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United States Government Accountability Office: 
GAO: 

Report to the Committee on Banking, Housing, and Urban Affairs, U.S. 
Senate: 

November 2012: 

ADA Paratransit Services:

Demand Has Increased, but Little is Known about Compliance:

GAO-13-17:

GAO Highlights:

Highlights of GAO-13-17, a report to the Committee on Banking, 
Housing, and Urban Affairs, U.S. Senate. 

Why GAO Did This Study:

The ADA, a civil rights law enacted in 1990, provided that it shall be 
considered discrimination for a public entity that operates a fixed-
route transit system to fail to offer paratransit service to disabled 
individuals that is comparable to services provided to those without 
disabilities. FTA is responsible for overseeing compliance with ADA 
requirements for paratransit services.  As requested, GAO examined: 
(1) the extent of compliance with ADA paratransit requirements, (2) 
changes in ADA paratransit demand and costs since 2007, and (3) 
actions transit agencies are taking to help address changes in the 
demand for and costs of ADA paratransit service. GAO analyzed FTA’s 
ADA compliance reports; conducted a generalizable web-based survey of 
145 transit agencies; interviewed federal officials; and interviewed 
officials from 20 transit agencies, chosen based on a variety of 
characteristics, including geographic diversity. 

What GAO Found:

Little is known about the extent of transit agencies’ compliance with 
the Americans with Disabilities Act (ADA) paratransit service 
requirements. FTA does receive some assurance that agencies are 
complying with federal statutes and regulations, including ADA 
paratransit requirements, because transit agencies that receive FTA 
funding are required to self-certify and assure that they are 
complying with the Department of Transportation’s ADA regulations. 
Additionally, FTA conducts specialized ADA paratransit compliance 
reviews that examine multiple aspects of an agency’s paratransit 
services; however, few transit agencies are selected for review each 
year. FTA generally relies on complaints, media reports, experience 
with an agency, and other information to select agencies for review, 
but does not have documented criteria for selecting agencies. This 
informal selection process does not align with federal guidance on 
internal controls related to communication, documentation, and 
monitoring. Lastly, according to FTA officials, all finalized ADA 
paratransit compliance review reports are to be available on FTA’s 
website, but GAO identified nine final review reports-—conducted from 
2004 to 2010-—that have not been posted to FTA’s website. 

Based on GAO’s survey, the demand for ADA paratransit trips increased, 
since 2007 for some transit agencies, and costs for providing the 
trips remain high. The average number of annual ADA paratransit trips 
provided by a transit agency increased 7 percent from 2007 to 2010; 
from 172,481 trips in 2007 to 184,856 trips in 2010. Increases in 
demand for ADA paratransit services were driven by the 10 largest 
transit agencies, measured according to the population size of their 
service areas. Also, ADA paratransit trips are much more costly to 
provide than fixed-route trips. Similarly, the average cost of 
providing an ADA paratransit trip in 2010 was $29.30, an estimated 
three and a half times more expensive than the average cost of $8.15 
to provide a fixed-route trip. The average cost of providing an ADA 
paratransit trip increased 10 percent from 2007 to 2010. GAO’s 
analysis of ADA paratransit data available in FTA’s National Transit 
Database (NTD) found that, according to GAO standards for data 
reliability, the data are not sufficiently reliable for the purpose of 
assessing changes in ADA paratransit demand and costs. For example, 
GAO found discrepancies, such as incomplete data, that may understate 
or overstate the number of ADA trips and amount of ADA expenses. 
According to FTA officials, some transit agencies fail to report these 
data, while others misunderstand the data fields and make reporting 
errors as a result. 

