Fixed Route Bus Service with ADA Complementary Paratransit Sample Policy

The purpose of this document is to provide rural public transit agencies with a sample of a written ADA policy for commingled fixed route bus and ADA complementary paratransit service.  This template is only appropriate for transit systems that provide fixed route service and ADA complementary paratransit using the same vehicle.  Under this scenario, the transit agency provides fixed route service, but deviates from the fixed route for ADA complementary paratransit-eligible persons with disabilities. For this type of commingled service, the transit agency must meet all of the ADA complementary paratransit requirements under 49 CFR Part 37 Subpart F.  Transit systems that provide fixed route service with separate ADA complementary paratransit, route deviation for all passengers, and/or general demand responsive services (in addition to, or instead of, fixed route services) should refer to the sample ADA policy template for these types of services.



The transit agency is advised to carefully read all elements of this policy template and edit to reflect its local policies and practices.  The items in red should be customized for the transit agency and its own local policies. 


The items in purple are additional notes and instructions related to customizing the template. Please make sure to delete these comments in the final policy document.


___(insert name of transit agency)__

Americans with Disabilities Act of 1990 (ADA)

Policy and Procedures

Date: _______



Introduction and Purpose

This ADA policy is written to establish operating and service guidelines and procedures for the implementation of the requirements of the Americans with Disabilities Act of 1990 (ADA), the U.S. Department of Transportation (U.S. DOT) regulations for implementing ADA (49 CFR Parts 27, 37 and 38), and applicable state laws and regulations.  [Note: This policy template reflects federal requirements. The transit agency will need to research if there are any state-specific disability nondiscrimination requirements that apply to them.  If there are no relevant state-specific requirements, the transit agency may want to delete “and applicable state laws and regulations” in their policy.  If there are state-specific requirements, they will need to be addressed in the transit agency’s policy.]  ___(insert name of transit agency)__ operates services on a fixed route basis. ___(insert name of transit agency)__ complies with ADA requirements with respect to such services. 


Policy Statement  

It is the policy of ___(insert name of transit agency)__ to comply with all the legal requirements of federal and state laws and regulations as they pertain to individuals with disabilities.  If state laws and federal regulations are contradictory, the federal ADA regulations prevail.  The transit system provides quality transportation services without discrimination to all persons including individuals with disabilities.  Discrimination on the basis of disability against any person by transit system employees will not be condoned or tolerated.


Goals:   Service is provided in a manner that meets these goals to:

  1. Provide safe, accessible, and dignified services to all persons, including individuals with disabilities
  2. Ensure that eligible individuals who are unable to board, ride or disembark from the fixed route service are provided complementary paratransit with comparable service availability and quality to the fixed route service
  3. Expedite the safe and efficient boarding, securing, transporting, and alighting of all passengers, regardless of mobility status
  4. Accommodate the wide range of mobility aids within the confines of available vehicles and commercial standard equipment


Applicability:  This policy applies to all transit system employees, services, facilities and vehicles.  It applies equally to all persons needing and/or using the services provided by the system.



Commuter Bus: Fixed route bus service, characterized by service predominantly in one direction during peak periods, limited stops, use of multi-ride tickets, and routes of extended length, usually between the central business district and outlying suburbs. Commuter bus service may also include other service, characterized by a limited route structure, limited stops, and a coordinated relationship to another mode of transportation.


Disability:  With respect to an individual, a physical or mental impairment that substantially limits one or more of the major life activities of such individual; a record of such an impairment; or being regarded as having such an impairment. 


Fixed Route Service:   Operates along a prescribed route according to a fixed (regular) schedule.


Mobility Device:  A device that is designed to assist an individual with disabilities with locomotion. Examples include wheelchairs, canes, crutches, and walkers.  Also called mobility aid.


Route Deviation Service: A system that permits user-initiated deviations from routes or schedules. 


Securement Area or Station: A designated location for riders using wheelchairs, equipped with a securement system.


Securement Device, Equipment or System:  Equipment used for securing wheelchairs against uncontrolled movement during transport.


Service Animal:  Any guide dog, signal dog, or other animal that has been individually trained to work or perform tasks for an individual with a disability, including, but not limited to, guiding individuals with impaired vision, alerting individuals with impaired hearing to intruders or sounds, providing minimal protection or rescue work, pulling a wheelchair, or fetching dropped items.      


