaid _____ Aging Services _____ Human Services
Other (please list)________________________________________________
___________________________________________________________________
___________________________________________________________________
G-8
5
SIGNATURE PAGE
1. I certify that the information I gave in this application is
true and correct. I understand that falsification of
information may result in denial of service. I understand all
information required to provide the service I request will be
disclosed to those who perform those services. I understand
that it may be necessary for me to participate in an in-person
evaluation to determine my eligibility for paratransit
services.
Applicant Signature _____________________________ Date ___________
2. Person.completing the form if other than applicant (please
check one):
_____ I certify that the information provided in this
application is true and correct based upon my own
knowledge of the applicant's health condition or
disability.
_____ I certify that the information provided in this
application is true and correct based upon my own
knowledge of the applicant's health condition or
disability, with the following exceptions or additions:
Signature of ______________________________________________________
person completing
form
Print Name ________________________________________________________
Relationship to Applicant _________________________________________
Phone _____________________
G-9
ADA Paratransit Eligibility Manual
Appendix H
Sample Eligibility Material Developed by:
Worcester Regional Transit Authority
Materials included:
- Cover Letter to Applicants
- Request for Certification Form
- Professional Verification Form
- Review Checklists (to check for completeness)
- "Routing Slip" (to track the process)
- "Final Determination" Documentation Form
- Reviewer Guidelines
Worcester
Regional 287 GROVE STREET
Transit WORCESTER. MASSACHUSETTS 01605
Authority (508) 791-2389 FAX (508) 752-1676
Dear Applicant:
The federal government has issued regulations implementing the
Americans with Disabilities Act (ADA). These regulations require
that the Worcester Regional Transit Authority (RTA) provide ADA
level van service for individuals with disabilities who are unable
to use regular bus service. This van service must be comparable to
the service people receive when they use the bus system.
Riders who become ADA eligible must be given trip priority over
riders who are not eligible. Therefore, current van riders must be
recertified to become eligible for ADA level van service.
Please complete the enclosed form "Request for Certification to use
WRTA Paratransit Van Services" and return it in the enclosed self-
addressed envelope.
The form asks you to designate the health care or rehabilitation
professional who is most familiar with your ability to travel.. The
person you designate could be a physical or occupational therapist,
a staff person or another health care professional who is very
familiar with your mobility. That person will be asked to verify
your mobility limitations by filling out a separate form. We will
mail the verification form to your health care or rehabilitation
professional.
Your application will be considered complete only when the RTA
receives the completed professional verification form. At that
time, your application will be reviewed for eligibility. It will
be your responsibility to make sure that your health care
professional completes this form and returns it to the RTA.
You will receive your eligibility decision in writing. If you are
determined ineligible for ADA level van service, you will be made
aware of your right to appeal the decision.
The Worcester Area Van Express (WAVE), one of the RTA paratransit
operations under contract to the RTA, will be handling your
application from this point forward. If you have questions
regarding this letter or the enclosed application, please feel free
to call Diana Johnson at 752-9283.
Sincerely,
Robert J. Ojala
Administrator
Enclosure
H-1
REQUEST FOR CERTIFICATION TO USE
WRTA PARATRANSIT VAN SERVICES
THIS APPLICATION IS TO BE FILLED OUT BY THE PERSON APPLYING FOR
ELIGIBILITY, NOT A HEALTH CARE OR REHABILITATION PROFESSIONAL.
The following application will be used by the Worcester Regional
Transit Authority (WRTA) to determine eligibility for ADA
Complementary Paratransit Van Service, Special Transit Mobility
Impaired and Elderly Medical Van Service. To use any of these WRTA
paratransit services you need to be able to meet the van at the
street level. The information obtained In this certification
process will be used by the WRTA for the provision of
transportation services. Information will only be shared with
other transit providers to facilitate travel In those areas. The
Information will not be provided to any other person or agency.
1. Name _____________________________________
Street Address____________________________
City/Town __________________ State ________ Zip ____________
Telephone Number (Home): __________ (Work): __________
(Optional) Please indicate with a check if you are:
____Under 60 ____Over 60 ____Over 70 ____Over 80 ____Over 90
2. Explain completely how your disability or disabilities prevent
you from using the WRTA's regular bus service? Use an
additional sheet if needed.
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
3. Is this condition temporary? _____ Yes _____ No
If Yes, expected duration until: Date: __________
4. Do changes in weather (extreme heat, cold, wind, rain, snow or
ice) prevent you from getting around on your own? ____Yes
____ No
If yes, explain completely below:
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
ADA-EO1
1
H-3
THE FOLLOWING INFORMATION WILL BE USED TO ENSURE THAT AN
APPROPRIATE VEHICLE IS USED TO PROVIDE YOUR RIDES AND THAT AN
ACCURATE ANALYSIS OF YOUR TRIP REQUESTS CAN BE MADE.
5. Do you require a Personal Attendant/PCA when you travel on
public transit?
_____ Yes _____ No
6. A. Do you use any of the following mobility aids? ___Yes ____No
If yes, check all that apply.
Manual Wheelchair _____ Electric Wheelchair _____
Powered Scooter _____ Cane _____
Assistive Dog _____ Crutches _____
Other (Please List): _________________________________________
B. Are you able to independently maneuver onto or off of a
wheelchair lift?
_____ Yes _____ No
7. Please answer all of the following questions that apply:
A. For individuals who do not use a mobility aid, how many city
blocks can you walk independently?
(Imagine a city block to be approximately 500 feet in
length. Check one.)
___0 Blocks ___1 Block ___2 Blocks ___3 Blocks ___4 Blocks
___5 Blocks ___6 Blocks ___7 Blocks ___8 Blocks ___9 Blocks
B. If you use a mobility aid(s) how many city blocks can you
travel independently?
___0 Blocks ___1 Block ___2 Blocks ___3 Blocks ___4 Blocks
___5 Blocks ___6 Blocks ___7 Blocks ___8 Blocks ___9 Blocks
C. How many 7-inch steps can you climb without assistance? ______
(The average step height is 7 inches)
D. How many 10-inch steps can you climb without assistance? _____
E. How far is the closest bus stop (in city blocks) from your
residence? ______
F. How long can you wait for a bus at a bus stop? (Please check
one)
____ 10 Minutes ____ 15 Minutes ____ 30 Minutes ____ Other
ADA-EOI
2
H-4
8. Use this space to provide any additional information which may
help us to better serve your transportation needs.
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
9. Would you like to have someone contact you to discuss training
in the use of the WRTA regular bus system? ___Yes ___ No
10. If this application has been completed by someone other than
the person requesting certification, that person must complete
the following:
Name _____________________________________
Street Address____________________________
City/Town __________________ State ________ Zip ____________
Daytime Telephone Number _______________
Signed ___________________________________ Date ____________
ADA-EO1
3
H-5
11. In order to allow the Worcester Regional Transit Authority to
evaluate your request, it is necessary to contact your health
care or rehabilitation professional to confirm the information
you have provided.
Please complete and sign the following authorization.
I authorize the WRTA to contact the health care or rehabilitation
professional listed below to obtain information regarding my
disability and its affect on my ability to get around on my own.
Name of Health Care Professional __________________________________
Street Address_____________________________________________________
City/Town __________________ State __________ Zip __________
Telephone Number ____________________
Applicant's Name ________________________________________
(PLEASE PRINT)
Applicant's Signature ___________________________________
Date: _____________________
12. 1 hereby certify that all of the information given in this
application is correct.
Applicant's Signature
Date: __________
ADA-EO1 Rev. 05/04/93
4
H-6
PROFESSIONAL VERIFICATION OF ADA
FUNCTIONAL LIMITATION(S) AFFECTING MOBILITY
Dear ______________________
The attached authorization form has been submitted by _____________
who has indicated that you are familiar with his/her disability.
The purpose of this form is not to verify his/her medical
condition, but to verify the affect of the medical condition on
his/her ability to get around on his/her own. All questions must be
answered for this form to be considered complete. This
information will allow the RTA to make a timely evaluation of
his/her request for transportation and must be returned within 5
days. Thank you for your cooperation.
1. Capacity in which you know the applicant:
__________________________________________________________________
How does the disability cause a functional limitation(s) that
affects this person's ability to get around? If the person's
ability to get around on his/her own varies in degree at different
times, explain the worst case scenario. Please be specific.
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
2. Is the condition temporary? _____Yes _____No
If yes, expected duration until: Date: __________
3. If the applicant has a disability affecting mobility. answer
the following:
a. Assuming the length of a city block is 500 feet, how many
blocks can this person walk without assistance?
___0 Blocks ___1 Block ___2 Blocks ___3 Blocks ___4 Blocks
___5 Blocks ___6 Blocks ___7 Blocks ___8 Blocks ___9 Blocks
b. Does this person use any mobility aids? ____Yes ____No
(If yes, please list below:)
__________________________________________________________________
__________________________________________________________________
c. With the use of a mobility aid(s), how many blocks can he/she
travel independently?
___0 Blocks ___1 Block ___2 Blocks ___3 Blocks ___4 Blocks
___5 Blocks ___6 Blocks ___7 Blocks ___8 Blocks ___9 Blocks
d. How many 7-inch steps (average step height) can this person
climb without assistance? ______
e. How many 10-inch steps can this person climb without
assistance? ______
f. How long can this person wait for a bus at a bus stop?
____ 10 Minutes ____ 15 Minutes ____ 30 Minutes ____ Other
g. Is individual able to independently maneuver onto and off of a
wheelchair lift with or without a mobility aid?
_____ Yes _____ No
h. Does this person require a Personal Attendant (PCA) when
traveling on public transit?
_____ Yes _____ No
1
H-7
i. Can this person read informational signs? ____Yes ____No
If no, please explain: _______________________________________
___________________________________________________________________
___________________________________________________________________
j. Can this person navigate independently? ____Yes ____No
If no, please explain: _______________________________________
___________________________________________________________________
___________________________________________________________________
Is the person able to:
k. Give his/her address and telephone number upon request?
____Yes ____No
l. Recognize landmarks? ____Yes ____No
m. Deal with unexpected situations or unexpected changes in
routine? ____Yes ____No
n. Ask for, understand and follow directions? ____Yes ____No
o. Safely and effectively travel through crowded and/or complex
facilities? ____Yes ____No
4. If any, what specific weather conditions prevent the
individual from getting around on his or her own?
____Yes ____No Please explain completely:
5. Please describe any other functional limitation(s) affecting
mobility not described above. Be specific:
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
6. Your Name and Title: _________________________________________
Office Address: ______________________________________________
Office Phone Number: _____________________
Signature: ________________________________ Date: ___________
RETURN COMPLETED FORM TO:THE WORCESTER REGIONAL TRANSIT AUTHORITY
287 GROVE STREET
WORCESTER, MA 01605
ATTN: DIANA JOHNSON
ADA-EO4 Rev. 02/25/93
2
H-8
WORCESTER REGIONAL TRANSIT AUTHORITY
ADA ELIGIBILITY APPLICATION CHECKLIST
STAFF INITIALS: __________ DATE: __________
Please indicate by a check if the following items are complete.
Each numbered item corresponds to the numbered sections on the
application.
_____ 1. Applicant's personally identifiable information
_____ 2. Explanation of how disability(ies) prevent applicant
from using RTA regular bus service
_____ 3. Condition temporary? Duration date.
_____ 4. Changes in weather affecting ability; if yes,
explanation provided
_____ 5. Personal Assistant/PCA ?
_____ 6._____ A. Mobility aids?
_____ B. Can maneuver onto and off of lift?
_____
_____ 7. _____ A. City blocks without assistance?
_____ B. City blocks without assistance, with mobility
aid?
_____ C. # of 7-inch steps?
_____ D. # of 10-inch steps?
_____ E. Closest bus stop?
_____ F. Length of time waiting for bus?
_____ 9. Optional. If yes, refer to travel trainer.
_____ 10. Optional. If answered, all required information is
complete.
_____ 11. Authorization release information is complete,
signed and dated by applicant. Signature must match
applicant's name in item #1.
_____ 12. Applicant signature and date 4 is complete.
Signature must match applicant's name in item #1.
ADA E-05 (Rev. 9/4/92)
H-9
REGIONAL TRANSIT AUTHORITY
ADA ELIGIBILITY VERIFICATION CHECKLIST
STAFF INITIALS: __________ DATE: __________
Please indicate by a check if the following items are complete.
Each numbered item corresponds to the numbered section on the
rehab/health care professional verification of functional
limitation(s) affecting mobility.
____ 1. Relationship to applicant; Explanation of how the
disability causes functional limitation(s) that affects
applicant's ability to get around.
____ 2. Condition temporary? Duration date.
____ 3. a. # of blocks applicant can walk without assistance?
____ b. Mobility aid?
____ c. With mobility aid, # of blocks he/she can travel?
____ d. Optional.
____ e. of 10-inch s
____ f. # of minutes he/she can wait at stop?
____ g. Maneuver on/off lift?
____ h. Personal Attendant/PCA?
____ i. Read informational signs?
____ j. Navigate independently?
____ k. Give address an:i telephone number?
____ l. Recognize landmarks?
____ m. Deal with situations/changes in routine?
____ n. Ask for, understand and follow directions?
____ o. Travel through crowded/complex facilities?
____ 4. Conditions in weather affecting mobility; if yes,
explanation provided?
____ 5. Optional.
____ 6. Professionals name, title, address, phone #, signature
and date.
ADA EO5a (Rev. 04/16/93)
H-10
WORCESTER REGIONAL TRANSIT AUTHORITY
ADA ELIGIBILITY ROUTING SLIP
APPLICANT _________________________________________________________
ADDRESS ___________________________________________________________
CITY/TOWN ___________________________ STATE ________ ZIP_________
TELEPHONE NUMBER (HOME)___________________ (WORK)_________________
CURRENT STATUS OF APPLICATION:
________ DATE APPLICATION SENT TO APPLICANT
__________ DATE APPLICATION RECEIVED BY WAVE
________ DATE APPLICATION REVIEWED VIA APPLICATION CHECKLIST
__________ COMPLETE __________ INCOMPLETE
_________ DATE REFERRED TO TRAVEL TRAINER
_________ DATE REQUEST SENT FOR PROFESSIONAL VERIFICATION (INCLUDE
COPY OF RELEASE OF INFORMATION SECTION FROM APPLICATION
__________ DATE POST CARD SENT
__________ DATE VERIFICATION RECEIVED BY WAVE
_________ DATE PROFESSIONAL VERIFICATION FORM REVIEWED VIA
PROFESSIONAL VERIFICATION CHECKLIST
__________ COMPLETE __________ INCOMPLETE
IF APPLICATION IS INCOMPLETE:
__________ DATE APPLICATION RETURNED TO APPLICANT
__________ DATE APPLICATION RECEIVED BY WAVE
__________ DATE APPLICATION RE-REVIEWED VIA
APPLICATION CHECKLIST
_______ COMPLETE _______ INCOMPLETE
IF PROFESSIONAL VERIFICATION FORM IS INCOMPLETE:
__________ DATE PROFESSIONAL VERIFICATION FORM IS
RETURNED TO PROFESSIONAL
__________ DATE PROFESSIONAL VERIFICATION FORM
RECEIVED BY WAVE
__________ DATE PROFESSIONAL VERIFICATION FORM RE-
REVIEWED VIA PROFESSIONAL VERIFICATION
CHECKLIST
______ COMPLETE ______ INCOMPLETE
_________ DATE APPLICATION COMPLETE AND REFERRED TO ELIGIBILITY
REVIEWERS
ADA E-07 (Rev.11/23/92)
H-11
ADA ELIGIBILITY ROUTING SLIP
Page 2
________ DATE OF ELIGIBILITY DETERMINATION AND RETURN OF FILE TO
WAVE (SEND LETTER #______________ IF ELIGIBLE) (CC._)
INCLUDE APPEAL PROCESS WHEN APPROPRIATE.
_________ DATE OF REVIEW WITH WAVE MANAGER AND ASSISTANT
MANAGER IF INELIGIBLE AND RETURN OF FILE TO
WAVE (SEND LETTER #______________ IF ELIGIBLE)
(CC._)
INCLUDE APPEAL PROCESS WHEN APPROPRIATE
_________ DATE DETERMINATION LETTER SENT
________ DATE APPEAL REQUEST RECEIVED BY WAVE
_________ DATE OF SCHEDULED APPEAL
_________ DATE OF APPEAL BOARD DECISION
_________ DATE APPEAL BOARD DECISION LETTER SENT TO APPLICANT
INCLUDE APPEAL PROCESS WHEN APPROPRIATE
ADA E-07 (Rev. 11/23/92)
H-12
ADA ELIGIBILITY ROUTING SLIP
Page 3
ADA ELIGIBILITY
FINAL DETERMINATION:
APPLICANT IS ______ ELIGIBLE ______ INELIGIBLE
______ CATEGORY I ______ CATEGORY I WITH LIMITS
______ CATEGORY II ______ CATEGORY II FUTURE CATEGORY I WITH
LIMITS
______ CATEGORY II FUTURE CATEGORY III
WITH LIMITS
______ CATEGORY III ______ CATEGORY III WITH LIMITS
(SEE DETERMINATION LETTER)
IF ELIGIBILITY IS CONDITIONAL, WHAT RESTRICTIONS/LIMITATIONS
APPLY?