Transit agencies are taking actions such as coordinating with other 
transportation providers, offering travel training, and improving 
accessibility to address changes in ADA paratransit demand and costs. 
According to GAO’s survey, about 59 percent of transit agencies are 
coordinating with health and human services providers to improve ADA 
paratransit services or address the costs of providing such services. 
About 44 percent of transit agencies are coordinating with other local 
transportation providers. Additionally, about 55 percent are using 
travel training to help paratransit riders’ transition to fixed-route 
services. Furthermore, GAO’s survey results showed that over 62 
percent of transit agencies have made accessibility improvements to 
their fixed-route systems since 2007. 

What GAO Recommends: 

The Secretary of Transportation should direct the FTA Administrator to 
(1) document and make publicly available a formal approach for 
selecting transit agencies for ADA paratransit compliance reviews, (2) 
post the backlog of ADA’s compliance-review final reports and 
establish a process for the timely posting of future reports, and (3) 
provide guidance to transit agencies on how to accurately complete 
existing ADA paratransit data fields in the NTD. The Department of 
Transportation neither agreed nor disagreed with the recommendations 
and provided clarifying comments, which GAO incorporated. 

View [hyperlink, http://www.gao.gov/products/GAO-13-17]. For more 
information, contact David J. Wise at (202) 512-2834 or wised@gao.gov. 

[End of section] 

Contents:

Letter:

Background:

Little Is Known about ADA Compliance for Paratransit:

Demand for ADA Paratransit Has Increased for Some Transit Agencies, 
and Costs Remain High:

Transit Agencies Are Taking a Number of Actions to Address Paratransit 
Demand and Costs:

Conclusions:

Recommendations for Executive Action:

Agency Comments:

Appendix I: Objectives, Scope, and Methodology:

Appendix II: Reliability of ADA Paratransit Data in FTA's National 
Transit Database:

Appendix III: GAO Contact and Staff Acknowledgments:

Tables:

Table 1: ADA Minimum Paratransit Service Requirements for 
Comparability to Fixed-Route Service:

Table 2: Types of ADA Paratransit Eligibility Determination Processes 
Used by Transit Agencies:

Table 3: Transit Agency Interviews:

Table 4: Percentage of Transit Agencies Reporting ADA Trips and ADA 
Expenses in NTD, 2005 through 2010:

Table 5: Percentage of Transit Agencies Reporting Demand-Response 
Service, ADA Trips, and ADA Expenses in NTD, 2005 through 2010:

Figures:

Figure 1: Basic Scheduling and Dispatching Operation of a Paratransit 
System:

Figure 2: Major Steps in the Compliance Review Process:

Figure 3: Average Number of Individuals Registered to Use ADA 
Paratransit Services at a Transit Agency and Average Number of ADA 
Paratransit Trips Provided by a Transit Agency, 2007 and 2010:

Figure 4: Average Reported ADA Paratransit and Fixed-Route Per-Trip 
Costs, 2010:

Figure 5: Percentage of Transit Agencies Reporting the Following as 
Major Contributors to Cost Increases in ADA Paratransit Services:

Figure 6: Average Reported ADA Paratransit and Fixed-Route Costs and 
Fares Per Trip, 2010:

Abbreviations:

ADA: Americans with Disabilities Act:

DOJ: Department of Justice:

DOT: U.S. Department of Transportation:

FTA: Federal Transit Administration:

NTD: National Transit Database:

TCRP: Transit Cooperative Research Program:

[End of section]

United States Government Accountability Office: 
Washington, DC 20548: 

November 15, 2012:

The Honorable Tim Johnson:
Chairman:
The Honorable Richard C. Shelby:
Ranking Member:
Committee on Banking, Housing, and Urban Affairs:
United States Senate:

Since 1970, it has been our nation's policy that individuals with 
disabilities have the same right as other individuals to use public 
transportation service, that special efforts be made in planning and 
designing public transportation service to ensure that it can be used 
by individuals with disabilities, and that all government programs 
assisting public transportation "shall carry out this policy." 
[Footnote 1] In 1990, the Americans with Disabilities Act (ADA), a 
civil rights law, prohibited discrimination against individuals with 
disabilities in several areas, including public transit, and applied 
to public entities whether or not they receive federal financial 
assistance.[Footnote 2] U.S. Senate and House of Representative 
reports accompanying the ADA stated that paratransit service was often 
inadequate;[Footnote 3] in addition to requiring accessibility of 
regular fixed-route bus and rail transit systems, the ADA provided 
that it shall be considered discrimination for a public entity that 
operates a fixed-route system to fail to provide paratransit service 
to individuals with disabilities that is comparable to the level of 
service provided to individuals without disabilities who use the fixed-
route system.[Footnote 4] Regulations issued under the ADA established 
requirements for who was eligible for ADA paratransit service and the 
minimum requirements for what ADA paratransit service must entail.

The Federal Transit Administration (FTA) within the Department of 
Transportation (DOT) is responsible for overseeing federal grants for 
public transportation, a responsibility that includes overseeing 
compliance with ADA requirements for paratransit service. In 2007, we 
reported that although there are indications that the accessibility of 
public transit is improving, less is known specifically about the 
extent of compliance with ADA paratransit requirements. We also 
reported that as more individuals are being served by ADA paratransit, 
transit agencies are struggling to balance the provision of these 
services with the increased costs of a growing paratransit ridership. 
[Footnote 5] As a result, many transit agencies are pursuing methods 
to contain paratransit costs while maintaining ADA compliance.

In this context, you asked us to review the provision of ADA 
paratransit service. We addressed the following questions:

(1) What is known about the extent of compliance with ADA paratransit 
requirements?

(2) What changes have occurred in ADA paratransit demand and costs 
since 2007?

(3) What actions are transit agencies taking to help address changes 
in the demand for and costs of ADA paratransit service?

To determine what is known about the extent of compliance with ADA 
paratransit requirements, we reviewed ADA regulations, FTA guidance on 
the regulations, and FTA's ADA compliance reports from 2005 to 2011. 
In addition, we examined FTA's National Transit Database (NTD) to 
assess the extent to which it contains data related to ADA paratransit 
services and transit agencies' compliance with ADA paratransit 
requirements. We also interviewed FTA officials about how the agency 
assesses compliance and consulted our prior work on transportation 
accessibility. To identify changes that have occurred in ADA 
paratransit demand and costs, we examined data from the NTD on the 
number of ADA paratransit trips provided annually and total annual 
expenditures attributable to ADA complementary paratransit 
requirements. In reviewing NTD data on ADA paratransit services, we 
determined that they were not reliable for our purpose, which was to 
assess changes in ADA paratransit demand and costs. Appendix II 
contains a more detailed discussion of our data reliability 
assessment. To identify changes that have occurred in ADA paratransit 
demand and costs since 2007 and to determine what actions agencies are 
taking to help address such changes, we conducted a generalizable Web-
based survey of transit agencies from May through July 2012. We 
identified 546 transit agencies that provided demand-response service 
in 2010 and sampled 145 of these agencies for participation in the 
survey.[Footnote 6] To identify the 145 transit agencies to be 
sampled, we first selected the 10 largest transit agencies in the 
United States, measured according to the population size of their 
service areas. These 10 agencies represent 29 percent of the total 
service area population in our total sample. We then randomly selected 
an additional 135 transit agencies to survey, ordered by size as 
measured by the population size of their service areas. About 77 
percent of our sample (112 respondents) completed the survey, 
including all 10 of the largest transit agencies.[Footnote 7] This 
report does not contain all of the results from the survey; our 
questionnaire and a more comprehensive tabulation of the results can 
be viewed in an electronic supplement to this report.[Footnote 8] To 
address our second and third objectives, we conducted semi-structured 
interviews with 20 transit agencies regarding their provision of ADA 
paratransit services. We selected transit agencies to interview based 
on the size of the agency (small and large, measured according to the 
number of ADA paratransit trips provided in 2010); geographic 
diversity; and other factors. We also interviewed representatives from 
relevant industry and disability advocacy groups. In addition, to 
identify the actions that transit agencies are taking to help address 
changes in demand for and costs of ADA paratransit service, we 
reviewed relevant literature pertaining to leading practices for 
addressing demand for and costs of paratransit services. Appendix I 
contains a more detailed discussion of our objectives, scope, and 
methodology.