Wheelchair:  A mobility aid belonging to any class of three- or more- wheeled devices, usable indoors, designed or modified for and used by individuals with mobility impairments, whether operated manually or powered.

General Guidance and Procedures for Implementing Policy

Recruitment and Employment:  As stated in the transit system’s personnel policies, the agency is an Equal Opportunity Employer and fully complies with ADA in its recruitment, hiring and continued employment practices.


Facility and Vehicle Accessibility: The transit system administrative facility, passenger facilities and vehicles shall meet or exceed the requirements of 49 CFR Parts 27, 37 and 38 and requirements of the State of __________________.   If state requirements do not meet federal requirements, the federal ADA regulations prevail.  All vehicles purchased for fixed route and route deviation service will be accessible.  Vehicles purchased for demand response service will only be non-accessible to the extent that the demand response system, when viewed in its entirety, provides the same level of service for individuals with disabilities as for individuals without disabilities. The transit system will conduct an analysis of service equivalency prior to the acquisition of any inaccessible vehicles for demand-responsive service.


Vehicle and Route Assignment:  To the extent possible, the assignment of particular types of vehicles will be based upon rider needs.  All vehicles assigned to fixed routes and deviated routes will be accessible.  


In addition to fixed route and route deviation service, ___(insert name of transit agency)__  also operates demand response service. To the extent that inaccessible vehicles comprise any proportion of the fleet, the transit system will ensure that equivalent service is provided to individuals with disabilities, including wheelchair users, that is consistent with U.S. DOT ADA regulations under 49 CFR Part 37, Section 37.77. This transportation will be provided in the most integrated setting appropriate to the needs of the individual and will be equivalent to the service provided other individuals with respect to:


  • Response time
  • Fares
  • Geographic area of service
  • Hours and days of service
  • Restrictions or priorities based on trip purpose
  • Availability of information and reservations capability
  • Any constraints on capacity or availability


[If your transit system does NOT operate demand response service other than route deviation, delete this paragraph and bullets.]


Maintenance of Accessible Features:  Accessibility features on vehicles, including lifts, ramps, wheelchair securement devices and public address systems, will be maintained in operative condition.  The preventive maintenance program of ___(insert name of transit agency)__ provides for regular and frequent maintenance checks of these features as well as preventive maintenance as recommended by the equipment manufacturers.  In addition, the lift must be cycled as part of each pre-trip inspection.  [Note: lift cycling as part of the pre-trip inspection is not required by ADA but is recommended by some states as a way to comply with the federal ADA requirement that transit systems conduct regular and frequent lift checks, sufficient to determine if lifts are actually operative.]


Drivers are required to report lift or ramp failures immediately.  Vehicles with inoperative lifts or ramps will be removed from service and replaced with an accessible vehicle until the inoperative lift or ramp is repaired.  Additional fixed route policies related to inoperative lifts or ramps are discussed under “Policies Specific to Fixed Route Service.”


Wheelchair Accommodation:  All accessible vehicles meet or exceed the requirements of 49 CFR Part 38. Transportation providers are required to carry a wheelchair and its user, as long as the lift can accommodate the size and weight of the wheelchair and its user, and there is space in the securement area for the wheelchair on the vehicle without blocking the aisle.  If a vehicle lift/ramp and securement area can accommodate a wheelchair (or other mobility device), ___(insert name of transit agency)__ will transport the device (and its user).

An individual who uses a wheelchair that, when occupied, exceeds the weight rating of the vehicle lift/ramp, will be offered the opportunity to board and disembark from the vehicle separately from the wheelchair.  However, transit agency personnel are not (required OR permitted) to operate a passenger’s wheelchair. [Note: Select appropriate word depending on your agency policy. It is not required under the ADA regulations, and for safety reasons your local policy may wish to prohibit personnel from operating a passenger’s wheelchair.]  The individual may travel with another individual who can assist with operating the unoccupied wheelchair to maneuver it on and off the lift/ramp.


Boarding:  Drivers and scheduling practices will provide adequate time for a passenger with a disability to board and/or disembark the vehicle, which includes adjusting the schedule if necessary and waiting for passengers to be seated before moving the vehicle.  Only a properly trained transit system employee can operate the lift or ramp and secure the wheelchair in the securement station.  Passengers may board facing toward or away from the vehicle. 