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
BASIS FOR DECISION:
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
______ Duration Date, if temporary
______ Personal Attendant/PCA required
REVIEWERS SIGNATURE ___________________________ DATE: ____________
ADA E-07 (Rev. 11/23/92)
H-13
WORCESTER REGIONAL TRANSIT AUTHORITY
REVIEWER'S ADA ELIGIBILITY CONTACT LOG
APPLICANT: _______________________ REVIEWER: ______________________
PURPOSE OF CONTACT: _______________________________________________
DATE _______________ COMMENTS/RESULTS ____________________________
HEALTH CARE/REHAB. CONTACT: ______________________________________
PURPOSE OF CONTACT: _______________________________________________
DATE ______________________ COMMENTS/RESULTS ______________________
ADA E-08 (Rev. 5/17/92)
H-14
WORCESTER REGIONAL TRANSIT AUTHORITY
ADA ELIGIBILITY GUIDELINES
APPLICANT: __________________________ DATE OF REVIEW: ____________
REVIEWER: ___________________________
CATEGORY I:
THIS CATEGORY RELATES TO AN INDIVIDUAL WHOSE DISABILITY PREVENTS
HIM OR HER FROM "NAVIGATING THE SYSTEM" INDEPENDENTLY.
SPECIFICALLY, THE INDIVIDUAL CANNOT BOARD, RIDE OR DISEMBARK FROM
AN ACCESSIBLE VEHICLE INDEPENDENTLY OR COMPLETE TRANSFERS WITHOUT
THE ASSISTANCE OF ANOTHER INDIVIDUAL.
___Yes ___No 1. Does individual require a Personal
Attendant/PCA to travel? (App.5,8) (Ver. 3H) If
Yes, eligible providing that other information
in the application and/or verification form
supports this claim.
2 . Can individual board, ride, and navigate
(transfers) on an accessible fixed route
system?
(App.2,3,4,7A-7D,7F,8) (Ver.1,2,3A,3C,3E,3F,4C,4D,SA-F,7)
___Yes ___No A. Can individual wait at bus stop (either with or
without a wheelchair or other ncbility aid) for
10 minutes in good weather conditions. If no,
eligible.
(App. 2,7F, 8) (Ver. 1, 3F,7)
___Yes ___No Does weather prevent individual from waiting at
bus stop for 10 minutes? Indicate: __________
___Heat ___Cold ___Rain ___Snow ___Wind ___Ice
(App. 4 and 2,7F, 8) (Ver. l,3F,6,7) If
eligible with limitation.
___Yes ___No B. Can individual independently maneuver onto/off
of a lift either with or without the use of a
mobility aid? If no, eligible providing that
other information in the application and/or
verification form supports this claim
(App.2,6B,7B,8) (Ver. 1,3C,3G,7)
___Yes ___No C. Orientation: Can individual independently
select correct bus, recognize destination and
disembark and make transfers? If no, eligible.
(App. 2,8) (Ver.1,4C,4D,5A-5F,7) (NOTE: Not
applicable for individuals with visual
impairments.)
___Yes___No D. Can individual actually tolerate riding the
bus? (i.e. stamina, balance, muscle weakness,
motion sickness, etc. or potential consequences
related to the progression of certain diseases,
or to the effect of treatments like
chemotherapy, radiation and dialysis.)
(App.2.3,4,8) (Ver.1,2,7) if no, eligible.
ADA E-09 (Rev. 11/23/92)
H-15
ADA ELIGIBILITY GUIDELINES (PAGE 2)
THIS CATEGORY RELATES TO AN INDIVIDUAL WITH A DISABILITY WHO CANNOT
GET TO AND FROM A STOP DUE TO THE INTERACTION OF ENVIRONMENTAL
CONDITIONS (TERRAIN AND WEATHER) WITH HIS OR HER IMPAIRMENT RELATED
CONDITION.
1. Does disability prevent individual from
independently getting to and from bus stop at
point of origin or destination? If yes,
eligible. (App. 2,7A,7B,7E,S)
(Ver.1,3A,3C,3F,4C,4D,5A-5F,7)
___Yes___No A. Is individual able to travel 3 blocks (1/4
mile) with or without the use of a mobility
aid? (Includes wheelchair, cane, crutches,
etc.) If no, eligible.
(App.2,7A.7B,7E.8)
(Ver.1,3A,3C,3F,4C,4D,5A-5F,7)
___Yes ___No 2. Does weather or terrain impact the person's
ability such that it prevents individual from
independently getting to and/or from a bus stop
at point of origin or destination? if yes,
eligible either with or without limitations.
(App.2,4,8) (Ver.1.6,7)
Indicate: ___Heat ___Cold ___Rain ___wind ___Ice
___Hills ___Rough Terrain
ADA E-09 (Rev.11/23/92)
H-16
ADA ELIGIBILITY GUIDELINES (PAGE 3)
CATEGORY II: TRANSITIONAL CATEGORY
IF A PERSON IS ELIGIBLE WITHOUT LIMITATIONS UNDER CATEGORY I OR
III, DO NOT PROCEED WITH CATEGORY II REVIEW.
THIS CATEGORY RELATES TO AN INDIVIDUAL WITH A DISABILITY WHO WOULD
BE CAPABLE OF USING AN ACCESSIBLE VEHICLE IF PRESENTED WITH ONE. AN
INDIVIDUAL ELIGIBLE UNDER THIS CATEGORY IS ONLY ELIGIBLE BECAUSE
THE WRTA'S FIXED ROUTE SYSTEM IS ONLY PARTIALLY ACCESSIBLE AT THE
PRESENT TIME.
EXCEPTION: AN INDIVIDUAL WHO LIVES ALONG AN ACCESSIBLE FIXES
ROUTE AND HAS RECURRING SUBSCRIPTION TYPE
DESTINATIONS ALSO SERVED BY AN ACCESSIBLE FIXED
ROUTE WILL BE REQUIRED TO USE THE FIXED ROUTE SYSTEM
FOR THOSE SUBSCRIPTION TRIPS EVEN BEFORE THE ENTIRE
SYSTEM IS ACCESSIBLE. HE OR SHE MAY, HOWEVER, BE
ELIGIBLE FOR PARATRANSIT RANDOM TRIP REQUESTS.
1. Does individual require system accessibility
features? (App.2,6A,7D,8) (Ver.1,3B,3E,4A-D,7)
If yes, eligible under Category II until system
has needed accessibility features.
___Yes ___No A. Does individual require a wheelchair to travel?
(App. 6A) (Ver. 3B) If yes, eligible under
Category II until system is lift equipped.
___Yes___No B. Is individual able to independently climb 3
consecutive 10-inch steps with or without use
of mobility aid (e.g. cane, walker, crutches,
etc.)? If yes, eligible Category II until
system is lift equipped. (App. 7D,B) (Ver.
1,3E,7)
___Yes___No C. Does individual with visual impairment require
driver announcements to be aware of steps and
transfer point (City Hall) and/or Bus
Identifier Kit to display while waiting at stop
to make drivers aware of desired bus # ? If
yes, eligible until these accessibility
features are available.
(App.2,8) (Ver. 1,4A-4D,7)
___Yes___No D. Does individual with hearing impairment require
a card to give driver that contains information
regarding destination, transfer if needed
and/or the need for assistance
securing/releasing wheelchair or other. If yes,
eligible until these accessibility features are
available. (App.2,8) (Ver. 1,7)
ITEMS #1 A, B, C OR D MUST BE ANSWERED "YES" FOR TRANSITIONAL
ELIGIBILITY (CATEGORY II)
ADA E-09 (Rev. 11/23/92)
H-17
H-18
ADA Paratransit Eligibility Manual
Appendix I
Sample Eligibility Material Developed by:
Municipality of Metropolitan Seattle (Metro)
Materials included:
- Flyer Sent to Registered Riders Regarding ADA Eligibility
- Application Form which Includes Professional Verification
- In-Person Assessment Forms Including Summary Information Page,
"Physical Functional Evaluation" Form, "Cognitive Functional
Evaluation" Form, and "Combined Functional Evaluation" Form
"Eligibility
- Appeals Process" Brochure
ADA
Americans With Disabilities Act
To all registered Special Transportation Service Program users
(Reserve-A-Ride and Taxi Scrip)
If you have a disability which prevents you from using the bus some
or all of the time, you may be eligible for Metro's new ADA
Paratransit Service. This new service will have more service days,
longer hours and new vans which will operate throughout King
County.
In order to use this new service, you will need an
ADA Paratransit ID Card
By applying now, you will be ready when Metro begins the new ADA
Paratransit Service in late 1993. Until then, there will be no
change in the Reserve-A-Ride or Taxi Scrip programs.
To apply, please do the following:
- Fill out the enclosed application form, or have someone fill
it out for you.
- Have Part E (Professional Verification) signed by one of the
professionals listed at the top of that page.
- Return the completed application form in the enclosed postage
paid envelope.
The Reserve-A-Ride and Taxi Scrip programs will continue. Recently,
you received materials about how to re-register for these programs.
If you have any questions, please call Metro at 689-3113 (voice) or
689-3116 (TDD).
METRO
I-1
ADA
Application for ADA Paratransit Service Certification
The Americans with Disabilities Act of 1990 (ADA) is a civil
rights bill which bans discrimination against people with
disabilities. To meet their needs, public bus companies must
provide a variety of services.
If you have a disability which prevents you from using a lift-
equipped Metro bus some or all of the time, you may be eligible for
ADA Paratransit service some or all of the time.
All information will be kept confidential. Only the
information required to provide the services you request will be
disclosed to those who perform those services. Your answers will
not be shared with any other person or company.
It is important that all parts of this form are completed. If
the application is not complete, it will be returned to you and
that will delay having your application processed.
Please use the envelope provided or return to:
Metro ADA Paratransit Certification
Accessible Services Section
821 Second Avenue, M.S. 134
Seattle, WA 98104-1598
If you have questions, please call 689-3113. TDD*:689-3116
PLEASE PRINT
Last Name ______________________ First ______________ Initial _____
Address ________________________ City ______________ Zip __________
Date of Birth (month/day/year): ___/____/____ ____Male ____Female
Daytime Phone __________________ Evening Phone ___________________
TDD*____________________________ Social Security # _______________
(optional)
Language Ability (please check all that apply)
____ English ____ Other (specify) _____________________
Emergency Contact Name ___________________ Relationship ___________
Daytime Phone _____________ Evening Phone ________________________
METRO *Telecommunications Device for the Deaf.
Application for ADA Paratransit Service Eligibility Page 2 of 9
I-3
MOBILITY INFORMATION
1. Which of these mobility aids or equipment do you use to help
you get where you need to go? (please check all that apply to
you)
_____ None
_____ Cane _____ Manual wheelchair _____ Service Dog
_____ White Cane _____ Power Wheelchair _____ Picture board
_____ Walker _____ Powered scooter/cart _____ Alphabet board
_____ Crutches _____ Bus route ID kit _____ Portable Oxygen
Other________________________________________________________
2. Using a mobility aid on your own, how many blocks can you go
on level ground?
____ less than 2 ____ 2 to 4 ____ more than 4
3. If you were to ride the regular metro bus would you need
someone with you?
____ Always ____ To help me get to or from the bus stop
____ Sometimes ____ To help me get on or off the bus
____ No ____ To help me get where I'm going
4. Have you ever had any training to learn how to use a regular
bus?
____ Yes The training was at:___________________________
____ No I learned: (check all that apply to you)
____ General bus travel
____ How to ride one or two specific routes
____ I finished the training
____ I did not complete the training
5. If you are found eligible for paratransit van services, will
you:
____ Be able to meet the van at the curb
____ Need driver assistance from your door?
____ Need driver assistance from the van to the door of your
destination?
Application for ADA Paratransit Service Eligibility Page 2 of 9
I-4
B. DISABILITY OR HEALTH CONDITION INFORMATION (Please read pages
3 and 4 before completing this section, and indicate all
conditions which affect your ability to use the bus.)
1. General Medical Conditions
___ None
___ Cancer ___ Kidney Failure ___ Pneumonia
___ Diabetes ___ Organ Transplant
Other _____________________________________________________________
2. Bone and Joint Conditions
___ None
___ Amputation of: ___ Ankylosing Spondylitis ___ Broken Bone:
_________________ ___ Arthritis _________________
(please specify) ___ Fusion (please specify)
___ Osteo-arthritis
___ Osteoporosis
___ Rheumatoid Arthritis
___ Scleroderma
___ Other _________________________________________________________
3. Brain/Nerves/Muscle Conditions
___ None
___ Alzheimer's Disease ___ Hemiplegia ___ Post-polio
___ Brain Injury ___ Huntington's Chorea ___ Quadriplegia
___ Cerebral Palsy ___ Multiple Sclerosis ___ Spina Bifida
___ Dementia ___ Muscular Dystrophy ___ Stroke
___ Epilepsy ___ Paraplegia ___Vertigo/Dizziness
___ Guillian-Barre ___ Parkinson's Disease
___ Other _________________________________________________________
4. Heart and Circulatory Conditions
___ None
___ Angina ___ Heart Attack ___ Peripheral Vascular
___ Congestive Heart Failure Disease
___ Heart Surgery ___ Edema ___ High Blood Pressure
___ Other ________________________________________________________
(more on next page)
Application for ADA Paratransit Service Eligibility Page 3 of 9
I-5
5. Lung and Breathing Conditions
___ None
___ Allergies ___ Chronic Obstructive ___ Emphysema
___ Asthma ___ Pulmonary Disease (COPD) ___ Lung Cancer
___ Cystic Fibrosis
___ Other _________________________________________________________
6. Vision/Hearing/Speech Conditions
___ None
___ Aphasia ___ Glaucoma ___ Hard of Hearing
___ Cataracts ___ Legally Blind ___ Partially Sighted
___ Deaf-Blind ___ Deaf ___ Visual Field Deficit
___ Diabetic Retinopathy ___ Night Blindness
___ Other ________________________________________________________
7. Developmental/Mental Conditions
___ None
___ Autism ___ Dwarfism ___ Mood Disorder
___ Psychosis ___ Thought Disorder
Developmental Disability: Mental Retardation:
___ Mild ___ Mild
___ Moderate ___ Moderate
___ Severe ___ Severe
___ Other _________________________________________________________
8. Is your health condition or disability temporary?
___ Yes How long do you expect it to last? # years ________
___ No How long have you had this condition or
disability?
___ I don't know ___ Since birth # years ____
9. Does your disability or health condition change from time to
time in ways which affect your ability to use the bus?
___ Yes Please describe _____________________________________
___ No ____________________________________________________
Application for ADA Paratransit Service Eligibility Page 4 of 9
I-6
C. REGULAR BUS USE INFORMATION
(Please answer all questions even if you do not ride the regular
Metro bus.)
1. Do you ride the regular Metro bus?
___ Yes How many days per week? _____________
How many days per month?_____________
___ No
___ No, but I used to ride the bus
2. Can you communicate with a bus driver yourself or with the
help of an aid (such as a letter board or bus route ID cards)?
___ Yes
___ No Please check all that apply.
___ I cannot understand the driver
___ I need a communication aid and don't have one
___ Other people cannot understand me
___ Other
3. How many blocks do you need to go to get to a Metro bus stop?
___ Less than 2 ___ 2 to 4 ___ More than 4 ___ Don't know
4. Using a mobility aid or on your own, can you make your way to
the Metro bus stop?
___ Yes
___ No Please check all that apply to you.
___ I can't find the stop because I get confused
___ I need someone to help me get there
___ I could with training
___ I don't want to ride the Metro bus
___ The ground is too uneven or steep for me to get there
___ I can't go that far
___ Snow or heavy rain make it impossible for me to get there
___ Other ___________________________________________________
Application for ADA Paratransit Service Eligibility Page 5 of 9
I-7
5. Can you wait 10 minutes at a Metro bus stop that does not have
seats and a shelter?.
___ Yes
___ No Please check afl that apply to you.
___ I get too confused and might get lost
___ I don't like to wait that long
___ Standing for 10 minutes makes me too tired to ride the bus
___ Very cold weather is dangerous to my health
___ Very hot weather is dangerous to my health
___ Other
___ No, but I could wait for 10 minutes at a stop which does have
seats and a shelter
6. Metro buses have lifts to help you get on the bus if you have
difficulty with steps. If you were to use the Metro bus lift,
could you get on and off the lift by yourself (whether
standing or with a mobility aid)?
