ADA POLICY GUIDELINES: Written Policies for Internal and External Use David Cyra, CYRA ETTC, LLC, Mukwonago, Wisconsin Doug Cross, Douglas J. Cross Transportation Consulting, Oakland CalACT Fall Conference, Monterey, September 20, 2012 A Decision making Framework Rules/Regulations Policies Procedures Handbooks Special Manuals Job Descriptions Standards Performance Evaluations Purpose of Policy Development Clarify performance areas, predictability Consistent application Enable fair decision making Improve working conditions Aid internal investigation Ensure quality transit service Safety and security Internal Policy Style Guide Subject Policy Statement Purpose Procedures Management Responsibilities Consequences References Guidelines Sign off Sheet Developing Paratransit Rider Policies Select which service policies should have written guidelines Apply ADA regulations, system standards, and other factors Develop policy statements Get input and approval from policy boards, advisory committees, and operating staff Present policies in ways riders and others can understand best Copyright 2012 David Cyra and Douglas J. Cross Page 1
External Policy Communication It is important that accessibility features and rules be understood by disabled passengers, as well as: Other transit passengers Families and caregivers People with disabilities Seniors Public officials Effective Policy Writing Tips In the language of policy writing, anything that aids understanding is good; anything that may confuse the reader is bad. Keep sentences short Avoid complex terms Write in the active voice, in the present tense Use active verbs whenever possible Drop all unneeded words Venues for Publishing or Posting Rider Policies Descriptions in printed/web rider s guides Newsletter items and reminders Special purpose brochures Website descriptions of service features/accessibility/policies Telephone "on hold" messages (for certain important topics) Onboard vehicle postings: decals (signage), ad cards, and posters Official "policy book" or document kept at office, with entire book or individual subjects made available to consumers when needed Best Practice Examples of Policies and Rider s Guides California Access Services, Inc.» Los Angeles City of Clovis Transit (Round Up and Stageline) East Bay Paratransit» Oakland (AC Transit & BART) City of Elk Grove Transit (e tran/e van) Marin County Transit/Marin Access (Whistlestop Wheels) Sacramento Regional Transit/Paratransit, Inc. Santa Clara VTA/Outreach» San Jose Santa Cruz Metro Western Contra Costa County Transit (WestCAT)» Pinole Other States Denver RTD King County Metro/Access» Seattle RTC of Southern Nevada» Las Vegas Copyright 2012 David Cyra and Douglas J. Cross Page 2
POLICY STATEMENT TOPICS Related to Providing ADA Paratransit Services David Cyra, CYRA ETTC, LLC, Mukwonago, Wisconsin Doug Cross, Douglas J. Cross Transportation Consulting, Oakland CalACT Fall Conference, Monterey, September 20, 2012 PREFACE This topic list describes a range of potential topics; not all of them will be needed or appropriate at individual agencies. Likewise, the list is not comprehensive, and other types of policy statements may be needed. Sample policy statements (see handouts) are only a general guideline, and should be tailored to the situation and style of each agency s normal policy language. WHAT CONSUMERS SHOULD EXPECT IN TERMS OF SERVICE DELIVERY How to Use the Service Time of day /area coverage (esp. if limited to 3/4 mi. from fixed route) Description of origin to destination service (see curb vs. door to door below) Advance reservation requirements Rules for trip time negotiation and tracking of denials/refusals Rules for subscription standing orders, same day, standby, and/or will call rides Explanation of scheduling window Definition of on time Trip by trip determinations Trip coordination with adjacent ADA paratransit systems Which system to call for rides Transfer procedures, including any hand offs Transfer facility locations and amenities Assistance Provided by Drivers Curb or door to door service How drivers will announce their arrival Whether drivers must stay within sight of vehicle Assistance walking, guiding mobility device users, or being seated Number and size of packages drivers will carry (see separate section for wheelchair/mobility device and lift/ramp usage) Vehicles and ride sharing Whether preferred vehicles can be guaranteed, or only as available What to expect in terms of extra time for picking up and dropping off other passengers Maximum ride time to be expected, if applicable (CONTINUED next page) Copyright 2012 David Cyra and Douglas J. Cross Page 3
RULES FOR USING THE SERVICE What/Who Will Be Transported Description of & maximum number; any size limits for: Attendants (PCA s; including children) Companions (including children) Service animals Pets Packages or shopping carts Baby strollers Oxygen or other life sustaining equipment (see separate section for wheelchair/mobility device and lift/ramp usage) Minimum Standards for Riders Minimal behavior/capability standards for riders Unattended passengers must be met at origin/destination Independent riding age for children PU and DO locations must be accessible to vehicle General Paying fares, including for attendants, companions; any premium fares Being ready to board How long driver will wait before leaving/no showing How and when to communicate problems: late rides, complaints, etc. Use/provision of child seats Seat belts Visitor policy General rules: eating, drinking, smoking, radio playing, illegal/hazardous substances, etc. Calling in Cancellations and Changes Deadline for canceling or modifying trips How no shows and late cancels will be assigned Description of penalties for violation Rules on Safety and Behavior Cleanliness and hygiene; refrain from use of scented products Disruptive behavior is prohibited and can result in suspension Whether or not passengers can disembark at locations other than scheduled (CONTINUED next page) Copyright 2012 David Cyra and Douglas J. Cross Page 4
ELIGIBILITY CERTIFICATION, SUSPENSIONS, AND APPEALS Eligibility Requirements Full vs. conditional Permanent vs. temporary Description of eligibility categories Length of certification Re certification requirements Application Requirements Must apply to home system Rules for completing written applications Description of in person interviews or assessments Consequences for incomplete app s. or falsification of information Eligibility Process Timeframe; presumptive eligibility for over 21 days Description of written notice of determination Description of I.D. card Definitions of conditional restrictions Outline of appeals process Suspension Policy Basis, i.e. number of no shows, late cancels, etc. within a period Not assessed for reasons beyond passenger s control How consumer will be notified of warnings or suspensions Length(s) of suspensions How service will be reinstated afterward Consequences for disruptive behavior Appeals of Suspensions and Changes in Eligibility Status Deadline for submissions Information required When/where hearings will be held Who can accompany or represent appellant Timeframe for deciding appeals Service provided pending determination INFORMATION ON FIXED ROUTE SERVICES AND ACCESSIBILITY Rationale for using fixed route as primary service Basic info. about local bus and rail transit services Key accessibility features of local fixed route transit Discount/free fares for disabled riders on fixed route (esp. in comparison w/ paratransit fares) Special training or assistance available travel training, peer support, boarding practice, etc. Contact information for local fixed route systems Copyright 2012 David Cyra and Douglas J. Cross Page 5