Determining ADA Paratransit Eligibility

357 Pages·2016·12.95 MB·English

by  Eileen Miller

This publication was downloaded from the National Aging and Disability
Transportation Center’s website (www.nadtc.org). It was developed by
Easter Seals Project ACTION, a technical assistance center operated by
Easter Seals, Inc. through a cooperative agreement with the U.S.
Department of Transportation, Federal Transit Administration.

National Aging and Disability Transportation Center
[email protected]
866-983-3222
Determining ADA
Paratransit Eligibility
An Approach, Recommendations
and Training Materials
CONTAINS
Guidance for Conducting
Physical Functional Assessment
for ADA Paratransit Eligibility
An Introduction to
FACTS Administration
Assessment and Scoring Exercises
Easter Seals
R
www.projectaction.org

Determining ADA
Paratransit Eligibility
An Approach, Recommendations
and Training Materials
PREPARED FOR: Update of 2003 Manual
Easter Seals ProjectACTION December 2014
1425 K Street NW, Suite 200
Washington, DC 20005
Phone: [phone] Easter Seals Project ACTION is funded
www.projectaction.org through a cooperative agreement with the
U.S. Department of Transportation, Federal
Transit Administration, and is administered
PREPARED BY:
by Easter Seals, Inc.
TranSystems
This information is disseminated by ESPA
& in the interest of information exchange.
ACCESS Transportation Systems Neither Easter Seals nor the U.S. DOT, FTA
assumes liability for its content or use.

Easter Seals
R

Table of Contents
Acknowledgements
Introduction
SECTION 1............. Overview of ADA Paratransit Eligibility
SECTION 2............. The Foundation for Accurate, Thorough
ADA Eligibility Determinations
SECTION 3............. Developing an Appropriate Process
SECTION 4............. Sample Brochures, Cover Letters and Application Forms
SECTION 5............. Recommendations for Conducting In-Person Interviews and
for Obtaining Follow-Up Information from Professionals
SECTION 6............. Recommendations for Conducting Physical Functional
Assessments for ADA Paratransit Eligibility
SECTION 7............. Instructions and Training Material for Administering the
Functional Assessment of Cognitive Transit Skills (FACTS)
SECTION 8............. Determining ADA Paratransit Eligibility for People with
Vision Disabilities
SECTION 9............. A Framework for Making “Difficult Determinations”
SECTION 10......... Managing the Process
Instructors Guide