___ I don't know, I've never tried it
___ Yes, I can get on and off by myself
___ Sometimes Please check all that apply.
___ No ___ There isn't room at my bus stop
___ The ground at my bus stop is too uneven or steep
___ I feel unsafe on the lift
___ My mobility aid won't fit on the lift
___ I need someone to help me on and off
___ Other ______________________________________________
7. Do you know where to get off the bus or can you find out?
___ Yes
___ No Please check all that apply.
___ I get confused or can't remember where I'm going
___ I don't know where the bus stop is
___ I need a communication aid and don't have one
___ I could with training
___ Other ___________________________________________________
Application for ADA Paratransit Service Eligibility Page 6 of 9
I-8
B. From where the bus stops to let you get off, can you make your
way to the place you need to go?
___ Yes
___ No Please check all that apply.
___ I get confused or can't remember where I'm going
___ I need someone to help me get there
___ I feel unsafe there
___ I don't want to ride the Metro bus
___ The ground is too uneven or steep for me to get there
___ I can't walk that far
___ I could with training
___ Other_____________________________________________________
9. Are there any other conditions which limit your ability to use
the bus?
___ Yes _______________________________________________
___ No _______________________________________________
_______________________________________________
(more on next page)
Application for ADA Paratransit Service Eligibility Page 7 of 9
I-9
D. Applicant Signature
Do Not Detach-must be submitted with application
1 I certify that the information I gave in this application is
true and correct. I understand that falsification of information
may result in denial of service. I understand all information will
be kept confidential, and only the information required to provide
the services I request will be disclosed to those who perform those
services. I understand that Metro may contact the health care
professional who has completed the Professional Verification
attached to this application, in order to confirm this information.
Applicant Signature ____________________________ Date _________
Please have page 9 completed before you send in this form!
2. Person completing form if other than applicant (please check
one):
____ I certify that the information provided in this application is
true and correct based upon information given me by the applicant.
____ I certify that the information provided in this application is
true and correct based upon my own knowledge of the applicant's
health condition or disability.
Exceptions or Additions: __________________________________________
___________________________________________________________________
Print Name ________________________________________________________
Signature ________________________________ Daytime Phone __________
Relationship to Applicant ______________________ Date______________
Address____________________________________________________________
City_______________________ State_____ Zip Code_____________
Application for ADA Paratransit Service Eligibility Page 8 of 9
I-10
E. Professional Verification
NOTE: THIS PORTION MUST BE COMPLETED BY ONE OF THE FOLLOWING
CURRENTLY LICENSED PROFESSIONALS: registered nurse, physician,
social worker, psychologist, physical therapist, chiropractor,
occupational therapist, speech pathologist, nurse practitioner,
physician's assistant, mental health counselor, respiratory
therapist, vocational rehabilitation counselor, or recreation
therapist employed by a medical facility.
The Americans with Disabilities Act of 1990 (ADA) is a civil
rights bill which bans discrimination against people with
disabilities. To meet their needs, public bus companies must
provide a variety of services.
The applicant may be found eligible for paratransit van
services for all trips he/she requests, or eligible (based on
functional ability) for some trip requests but not for others, or
capable of using the regular bus.
NOTE: Most Metro buses are equipped with a lift for people
who use a wheelchair or cannot climb stairs.
The information you provide will enable us to make an
appropriate determination for each trip request. All information
will be kept confidential. Thank you for your assistance.
Capacity in which you know the applicant:__________________________
Physical and/or cognitive condition which functionally prevents use
of lift-equipped bus:______________________________________________
Is this condition temporary? ___No ___Yes, for _____ months
___ I have reviewed all of the information contained in this
application, and hereby certify that all information is true and
correct to the best of my knowledge and ability.
Exceptions or Additions:___________________________________________
___________________________________________________________________
Print Name and Title_______________________________________________
Signature______________________________________ Date______________
Clinic/Agency__________________________________ Phone_____________
Address______________________________ City__________ Zip_______
___
Professional License, Registration or Certification# ______________
Application for ADA Paratransit Service Eligibility Page 9 of 9
I-11
EVERGREEN MEDICAL CENTER TRANSIT ACCESS PROJECT
ADA PARATRANSIT SERVICE ELIGIBILITY DETERMINATION
Name_______________________________________________________________
SSN#_______________________ DOB_____________________ Date__________
A. Determination
____ Not eligible (Skip to E)
____ Eligible (Skip C)
____ regular
____ temporary _____ 3 _____ 6 _____ 9 _____ 12 months
____ Conditionally eligible (complete all section)
____ regular
____ temporary _____ 3 _____ 6 ______ 9 _____ 12 months
B. Type of Eligibility
____ 1. Unable to independently board, ride or disembark from
lift-equipped bus
____ 2. Able to independently board, ride or disembark from lift-
equipped bus, but route desired is not lift equipped
____ 3. Specific impairment-related condition prevents travel
to/from a bus stop
C. Eligibility Conditions which apply to a specific trip request
____ 1. You require a Personal Care Attendant
____ 2. No accessible bus.service is available
____ 3. Distance plus disability prevent using bus
____ 4. Hill, terrain, etc., prevent using bus
____ 5. Very hot weather
____ 6. Very cold weather
____ 7. Hours of darkness
____ 8. Snow, or very icy conditions
____ 9. Duration/complexity of regular bus trip
____ 10. You have not had bus travel training
____ 11. Extremely poor air quality
____ 12. Able to transport oversized mobility aid
D. Travel Training
____ Not recommended
____ Recommended: ____ Route-specific
____ General bus travel
____ Boarding/disembarking
E. Comments
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
F.
Evaluator__________________________________ Date___________________
Coordinator________________________________ Date___________________
I-13
PHYSICAL FUNCTIONAL EVALUATION
Name______________________________Evaluator__________
Date_______________Age__________DOB__________Phone_______________
Address__________________________________________________
Transportation Mode____________________SSN#_______________
Mobility Aides____________________Vision_______________
Auxiliary Aides_______________Hearing_______________
(1=pass, 2=incorrect, 3= not tested)
1. Distance:
Do not evaluate if BP is 200/105 or O2 saturation rate 88.
Discontinue if BP increases to 250/110, HR 75% of maximum for age,
or if O2 sat. rate drops suddenly. 75% maximum for age_____________
Resting 330 Feet 660 Feet
HR ________ ________ ________ 1 2 3
BP ________ ________ ________ 1 2 3
02 Sat. ________ ________ ________ 1 2 3
Time ________ ________ ________ 1 2 3
(Pass = Able to travel 660 feet within
8 minutes within vital guidelines)
COMMENTS: ____________________________________________ 1 2 3
2. Curbs and Curb cuts:
A. Able to maneuver independently
1) Up 6" curb 1 2 3
2) Down 6" curb 1 2 3
B. Able to maneuver independently
1) Up curb cut 1 2 3
2) Down curb cut 1 2 3
(Pass = 2/2 correct from A or B)
COMMENTS: ____________________________________________ 1 2 3
3. Timed Street Crossing:
A. Able to complete in 50 seconds 1 2 3
COMMENTS:_____________________________________________ 1 2 3
4. Mobility Device:
A. Measurement: 1 2 3
(Pass= device does not exceed 30" width, 48" length)
B. Weight: 1 2 3
(Pass= device and client combined do not exceed 600 pounds)
COMMENTS:_____________________________________________ 1 2 3
I-15
5. Mock-ups
A. Time for lift/stairs portion: __________________ 1 2 3
(Pass= Able to complete in 3:00 or less.)
B. Time for interior portion:______________________ 1 2 3
(Pass= Able to complete in 3:00 or less.)
(Pass= Able to complete both A & B within 5:00 minutes)
Observations:
Moves on/off lift independently Y N
Moves up/down stairs independently Y N
Maintains balance Y N
Uses handrails Y N
Seats self-independently Y N
Maneuvers to the tie-down independently Y N
COMMENTS:____________________________________________ 1 2 3
General Observations:
Physical assistance for: Verbal cues for:
_____Endurance _____Safety
_____Strength _____Technique
_____Balance _____Other______________________
_____Coordination
_____Other_________________________________________________________
Determination:
_____Not eligible _____Conditionally Eligible
_____Eligible _____Temporarily Eligible
Evaluator: ________________________________________________________
I-16
COGNITIVE FUNCTIONAL EVALUATION
Name_______________Evaluator_______________
Date_______________Age__________DOB__________Phone__________
Address___________________________________
Transportation Mode____________________SSN#_______________
Mobility Aides_________________________Vision__________
Auxiliary Aides____________________Hearing__________
(1=pass, 2=fail, 3=not tested)
1. Orientation:
A. What is your address? 1 2 3
B. Without looking at a clock, tell me what time it is now 1 2 3
(Correct = within 1 hour)
C. Where are you right now? 1 2 3
D. How did you get here? 1 2 3
COMMENTS:________________________________________________ 1 2 3
2. Safety:
A. If you were lost, what would you do? 1 2 3
(Correct-- ask someone nearby for help or call someone)
B. What is your telephone number? 1 2 3
C. Able to dial number or direct someone to assist them 1 2 3
3. Number Recognition: (3 seconds per slide)
A. You need to catch Route 2.
Ring the bell when you see bus #2 1 2 3
B. You need to catch Route 26.
Ring the bell when you see bus #26 1 2 3
C. You need to catch Route 235.
Ring the bell when you see bus #235 1 2 3
COMMENTS:___________________________________________ 1 2 3
4. A. Information obtained from phone call:
1) What bus number do you catch? 1 2 3
2) Where will you catch the bus? 1 2 3
3) What time do you need to catch the bus? 1 2 3
B. Information obtained from written or taped note:
1) What bus number do you catch? 1 2 3
2) Where will you catch the bus? 1 2 3
3) What time do you need to catch the bus? 1 2 3
(Pass = 3/3 correct from A or B)
COMMENTS: ____________________________________________ 1 2 3
I-17
5. Route Finding:
A. Initiates activity within 2 minutes_________________1 2 3
B. Able to find route__________________________________1 2 3
C. Able to find way back_______________________________1 2 3
D. Completes entire route within 20 minutes____________1 2 3
COMMENTS:______________________________________________1 2 3
6. Safety Street Crossing.
A. Looks both ways for traffic_________________________1 2 3
B. Crosses in crosswalk area___________________________1 2 3
COMMENTS:______________________________________________1 2 3
7. Retention of Route Information:
A. What bus number do you catch?_______________________1 2 3
B. Where will you catch the bus?_______________________1 2 3
C. What time will you need to catch the bus?___________1 2 3
COMMENTS:______________________________________________1 2 3
Determination:
_____Not eligible _____Conditionally eligible
_____Eligible _____Temporarily eligible
EVALUATORS: ______________________________________________________
I-18
COMBINED FUNCTIONAL EVALUATION
Name_________________________Evaluator____________________
Date_______________Age__________DOB_______________Phone__________
Address______________________________
Transportation Mode_________________________SSN#_______________
Mobility Aides____________________Vision__________
Auxiliary Aides_______________Hearing__________
(1=pass, 2=fail, 3=not tested)
*NOTE: Take resting vitals at this time
1. Orientation:
A. What is your address?___________________________________ 1 2 3
B. Without looking at a clock, tell me what time it is now_ 1 2 3
(Correct = within 1 hour)
C. Where are you right now?________________________________ 1 2 3
D. How did you get here?____________________________________1 2 3
COMMENTS___________________________________________________ 1 2 3
2. Safety:
A. If you were lost, what would you do?_______________ 1 2 3
(Correct-ask someone nearby for help or call someone)
B. What is your telephone number?_____________________ 1 2 3
C. Able to dial number or direct someone to assist them1 2 3
COMMENTS:_____________________________________________ 1 2 3
3. Number Recognition: (3 seconds per slide)
A. You need to catch Route 2.
Ring the bell when you see bus #2 1 2 3
B. You need to catch Route 26.
Ring the bell when you see bus #26 1 2 3
C. You need to catch Route 235.
Ring the bell when you see bus #235 1 2 3
COMMENTS:___________________________________________ 1 2 3
4. Obtaining Route Information:
A. Information obtained from phone call:
1) What bus number do you catch? 1 2 3
2) Where will you catch the bus? 1 2 3
3) What time do you need to catch the bus? 1 2 3
B. Information obtained from written or taped note:
1) What bus number do you catch? 1 2 3
2) Where will you catch the bus? 1 2 3
3) What time do you need to catch the bus? 1 2 3
(Pass = 3/3 correct from A or B)
COMMENTS: ____________________________________________ 1 2 3
I-19
5. Mobility Device:
A. Measurement: 1 2 3
(Pass= device does not exceed 30" width, 48" length)
B. Weight: 1 2 3
(Pass= device and client combined do not exceed 600 pounds)
COMMENTS:_____________________________________________ 1 2 3
6. Mock-up:
A. Time for lift/stairs portion: __________________ 1 2 3
(Pass= Able to complete in 3:00 or less.)
B. Time for interior portion:______________________ 1 2 3
(Pass= Able to complete in 3:00 or less.)
(Pass= Able to complete both A & B within 5:00 minutes)
Observations:
Moves on/off lift independently Y N
Moves up/down stairs independently Y N
Maintains balance Y N
Uses handrails Y N
Seats self-independently Y N
Maneuvers to the tie-down independently Y N
COMMENTS:____________________________________________ 1 2 3
7. Route Finding:
A. Initiates activity within 2 minutes_________________1 2 3
B. Able to find route__________________________________1 2 3
C. Able to find way back_______________________________1 2 3
D. Completes entire route within 20 minutes____________1 2 3
COMMENTS:______________________________________________1 2 3
8. Distance:
Do not evaluate if BP is 200/105 or O2 saturation rate 88.
Discontinue if BP increases to 250/110, HR 75% of maximum for age,
or if O2 sat. rate drops suddenly. 75% maximum for age_____________
Resting 330 Feet 660 Feet
HR ________ ________ ________ 1 2 3
BP ________ ________ ________ 1 2 3
02 Sat. ________ ________ ________ 1 2 3
Time ________ ________ ________ 1 2 3
(Pass = Able to travel 660 feet within
8 minutes within vital guidelines)
COMMENTS: ____________________________________________ 1 2 3
I-20
9. Curbs and Curb cuts:
A. Able to maneuver independently
1) Up 6" curb 1 2 3
2) Down 6" curb 1 2 3
B. Able to maneuver independently
1) Up curb cut 1 2 3
2) Down curb cut 1 2 3
(Pass = 2/2 correct from A or B)
COMMENTS: ____________________________________________ 1 2 3
10. Timed Street Crossing
A. Looks both ways for traffic 1 2 3
B. Crosses at crosswalk area 1 2 3
C. Able to complete in 50 seconds 1 2 3
COMMENTS:__________________________________________ 1 2 3
General Observations:
Physical assistance for: Verbal cues for:
_____Endurance _____Safety
_____Strength _____Technique
_____Balance _____Other_____________________
_____Coordination
_____Other________________________________________________________
11. Retention of Route Information:
A. What bus number do you catch? 1 2 3
B. Where will you catch the bus? 1 2 3
C. What time will you need to catch the bus? 1 2 3
COMMENTS:____________________________________________ 1 2 3
Determination:
_____Not eligible _____Conditionally Eligible
_____Eligible _____Temporarily Eligible
Evaluator: _______________________________________________________
I-21
ADA Paratransit Eligibility Manual
Appendix J
Sample Eligibility Material Developed by:
Washington Metropolitan Area Transportation Authority (WMATA)
Materials included:
- Application Form
- Professional Verification Form
- Reviewer Guidelines
APPLICATION FOR CERTIFICATION OF
AMERICANS WITH DISABILITIES ACT(ADA)
PARATRANSIT ELIGIBILITY
Limited Service Starts March 1994
This form is for use by persons who wish to apply for eligibility
for Washington metropolitan area ADA Paratransit service.
Individuals with disabilities which prevent them from being able to
use regular transit may be able to use the Washington Metropolitan
Area Transit Authority (WMATA) ADA Paratransit service. Regular
transit includes Metrorail, Metrobus and other fixed route bus
service (Ride-On, The Bus, Connect-A-Ride, Fairfax Connector, RIBS,
Tyson Shuttle, CUE Bus, DASH and Arlington Trolley). All Metrorail
service is accessible to individuals with disabilities. And
Metrobus service is accessible on an on-call basis, with lifts on
buses. In the near future, there will be more accessible transit
service in the Washington metropolitan area.
The information obtained in this certification process will only be
used by WMATA to assess the applicant's eligibility and to provide
transportation services.