Priority Seating:   With the exception of the wheelchair securement stations, the transit system does not require any passenger to sit in designated seating. 


Priority seating for seniors and individuals with disabilities is to be designated by permanent signage in each vehicle.  In cases where an individual with a disability requests use of priority seating that is currently occupied by another passenger, the driver will ask that passenger to move so as to allow the individual with a disability use of the priority seating. In cases where a wheelchair user requires the use of a securement location, the driver will ask any passenger (including other passengers with disabilities) to vacate the securement location.


Driver Assistance: Drivers will make themselves available for assistance to individuals with disabilities and will assist upon request of the passenger.  Drivers will leave their seat to assist a passenger with using the vehicle ramp, lift and/or securement system.  Drivers will use the accessibility-related equipment and features on their vehicles as described in these policies.


Wheelchair Securement:  [Note: Select one of the next two paragraphs depending on your agency policy.  U.S. DOT regulations do not mandate securement unless requested by a rider using a wheelchair.]  


___(insert name of transit agency)__ does not require that wheelchairs be secured on board the vehicle.  However, the driver will secure a passenger’s wheelchair if requested by the passenger. 


___(insert name of transit agency)__ requires that all wheelchairs be secured.  Drivers should not allow a passenger to ride if they are not secured properly unless the securement system will not accommodate the wheelchair.  Drivers cannot deny a passenger a ride based on the inability to secure the wheelchair.  However, drivers must warn the passengers of the danger of riding in a non-secured wheelchair.  Passengers who refuse to allow their wheelchairs to be secured may be denied service. 


Securement of wheelchairs is the responsibility of the driver.  Drivers are trained in the proper operation of all securement equipment based on the equipment manufacturer’s specifications.  Drivers will listen to and respect riders’ instructions on how to secure their equipment. Drivers cannot be expected to be familiar with each and every wheelchair type that may come aboard, and securement attachment points may differ by wheelchair manufacturer.  The rider may be in the best position to instruct the driver on how to properly secure their mobility device.    


If the securement system is not compatible with the wheelchair the passenger is using, the driver will still make an attempt to safely secure the wheelchair.  If the wheelchair cannot be secured because of the wheelchair design, the passenger still has the right to ride in the vehicle. 


Drivers must secure wheelchairs in the designated securement area only, even if the passenger wants their mobility device to be secured in a non-designated area.  The wheelchair is not allowed to block the aisle.


[Note: Select one depending on your agency policy. Make sure you treat all riders with and without disabilities the same.] Seat belts and shoulder harnesses are recommended but not required for passengers riding in their secured wheelchair.  OR: Seat belts and shoulder harnesses are required for ALL passengers. Seat belts will never be used instead of independent securement of the passenger’s wheelchair.


In cases where an individual using a wheelchair attempts to board and requires use of a securement location that is currently occupied by another passenger that is not using a wheelchair, the driver will ask that passenger to allow the individual using a wheelchair to use the securement position.


Use of Lift or Ramp by Individuals with Disabilities Not Using a Mobility Device:  The driver will deploy the lift or ramp for an individual with a disability who is not using a mobility device to board or alight the vehicle upon request.


Accommodation of Other Mobility Devices: Mobility devices that are not wheelchairs, but which are primarily designed to for use by individuals with mobility impairments, will be accommodated to the extent that the ADA-compliant lift or ramp and securement areas can safely do so.  However, these devices are the responsibility of the individual passenger, and must be secured in a manner that does not interfere with the safe operation of the vehicles and the transport of other passengers.  


Transfer to Fixed Seating: All passengers using wheelchairs have an option of transferring to fixed seating once on board the vehicles.  Drivers may recommend, but never require, wheelchairs users to transfer to fixed seating. No waivers are allowed to be required. 


Accommodation of Portable Oxygen:  Individuals are allowed to travel with respirators and portable oxygen supplies on board, consistent with applicable U.S. DOT rules on the transportation of hazardous materials in 49 CFR Subtitle B, Chapter 1, Subchapter C. [Note: U.S. DOT requirements related to transportation of hazardous materials not part of the U.S. DOT ADA requirements and thus are not spelled out in this ADA policy template.]