Acknowledgements
The information and material in this workbook was collected and prepared with the
assistance of a number of individuals and organizations.
2014 UPDATED EDITION
Principal Authors
Russell Thatcher – TranSystems, Boston, Mass.
Karen Hoesch – ACCESS Transportation Systems, Pittsburgh, Pa.
Review Committee
Doug Douglas – Dallas Area Rapid Transit, Dallas, Texas
Tammy Haenftling – Dallas Area Rapid Transit, Dallas, Texas
Eugene Lozano – California State University Sacramento
Michael Wehmeyer, Ph.D. – University of Kansas Dept. of Special Education, Lawrence, Ks.
2003 EDITION
Mr. Ken Thompson of Easter Seals Project ACTION served as the Project Liaison and managed the
overall effort. Ms. Donna Smith of Project ACTION also provided valuable input on issues related to
eligibility determinations for applicants with vision disabilities.
Ms. Karen Hoesch of ACCESS Transportation Systems, Inc. of Pittsburgh, PA was the Project Manager
and a principal author of the workbook. Mr. Russell Thatcher of TranSystems in Cambridge, MA
(formerly Multisystems, Inc.) was also a principal author.
Ms. Susan L. Chase of Working Order in Pittsburgh, PA, and Dr. Graham Ratcliff, of Health South
Harmarville Rehabilitation Center in Pittsburgh assisted in the development of recommendations for
assessing cognitive functional abilities and in the development of the FACTS training CD-ROM.
Dr. Rosemary Lysaght of the Division of Occupational Therapy at the University of Utah’s College of
Health, Logan, UT was instrumental in developing recommendations for conducting physical functional
assessments, compiled the information on recommended core competencies for conducting physical
functional assessments, and assisted in the development of the training CD-ROM included in Section 5.
Ms. Bonnie Dodson-Burk, a Certified Orientation & Mobility Specialist in Hollidaysburg, PA authored
the text on “How People Who Are Visually-Impaired or Blind Travel,” “Low Vision and Mobility,” and
“Features of an Accessible Intersection” which are included in Section 7.
Input and recommendations were also provided throughout the project by the following representatives
of several national and state disability organizations and disability membership organizations.
• Ms. Aloma Bouma, National Federation of the Blind, Baltimore, MD.
• Mr. Charles Crawford: Executive Director, American Council of the Blind, Washington, D.C.
• Mr. Gus Estrella, Policy Analyst, United Cerebral Palsy Associations, Washington, D.C.
• Mr. K. T. Hertz, National Association of Area Agencies on Aging, Washington, D.C.
• Ms. Maureen McCloskey, Paralyzed Veterans of America, Washington, D.C.
• Ms. Cari Watrous, Governor’s Office for Individuals with Disabilities, Baltimore, MD.
The following transit agency representatives and contractors involved in the development and
administration of ADA paratransit eligibility determination processes across the country also provided
input and shared information and materials from their areas. Contributing their experience and
information were:
• Ms. Cherryl Beveridge, Paratransit Operations Manager, Utah Transit Authority, Salt Lake City, UT.
• Ms. Constance Sakell, NRC Program Director, Neurological Rehabilitation Center, Tamarac, FL.
• Ms. Holly Dick, Community Liaison, ACCESS Transportation Systems, Inc., Pittsburgh, PA.
• Ms. Tammy Haenftling, Assistant Vice President, Paratransit Management Services, Dallas Area Rapid
Transit, Dallas, TX.
• Mr. Art Hulscher, Administrator of Disabled Services, Orthopaedic Hospital, Los Angeles, CA.
• Ms. Susan Joseph, Senior Management Analyst, Regional Transportation Commission, Las Vegas, NV.
• Mr. W. Joe King, Jr., Eligibility Determination Administrator, Access Services, Inc. Los Angeles, CA.
• Ms. Anne LeFevre, ADA Certification Specialist, Regional Transportation Authority, Chicago, IL.
• Ms. Patricia Mazur, Physical Therapist, Easter Seals of Western Pennsylvania, Pittsburgh, PA.
• Ms. Nancy Mott, Occupational Therapist, Easter Seals of Western Pennsylvania, Pittsburgh, PA.
• Ms. Linda Robinson, ADA Eligibility Specialist, Paratransit Management Services, Dallas Area Rapid
Transit, Dallas, TX.
• Mr. Philip Shayne, Manager of Regional Services, Regional Transportation Authority, Chicago, IL.
• Ms. Jeri Wise, PT, Supervisor of CAT Paratransit Assessment Program, Nova Care, Las Vegas, NV.
• Mr. Edward Wisniewski, Manager - Paratransit Service, Broward County Transit, Pompano Beach, FL.
The Port Authority of Allegheny County and the Pennsylvania Department of Transportation provided
generous support, and many of Pittsburgh’s transit customers with disabilities assisted in the
completion of the video portions of the CD.
Finally, a special thanks to the staff at Panta Rhei Media, Inc. of Turtle Creek, PA for their patience and
professionalism in producing the CD-ROMs contained in Sections 5 and 6.
Introduction
Determining ADA Paratransit Eligibility: An Approach, Guidance and Training Manual was
developed and disseminated by ESPA in 2003 to provide fixed-route transit providers with information
and resources regarding the ADA complementary paratransit service eligibility process. This manual is
a revision and update of the 2003 document prepared by ESPA. It includes information about the latest
revisions to the DOT ADA regulations. It also incorporates information about successful approaches
and materials developed by transit agencies since 2003, and it addresses common questions and
issues raised by transit agencies as well as by persons with disabilities.
Background & Purpose
Section 223 of the Americans with Disabilities Act of 1990 (ADA)  1 requires public entities that operate
non-commuter fixed-route transportation services also provide complementary paratransit service for
people with disabilities who are unable to use the fixed route system. The regulations issued by the
U.S. Department of Transportation (DOT)  2, 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 that are subject to the complementary paratransit requirements to develop and administer a
process for determining if people who request service meet the regulatory criteria for eligibility.
Since the issuance of regulations in 1991, technical assistance materials have been developed by
DOT, the Federal Transit Administration (FTA), and Easter Seals Project ACTION (ESPA) to assist
transit agencies with the implementation and management of ADA paratransit eligibility determination
processes. Initial information on the development of complementary paratransit plans, including
the establishment of eligibility determination processes, was provided in FTA’s ADA Paratransit
Handbook  3 immediately following the issuance of the regulations. In 1993, FTA also prepared and
disseminated the Americans with Disabilities Act (ADA) Paratransit Eligibility Manual  4, which
provided additional information on implementing and appropriate process. Finally, in 2003, ESPA
developed and disseminated Determining ADA Paratransit Eligibility: An Approach, Guidance and
Training Materials  5, which offered specific information on including in-person interviews and functional
assessments in the overall process.
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 Gaffney, J.K., ADA Paratransit Handbook: Implementing the Complementary Paratransit Service
Requirements of the Americans with Disabilities Act of 1990, U.S. DOT Report #UMTA-MA-06-0206-91-1, prepared for the
Federal Transit Administration, Office of Technical Assistance and Safety, Washington D.C., September, 1991.
4 EG&G Dynatrend, Americans with Disabilities Act (ADA) Paratransit Eligibility Manual, U.S. DOT Report No.
DOT-T-93-17, Prepared for the Federal Transit Administration, Washington D.C., September 1993.
5 TranSystems, Inc. and ACCESS Transportation Systems, Inc., Determining ADA Paratransit Eligibility: An Approach,
Guidance and Training Materials, Easter Seals Project ACTION, Washington D.C., August 15, 2003.