THIS APPLICATION IS AVAILABLE IN ALTERNATIVE FORMATS. IF YOU NEED
ASSISTANCE, PLEASE CALL (202) 962-2700 VOICE; (202) 962-2033.
ALL INFORMATION CONTAINED IN THIS
APPLICATION WILL BE KEPT CONFIDENTIAL
1
37.005 (7/93)
J-1
APPLICATION FOR CERTIFICATION OF
AMERICANS WITH DISABILITIES ACT(ADA)
PARATRANSIT ELIGIBILITY
HOW TO APPLY FOR PARATRANSIT ADA ELIGIBILITY:
1. Read the brochure entitled WMATA ADA Paratransit, the
Americans With Disabilities Act and You, which is available
from WMATA and some local social service agencies.
2. Fill-out Part A of this application if you believe you
qualify.
3. Take or send the application (Parts A and B) to your health
care professional to have Part B completed. Both Part A and
Part B must be completed in order for your application to be
considered.
4. Mail the completed application (Parts A and B) to WMATA,
Department of ADA, 500 5th St., N.W., Washington, DC 20001.
Failure to completely fill out the application will delay the
application process.
YOU WILL BE NOTIFIED ABOUT YOUR ELIGIBILITY
- WMATA will notify you of your eligibility.
- If you have not been notified within 21 days of submitting
your application, call (202) 962-2700 Voice; (202) 962-2033
TDD. If a determination of your eligibility has not been
made, you will be temporarily eligible for paratransit
service.
- If you are denied eligibility, you have a right to appeal.
Information on the appeals process will be sent to you. Call
(202) 962-2700 Voice; (202) 962-2033 TDD for more information.
2
J-2
PART A - FOR THE APPLICANT TO COMPLETE
1 - WHO QUALIFIES: Under the ADA regulations, there are three
categories of persons who are eligible for ADA paratransit. Any
individual with a disability qualifies who:
1. Is unable, as the result of a physical or mental
impairment, to get on, ride, or get off an accessible
vehicle on the public transit system; or
2. Needs the assistance of a wheelchair lift or other
boarding assistance device and is able, with such
assistance, to get on, ride, and get off an accessible
vehicle BUT such a vehicle is not available on the route
when the individual wants to travel; or
3. Has a specific impairment-related condition (including
vision, hearing or impairments causing disorientation)
which prevents travel to or from a station or stop on the
system.
____ Please check here if at least one of these categories applies
to you.
If you qualify for the WMATA ADA Paratransit Service but
reside outside the paratransit service area, you may still use the
service for trips that start and end in the paratransit service
area. It is the responsibility of the person who wants to use
paratransit service to arrive within 3/4 mile of the service area.
(For further information, see the ADA service brochure or call the
appropriate telephone number listed on page 4 for your local
government.)
You may qualify for other specialized service provided by your
local government, such as senior transit services, even if you are
not eligible for WMATA ADA Paratransit Service.
3
J-3
PART A - FOR THE APPLICANT TO COMPLETE
If you live or want to travel in one of the following
jurisdictions, you may wish to call the appropriate number for
service or information.
District of Columbia To be announced
Montgomery County, MD (301)468-4446 Voice; 468-4447 TDD
Prince George's County, MD (301)952-5656 Voice; 925-5167 TDD
Fairfax County, VA (703)324-7050 Voice; 324-7050 TDD
City of Fairfax, VA To be announced
City of Alexandria, VA (703)838-3800 Voice; 838-5056 TDD
Arlington County, VA (703)358-5300 Voice; 358-4612 TDD
City of Falls Church, VA (703)241-5005 Voice; 241-5149 TDD
You may qualify for reduced fares on Metrobus and Metrorail
even if you do not qualify for paratransit service. Call (202)
637000 Voice; (202) 638-3780 TDD for more information.
2. Name:______________________________________________________
Address:______________________________________________________
City:_________________________________________________________
State:__________________________ Zip Code____________________
Home Telephone Number: _________________________
Other Daytime Telephone Number: ________________
TDD: (___)_________________
4
J-4
PART A - FOR THE APPLICANT TO COMPLETE
3. In case of an emergency, is there someone in the local area
who should be notified (family, friend, neighbor, case worker,
etc.)?
_____ Yes _____ No
Name: _________________________________________
Telephone Number: _____________________________
TDD: (___)_________________
As you answer the following questions, please keep in mind
that:
- You may be able to use accessible buses operating on fixed
routes. Accessible buses have equipment (including ramps,
lifts and other devices) to assist individuals with
disabilities. Bus operators make stop announcements.
- Metrorail service is accessible to individuals with
disabilities.
5
J-5
PART A - FOR THE APPLICANT TO COMPLETE
Check one box only:
4. A. ___ I can get to and from a fixed route bus stop or
Metrorail station.
4. B. ___ I cannot get to and from a fixed route bus stop or
Metrorail station.
4. C. ___ I can get to and from a fixed route bus stop or
Metrorail station only if (circle all that apply):
1. curb cuts have detectable warnings
2. I have an attendant with me
3. I need to travel less than _______ feet to or from the stop or
station
4. I am familiar with the area
5. I receive travel training for the stops and stations I use
6. the median strip is accessible
7. there are curb cuts along the route to the stop
8. there is a sidewalk
9. the ground is level or only slightly inclined
10. there are stairs with handrails at changes in level
11. there are no stairs
12. the path is free of ice or debris
13. other________________________________________________________
__________________________________________________________________
6
J-6
PART A - FOR THE APPLICANT TO COMPLETE
Check one box only:
5. A. ____ I can generally wait outside at a fixed route bus
stop or at an outside Metrorail station.
What is the maximum period you can wait outside? _______
5. B. ___ I cannot wait outside at a fixed route bus stop or
at an outside Metrorail station.
5. C. ___ I can wait outside at a fixed route bus stop or at
an outside Metrorail station only if (circle all
that apply):
1 there is a bench
2. there is a shelter
3. the wait is no longer than _____ minutes
4. other______________________________________________
6. A. Will you use any of the following when you ride
paratransit? _____ Yes _____ No If yes, check all that
apply:
___ Manual wheelchair ___ Service animal
___ Cane ___ Powered wheelchair
___ Oxygen Bottle ___ White cane
___ Powered scooter ___ Prosthesis
___ Walker ___ Communications board
___ Transfer board ___ Crutches
___ Hearing Aid ___ Boarding chair
___ Other
Your answer to this question will ensure that appropriate
paratransit service is provided.
7
J-7
PART A - FOR THE APPLICANT TO COMPLETE
6. B. If you use a wheelchair, is it less than 30 inches wide
by 48 inches long and does it weigh less than 600 pounds
when your weight is added? _____ Yes _____ No
Check one box only:
7.A.___ I can independently recognize my destination and leave
the vehicle.
7.B.___ I cannot independently recognize my destination and leave
the vehicle.
7.C.___ I can recognize my destination and leave the vehicle only
if (circle all that apply):
1. I receive travel training
2. the driver announces my stop
3. other______________________________________________
Check one box only:
8.A.___ I can ride on an accessible bus operating on a fixed
route.
8.B.___ I cannot ride on an accessible bus operating on a fixed
route.
8.C.___ I can ride on an accessible bus operating on a fixed
route only if (circle all that apply):
1. I have an attendant with me 4. every bus on my route
is accessible
2. I am familiar with the route 5. a seat is available
3. I have received travel training 6. other
8
J-8
PART A - FOR THE APPLICANT TO COMPLETE
Check one box only:
9.A.___ I can use Metrorail.
9.B.___ I cannot use Metrorail.
9.C.___ I use Metrorail only if (circle all that apply):
1. I have an attendant with me
2. I am familiar with the route
3. I have received travel training
4. there are no stairs
5. there are stairs with handrails at changes in level
6. the elevators are working
7. a seat is available
8. my stop is clearly and audibly announced
9. other______________________________________________
10.A. Do you require a Personal Care Attendant when you travel?
_____ Yes _____ No
If you use a wheelchair or a scooter, please answer 10.B. and
10.C.
10.B. Can you transfer to a car? _____ Yes _____ No ____ Sometimes
10.C. Are you willingly to transfer? _____ Yes _____ No
Your responses will not affect your eligibility to use paratransit.
9
J-9
PART A - FOR THE APPLICANT TO COMPLETE
11.___ Please check here if you are interested in travel
training. Travel training may help you to use the fixed
route bus and Metrorail systems for specific routes or
for all routes. Travel training professionals may be
available to work with you. For more information about
travel training, call (202) 9622700 Voice; (202) 962-2033
TDD.
12. How does your disability affect your ability to use
transportation? (Please provide any information that would
help.)
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
The REQUEST FOR PROFESSIONAL CERTIFICATION (Part B attached) must
be filled out by an appropriate health care professional.
WHO CAN CERTIFY: If your disability prevents you from using fixed
route service, one of the following health care professionals, as
appropriate to your case, may be able to certify you as ADA
eligible.
13. The following health care professional is authorized to
provide information to WMATA that is required to complete this
certification, including Part 8, and any clarifications required by
WMATA.
(Clearly print the name of the health care professional who will be
certifying your application and check the type of health care
professional he or she is.)
Name___________________________________________
___Licensed physician ___Certified audiologist
___Licensed physical therapist ___Certified psychologist
___Certified rehabilitation specialist ___Nurse (LPN or RN)
___Registered occupational therapist ___Licensed social worker
___Certified speech pathologist ___Licensed optometrist
10
J-10
PART A - FOR THE APPLICANT TO COMPLETE
14. I hereby certify that to the best of my knowledge the
information given above is correct and I authorize the health
care professional named in item #13 to provide information to
WMATA.
Signature of Applicant___________________________________
Date_______________________
15. If - you are not the applicant but have completed this
application on the applicant's behalf, you must provide the
following information:
Your name___________________________________________
Address_____________________________________________
City_______________________ State ________ Zip___________
Daytime Phone Number____________
Relationship to applicant____________
I certify that to the best of my knowledge the information
given above is correct.
Signed__________________________ Date__________
WHEN YOU HAVE COMPLETED PART A
Take or mail Parts A and B to the health care professional named in
item #13.
When Part B has been completed, mail Parts A and B to WMATA,
Department of ADA, 600 5th Street, N.W., Washington, DC 20001.
11
J-11
PART B - REQUEST FOR
PROFESSIONAL ADA CERTIFICATION
(Please print or write legibly)
You are being asked by the applicant named in Part A to provide
information regarding his/her ability to use our transit services.
The Washington metropolitan area fixed route transit systems will
provide paratransit services to persons who cannot use fixed route
transit services. The information you provide will allow us to
evaluate the request and to provide service for specific trip
requests. Thank you for your cooperation in this matter.
To qualify for paratransit service, the applicant must be unable to
use regular transit service due to a physical or mental disability.
Regular transit includes Metrorail, Metrobus and other fixed route
bus service (for example, DASH, Ride On, The Bus). All Metrorail
service is accessible to individuals with disabilities, and
Metrobus service is accessible on an on-call basis, with lifts on
buses. In the near future, there will be more accessible transit
service in the Washington metropolitan area.
Individuals qualify for paratransit service if:
1. as a result of their disabilities, they cannot get on, ride,
or get off a lift-equipped fixed route bus or Metrorail
vehicle; and/or
2. they have specific impairment-related conditions which prevent
them from getting to or from a fixed route bus stop or
Metrorail station.
Please note: This does not include persons who find it
uncomfortable or difficult to get to and from fixed route bus stops
or Metrorail stations.
Please be certain to base your evaluation solely upon the
applicant's ability to use regular transit.
Your certification should consider only the presence of a disabling
condition.
12
J-12
PART B - REQUEST FOR
PROFESSIONAL ADA CERTIFICATION (cont.)
CERTIFICATION PROCESS:
These are the steps of the certification process.
1 . The applicant (or representative) has completed Part A. Please
read Part A in its entirety.
2. In completing Part B, please follow the listed criteria.
3. You may be contacted if any questions remain.
4. The application must be filled out COMPLETELY or it will not
be processed.
5. Return the completed application to the applicant within 7
days of receipt. The applicant will mail the entire
application to the Washington Metropolitan Area Transit
Authority (WMATA).
6. A determination of the applicant's eligibility will be made by
WMATA within 21 days following receipt of the application.
7. If you have any questions, you may call WMATA at (202) 962-
2700 Voice; (202) 962-2033 TDD.
1. I have read Part A in its entirety. Yes ____ No ____
2. I agree with the information in Part A. Yes ____ No ____
If no, please explain:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
13
J-13
PART B - REQUEST FOR
PROFESSIONAL ADA CERTIFICATION (cont.)
3. Condition causing disability: _______________________________
4. Severity: Mild____ Moderate____ Severe____ Profound____
5. Expected duration of disability:
____ Temporary: Expected duration until
____ Long-term: Conditions with potential for improvement or
long periods of remission.
____ Permanent: Conditions with no expectation of improvement.
6. Is there any other effect(s) of the disability that WMATA
should be aware of? If so, please provide the information
here. (Please print or type.)
14
J-14
PART B - REQUEST FOR
PROFESSIONAL ADA CERTIFICATION (cont.)
7. CONCLUSION:
There are three categories of eligibility described in Part A of
this application on page 3. You may conclude that the applicant can
be included in one of these categories, or that he/she is not
eligible for the WMATA Paratransit Program. (Please check the boxes
that apply.)
It is my professional opinion that the applicant,_________________,
has a disability and the applicant (print name of applicant)
(check all that apply):
A. Has a specific impairment-related condition which prevents the
applicant from traveling to or from Metrorail stations or
fixed route bus stops. _____ Yes _____ No
B. Needs the assistance of a wheelchair lift or other boarding
assistance device and is able, with such assistance, to get
on, ride, and get off vehicles which are accessible to and
usable by individuals with disabilities. ____ Yes ____ No
C. Is unable, as the result of a physical (including a vision
impairment) or mental impairment, and without the assistance
of another individual (except the operator of a wheelchair
lift or other boarding assistance device), to get on, ride, or
get off vehicles on the transit system which are accessible to
and usable by individuals with disabilities. ____ Yes ____No
15
J-15
PART B - REQUEST FOR
PROFESSIONAL ADA CERTIFICATION (cont.)
8. I hereby certify that the above information is true. I
understand that false certification may be reported to the
licensing jurisdiction under the District of Columbia Code
Annotated, Section 2-3305.15, Code of Virginia 54.1-2915, or
Maryland Health Occupations Code Annotated 14-404 or
appropriate code for state of license/certification.
Signature __________________________ Date_______________
Print Name ______________________________________________
Street Address __________________________________________
City State ___________________________ Zip _____________
Telephone Number ______________
License/Certification: Number______________ State _____
Profession (check one):
____Licensed physician ____Certified audiologist
____Licensed physical therapist ____Certified psychologist
____Certified rehabilitation specialist ____Nurse (LPN or RN)
____Licensed social worker ____Registered occupational
____Licensed optometrist therapist
____Certified speech pathologist
THANK YOU FOR YOUR ASSISTANCE!
Please return this application to the person seeking ADA
certification.
16
J-16
WASHINGTON METROPOLITAN AREA TRANSIT AUTHORITY
(WMATA)
PARATRANSIT ELIGIBILITY STANDARDS GUIDE
APPLICANT INFORMATION
Name: ____________________________________
Address: _________________________________
Phone:(___)____________________________(___)______________________
Home Phone V or TDD Office Phone V or TDD
APPLICANT TOTALS
_____ _____ _____ _____ _____ _____ _____ _____
1 1 2 3 TG TRANS NO P.I.
PCA TRANS
REFERRAL NOT ELIGIBLE
PROFESSIONAL TOTALS
_____ _____ _____ NOT ELIGIBLE
1 2 3
COMMENTS/RECOMMENDATIONS (Circle all that apply)
PART A INCOMPLETE 1 2 3 Accessible Bus Transfer Not Eligible
PART B INCOMPLETE Trip by Trip Travel Training No Transfer
Referral
Notes: If P.I. total 5, circle "Not Eligible" above
Date Application Received:______________ Date of Review:_________
Print your name: ______________________________
Your signature: _______________________________
37.006 (7/93)
J-17
FORWARD AND DEFINITIONS
WASHINGTON METROPOLITAN AREA TRANSIT AUTHORITY (WMATA)
PARATRANSIT ELIGIBILITY STANDARDS GUIDE
This Eligibility and Standards Guide has been designed expressly
for the Washington Metropolitan Area Transit Authority (WMATA) as a
tool which will assist in determining the "ADA Eligibility" of
applicants who wish to use complementary paratransit service. This
guide has been copyrighted by REELife Solutions, and may only be
used and duplicated by WMATA, and those transit entities which
comprise WMATA.