Service Animals:  In compliance with 49 CFR Part 37, the transit system allows trained service animals to accompany passengers with disabilities.  The driver will not ask for proof of the qualifications of the animal, but may ask what tasks the animal has been trained to perform.  However, any animal which is not under the passenger’s control or which becomes a direct threat to the health or safety of other passengers may be restricted from riding.


Alighting:  It is the responsibility of the driver to determine that the location for passenger alighting is safe.  For fixed route, the driver will allow a passenger who uses the lift or ramp to alight at any stop, unless the lift or ramp cannot be deployed, will be damaged if deployed, or conditions at the stop would present unsafe conditions for all passengers.  Only the driver will unsecure the wheelchair and operate the lift or ramp to return the passenger to the ground level. 


Staff Training:  All drivers and transit system staff are trained to proficiency in use of accessibility equipment, the operating policies related to each of the service requirements described, and in properly and respectfully assisting and treating individuals with disabilities with sensitivity.   Mechanics are also trained to properly maintain lifts and other accessibility equipment.


Rider Information:  All printed informational materials are made available in accessible formats upon request, for example, large print for individuals with low vision or audio for blind individuals, as well as accessible electronic formats.


Complaint Procedure:  All complaints of discrimination on the basis of disability will be promptly and objectively investigated and forwarded to the __(insert title of employee responsible for responsible for coordinating the transit agency’s compliance with 49 CFR Part 37) ____ and promptly and objectively investigated.  ___(insert name of transit agency)__ will promptly communicate its response to the complaint allegations, including its reasons for the response, to the complainant.  The response will be documented.  Corrective or disciplinary action will be taken for behavior prohibited by this policy, up to and including termination of employment.  [Note: attach the instructions that the transit agency provides to the public, as well as the complaint form if one has been established.]  Documentation of each complaint will be kept on file for __(insert local recordkeeping policy)___.   [Note: the DOT regulations require FTA grantees to maintain all complaints of noncompliance with 49 CFR Part 27 for one year, and a record of all such complaints, which may be in summary form, for five years.]    


Reasonable Modification of Policy:  If a passenger with a disability requires modification of any of ___(insert name of transit agency)__’s policies and practices to accommodate their disability to use the service, the passenger may request such a modification by contacting __(insert name or office to which requests for modification of policy should be directed)____.  The transit system will work with the individual to find an acceptable accommodation solution.

Where a request for modification cannot practicably be made and determined in advance operating personnel will make a determination of whether the modification should be provided at the time of the request. Operating personnel may consult with ___(insert name of transit agency)__ management before making a determination to grant or deny the request.


Requests for modification of policies and practices may be denied only on one or more of the following grounds:

  • Granting the request would fundamentally alter the nature of ___(insert name of transit agency)__’s services, programs, or activities;
  • Granting the request would create a direct threat to the health or safety of others;
  • Without the requested modification, the individual with a disability is able to fully use ___(insert name of transit agency)__'s services, programs, or activities for their intended purpose.


In any case in which ___(insert name of transit agency)__ denies a request for a reasonable modification, the agency shall take, to the maximum extent possible, other actions (that would not result in a direct threat or fundamental alteration of service) to ensure that the individual with a disability receives the services or benefit provided by ___(insert name of transit agency)__.

Guidelines and Procedures for Implementing Policy Specific to Fixed Route Services


Inoperative Lifts and Ramps:  Vehicles with inoperative lifts must be taken out of fixed route service as soon as possible (no later than the beginning of the vehicle’s next service day) and inoperative equipment will be replaced promptly with an accessible spare vehicle. The inoperative lift will be repaired before the vehicle returns to service. For vehicles equipped with ramps, it may be possible to continue in service as long as the ramp can be and is deployed manually when necessary. If an inoperative ramp cannot be (or is not) deployed manually, the transit agency will apply the policy for a vehicle with an inoperative lift.


If there is no accessible spare vehicle available to take the place of a vehicle with an inoperable lift/ramp on a route, the vehicle with the inoperable lift/ramp may be kept in service for no more than [three days maximum if the entity serves an area of over 50,000 population – OR five days if the entity serves an area of 50,000 or less population].  In such cases alternative transportation will be provided to individuals with disabilities who are unable to use the vehicle because its lift/ramp does not work.  [Note: Alternative transportation is only required if the headway to the next accessible vehicle on the route exceeds 30 minutes, but few rural and small urban systems operate on such frequent headways.]