We conducted this performance audit from September 2011 to November 
2012 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives.

Background:

The ADA requires that fixed-route transit systems be made accessible 
to persons with disabilities--for example, by having lift and ramp 
equipped vehicles and announcing transit stops--but acknowledges that 
some disabled individuals are not able to use fixed-route services 
even with such accessibility features.[Footnote 9] To ensure that 
these individuals have equal access to public transportation, the ADA 
introduced a requirement that all public entities operating a fixed- 
route transit system must provide complementary and comparable ADA 
paratransit service.

ADA Paratransit Requirements:

DOT issued final regulations to implement the ADA's public 
transportation provisions on August 22, 1991.[Footnote 10] The 
regulations do not explicitly state how transit agencies are to 
provide paratransit service; rather, they require such agencies to 
offer a level of service that is "comparable" to the level of service 
offered to the general public without disabilities. Comparability is 
defined using six ADA minimum service requirements: service area, 
hours and days of service, fares, response time, trip purpose 
restrictions, and capacity constraints (see table 1).

Table 1: ADA Minimum Paratransit Service Requirements for 
Comparability to Fixed-Route Service:

ADA paratransit requirement: Service area[A]; 
Description: Generally within ¾ mile of a fixed route. 

ADA paratransit requirement: Hours and days of service[B]; 
Description: Same hours and days as fixed route. 

ADA paratransit requirement: Fares[C]; 
Description: Fares may not exceed twice the fare that would be charged 
to an individual paying full fare for a trip of similar length, at a 
similar time of day on the fixed route. A personal care attendant 
shall not be charged. 

ADA paratransit requirement: Response time[D]; 
Description: Paratransit service must be provided at any requested 
time on a particular day in response to a request for service made the 
previous day. Real time scheduling, in which a call to the transit 
provider would result in pickup the same day, is explicitly allowed 
but not mandated. 

ADA paratransit requirement: Trip purpose restrictions[E]; 
Description: No restrictions or priorities based on trip purpose are 
allowed. 

ADA paratransit requirement: Capacity constraints[F]; 
Description: The following are not allowed: restrictions on the number 
of trips per eligible individual; waiting lists for access to the 
service; substantial numbers of significantly untimely pickups for 
initial or return trips; substantial numbers of trip denials or missed 
trips; and substantial numbers of trips with excessive trip lengths. 

Source: GAO analysis of ADA requirements.

[A] 49 C.F.R. § 37.131(a). 

[B] 49 C.F.R. § 37.131(e). 

[C] 49 C.F.R. § 37.131(c). 

[D] 49 C.F.R. § 37.131(b). 

[E] 49 C.F.R. § 37.131(d). 

[F] 49 C.F.R. § 37.131(f). 

[End of table] 

ADA paratransit service is generally an origin-to-destination service, 
meaning that paratransit vehicles pick up riders at their homes or 
other locations and take them to their desired destinations.[Footnote 
11] Transit agencies are allowed to establish whether they will 
provide door-to-door service, wherein the driver offers assistance 
from the rider's door to the vehicle (and comparable assistance at the 
destination), or curb-to-curb service, wherein assistance is not 
provided until the rider reaches the vehicle. According to DOT 
guidance, if the base model of service chosen is curb-to-curb, it may 
still be necessary to provide door-to-door service for those persons 
who require it in order to travel from their point of origin to their 
point of destination.[Footnote 12]

ADA Paratransit Eligibility Process:

All public transit agencies required to provide ADA paratransit 
services must establish a process for certifying individuals 
(including both local residents and visitors in the transit agencies' 
respective service area) as ADA paratransit eligible.[Footnote 13] The 
ADA does not specify a process for how transit agencies determine 
eligibility, but it states the criteria that must be used to make the 
determination.[Footnote 14] A Transit Cooperative Research Program 
(TCRP) report on ADA paratransit eligibility certification practices 
found that most included a combination of the processes identified in 
table 2.[Footnote 15]

Table 2: Types of ADA Paratransit Eligibility Determination Processes 
Used by Transit Agencies:

ADA eligibility determination processes: Self-certification by the 
applicant; 
Description: Requires the applicant to fill out an application form, 
with verification by a medical professional on an as-needed basis. 

ADA eligibility determination processes: Professional verification via 
written documentation and/or telephone conversation; 
Description: Requires a medical professional to independently verify 
and document the physical condition and mobility needs of the 
applicant. Additionally, professional verification interviews may be 
conducted by telephone or in person, depending on the situation. 

ADA eligibility determination processes: In-person interview; 
Description: Requires that some or all applicants receive a face-to- 
face interview to determine the level of service for which the 
applicant does or does not qualify. 

ADA eligibility determination processes: In-person functional 
assessment; 
Description: Requires some or all applicants to undergo observation or 
testing of their specific abilities, skills, or limitations to 
accurately determine their functional ability to access the fixed-
route system. 

ADA eligibility determination processes: In-person cognitive 
assessment; 
Description: If the information provided by the applicant and 
professional is not sufficient to make a determination, the transit 
agency may ask the applicant to participate in a cognitive assessment. 

Source: GAO analysis of information from the TCRP. 

[End of table] 

While the ADA establishes minimum requirements for ADA paratransit, 
transit agencies are free to provide any additional level of service 
that they or their communities find appropriate.[Footnote 16] Types of 
additional services could include operating paratransit service beyond 
the fixed-route service area (which may include collecting fares for 
such trips in excess of twice the fixed-route service fare); providing 
service when the fixed-route system is not operating; and allowing 
same-day trip requests.

Providing ADA Paratransit Service:

According to the Center for Transportation Research, scheduling trips 
and dispatching vehicles are critical functions in providing ADA 
paratransit service. Scheduling ADA paratransit trips requires 
providers to match available vehicles to riders' trip time and 
destination requests. In general, the process starts when a passenger 
calls to reserve a trip. At that time the passenger's eligibility to 
receive the service is verified. Service must be provided on at least 
a next-day basis, though DOT's ADA regulations permit transit agencies 
to accept advance reservations up to 14 days in advance.[Footnote 17] 
A destination request is then either entered into paratransit's 
scheduling software or scheduled manually. On the day of the trip, the 
dispatcher creates a log sheet or manifest with the trip information 
for the driver, and the passenger is then picked up and dropped off 
(see figure 1).[Footnote 18]

Figure 1: Basic Scheduling and Dispatching Operation of a Paratransit 
System:

[Refer to PDF for image: illustration] 

Schedule Ride: 
At least one day in advance of a desired ride, a rider calls the 
transit agency's reservation center to schedule a paratransit ride. 

Dispatch Paratransit Vehicle: 
The day of the ride, the transit agency's dispatch center creates a 
schedule for the paratransit vehicles and dispatches a vehicle to the 
rider's pick-up location. 

Pick-up Rider: 
The paratransit vehicle arrives at the rider's pick-up location, and 
the driver assists the rider in boarding the vehicle and securing a 
mobility device. 

Take Rider to Destination: 
The paratransit vehicles may pick up additional riders, and then drop 
off the rider at the pre-determined destination. 

Source: GAO analysis. 