The following is a key which defines the terms used in this guide:
Category 1:(Paraphrased) An individual with a disability is ADA
paratransit eligible if s/he is unable, as the result of a physical
or mental impairment, to board, ride, or disembark from an
accessible vehicle... without the assistance of another individual
(except the operator of a wheelchair lift or other boarding
assistance device).
Category 2:(Paraphrased) An individual with a disability is ADA
paratransit eligible if s/he needs the assistance of a wheelchair
lift or other boarding assistance device and is able, with such
assistance, to board, ride, and disembark from an accessible
vehicle ... but an accessible vehicle is not available, on the
regular system route, to the individual during regular hours of
operation.
Category 3:(Paraphrased) An individual is ADA paratransit eligible
if s/he has a specific impairment-related condition which prevents
her/him from traveling to a boarding location, or from a
disembarking location on the regular system.
Trip by Trip:
If an individual meets the eligibility criteria of this section
with respect to some trips, but not others, the individual shall be
ADA paratransit eligible only for those trips for which he/she
meets the criteria.
J-18
Possible Ineligibility (P.I.): This category indicates that the
applicant may not Joe eligible for paratransit due to the fact that
s/he is capable of utilizing an optional transit system (i.e. fixed
route bus or metrorail).
Personal Care Attendant (PCA): This category implies is that the
applicant can only use public transit with the assistance of
another individual. Therefore, the applicant would be eligible for
paratransit under Category 1. This is an individual who assists the
applicant during transport. The PCA shall not be charged for
complementary paratransit service.
Accessible Bus (ACC BUS) : This category implies that the applicant
may be able to ride the fixed route system if every bus on her/his
route is accessible.
Travel Training (TG) : This category implies that an applicant may
be able to use fixed route service if individualized travel
training is provided to that individual for a particular trip.
Transfer (TRANS): This category indicates that the applicant is
able to and/or willing to board a vehicle which is not lift-
equipped (i.e. taxicab).
Not Able to Transfer (NO TRANS): This category indicates that the
applicant is not able to and/or not willing to board a vehicle
which is not lift-equipped.
Not Eligible (NOT ELIG): This category indicates that the
applicant' is not eligible to receive paratransit service because
either s/he uses a wheelchair which cannot be accommodated on the
available lifts, or it is the professionals opinion that the
applicant is not "ADA Eligible".
ii
J-19
ELIGIBILITY STANDARDS GUIDE
- PART A -
APPLICANT
QUESTION REVIEWER ACTION ELIGIBILITY CATEGORY
RESPONSE Trip
1 2 3 by P.I.
Trip
If the box is checked,
continue with the review.
Who Qualifies?.
If the box not checked,
continue with the review-
the applicant may have
misunderstood the question.
2.
Check all information for
Personal legibility and completeness.
Information If unclear, contact for
clarification.
3.
Check for legibility and
Emergency completeness. If unclear,
Contact for clarification.This
Information is not required,
but if It is provided, be sure
it is legible.
Page 1
J-20
QUESTION REVIEWER ACTION ELIGIBILITY CATEGORY
RESPONSE Trip
1 2 3 by P.I.
Trip
Get To & From
A.
If this box is checked,
I Can... the applicant may not
be eligible under Category
3. Mark the P.I. box.
B.
If this box Is checked,
the applicant may be
I Cannot... eligible under Category 3.
Mark the box.
C.
If #s 1, 2, or 3 (less than
101 ft.) are circled,
I Can mark Category 3.
Only If...
If #a 4 or 5 are circled,
then the applicant may be
eligible for travel training
and/or trip by trip services.
Mark Categories T and TG.
If #s 6, 7, 8, 9, 10, 11 or 12
are circled, then you must
determine If the facility Is
under the control of the Transit
Authority. If yes, then mark Category T
and notify Plant Maintenance. If no,
then leave blank.
If #13 Is circled, then this application
may need to be referred out. If you are
unable to make a determination, circle REFERRAL
"Referral".
TOTAL COLUMNS Referral
TT
Highlight any box which totals 1 or more. Referral 3 G P.I
Page 2
J-21
QUESTION REVIEWER ACTION ELIGIBILITY CATEGORY
RESPONSE Trip
1 2 3 by P.I.
Trip
5.
Wait Outside?
A. If this box Is checked and
the maximum period Is more
than 1 (one) hour, mark
I Can... the P.I. box.
B.
If this box Is checked, the
I applicant may be eligible under
Cannot... Category 3. Mark the box.
C. If #s 1 or 2 are circled, mark Category T
and notify Plant Maintenance.
I Can Only If...
If #3 Is circled, and the wait Is longer
than 30 minutes, mark Category T.
If #4 Is circled, then this application may
need to be referred out. If you are unable REFERRAL
to make a determination, circle "Referral'.
TOTAL COLUMNS Referral
Highlight any box which totals 1 or more. Referral 3 T P.I.
Page 3
J-22
QUESTION REVIEWER ACTION ELIGIBILITY CATEGORY
RESPONSE Trip
1 2 3 by P.I.
Trip
6.
Mobility Aide
A.
When You Skip to Question B.
Ride...
B.
If this box is checked "No",
Wheelchair the chair is not considered
Dimensions a "common wheelchair," and
therefore service which requires
a lift may be refused.
Mark the P.I. box.
Total Columns
Not
Page 4 Highlight this box if it totals 1. Elig
QUESTION REVIEWER ACTION ELIGIBILITY CATEGORY
RESPONSE Trip
1 2 3 by P.I.
Trip
7.
Recognize & Leave
A.
If this box 13 checked, the
I Can... applicant may not be eligible
under Categories 1 or 3.
Mark the P.I. box.
B.
If this box 13 checked, the
I Cannot... applicant may be eligible under
Categories 1 or 3.
Mark Categories 1 and 3.
C.
If #1 is circled, mark Category TG.
I Can [Note: Travel training may be TG
Only If... offered.]
If #2 Is circled, mark the P.I. box.
If #3 is circled, then this application
may need to be referred out. If you
are unable to make a determination, REFERRAL
circle "Referral."
Referral
TOTAL COLUMNS
Highlight any box which totals 1 or more. 1 Referral 3 TG P.I.
Page 5
J-24
QUESTION REVIEWER ACTION ELIGIBILITY CATEGORY
RESPONSE Trip
1 2 3 by P.I.
Trip
8.
Accessible Bus
A.
If this box Is checked, the
applicant may not be eligible
under Category I
I Can... Mark the P.I. box.
B.
If this box Is checked, the
I applicant may be eligible under
Cannot... Category 1.
Mark the box.
C.
If #1 Is circled, mark Category 1.
I Can Only If...
If #s 2 or 3 are circled, then the
Applicant may be eligible for travel
training and/or trip by trip services.
Mark Categories T and TG.
If #4 Is circled, mark Category 2.
If #5 Is circled, mark the P.I. box.
If #6 Is circled, then this application
may need to be referred out. If you
are unable to make a determination, REFERRAL
circle "Referral."
Referral
TOTAL COLUMNS
2 TT
Highlight any box which totals 1 or more. 1 ACC Referral G P.I.
BUS
Page 6
J-25
QUESTION REVIEWER ACTION ELIGIBILITY CATEGORY
RESPONSE Trip
1 2 3 by P.I.
Trip
9.
Metrorail
A .
If this box Is checked, the applicant
I Can... may not be eligible under Categories
1 or 2. Mark the P.I. box.
B.
If this box Is checked, the applicant
I Cannot... may be eligible under Category 1.
Mark the box.
C.
If #1 Is circled, mark Category 1.
I Can Only If...If #s 2 or 3 are circled, then the
applicant may be eligible for travel
training and/or trip by trip services.
Mark Categories T and TG.
If #s 4 or 5 are circled, mark Category
T and notify Plant Maintenance
If #s 6, 7, or 8 are circled, mark the
P.I. box.
If # 9 is circled, then this application
may need to be referred out. If you
are unable to make a determination, REFERRAL
circle "Referral."
TOTAL COLUMNS Referral
TT
Highlight any box which totals 1 or more. 1 Referral G P.I.
Page 7
J-26
QUESTION REVIEWER ACTION ELIGIBILITY CATEGORY
RESPONSE Trip
1 2 3 by P.I.
Trip
Travel
A. If the "YES" box is checked, the
applicant may be eligible under
Personal Care Category 1. Mark the box.
Attendant (PCA)?
B. If the "YES" box is checked, mark the
"TRANS" box.
Can You
Transfer? If the "NO" box is checked, mark the
"NO TRANS" box.
C.
If the "YES" box is checked, mark the
Willing "TRANS" box.
to
Transfer? If the "NO" box is checked, mark the
"NO TRANS" box.
TOTAL COLUMNS
Highlight any box which totals 1 or more. 1
PCA
Page 8
J-27
QUESTION REVIEWER ACTION ELIGIBILITY CATEGORY
RESPONSE Trip
1 2 3 by P.I.
Trip
Travel Training
Do You Want... If this box Is checked, look to see if
the "TG" box Is highlighted on pages 2,
5, 6, and/or 7. If the above Is true, TG
mark the box.
TOTAL COLUMNS
Page 9 Highlight this box if it totals 1. TG
J-28
QUESTION REVIEWER ACTION ELIGIBILITY CATEGORY
RESPONSE Trip
1 2 3 by P.I.
Trip
12.
Effects of Read in order to assist with your
Disability.. decision.
13.
Check the name to make sure it is
Who Can Certify.. legible.
14.
Check that the application is signed
Signature... and dated. if it is not signed, the
application may have been
completed by someone other than
the applicant, so check for question
15.
15.
If question 14 is not signed, the
Completed on other person would have to fill In
Applicant's the information in question 15.
Behalf... Check that the information is
complete, legible, and that there is
a signature and date.
Page 10
J-29
ELIGIBILITY STANDARDS GUIDE
-PART B- PROFESSIONAL VERIFICATION
QUESTION REVIEWER ACTION ELIGIBILITY CATEGORY
RESPONSE Trip
1 2 3 by P.I.
Trip
1.
I have read This box must be checked "YES' to
Part A In continue review.
Its entirety.
2.
If the box Is checked 'YES", continue
the review.
I agree with the
Information...
Even if the box Is checked "NO", the applicant may
still be eligible under Category 1. Read the
Information provided. If and only If the described
effects prevent the applicant from riding an
accessible bus or Metrorail, mark the box.
Even if the box Is checked "NO", the applicant may
still be eligible under Category 3. Read the
Information provided. If and only If the described
effects prevent the applicant from getting to or
from a bus or Metrorail stop, mark the box.
3.
Condition causing... Continue the review.
4.
Severity Check that one severity Is Indicated.
5.
Check that one duration is Indicated.
Expected duration If the condition is temporary, check
that a duration date is Included.
Write date an cover, under "Notes."
6.
Other effect(s)... Continue the review.
TOTAL COLUMNS
Page 11 Highlight any box which totals 1. 1 3
J-30
QUESTION REVIEWER ACTION ELIGIBILITY CATEGORY
RESPONSE Trip
1 2 3 by P.I.
Trip
Check that the name of the
The applicant applicant Is legible; If not,
contact the professional.
A.
Impairment If the "YES" box is checked, the
related applicant may be eligible under
condition... Category 3. Mark the box.
If the "YES" box is checked, the
B. applicant may be eligible under
Category 2. Mark the box.
Needs [Note: If this is marked, the
assistance applicant may be able to ride a
of lift... 100% accessible route.]
C. If the "YES" box is checked, the
applicant may be eligible under
Is unable... Category 1. Mark the box.
If A, B, and C are all marked
"NO", the applicant is not
All marked eligible. Mark the P.I. box.
"NO"
TOTAL COLUMNS
Highlight any box which totals 1. 1 2 3 NOT
ELIG
Page 12
J-31
QUESTION REVIEWER ACTION ELIGIBILITY CATEGORY
RESPONSE Trip
1 2 3 by P.I.
Trip
Check that all Information is Include
8. and is legible. It may be necessary
Professional to contact the professional again.
Information. Check that there is a signature, a
certification number, and a date. If any of
the above are missing, contact professional.
Page 13
J-32
ADA Paratransit Eligibility Manual
Appendix K
Sample Eligibility Material Developed by:
Delaware Administration for Specialized Transportation (DAST)
Materials included:
- Application Form
- Professional Verification Form
AMERICANS WITH DISABILITIES ACT
ADA
PARATRANSIT ELIGIBILITY
APPLICATION
DELAWARE ADMINISTRATION FOR
SPECIALIZED TRANSPORTATION
DOVER, DE 19903-1347
(302) 739-3278
1-800-553-3278
1-800-252-1600/TDD
K-1
REQUEST FOR CERTIFICATION OF ADA PARATRANSIT ELIGIBILITY
DELAWARE ADMINISTRATION FOR SPECIALIZED TRANSPORTATION
DAST
The Americans with Disabilities Act (ADA) requires that disabled
individuals be guaranteed access to transportation services.
DAST's paratransit services are provided for disabled persons
unable to use fixed route services.
HOW TO APPLY FOR DAST PARATRANSIT ADA ELIGIBILITY:
1. Fill out PART A of this application.
2. Take or send the application to your health care professional
to have PART B completed.
3. Mail the completed application to DAST, P.O. Box 1347, Dover,
DE 199031347.
4. DAST will notify you as to your eligibility status.
5. If you have not heard about your eligibility status within 21
days of submitting your application, please call (302) 739-
3278/TDD 1-800-252-1600. If a determination has not yet been
made, you will be temporarily eligible.
6. If you are denied eligibility, you will have a right to appeal
the eligibility decision. Please contact DAST for details on
the appeals process.
PAGE 1
K-2
PART A - APPLICANT
1. NAME OF APPLICANT___________________________________
2. ADDRESS_____________________________________________
CITY_______________________ STATE______________ ZIP_________
If address is a P.O. Box or RD #, please give street address, road
number, and etc.:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
3. TELEPHONE NUMBER (Home)_(____)___________________
Other Daytime Telephone Number_(____)_______________
4. DATE OF BIRTH____/____/____
5. MALE_______ FEMALE_______
6. In case of an emergency, is there someone in the local area
who should be notified?
_____YES _____No
NAME________________________________________________
ADDRESS_____________________________________________
PHONE_(____)_________________
RELATIONSHIP________________________________________
PAGE 2
K-3
Check the category and all criteria that apply:
____CATEGORY 1
I have a physical, mental, or visual disability, or
impairment, which PREVENTS me from utilizing fixed route buses
without an attendant for:
(1)____boarding
(2)____riding
(3)____disembarking
(4)____other (describe): ____________________________________
CATEGORY 2
I can use buses with wheelchair lift, but
(1)____Buses with wheelchair lifts are not available in my
area.
(2)____Wheelchair lift can not be deployed at my stop(s): List
Location:
_____________________________________________________________
(3)____My mobility aid is 30"w x 48"l or less, but the bus
will not accommodate it.
CATEGORY 3
I can use accessible buses, but have an impairment-related
condition which prevents me from traveling to/from a bus
boarding location. Describe the impairment or condition:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
PAGE 3
K-4
Do you use any of the following aids (check all that apply)?
_____ Manual Wheelchair* _____ Electric Wheelchair*
_____ Power Scooter* _____ Cane
_____ Crutches _____ White cane
_____ Guide Dog _____ Walker
* Please note that your trip origin and destination must be
accessible by ramp or lift. IF NOT ACCESSIBLE, please have someone
available to assist you up and down steps. Drivers are not
permitted to assist wheelchair customers up or down steps.
Are there any other effects of your disability which we need to be
aware of?
Obesity/weight ____ Seizures ____
Paralysis ____ Need for catheter ____
Shortness of breath ____ Dizziness ____
Other, Please explain ____________________________________________
__________________________________________________________________
__________________________________________________________________
Do you require a Personal Care Attendant** when you use DAST
(circle one)?
YES NO OCCASIONALLY
** Personal Care Attendant must be provided by customer.
____ Please check here if you would be interested in travel
training for DART or CDT. Professionals are interested in making it
easier for you to use Delaware's public transportation systems. You
may qualify for reduced transit fares.
Page 4
K-5
If you have completed this application for another person you must
provide the following information:
YOUR NAME_________________________________________________________
ADDRESS___________________________________________________________
CITY_________________________________STATE____________ZIP_________
DAYTIME PHONE_____________________________________________________
SIGNED_______________________________DATE___________
I hereby certify that the information given above is correct.
APPLICANT SIGNATURE______________________________________
DATE__________________
PAGE 5
K-6
PART B
REQUEST FOR PROFESSIONAL VERIFICATION
Dear Health Care Professional:
You are being asked by_______________________________(applicant) to
provide Information regarding his/her ability to use our transit
services. Federal law requires that DAST provide paratransit
services to persons who cannot use fixed-route transit services.