Route Identification to Passengers Waiting at Shared Stops:  Where vehicles for more than one route serve the same stop, each driver will stop and announce their route to passengers waiting at the stop.  These stops have been listed for each route and the lists are provided to drivers during training.  [Note: The agency may wish to attach the lists of these stops to the policy.]  [Note: as a supplemental approach, if preferred by the customers in your community, the agency may provide customers with route hailing kits (containing numbered cards, for example) to allow passengers to inform drivers of the route they want to use or to be identified by the driver as a potential customer seeking a ride on a particular route.]


Route Orientation Announcements: Fixed route drivers will announce the following stops to passengers on board the vehicle (using the vehicle’s public address system on larger vehicles if such is available): 1) transfer points with other routes, 2) major intersections or destination points, 3) sufficient intervals along a route to orient passengers with visual disabilities to their location, and 4) any stop requested by a passenger with a disability.  Stops that fall into the first three categories are listed for each route and provided to drivers during training.  [Note: The agency may wish to attach the lists of these stops to the policy.]


Bus Stop Accessibility:  When establishing new bus stops, it is the policy of ___(insert name of transit agency)__ to select locations that are accessible to riders using mobility devices, to the extent feasible.  When installing improvements at existing bus stops, the improvements will be made accessible in accordance with US DOT ADA standards for transportation buildings and facilities.  In the event that a particular stop is not accessible, the transit system will provide complementary paratransit to any individual who is unable to use the fixed route system because that stop is inaccessible.  If an individual with a disability requests that an existing stop be made accessible, ___(insert name of transit agency)__ will work with the jurisdiction that is responsible for the street and sidewalk (if applicable) to include accessibility improvements to the stop within the jurisdiction’s ADA transition plan for sidewalks.  


ADA Complementary Paratransit:  Individuals who are unable to use the fixed route service because of a disability will be provided with complementary paratransit service that is comparable to the fixed route service in service availability and quality.  The policies for ADA Complementary Paratransit are provided in the next section.  [Note: ADA Complementary Paratransit is not required for commuter bus service.]

Guidelines and Procedures for Implementing Policy Specific to ADA Complementary Paratransit Services


Introduction:  ___(insert name of transit agency)__ provides ADA complementary paratransit services for individuals whose disabilities prevent them from independently using the fixed route system.  This is demand response service that is equivalent to the fixed route service in terms of service characteristics as described under 49 CFR Part 37, Subpart F.  


Eligibility Determination Process: To be eligible to use the ADA complementary paratransit service, applicants must complete an ADA complementary paratransit eligibility determination process.  Eligible individuals will receive documentation of ADA complementary paratransit eligibility, which can be used in other areas.


Eligibility Criteria: The certification process strictly limits ADA complementary paratransit eligibility to the regulatory definition of eligibility.  Only those persons who meet the regulatory definition will be given documentation indicating that they are “ADA Paratransit Eligible.”  A person will be considered eligible for ADA complementary paratransit if:


  • The individual is unable, as the result of a physical or mental impairment (including a vision impairment), and without assistance of another individual (except the operator of a wheelchair lift/ramp or other boarding assistance device), to board, ride, or disembark from any vehicle on the system which is readily accessible to and usable by individuals with disabilities.


  • The individual with a disability is capable of using the system with the assistance of a wheelchair lift/ramp but the route they want to use is not sufficiently ADA accessible for the individual to use it.


  • The individual with a disability has a specific impairment-related condition, which prevents such individual from traveling to a fixed route boarding location or from a disembarking location.


Temporary eligibility for ADA complementary paratransit service will be allowed for those with a disability that is only temporary in nature.  Temporary eligibility is established during the certification process.


[Note: If your system uses Conditional Eligibility, include the following paragraph.]  In addition, if individuals who are determined to be ADA complementary paratransit eligible can use fixed route service under certain conditions (for example, trips for which they have been trained to navigate or under variable conditions that affect an individual’s disability), the eligibility will be considered “Conditional” and documentation which they are given will indicate the limitations/condition of their eligibility.