[End of figure]

Federal Roles and Responsibilities:

Two federal agencies, DOT and the Department of Justice (DOJ), have 
key roles in monitoring, overseeing, and enforcing ADA requirements 
and providing technical assistance.[Footnote 19] Their general roles 
and responsibilities are as follows:

* Regulations. The Secretary of Transportation has sole authority to 
issue regulations to carry out the section of the ADA governing 
paratransit as a complement to fixed-route service.[Footnote 20] FTA 
has primary responsibility for administering these regulations. 
[Footnote 21]

* Oversight. As part of DOT's oversight, FTA conducts general and 
special oversight reviews to evaluate the use of funds and adherence 
to civil rights laws, among other things, by recipients of Urbanized 
Area Formula Program grants (grantee) use of funds and adherence to 
civil rights laws, among other things.[Footnote 22] Civil rights 
reviews are one of five types of special reviews.[Footnote 23] FTA's 
Office of Civil Rights is responsible for civil rights compliance and 
monitoring to ensure nondiscriminatory provision of transit services. 
ADA compliance reviews are a subset of civil rights special reviews, 
[Footnote 24] and can be targeted to one of three specific ADA areas: 
fixed-route compliance, rail station compliance, and ADA paratransit 
service compliance.[Footnote 25] FTA also provides technical 
assistance to transit agencies on fulfilling ADA requirements and 
investigates discrimination complaints filed by the public.

Data. FTA is also responsible for maintaining the NTD, which was 
established by Congress to be the primary source for information and 
statistics on the nation's transit systems. Recipients or 
beneficiaries of certain grants from FTA are required to submit data 
to the NTD on information such as their operating expenses, revenue, 
and services.[Footnote 26] Transit agencies reporting to NTD are 
required to provide two data points related to ADA paratransit 
services: the number of ADA paratransit trips provided annually and 
total annual expenditures for paratransit services that are 
attributable to ADA requirements.

* Enforcement. DOJ's ADA enforcement responsibility generally involves 
either filing a federal lawsuit upon referral of a finding of 
noncompliance by DOT or by intervening in a privately filed lawsuit. 
DOJ may also resolve complaints of ADA noncompliance through 
settlement agreements and consent decrees with public transit agencies 
aimed at obtaining ADA compliance.

Little Is Known about ADA Compliance for Paratransit:

There is no national level information to accurately measure the 
extent to which agencies providing ADA paratransit service are 
complying with ADA's paratransit service requirements. However, as a 
condition of receiving federal funds, every transit agency has to self-
certify and assure that it is complying with the DOT ADA 
regulations.[Footnote 27] According to FTA, this certification and 
assurance is its starting point for assessing transit agencies' 
compliance with ADA requirements. Additionally, every Urbanized Area 
Formula Program grantee receives the general oversight FTA triennial 
review once every 3 years, which is one of the primary means FTA uses 
to evaluate whether grantees are meeting federal requirements. 
Although the triennial reviews include a review of the grantee's 
compliance with ADA requirements, they provide no detailed information 
about ADA paratransit compliance because ADA compliance is 1 of 24 
areas of transit operations covered in the review.[Footnote 28] 
According to FTA officials, negative triennial review findings may be 
considered in selecting transit agencies for a specialized ADA 
paratransit review.[Footnote 29]

FTA's specialized ADA paratransit compliance reviews examine multiple 
aspects of a transit agency's paratransit service. Compliance reviews 
include an examination of the selected transit agency's policies and 
standards for providing ADA complementary paratransit services. 
Reviews also include a determination of whether capacity constraints 
or areas of non-compliance exist. For example, a capacity constraint 
determination can be made by reviewing data on the selected transit 
agency's on-time performance, on-board travel time, telephone-hold 
times, and trip denials. The review also examines compliance related 
to eligibility determinations, fares, and other ADA paratransit 
service requirements.