The Information you provide will allow us to evaluate this request
and Its application to specific trip requests. Thank you for your
cooperation In this matter.
To qualify for DAST Paratransit service, a person must be unable to
use regular pubic transit due to a physical or mental disability.
Individuals qualify if:
1. as the result of their disability, they cannot board, ride, or
disembark from a Delaware Administration for Regional Transit
(DART), or Central Delaware Transit (CDT) or Delaware Resort
Transit (DRT) bus; or
2. they have a specific impairment-related condition which
prevents them from getting to or from a bus stop.
PLEASE NOTE: This does not include persons who find ft
uncomfortable or difficult to get to and from bus stops.
Resources for this program are limited and your evaluation of each
person must be based solely upon the individual's ability to use
regular transit. Your verification should consider only the
presence of a disabling condition, not the applicant's age or
economic status. Please exercise care in evaluating applicants for
this program. False verification could result in travel limitation
for persons legitimately qualified to use the program.
CERTIFICATION PROCESS
1. Applicant (or representative) has completed PART A.
2. Health Care professionals completing PART B must be guided by
the criteria explained herein.
3. DAST may contact the certifying health care professional to
verity the accuracy of the information.
4. DAST will make the final determination as to the applicant's
eligibility.
5. The application must be filled out COMPLETELY for processing
to occur.
PAGE 6
K-7
DAST PARATRANSIT Is a limited special transportation service for
disabled persons who, because of a mental or physical disability,
find it IMPOSSIBLE to use regular public transportation. All parts
must be completely filled out by the authorized person who signs
below. Incomplete registration forms will be returned to the
applicant.
A. Indicate (X) nature of applicant's disability (check as many
Items as may apply.)
1.____ Non-Ambulatory (uses Wheelchair for mobility)
2.____ Impaired or Assisted Ambulation requiring:
Specify Mobility Aid
3.____ Arthritis
Specify Extremity
4.____ Amputation
Specify Extremity
5.____ Cerebrovascular Accident
6.____ Pulmonary Ills
Does applicant use a Portable Oxygen Tank? YES NO
7.____ Neurological Handicap
5.____ Cardiac Ills
9.____ Kidney Disease
Dialysis
10.____ Sight Disabilities
Legally Blind
Visually Impaired
11.____ Incoordination
12.____ Mental Retardation (circle level)
Moderate Severe Profound
13.____ Cerebral Palsy
14.____ Autism
15.____ Severe Muscle Spasms
16.____ Seizures
17.____ Loss of Consciousness
18.____ Mental Illness - Please specify what It is about
this cognitive disability that makes this individual
unable to use regular public transit buses:
________________________________________________________
________________________________________________________
________________________________________________________
19.____ Other
(describe)________________________________________
_____________________________________________________________
Describe type and severity of disability In detail and how it
prevents use of transit:
_____________________________________________________________
_____________________________________________________________
_____________________________________________________________
B. The disability is ____Permanent or ____Temporary
If temporary, expected duration is ____months.
PAGE 7
K-8
C. In your opinion, must this Individual bring a competent
attendant on each trip?
_____ Yes _____ No
If applicant Is visually Impaired or blind, developmentally
disabled, suffer from a neurological Impairment or Is mentally
retarded, has applicant received training to use fixed route buses?
_____ Yes _____ No
Check only one:
____Can use regular public transit buses on a fixed route
schedule.
____Can not use regular public transit at all.
____Can use regular public transit only to destinations for
which travel trained.
If there Is any other effect of the disability of which DAST should
be aware. Please provide an explanation:_________________________
__________________________________________________________________
D. Your professional area of specialization is:
Check one:_____ Podiatrist
_____ Optometrist
_____ Audiologist
_____ Psychologist
_____ Physical Therapist
_____ Physician
_____ Rehabilitation Specialist
_____ Independent Living Specialist
_____ Registered Nurse/Licensed Practical Nurse
YOUR NAME: _________________________________________
TITLE: _____________________ AGENCY/COMPANY NAME: ________________
PROFESSIONAL LICENSE # (if applicable): _________________
OFFICE ADDRESS: __________________________________________________
OFFICE PHONE NUMBER: _____________________
I hereby certify that the above information is true. DAST
will (1) verify the validity of the license of the health
professional providing the certification, (2) make the final
determination on an applicant's eligibility for DAST
Paratransit Service.
SIGNATURE________________________________DATE_____________________
THANK YOU FOR YOUR ASSISTANCE
WP51\CERTIFY.APP\022293
PAGE 8
K-9
ADA Paratransit Eligibility Manual
Appendix L
Sample Eligibility Material Developed by:
Regional Transportation Authority (Chicago)
Materials included:
- Application Form
- "In-Depth Review Report" Used in In-Person
Assessments
- "Certification Categories" which Define
General Types of Certification Provided
Click HERE for graphic.
L-1
Regional Transportation Authority
ADA Paratransit Application
Section 1. General Information
Please answer the following questions.
If you need help filling out this application, you can call us at
(312) 917-HELP voice, or (312) 917-1338 TTY for the hearing
impaired (Mon-Fri 8:30 AM - 5:00 PM). You may also contact any
agency on the "Help List" which is attached to the end of this
application.
1. Do you need this application and future written information
given to you in a different way?
____ YES, please tell us what that is, or you can call the RTA
for assistance:
____Large Print
____Braille
____Audio Tape
____in Spanish (en espanol)
____Other________________________________
____ NO, please continue
Please print or type the following information: Middle
Middle
First Name________________________ Initial _____ Sex: M___F___
Last Name__________________________
Address__________________________________________________________
City________________________County__________State____ Zip________
Telephone[day]__________[evening]________________
Social Security# _______ -_______ -_______Birthday month__________
Name of person filling out this form______________________________
(if other than applicant)
I understand that the purpose of this form is to determine if I am
eligible to ride Special Services. The RTA may need to talk to me
or to see me later to get more information.
I understand that I must be truthful in answering the questions on
this form. Giving false information is against the law, and could
result in losing Special Services as well as a penalty under the
law.
I agree to notify the RTA if I no longer need to use Special
Services.
________________________________________ _________________________
(Applicant Signature) (Date)
2
L-2
Please give us the name and phone number of a friend or relative in
case we are unable to reach you at your regular number:
Name__________________________________________
Telephone [day]______________________ [evening]__________________
Relationship______________________________
2. Do you have an RTA Reduced Fare Card for half fares on public
transit services ?
____YES, please give us your ID#______________________
____NO
3. Is your health condition or transportation disability
temporary ?
____YES, I expect it to last for another months
____NO, it is a permanent condition
____I don't know
4. Have you had this health condition or transportation
disability for more than one year?
____YES
____NO
____I don't know
5. Does your health condition or transportation disability change
from day to day in a way that makes it very difficult to use
fixed route bus or "L" trains
____YES, my condition is good on some days and bad on other
days.
____NO, my condition doesn't change much from day to day.
____I don't know.
PLEASE ANSWER THIS QUESTION IF YOU ANSWERED YES TO #5.
6. If you have a health condition or transportation disability
that changes from day to day, please tell us the number of
blocks that you can travel, using a mobility aide or on your
own ?
A. On a day when my health condition is good: Choose ONLY
ONE answer.
____I can't travel outside my house
____I can get to the curb in front of my house
____I can travel up to 1 block
____I can travel up to 2 blocks
____I can travel up to 4 blocks
____I can travel 6 blocks, or more
____I don't want to travel outside
3
L-3
B. On a day when my health condition is bad: Choose ONLY ONE
answer.
____I can't travel outside my house
____I can get to the curb in front of my house
____I can travel up to 1 block
____I can travel up to 2 blocks
____I can travel up to 4 blocks
____I can travel 6 blocks, or more
____I don't want to travel outside
7. Does the weather ever keep you from using fixed route buses or
"L" trains?
____ YES, Please tell us how the weather keeps you from using
fixed route buses or "L" trains_________________________
________________________________________________________
________________________________________________________
____ NO
____ I don't know
PLEASE ANSWER THIS QUESTION IF YOU ANSWERED YES TO #7.
8. If the weather affects your ability to use fixed route buses
or "L" trains please tell us how far you can travel, using a
mobility aide or on your own ?
A. When the weather is good: Choose ONLY ONE answer.
____I can't travel outside my house
____I can get to the curb in front of my house
____I can travel up to 1 block
____I can travel up to 2 blocks
____I can travel up to 4 blocks
____I can travel 6 blocks, or more
____I don't want to travel outside
B. When the weather is bad: Choose ONLY ONE Answer.
____I can't travel outside my house
____I can get to the curb in front of my house
____I can travel up to 1 block
____I can travel up to 2 blocks
____I can travel up to 4 blocks
____I can travel 6 blocks, or more
____I don't want to travel outside
4
L-4
9. Which of the following mobility aides or equipment do you use
to help you get where you need to go ? (Please check all that
apply)
I use a:
____cane ____long white cane
____walker ____leg braces
____crutches ____manual wheelchair
____personal care attendant
____powered wheelchair ( manufacturer & model__________
____powered scooter ( manufacturer & model______________
____service animal
____other____________________________________
____ I do not use a mobility aide, personal care
attendant, or service animal.
10. Do you normally travel with a personal care attendant ?
__YES, please check all that apply
I always need a personal care __ get to the bus stop or
attendant to: "L" station
__ get on or off the bus
or "L" train.
__YES, __ help me while I ride
I sometimes need a personal care the bus or "L" train
attendant to: __ when I use special
services
__NO __ other________________
11. Which of the following limit your ability to use fixed route
buses or "L" trains? (check all that apply)
____physical disability
____visual impairment/blindness
____developmental disability
____mental illness
____other
Section 2. Questions about using fixed route buses and ("L") trains
PLEASE ANSWER THESE QUESTIONS EVEN IF YOU DO NOT REGULARLY RIDE
BUSES OR "L" TRAINS:
(Be sure to check all boxes on the shaded area that apply to you.)
12. Do you now use fixed route CTA or Pace buses?
____YES,
how many days in one week____
or, how many days in one month____
____NO,
is there something that would help
you to ride the fixed route bus?
please check all that apply
____ knowing more about fixed route buses
____ learning to go from home to work or school
____ a lift (accessible bus)
____ communications aid
____ I would ride if there were accessible bus
routes where I need to go
____ learning to travel with crowds, noises, traffic
____ other_________________________________________
5
L-5
13. Do you now ride "L" trains?
____YES,
how many days in one week____
or, how many days in one month____
____NO,
is there something that would help you to ride "L"
trains?
please check all that apply
____ knowing more about "L" trains
____ elevator at the station
____ escalator at the station
____ knowing which stations to use
____ learning about standing on the platform to
catch the train
____ I would ride if there were accessible "L"
stations where I need to go
____ learning to travel with crowds, noises, traffic
____ other_________________________________________
14. Can you transfer from one fixed route bus to another or
between the bus and the "L" train?
____YES, always
____YES, sometimes
____NO
I don't know because I have never tried it
please check all that apply
____ I get too confused and might get lost.
____ I can transfer if it's someplace I go all the
time.
____ I don't like to transfer.
____ I can't hold a paper transfer.
____ I don't want to use the fixed route service.
____ other_________________________________________
15. Can you use the telephone to get bus and train information?
____YES, by myself
____YES, with assistance
please tell us what type of assistance:_________________
____NO, not at all
please tell us why:_____________________________________
________________________________________________________
________________________________________________________
16. Can you follow written or oral instructions to use fixed route
buses or "L" trains?
____ YES, always
____ YES, sometimes
____ NO
____ I don't know because I have never tried it
please check all that apply
____ I get too confused and might get lost.
____ I don't want to use the fixed route buses or
"L" trains.
____ I probably could with training
____ other_________________________________________
L-6
17. Using a mobility aid or on your own, can you make your way to
or from the bus stop nearest your home ?
_____ Yes, always
_____ Yes, sometimes
_____ NO
_____ I don't know because I have never tried
please check all that apply
____ I cannot find the bus stop because I get
confused and might get lost.
____ I don't know where the bus stop is.
____ I don't want to ride fixed route buses.
____ I can't go that far.
____ My surroundings keep me from getting there.
____ I probably could with training.
____ I can't travel to the bus stop in bad weather.
____ I can travel to the bus stop when my health
condition is good, but not when i'm having a
bad day.
____ other_________________________________________
18. Can you wait 10 minutes at a bus stop that has a seat and a
shelter?
_____ Yes, always
_____ Yes, sometimes
_____ NO
_____ I don't know because I have never tried it
please check all that apply
____ I don't like to wait that long.
____ I can't wait that long in bad weather.
____ I can wait 10 minutes when my health condition
is good, but not when I'm having a bad day.
____ other_________________________________________
19. Can you wait 10 minutes at a bus stop that does not have a
seat and a shelter?
_____ Yes, always
_____ Yes, sometimes
_____ NO
_____ I don't know because I have never tried it
please check all that apply
____ I don't like to wait that long.
____ I can't stand that long.
____ I can't wait that long in bad weather.
____ I can wait 10 minutes when my health condition
is good, but not when I'm having a bad day.
____ other_________________________________________
20. Can you get on and off a fixed route bus standing or with a
mobility aid)
-YES, always
-YES, sometimes
-NO
-I don't need to use the lift
-I don't know because I have never tried the lift
please check all that apply
____ My mobility aid won't fit on the lift.
____ I can't steady myself when the lift is moving.
____ I don't want to use the lift.
____ I don't feel secure on the lift.
____ I probably could with training.
____ other_________________________________________
7
L-7
21. Can you get on and off a fixed route bus when it does not have
a passenger lift ?
____ YES, always
____ YES, sometimes
____ NO
____ I don't know because I have never tried it
please check all that apply
____ I don't want to ride fixed route buses.
____ I need a lift.
____ I probably could with training.
____ other_________________________________________
22. Can you get on and off the "L" train at a station with ramps
or elevators?
____ YES, always
____ YES, sometimes
____ NO
_____ I don't need to use an elevator or ramp
____ I don't know because I have never tried it
please check all that apply
____ My mobility aid won't fit on the elevator
____ I can't board the train when there is a gap
between the train and the platform
____ I don't want to use the "L".
____ I probably could with training.
____ other_________________________________________
23. Can you follow written or oral instructions to pay your bus or
"L" train fare?
____ YES, always
____ YES, sometimes
____ NO
____ I don't know because I have never tried it
please check all that apply
____ I get too confused.
____ I am not sure how much to pay.
____ I don't know where or when to pay.
____ I don't want to use the bus or "L".
____ I probably could with training.
____ other_________________________________________
24. Can you put your fare in the fare box on the bus?
____ YES, always
____ YES, sometimes
____ NO
____ I don't know because I have never tried it.
please check all that apply
____ I need help from an attendant or another
passenger.
____ I don't know where the farebox is.
____ I can't put my fare in the farebox when the bus
is moving.
____ I probably could with training.
____ other_________________________________________
8
L-8
25. Once inside, can you get to a seat or wheelchair position by
yourself on a fixed route bus or "L" train?
____ YES, always
____ YES, sometimes
____ NO
____ I don't know because I have never tried it
please check all that apply
____ I need someone to help me.
____ I have a balance problem.
____ I can't hold onto the handrails.
____ I have trouble finding a seat.
____ I need the seat nearest the door.
____ I probably could with training.
____ other_________________________________________
26. Do you know where to get off the bus or train or can you find
out?
____ YES, always
____ YES, sometimes
____ NO
____ I don't know because I have never tried it
please check all that apply
____ I get confused or can't remember where I am
going.
____ I don't know where my bus stop or "L" station
is located.
____ I can if the driver calls out the stops.
____ I probably could with training.
____ other_________________________________________
9
L-9
Section 3. Questions about training
27. For informational purposes, please tell us about your training
experience. Have you ever had any training to learn how to use
fixed route buses or "L" trains?
____ YES, was trained by_____________________________________
I was trained in: month______________ year_____________
I learned: (please check all that apply)
____ to travel to and from bus stops or "L" stations
____ general bus travel
____ general travel on "L" trains
____ how to read bus and "L" train destination signs
____ getting on or off the bus or "L" train
____ how to communicate with bus drivers & "L" train
conductors
____ asking for help or saying no when offered help
____ I started but did not finish training
____ I received training but want more so that I can
travel
____ to ride on specific bus routes or "L" train lines
please list them:
1._______________ 4._______________
2._______________ 5._______________
3._______________
_____ NO, (please check all that apply)
____ I would like to get training so that I can use buses
and "L" trains.
____ I do not want to receive training.
____ I have not had any training but am able to use buses
and "L" trains.
28. If available, do you want training or re-training to use fixed
route buses or "L" trains?