Application Form:  A copy of the application form used for ___(insert name of transit agency)__ ADA complementary paratransit service is provided at the end of this section. [Attach.]  Large print, audio, electronic, and other accessible formats are available upon request, as well as in Spanish [or other applicable language per your system’s Limited English Proficiency / Language Assistance Plan].


Review Process and Time Frame:  Upon receipt of a completed application, ___(insert name of transit agency)__ will review the application and determine the individual’s eligibility within 21 days of receipt. This responsibility has been assigned to the ADA Coordinator [or other designated individual]. If a determination is not made within 21 days, the applicant is treated as eligible and will receive service until such time as a determination of eligibility is made.


[Note: If your system also relies on an in-person assessment, include a description of this process, responsible parties, and time frame.]


Notification of Eligibility:  Each applicant will be notified in writing by mail of their status within 21 days of submitting a properly completed application (and completing the in-person assessment if applicable).  If determined eligible, this letter will serve as temporary eligibility documentation as described below. The procedures for using ADA complementary paratransit will also be mailed with this letter in a format useable by the individual (such as large print, audio, or electronic file).


Those persons determined to be ineligible will be provided with specific information as to why their application was rejected and instructions on how they can appeal the decision (described below).  This information will also be mailed with this letter in a format useable by the individual.


Documentation:  The ___(insert name of transit agency)__ will provide certified individuals with documentation that can be used as identification for reciprocal eligibility for ADA complementary paratransit service in other areas of the communities in the United States.  This documentation will include the following information:


  • Name of eligible individual
  • Name of certifying transit provider – ___(insert name of transit agency)__
  • Telephone number of the ___(insert name of transit agency)__ ADA Coordinator
  • Whether or not the rider requires use of a lift or ramp
  • Expiration date
  • Any conditions or limitations on eligibility
  • Whether person travels with a PCA
  • Information on the appeal process if the individual is denied eligibility or has conditions placed on eligibility.


Term of Eligibility:  Once determined eligible, a person maintains eligibility for ___ years. Recertification is required every ____ years. [Note: Fill in the number of years, per your system’s specific eligibility process.  The ADA regulations state that recertification may be required at “reasonable intervals.” Typical intervals used by many transit systems are three and five years.]  Persons given temporary eligibility remain eligible for the duration of time of the temporary disability, as determined through the certification process and indicated in the documentation that is to be provided to the applicant.


Appeals Process:  The appeals process will be explained to all applicants who are rejected or permitted only partial (conditional or temporary) service.  The applicant has 60 days to file an appeal with ___(insert name of transit agency)__, with the decision to be made by the ___(insert name of transit agency)__ Chief Operating Officer [or other official not involved in the original decision]. The notification of intent to appeal may be submitted in person, by telephone, or in writing. Written appeals may not be required, but riders may have that option.The applicant will be afforded an opportunity to be heard and to present information and arguments in person. The Chief Operating Officer has 30 days from the date of the appeal to render a decision concerning the appeal.  If a decision is not reached within 30 days, the applicant will be presumed eligible until a decision has been reached.  The ADA regulations require that the person who makes a determination on an appeal must not be involved in the initial determination of the individual’s eligibility. [Note: The ADA establishes the right to complementary paratransit as a civil right, and as such, there is an obligation on the part of the transit system to ensure “due process.”  Small transit agencies that do not have enough internal staff to have a second decision-maker for the appeals process could consider involving external individuals with disabilities or specialists in various types of disabilities (such as orientation and mobility specialists, mental health professionals, social workers, physical and occupational therapists).  See Chapter 9 of FTA Circular 4710.1 for an explanation on the separation of functions required for the appeals process (Section 9.7.2) and suggestions for selecting individuals to hear appeals (Section 9.7.4).]


ADA Complementary Paratransit Service for Visitors:  ADA complementary paratransit eligible individuals visiting from other localities outside of the system’s service area will also be served when eligible trips are requested.  The visiting individual’s local certification will be honored by ___(insert name of transit agency)__.   If a visitor does not have ADA complementary paratransit certification from another jurisdiction, but makes a claim of eligibility, that claim will be honored as required by the ADA.  However, in such cases, ___(insert name of transit agency)__ reserves the right to require proof that the individual is not a local resident, and if the individual has a disability which is not apparent.  Service to visitors is limited to 21 days during any 365-day period beginning with the visitor’s first use of the service during that period. Visitors who anticipate requiring service for more than 21 days in a 365-day period must apply for eligibility.