____ YES, I want the following training, if it is available:
(please check all that apply)
____ how to travel to and from bus stops or "L" stations
____ general bus travel
____ general travel on "L" trains
____ how to read bus and "L" train destination signs
____ getting on or off the bus or "L" train
____ how to communicate with bus drivers & "L" train
conductors
____ how to ask for help or saying no when offered help
____ how to ride on specific bus routes or "L" train
lines
please list them:
1._______________ 4._______________
2._______________ 5._______________
3._______________
_____ NO, (please check all that apply)
____ I do not want to receive training.
____ I do not think I can travel on fixed route service,
even with training.
____ I trained myself but would like and update on
training schedules and equipment.
10
L-10
29. Is there anything else you want to tell us about your
disability and transportation?
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
11
L-11
Section 4. Travel Information
FREQUENT PUBLIC TRANSIT ORIGINS AND DESTINATIONS
Please list your five most frequent trips, and how you get there
now.
SAMPLE
How many times per
Origin Destination week do you go there?
1. home 181 W. Madison, Chicago 5
How do you get there now?
_X_ fixed route bus or "L" train __ Special Services __Other
How many times per
Origin Destination week do you go there?
1.________________________________________________________________
How do you get there now?
__ fixed route bus or "L" train __ Special Services __Other
2.________________________________________________________________
How do you get there now?
__ fixed route bus or "L" train __ Special Services __Other
3.________________________________________________________________
How do you get there now?
__ fixed route bus or "L" train __ Special Services __Other
4.________________________________________________________________
How do you get there now?
__ fixed route bus or "L" train __ Special Services __Other
5.________________________________________________________________
How do you get there now?
__ fixed route bus or "L" train __ Special Services __Other
12 Ver. #1 8/5/93
L-12
EXHIBIT B
IN-DEPTH REVIEW REPORT
Instructions to reviewer:
Please complete the three sections of this report for each
applicant evaluated:
1. Reviewer Comments and Travel Training Recommendations. 2.
Functional Assessment(application questions), and 3. Eligibility
Recommendation. In addition to the three sections, please provide
the following information:
Please print or type the following information:
Applicant Name____________________________________________________
Name of Reviewer__________________________________________________
Address of Reviewer_______________________________________________
City_______________________ State_________ Zip_________
Telephone_(____)________________
Date of Application Referral_________
Date of Applicant Interview__________
Have results of evaluation been conveyed to the applicant?
__YES __NO
Reviewer Signature of Completion__________________________________
Date_______________________
1. Reviewer Comments & Travel Training Recommendation
Reviewer Comments:
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
Travel Training Recommendation:
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
L-13
2. Functional Assessment (application questions)
A. Does applicant now use fixed route CTA or Pace buses?
____ YES
how many days a week?____
how many days a month?____
____ NO (answer questions below by checking all that apply)
What would help applicant to ride fixed route buses?
____ knowing how to use fixed route buses
____ a lift (accessible bus)
____ communications aid
____ would ride if there were accessible bus routes where
he/she needed to go
____ does not ride because he/she has trouble dealing with
crowds
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
B. Does applicant now ride CTA "L" trains?
____ YES
how many days a week?____
how many days a month?____
____ NO (answer questions below by checking all that apply)
What would help applicant to ride fixed route buses?
____ knowing how to use "L" trains
____ elevator at the station
____ escalator at the station
____ would ride if there were accessible "L" stations where
he/she needed to go
____ does not ride because he/she has trouble dealing with
crowds
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
L-14
Can applicant transfer from one fixed route bus to another or
between the bus and the "L" train ?
____ YES, always
____ YES, sometimes (answer question below by checking all
that apply)
____ NO (answer question below by checking all that apply)
____ Applicant doesn't know because he or she has never tried
it
CHECK ALL THAT APPLY
____ applicant gets too confused and might get lost
____ applicant doesn't like to transfer
____ applicant doesn't want to use fixed route service
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
D. Can applicant use the telephone to make calls?
____ Yes, with no assistance
____ Yes. with assistance. Note what type of assistance is
needed:
(i.e., TTY machine)_____________________________________
____ NO. not at all
why:____________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
L-15
E. Can applicant follow written or verbal instructions to use
fixed route buses or "L" trains?
____ Yes. always
____ Yes, sometimes (answer question below by checking all
that apply)
____ NO (answer question below by checking all that apply)
____ Applicant doesn't know because he or she has never tried
it
CHECK ALL THAT APPLY
____ applicant gets too confused and might get lost
____ applicant doesn't want to use fixed route buses or "L"
trains
____ applicant probably could with training
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
F. Using a mobility aid or on his/her own, can applicant make
his/her way to or from the bus stop nearest his/her home?
____ Yes. always
____ Yes, sometimes (answer question below by checking all
that apply)
____ NO (answer question below by checking all that apply)
____ Applicant doesn't know because he or she has never tried
it
CHECK ALL THAT APPLY
____ applicant cannot find bus stop, gets too confused and
might get lost
____ applicant doesn't know where bus stop is located
____ applicant doesn't want to use fixed route buses or "L"
trains
____ applicant can't go that far
____ applicant doesn't feel secure
____ applicant probably could with training
____ applicant can't travel to the bus stop in hot weather
____ applicant can't travel to the bus stop in cold weather
____ applicant can travel to the bus stop on "good days" but
not on "bad days"
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
L-16
G. Can applicant wait 10 minutes at a bus stop that has a seat
and a shelter?
____ Yes. always
____ Yes, sometimes (answer question below by checking all
that apply)
____ NO (answer question below by checking all that apply)
____ Applicant doesn't know because he or she has never tried
it
CHECK ALL THAT APPLY
____ applicant doesn't like to wait that long
____ applicant can't wait that long in hot weather.
____ applicant can't wait that long in cold weather.
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
H. Can applicant wait 10 minutes at a bus stop that does not have
a seat and a shelter ?
____ Yes. always
____ Yes, sometimes (answer question below by checking all
that apply)
____ NO (answer question below by checking all that apply)
____ Applicant doesn't know because he or she has never tried
it
CHECK ALL THAT APPLY
____ applicant doesn't like to wait that long
____ applicant can't stand that long
____ applicant can't wait that long in hot weather.
____ applicant can't wait that long in cold weather.
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
L-17
I. Can applicant get on and off a fixed route bus when it has a
passenger lift (either standing or with a mobility aid) ?
____ Yes. always
____ Yes, sometimes (answer question below by checking all
that apply)
____ NO (answer question below by checking all that apply)
____ Applicant doesn't know because he or she has never tried
it
CHECK ALL THAT APPLY
____ applicant's mobility aid won't fit on the lift
____ applicant can't steady himself/herself when the lift is
moving
____ applicant doesn't want to use the lift
____ applicant doesn't feel secure on the lift
____ applicant probably could with training
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
J. Can applicant get on and off a fixed route bus when it does
not have a passenger lift?
____ Yes. always
____ Yes, sometimes (answer question below by checking all
that apply)
____ NO (answer question below by checking all that apply)
____ Applicant doesn't know because he or she has never tried
it
CHECK ALL THAT APPLY
____ applicant doesn't want to use fixed route buses
____ applicant probably could with training
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
L-18
K. Can applicant get on and off the "L" train at a station with
ramps or elevators?
____ Yes. always
____ Yes, sometimes (answer question below by checking all
that apply)
____ NO (answer question below by checking all that apply)
____ Applicant doesn't need to use an elevator or ramp
____ Applicant doesn't know because he or she has never tried
it
CHECK ALL THAT APPLY
____ applicant mobility aid won't fit on the elevator
____ applicant can't board the train when there is a gap
between the "L" train and the platform
____ applicant doesn't want to use the "L"
____ applicant probably could with training
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
L. Can applicant follow written or verbal instructions to pay
his/her bus or "L" train fare?
____ Yes. always
____ Yes, sometimes (answer question below by checking all
that apply)
____ NO (answer question below by checking all that apply)
____ Applicant doesn't know because he or she has never tried
it
CHECK ALL THAT APPLY
____ applicant gets too confused
____ applicant is not sure how much to pay
____ applicant doesn't want to use the bus or "L"
____ applicant probably could with training
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
L- 19
M. Can applicant put his/her fare in the fare box?
____ Yes. always
____ Yes, sometimes (answer question below by checking all
that apply)
____ NO (answer question below by checking all that apply)
____ Applicant doesn't know because he or she has never tried
it
CHECK ALL THAT APPLY
____ applicant needs help from attendant or another passenger
____ applicant can't put his/her fare in the fare box when the
bus is moving
____ applicant probably could with training
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
N. Can applicant use paper transfer?
____ Yes. always
____ Yes, sometimes (answer question below by checking all
that apply)
____ NO (answer question below by checking all that apply)
____ Applicant doesn't know because he or she has never tried
it
CHECK ALL THAT APPLY
____ applicant needs help from attendant or another passenger
____ applicant probably could with training
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
L-20
O. Once inside can applicant get to a seat or wheelchair position
by himself/herself on a fixed route bus or "L" train?
____ Yes. always
____ Yes, sometimes (answer question below by checking all
that apply)
____ NO (answer question below by checking all that apply)
____ Applicant doesn't know because he or she has never tried
it
CHECK ALL THAT APPLY
____ applicant needs someone to help him/her
____ applicant has a balance problem
____ applicant cannot hold onto the handrails
____ applicant needs the seat nearest the door
____ applicant probably could with training
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
P. Does applicant know where to get off the bus or train, or can
he or she find out?
____ Yes. always
____ Yes, sometimes (answer question below by checking all
that apply)
____ NO (answer question below by checking all that apply)
____ Applicant doesn't know because he or she has never tried
it
CHECK ALL THAT APPLY
____ applicant gets confused or can't remember where he or she
is going
____ applicant doesn't know where his/her bus stop or "L"
station is located
____ applicant probably could with training
____ other___________________________________________________
ADDITIONAL COMMENTS RELATED TO THIS FUNCTION:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
L-21
3. Eligibility Recommendation
NON-TEMPORARY:
CERTIFICATION FOR ALL TRIPS
BASIS FOR RECOMMENDATION & SPECIFIC LIMITATIONS OF APPLICANT
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
TRANSITIONAL CERTIFICATION
BASIS FOR RECOMMENDATION & SPECIFIC LIMITATIONS OF APPLICANT
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
CONDITIONAL VARIABLE CERTIFICATION
BASIS FOR RECOMMENDATION & SPECIFIC LIMITATIONS OF APPLICANT
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
CONDITIONAL COLD WEATHER CERTIFICATION
CONDITIONAL HOT WEATHER CERTIFICATION
PLEASE PROVIDE DETAILED INFORMATION
BASIS FOR RECOMMENDATION & SPECIFIC LIMITATIONS OF APPLICANT
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
L-22
CONDITIONAL ORIENTATION CERTIFICATION
PLEASE PROVIDE DETAILED INFORMATION INCLUDING ROUTES WHICH
APPLICANT IS TRAINED FOR AND UNDER WHAT CONDITIONS
BASIS FOR RECOMMENDATION & SPECIFIC LIMITATIONS OF APPLICANT
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
CONDITIONAL TRAINING ELIGIBILITY
BASIS FOR RECOMMENDATION & SPECIFIC LIMITATIONS OF APPLICANT
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
TEMPORARY:
TEMPORARY CERTIFICATION
(6 MONTH PERIOD OF ELIGIBILITY)
BASIS FOR RECOMMENDATION & SPECIFIC LIMITATIONS OF APPLICANT
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
TEMPORARY TRAINING CERTIFICATION
PLEASE PROVIDE ADDITIONAL INFORMATION ON TYPE OF TRAVEL TRAINING
REQUIRED:
BASIS FOR RECOMMENDATION & SPECIFIC LIMITATIONS OF APPLICANT
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
L-23
L-24
REGIONAL TRANSPORTATION AUTHORITY
Chicago, Illinois
ADA Paratransit Eligibility Categories
ALL TRIPS
Client is eligible for ADA paratransit trips for all travel.
CONDITIONAL - VARIABLE DISABILITY CONDITION
Client is eligible for ADA paratransit trips only on days when the
client self-determines that his/her disability prevents use of
fixed route service.
CONDITIONAL - ORIENTATION
Client is eligible for ADA paratransit trips except when the trip
requested has a noneligible origin and destination. A non-eligible
origin and destination might be, for example: 1) a trip that the
client is already making consistently and successfully on fixed
route service, or 2) a trip for which the client has successfully
completed travel training. The non-eligible trips will be
specifically defined in the client's eligibility determination.
CONDITIONAL - WINTER MONTHS
Client is eligible for ADA paratransit trips only from November 15
through March 15.
CONDITIONAL - SUMMER MONTHS
Client is eligible for ADA paratransit trips only from July 15
through August 31.
TEMPORARY - TRAINING
Client is eligible for ADA paratransit trips for all travel
during a period when travel training will be made available to
the client. At the completion of either the temporary period
or the travel training, a final eligibility determination will
be made.
Page 1
L-25
TEMPORARY - DISABILITY CONDITION
Client will be eligible for ADA paratransit service for the period
of estimated disability. Generally, the client will be eligible
for ADA paratransit service for all travel during this period,
although the potential exists for conditional-type restrictions
under this category.
TEMPORARY - VISITOR
Client will be eligible for ADA paratransit service for a 2 1 -day
period, based upon the ADA eligibility granted by another public
mass transportation provider. Generally, the client will be
eligible for ADA paratransit service for all travel during this
period, although the potential exists for conditional-type
restrictions under this category.
Page 2 saf
09/08/93
L-26
ADA Paratransit Eligibility Manual
Appendix M
Sample Eligibility Material Developed by:
Port Authority of Allegheny County (PAT)
Materials included:
- Excerpt from ADA Paratransit Plan Update which
Summarizes the Eligibility Process (Note "Functional
Tests" on pp. 46 - 53)
- "Personal Assistance Certification" Form (certifies
need for a PCA)
- Application Form
- "Functional Evaluation - Physical" Form Used in In-
Person Assessment of Individuals with Physical
Disabilities
B. Description of Process to Certify Individuals as Paratransit
Eligible
The information provided in this section is generally a
summary of the eligibility information provided in the 1992
Paratransit Plan. Forms referenced herein were provided in the
1992 Plan and are not repeated. Descriptions of the functional
tests have been updated and are included herein.
1. Description of Categories of Eligibility
ACCESS ADA paratransit service will be offered by
Port Authority of Allegheny County to individuals with
physical, cognitive or visual disabilities who have been
certified as functionally unable to use Port Authority Is
fixed route system either permanently, temporarily or
under certain circumstances.
It is recognized that individuals with disabilities
may be certified as eligible under a variety of
conditions. some may be able to use fixed route service
some of the time, some may never be able to use fixed
route service and some may be unable to use fixed route
service on a temporary basis. After the evaluation
procedure has been completed, each applicant will be
assigned to a Category of Use. A description of these
Categories of Use follows.
a. Permanent
Individuals who have been judged functionally
unable to saf ely and independently board, ride or
disembark from a fully accessible transit vehicle
M-1
will be eligible for unrestricted paratransit use.
b. Transitional
Transitional or temporary eligibility will
apply to individuals who are functionally able to
use fixed route service, but do not have an
accessible vehicle on their route; individuals with
temporary disabilities that, temporarily prevent the
use of fixed route service, or persons with visual
or cognitive impairments who are in the process of
receiving mobility training.
c. Conditional
Conditional or trip-by-trip eligibility will
apply to individuals who are able to use Port
Authority's fixed route service sometimes, but may
require ACCESS service in special circumstances.
Determination of eligibility for any paratransit
trip request in this category will be based on a
specific set of criteria which relate to the
interaction of an individuals disability and
functional ability in certain circumstances which
prevent travel to a bus stop. Unavailability of
fixed route service by itself will not constitute
eligibility for a person who would otherwise be
functionally able to take the same trip on fixed
route were the service available. These
circumstances will include, but are not limited to:
- Dangerous pedestrian or traffic situations.
M-2
- Susceptibility to hypothermia and/or heat
sensitivity (this could be seasonal).
- Terrain.
- Treatments resulting in severe fatigue (ex:
dialysis, chemotherapy).
- Progressive, episodic disabilities (good/bad
days).
- Ability to negotiate a transfer if one is
required.
2. Description of Application and Certification Process
a. Availability of Information About the Process
Information about the process for applying for
paratransit service may be obtained by calling the ACCESS
administration office at 562-5353 Monday through Friday
between 8:00 a.m. and 4:30 p.m. All persons must apply
for paratransit service eligibility in person at the
Easter Seal Society or other locations) to be determined
by the ACCESS administrative office. Other community
based locations may be identified in the future.
An appointment must be scheduled for the
application/certification process. At the time the
appointment is scheduled, the applicant will be told what
documentation should be brought to the interview.