Personal Care Attendants:  ___(insert name of transit agency)__ will provide ADA complementary paratransit service for a personal care attendant (PCA) traveling with the eligible rider.  The need to travel with a PCA will be determined by the applicant, and noted as part of the eligibility determination process.  It is important to note that the PCA may not directly be needed for transportation, but may be needed at the individual’s trip destination (for example, to assist with grocery shopping) and thus need for a PCA will not be limited to those individuals who require assistance in traveling.  An individual who is certified as needing a PCA cannot be denied service if they chose to travel without a PCA, and may not be required to travel with the same PCA for every trip.


Service Characteristics and Operating Policies:  ADA complementary paratransit is comparable to ___(insert name of transit agency)__’s fixed route system (excluding commuter bus routes), based on the following service characteristics and operating policies.


Geographic Service Area:  ADA complementary paratransit is provided within a three-quarter mile radius corridor surrounding each fixed route, plus relatively small areas enclosed by fixed routes.  [Attach a map of the service area and/or boundaries of areas covered.]


Days and Hours of Service:  ADA complementary paratransit is provided within the same days and hours as the fixed route services.  [Attach the current fixed route operating schedules.]


Fares:  The one-way trip charge for ADA complementary paratransit is $_____.  The fare charged for ADA complementary paratransit will not exceed twice the regular general public cash fare for the equivalent trip on the fixed route service.  In the event that the regular public cash fare is increased the transit system may increase the ADA complementary paratransit fare accordingly.  [Attach the current fixed route and paratransit fares.]


If the ADA complementary paratransit-eligible individual travels with a PCA, the PCA will not be charged a fare for ADA complementary paratransit.


Trip Purpose: ADA complementary paratransit is provided for trips of any purpose; no priorities are placed on specific types of trips.


Trip Scheduling and Response Time:  Reservations are accepted for ADA complementary paratransit trip reservations on a next-day basis, until regular close-of-business hours.   Riders may schedule trips by calling the ___(insert name of transit agency)__ office Monday through Friday from _____ a.m. to ____ p.m., Saturday from _____ a.m. to ____ p.m., and Sunday ____ a.m. to ____ p.m. (if applicable) to schedule trips for the next service day.   For trips on Monday and service days following holidays, reservations are accepted on Sundays and holidays via __________ [Note: Detail how your system meets this requirement such as an answering machine/pager, Sunday office hours, or other means].


Service Capacity and Scheduling Flexibility: As required, ___(insert name of transit agency)__ will provide adequate capacity to meet all demand for eligible ADA complementary paratransit trips.  In some cases it may be necessary to negotiate trip times with the rider; however, in no case will any trip be scheduled more than one hour before or after the rider’s desired time (that is, a trip requested for 11:00 a.m. may be scheduled as early as 10:00 a.m. or as late as 12:00 noon). 


In order to meet the ADA requirement for ensuring adequate capacity, ___(insert name of transit agency)__ will monitor the following indicators of capacity to ensure that no patterns or practices of capacity constraints are found:


  • On-time performance___(insert name of transit agency)__ measures on-time performance according to vehicles that arrive within a promised _(insert number of minutes)_ “window” of time. A vehicle that arrives within this “window” is considered on-time. Note that the FTA considers a pick-up “window” of longer than 30 minutes to be unacceptable. For example, if the rider is promised the vehicle will arrive between 10:15 to 10:45 am, the vehicle is considered on-time if it arrives at 10:16, 10:33 or 10:45.  The ADA prohibits substantial numbers of significantly untimely pick-ups for initial or return trips, as this may be a capacity constraint. Refer to Chapter 8, Section 8.5.3 of the FTA ADA Circular for a discussion on determining what would be untimely service.]  ___(insert name of transit agency)__ will try to ensure that all trips are on-time but because of the realities of operating conditions (e.g., poor weather, road construction), not all trips will be on-time.  Should on-time performance fall below ___ percent, actions will be taken to address and improve trip timeliness.


  • Trip denials and missed trips___(insert name of transit agency)__ plans to meet all requests for ADA complementary paratransit service based on expected demand and to avoid any trip denials or missed trips.  There may be insignificant numbers of trips denied due to unforeseen conditions.  There may also be an insignificant number of missed trips, defined as a trip where the vehicle arrives late and the rider either is no longer there or declines the trip due to lateness, because of the realities of operating conditions.  Trip denials and missed trips will be monitored to ensure capacity is adequate.


  • Trips with excessive lengths___(insert name of transit agency)__ monitors travel times on ADA complementary paratransit to ensure comparability to the same or comparable trip if taken on fixed route.  [Note: FTA recommended basing complementary paratransit travel time on the comparable fixed route travel time, plus 20 to 30 minutes to allow for a reasonable estimate of time spent walking to and from a bus stop, waiting for the bus to arrive, and making any necessary transfers from one vehicle to another.  State DOTs may have additional guidance for subrecipients around this requirement. If state requirements/guidance and federal regulations are contradictory, the federal ADA regulations prevail.  Paratransit trip lengths must be monitored to ensure compliance with ADA. For FTA guidance on setting performance standards on and monitoring trip lengths, see Section 8.5.5 of the FTA ADA Circular.]


Subscription Trips:  As permitted by the ADA regulations), ___(insert name of transit agency)__ may provide a portion of its ADA complementary paratransit trips on a subscription basis (also called standing orders).  Unlike other ADA complementary paratransit trips, trip priorities and waiting lists for subscription service may be established.  [You can decide to set priorities for subscription service – if so note here.]   ___(insert name of transit agency)__ does not have capacity constraints, there are no restrictions on the percentage of trips that will be provided as subscription trips.  [Note: The requirements specify that subscription service may not absorb more than 50 percent of the available trips at any time of the service day, unless there remain trips available for non-subscription riders.  That is, as long as there is capacity available for non-subscription trips (i.e., no trip denials) for next-day service, trips for subscription riders may exceed 50 percent of the available trip capacity.]


Companions:  An ADA complementary paratransit rider is permitted to travel with at least one companion (and more than one on a space-available basis).  Companion passengers pay the same fare as ADA riders.  The eligible ADA rider shall reserve space for the companion(s) when the rider reserves the ride.  Any companions traveling with the eligible individual must share the same trip origin and destination as the eligible individual. The companion is in addition to any PCA with which the rider may travel.


Origin-to-Destination Service and Passenger Assistance:  ADA complementary paratransit services will be provided on a curb-to-curb basis [Note if you do all trips door-to- door and, if so, adjust the next paragraph].  ___(insert name of transit agency)__ drivers will assist ADA complementary paratransit riders with boarding and disembarking from vehicles and in securing their mobility devices.  All drivers who operate ADA complementary paratransit services will be proficiently trained in passenger assistance and sensitivity towards individuals with disabilities.


Riders will be required to travel to the curb outside of their trip origin in time for their scheduled pick-up.  Riders who require additional assistance in the form of door-to-door service in order to use the ADA complementary paratransit may request a modification of this policy by contacting the ADA coordinator at _____.  In such case, the driver will provide assistance on a door-to-door basis.  This ensures that ___(insert name of transit agency)__ meets the ADA requirement to provide service on an “origin to destination” basis.  While limited assistance in guiding a passenger from their door to the curb may be provided on a case-by-case base, this must be prearranged and indicated when the trip is scheduled. 


The staff of ___(insert name of transit agency)__ will not lift a passenger, leave a vehicle unattended or out of visual observation for a lengthy period of time, enter a rider’s home, care for service animals, operate a power wheelchair, provide personal care attendant (PCA) service, or take actions that would be clearly unsafe.  If more extensive assistance is needed by the individual than ___(insert name of transit agency)__ can provide as a provider of public transportation, the individual will be responsible for arranging personal assistance.  Staff of ___(insert name of transit agency)__ will work with the individual and/or the rider’s caregiver/social worker to clarify parameters of the assistance provided by the driver and formally document this in a letter sent to the individual.


No Show Policy: If no shows become a problem for ADA complementary paratransit riders, the ___(insert name of transit agency)__ will establish an ADA no-show policy with input from the disability community. A no-show policy allows a transit system to discipline riders who establish a pattern or practice of missing scheduled trips, which can have a negative effect on paratransit performance. [If your transit agency has established a no-show policy, replace this paragraph with your local policy.  The FTA ADA Circular provides a sample no-show policy as an attachment to Chapter 9.]