M-3
1. Interview
An application, in the form of an interview,
will be completed for each applicant. This personal
interview will be conducted to gather information
from the applicant about his/her disability, current
use (if any) of fixed route transit services, and
their own assessment of their environment and
functional ability.
2. Documentation
The applicant must bring current verification
of his/her disability.
3. Professional Verification
Applicants currently receiving service from an
agency may choose to have professional verification
of functional ability accompany their application
for service. Designated staff at specified agencies
will be authorized to complete professional
verification forms for their clients.
4. Functional Tests
Because paratransit eligibility is based
primarily on functional ability to independently use
fixed route service, functional tests and certain
recognized, standardized tests which are reasonable
predicators of functional ability are an important
component
M-4
of the determination of eligibility. The following
functional tests will be performed as part of the
screening process.
(a) Bus Boarding/Disembarking Test
A licensed physical therapist on the staff
of the Easter Seal Society conducts this
physical limitation evaluation which examines
the applicant's ability to ambulate on a flat
surface, maintain balance and independently
negotiate steps.
Both a mockup of the front end of a bus
and a mockup of a curb are used for the
physical test of the applicant's ability to
board a bus. The individuals lower and upper
extremity functions will be evaluated as the
therapist determines ability to independently
initiate the first step, maintain balance,
grasp the handrail and negotiate the steps.
The therapist will be primarily evaluating the
applicants:
- Strength
- Endurance
- Balance/Coordination
- Weight Bearing Ability
- Range of Motion
M-5
After the physical test has been
administered, the therapist will note his/her
observations and state his/her professional
evaluation of the applicant's functional
ability to safely and independently board any
bus which is not fully accessible, as well as
ability to use the lift on an accessible bus.
This evaluation and recommendation will
become part of the application.
ACCESS riders who were certified prior to
March 1, 1993 were certified based on their
inability to board an inaccessible bus.
Recertification of current ACCESS riders to
determine ability to use an accessible bus will
be conducted after about one half of Port
Authority's routes are accessible.
Specific information about the
recertification process will be included in
future paratransit plan updates.
(b) Cognitive Evaluation Assessment Tools
Based on the applicant's cognitive
disability, one or more of the following
assessment tools will be considered:
(1) Mini-Mental State Examination (MMSE)
The MMSE will be administered by a
M-6
trained interviewer at the time of the
application. If the applicant has had the test
administered within the last month, he/she may
bring the test results along with verification
from the agency which administered the test.
(2) Ranchos Los Amigos Scale
Results performed by an approved
rehabilitation facility within the last 30 days
will be accepted.
(3) Functional Assessment Based on Subtests from
Standard Instruments:
An assessment of the individuals
functional abilities will be made based on
subtests from the following standard
instruments which will be administered by a
trained professional at the time of application
for paratransit eligibility.
Communicative Abilities in Daily Living
(CADL) cognitive Competency Test (CCT) River
Mead Behavioral Memory Test Tests of specific
cognitive domains including memory, attention,
and problem solving.
(4) Simulated Training Instrument
In conjunction with the functional
M-7
assessment based on subtests from standard
instruments, the applicant's ability to learn
to use fixed route service will also be
assessed through a simulated training
instrument. The instrument, developed locally,
is a realistic simulation of the environment
with both learning and assessment components.
3. Description of Eligibility Case Review Process
An applicant for ACCESS ADA paratransit service who
has been notified in writing that eligibility has been
denied, may request a review of the eligibility
determination. The completed Case Review Application
will forwarded to the Review Committee as soon as it is
received.
The Review Committee is a group of professionals and
advocates not employed by Port Authority or ACCESS, whose
function is to consider eligibility appeals and make a
joint recommendation concerning eligibility.
The Review Committee, through the release of
information consent, will have access to the individuals
entire application for ADA paratransit eligibility and
will be permitted to contact the applicant's physician
and/or other agency professionals as appropriate
concerning the functional ability of the applicant to use
fixed route transit services. It will be the job of the
M-8
Review Committee to make a recommendation concerning
eligibility and to outline their decision as it relates
specifically to the eligibility criteria.
C. Personal Assistance Certification
Individuals who require a personal assistant to perform at
least one daily living activity when they travel, may travel with
one person as a personal assistant at no charge effective March 1,
1993. Activities performed by a personal assistant may include:
mobility assistance; personal care; eating; or communication
(including verbal communication translation, sign language
interpretation, or services of a reader).
The rider will self certify his/her need for a personal
assistant using the form found in Exhibit A on the following page.
This certification form will be sent to all current ACCESS riders
in February. For new applicants, the certification of need for a
personal assistant will be obtained at the time of registration.
M-9
ACCESS
TRANSPORTATION SYSTEMS, INC.
FOR OFFICE USE ONLY
I.D. NUMBER________________
EVALUATION DATE________________________ DATE ISSUED:______________
PERMANENT _____________REFUSED__________CARRIER:___________ #_____
TRANSITIONAL___________EXPIRATION DATE:___________
CONDITIONAL: 1 2 3 4 5 6 7 8 9 P.A.:
SPECIAL ASSISTANCE:________________________ ____ Yes ____ NO
APPLICATION FOR ACCESS PARATRANSIT SERVICES
Name__________________________________ Date of Birth_____________
Last First
Address_________________________________________ Apt.____________
City___________ State____ Zip Code_______
SOCIAL SECURITY#____________ Phone (H)___________ (W)_____________
What is the disability which prevents you from using PAT Bus
Service:
__________________________________________________________________
Have you brought verification of your disability? ____Yes ____ No
Is your disability permanent? ____Yes ____ No
If no, how long do you expect to have a disability?______________
Designate any mobility aids you use (check all that apply).
_____Manual Wheelchair _____Dog Guide _____Prosthesis
_____Motorized Wheelchair_____White Cane _____Crutches
3 Wheeled________ _____Walker _____Other
4 Wheeled________ _____Cane ________________
Manufacturer_____ _____Braces ________________
701 Smithfield Street / Pittsburgh, Pennsylvania 15222-3906 / (412)
562-5353 / FAX (412) 391-0594
M-11
Please read the following 10 statements and circle the one
statement that applies to you. (Circle one)
1. I can use PAT service sometimes, but for certain trips either
I have not been trained, or there are other barriers present.
2. I have a temporary disability which prevents me from getting
on any bus which is not fully accessible. I will need ACCESS
service only until I recover.
3. I have an ambulatory disability which prevents me from
boarding any PAT vehicle which is not fully accessible.
4. I have an ambulatory disability which prevents me from
boarding even an accessible PAT vehicle without assistance.
5. I have a cognitive disability which prevents me from
remembering and understanding all I have to do to find my way
to and from the PAT stop, and ride the bus. I don't feel that
I can ever learn.
6. I have a cognitive disability which prevents me from
remembering and understanding all I have to do to find my way
to and from the PAT stop, and ride the bus. I think that with
training I can learn, but I don't know how right now.
7. I have a visual disability which prevents me from finding my
way to and from the PAT stop. I don't feel that I can ever
learn.
8. I have a visual disability which prevents me from finding my
way to and from the PAT stop. I think that with training I
can learn, but I don't know how right now.
9. I have a severe medical condition. My condition results in an
impairment which makes it impossible for me to use PAT
service.
10. I have an episodic disability. I can use the bus on those
days when I am feeling well, but on "bad days", I can't make
it to the stop, or even get on the bus.
- Do you currently use PAT service at all? ____Yes ____ No
- Do you have a PAT half fare card? ____Yes ____ No
- Can you name any PAT bus routes which serve your neighborhood?
- Where is the closest bus stop to your home? Please give the
location (Ex: Corner 5th and Grant)
_____________________________________________________________
M-12
- List your 4-5 most frequent destination, and how you get
there.
Destination Address Frequency of Travel How Do You Get There Now?
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
- Are there places you would like to go that you can't get to
now?
Destination Address Frequency of Travel How Do You Get There Now?
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
- How did you find out about ACCESS?___________________________
_____________________________________________________________
- How did you get to this appointment today? (What means of
transportation?)
_____________________________________________________________
EMERGENCY CONTACT
- May we have the name of someone you would like us to contact
in case of an emergency. (Please select someone who would not
be riding in the vehicle with you.)
Name ____________________________________________________
Phone (Home) _________________ (Work)___________________
Relationship ____________________________________________
I certify that this information is correct.
Signature _____________________________ Date _______________
To be completed if the applicant was assisted by someone else in
the completion. of the application.
Name ________________________________________
Daytime Phone _______________________________
Address _____________________________________
Relationship ________________________________
Signature ___________________________________
M-13
- Can you get to this bus stop by yourself:
_____ Yes _____ No _____ Sometimes
If no, why not?
__________________________________________________________
- If you use PAT bus service now, do you need the assistance of
another person?
(Circle One) Always Sometimes Never
Which routes do you currently travel?
____________________________________________________________
What is it about riding a PAT bus that is most difficult for you.
(Ex: The bus moves before you are seated, etc.)
__________________________________________________________________
__________________________________________________________________
- Are there any ridership or usage factors about PAT bus service
which are a particular challenge to you? (Ex: Frequent
"standing room only", etc.)
______________________________________________________________
______________________________________________________________
- If you do not use PAT service, what are the conditions of your
disability which prevent you from riding the bus or "T"?
______________________________________________________________
______________________________________________________________
- How many steps are there at the entrance you use at your
residence?
______________________________________________________________
______________________________________________________________
- Are there sidewalks at your residence? _____ Yes _____ No
- How would you describe the terrain where you live? (Ex: very
steep hill, long gradual hill, flat, etc.)
______________________________________________________________
______________________________________________________________
- Can you ever cross the street by yourself? _____ Yes _____ No
If yes, under what circumstances?
______________________________________________________________
______________________________________________________________
- Have you ever received mobility training? _____Yes _____ No
If yes, where were you trained?______________________________
by (Agency)__________________________________________________
Was it route specific? _____Yes _____No
Which routes/destinations did you learn?_____________________
______________________________________________________________
M-14
ACCESS
TRANSPORTATION SYSTEMS, INC.
RELEASE OF INFORMATION
I receive services from the following rehabilitation facility or
health care professional or agency which is familiar with my
disability. You have my permission to contact them to provide
information to ACCESS for the purpose of completing this
certification procedure.
(Please use a separate form for each agency)
Name______________________________________________________________
Address___________________________________________________________
__________________________________________________________________
Staff Person Familiar with my Case________________________________
I understand that this information will be held by ACCESS in the
strictest confidence and will not be shared with any other person
or agency.
Signature of Applicant____________________________________________
Witness___________________________________________________________
Date_______________________
701 Smithfield Street / Pittsburgh, Pennsylvania 15222-3906 / (412)
562-5353 / FAX (412) 391-0594
M-15
ACCESS
TRANSPORTATION SYSTEMS, INC.
PERSONAL ASSISTANCE CERTIFICATION
ACCESS
NAME_____________________________________ ID No.__________________
Last First Mi.
ADDRESS:________________________________ APT.#_______________
__________________________________________________________________
City State Zip Code
Home Phone:_______________________ Work Phone:___________________
What is your disability?__________________________________________
What mobility equipment do you use?_______________________________
I certify that I need the services of a personal assistant to make
independent travel possible. A personal assistant is someone
designated or employed specifically to assist me with the
completion of at least one daily activity on a regular basis.
I will need a personal assistant permanently or temporarily or
occasionally. If temporary, provide expected duration
I certify that the information provided is true and correct.
Signature:_______________________________ Date:_________________
Witness (if completed by someone else):___________________________
701 Smithfield Street / Pittsburgh, Pennsylvania 15222-3906 / (412)
562-5353 / FAX (412) 391-0594
M-16
ACCESS
TRANSPORTATION SYSTEMS, INC.
APPLICATION FOR ACCESS PARATRANSIT SERVICE
PROFESSIONAL VERIFICATION
Applicant's Name__________________________________________________
Address___________________________________________________________
1) In what capacity do you know the applicant? _________________
_____________________________________________________________
2) What was the last date of face to face contact by you or your
agency with this client (other than related to this
application)?
_____________________________________________________________
3) What is the medical diagnosis of the applicant's disability?
_____________________________________________________________
4) What was the date of onset?
_____________________________________________________________
5) What is the expected length of duration?
_____________________________________________________________
6) To your knowledge, how does the applicant currently use PAT
fixed route transit, if at all? (Example: with assistance
only; on these specific routes only, etc.)
_____________________________________________________________
7) In your opinion, what are the applicant's functional
limitations which prevent him/her from utilizing fixed route
transit independently? Please be specific.
_____________________________________________________________
8) Are there any circumstances under which you believe the
applicant could independently use fixed route transit? Please
Describe. (Example: if the driver announced the stops.)
_____________________________________________________________
701 Smithfield Street / Pittsburgh, Pennsylvania 15222-3906 / (412)
562-5353 / FAX (412) 391-0594
M-17
9) Has the applicant ever received any community orientation and
mobility training?
_____ Yes _____ No _____ Don't Know
If Yes: Year Trained________ Trained By: ______________
Agency_______________________________________________________
If it was route specific, please list routes and/or
destinations.
_____________________________________________________________
Was training completed? _____ Yes _____ No
If No: Do you believe that the applicant could be successfully
trained to travel independently via public transportation -
and under what conditions?
_____________________________________________________________
_____________________________________________________________
10) Is there any additional information regarding the applicant
which you believe impacts on his/her functional ability to use
PAT fixed route service, or any special circumstances which
you believe should be considered?
_____________________________________________________________
_____________________________________________________________
I certify that this information is true and correct to the best of
my knowledge.
Signature-Title___________________________________________________
__________________________________________________________________
Please Print or Type Name Please Print Title
Agency____________________________________ Phone_________________
Address___________________________________________________________
Date______________________________________________________________
M-18
FUNCTION EVALUATION - PHYSICAL
Step Test (Strength/Weight Bearing/Range of Motion)
Curb/Curb Cut
Balance/Coordination
Ambulation on Level Surface or Pushing Wheelchair
Street Crossing Simulation
Maneuver on to Lift
Other Observations
Recommendation:
___________________________________________________________________
Physical Therapist Date
M-19
ADA Paratransit Eligibility Manual
Appendix N
Information about the Applicant Tracking System
used by Seattle Metro
Managing ADA Paratransit Compliance Through Automation
Nancy Poultney, Janey Elliott and the staff at Seattle Metro
Accessible Services, have taken a progressive approach to managing
the certification process of individuals who apply for ADA
Paratransit Eligibility by automating their processes using the
SIGMA IV Applicant Management System (AMS).
The SIGMA IV AMS is a powerful and flexible tool designed specially
for the tracking of all types of applicants. Seattle Metro's
Accessible Services Section uses AMS to track applicants as they
progress through the certification process, sending notices of
status and keeping track of time frames related to processing time,
all of which is important to ensure compliance with ADA.
AMS is used to manage rider eligibility records for both the ADA
and Access paratransit programs. Information on approximately
21,000 riders is currently being stored, with a total database of
up to 50,000 riders expected when Metro reaches full ADA
compliance. Accessible Services uses AMS to do the following:
- Produce labels for weekly mailings of ADA registration and
Access reregistration materials;
- Track applicants through the ADA eligibility determination and
appeal process, including tracking time limits for
determination, external review, eligibility to appeal, etc.;
- Generate over 20 different individually-addressed form letters
(including large type for people with limited vision) to
notify riders of various types of eligibility determination,
referral for review and appeal status and service changes, all
documented with Notice Tracking;
- Produce management reports using ad hoc reporting and the
Workload Activity tracking capabilities of AMS.
When ADA paratransit service starts up in late 1993, information
from the records of eligible riders will be exported daily via
modem from the AMS file to Metro's paratransit services broker for
use with an automated scheduling and dispatch system. This will
allow Metro to protect rider confidentiality while providing the
broker with the information required to determine eligibility and
deliver service.
If you have specific questions on how Metro Seattle Accessible
Services is using SIGMA IV AMS to automate the paratransit
certification process, contact Janey Elliott in Seattle at (206)
689-3115.
The SIGMA IV Applicant Management System is a PC based program that
is distributed exclusively by Sigma Data Systems, Inc., 6375 E.
Tanque Verde Road, Suite 250, Tucson, A.Z 85715. For more
information on how to automate your ADA Paratransit certification
process, contact Sigma Data Systems at (800) 677-1275.
N-1
N-2 *U.S. G.P.O.:1993-301-717:80404
NOTICE
This document is disseminated under the sponsorship of the U.S.
Department of Transportation in the interest of information
exchange. The United States Government assumes no liability for
its contents or use thereof.
The United States Government does not endorse manufacturers or
products. Trade names appear in the document only because they are
essential to the content of the report.
This report is being distributed through the U.S. Department of
Transportation's Technology Sharing Program.
DOT-T-93-17