FTA uses contractors to conduct the vast majority of its grantee 
oversight reviews, including specialized compliance reviews such as an 
ADA paratransit compliance review, although FTA is responsible for 
overseeing the work performed by its contractors.[Footnote 30] The 
results of compliance reviews are documented in written reports. Data 
about review findings are entered into FTA's electronic oversight- 
tracking system, OTRAK. If a deficiency is identified in the course a 
compliance review, FTA requires the transit agency to take steps to 
correct the deficiency and monitors the transit agency's progress. FTA 
can keep compliance reviews open and delay final report publication 
until problems are resolved, a resolution that could occur quickly or 
take years. (See figure 2 for a description of the major steps in the 
compliance review process.) 

Figure 2: Major Steps in the Compliance Review Process:

[Refer to PDF for image: process illustration] 

Schedule Review and Conduct Pre-Review Work: 
The contractor works with the regional civil rights officer to arrange 
a mutually agreed upon dale and time to conduct the site visit for the 
review. Additional information required for the contractor's review 
prior to the on-site review is requested in a letter prepared by the 
Office of Civil Rights confirming the dates of the compliance review.

Conduct Opening Conference: 
The contractor conducts an opening conference with the ADA coordinator 
and other appropriate grantee personnel before beginning the on-site 
review. 

 Conduct On-Site Compliance Review: 
The contractor conducts an in-depth and comprehensive compliance 
review and completes the site visit in accordance with the agreed upon 
schedule. 

Conduct Exit Meeting: 
 
At the conclusion of the on-site review, at the date, time, and 
location pre-arranged by FTA, the contractor conducts an on-site oral 
exit meeting with the general manager or designated representative, 
the ADA coordinator, and other appropriate grantee and grantee 
contractor personnel. The purpose of this meeting is to present the 
contractor's preliminary findings and to allow the entity's 
representative an opportunity to comment orally on the findings. 

Prepare a Draft Report on the Review: 
Within 45 calendar days of completing the review, the contractor 
forwards a draft report as an e-mail attachment to the program manager 
and contracting officer concurrently. The report includes a 
description of the entity reviewed, narrative description of areas 
reviewed, and findings (organized by chapters that mirror OTRAK 
categories), and recommended actions to correct deficiencies. 

Prepare a Final Report and Transmittal Letter on the Review and Post 
on Website: 
The grantee is allowed 30 days from the time of receipt of the draft 
report to submit its response. Upon receipt of the grantee's response, 
the contractor prepares a final report incorporating FTA revisions and 
the grantee's response within 21 calendar days, and then provides an 
electronic copy to the program manager and contracting officer 
concurrently. Contractor guidance requires that all reports meet 
formatting requirements so that the reports may be made available to 
the public through FTAs website. 

Respond to Three Quarterly Progress Reports: 
The monitoring process includes critical analysis of the quarterly 
reports submitted. 

Input All Process Stages and Findings into OTRAK: 
The contractor enters all process stages, findings from the review, 
and closed findings into OTRAK. Process stages include desk review, 
opening conference, closing conference, and transmittal of key 
documents to FTA. 

Source: GAO review of FTA information. 

[End of figure]

While compliance reviews represent an in-depth examination of a 
transit agency's paratransit service, few transit agencies have been 
selected for an ADA paratransit compliance review. FTA's most recent 
contract calls for only 10 compliance reviews of complementary 
paratransit services to be conducted from 2008 through 2011, or 
roughly 2 to 3 reviews per year.[Footnote 31] According to FTA 
officials, there are approximately 628 urbanized area fixed-route 
transit agencies that could be eligible for ADA compliance reviews. 
Officials told us that the limited number of ADA paratransit 
compliance reviews conducted each year is because of resource 
constraints and the time needed to complete an in-depth review. We 
analyzed 15 ADA paratransit compliance review final reports from 
January 2005 through April 2011 posted on the FTA website.[Footnote 
32] We found that all 15 transit agencies reviewed from 2005 to 2011 
had findings of non-compliance or recommendations related to ADA 
paratransit service. The following are examples of non- compliance 
findings and recommendations from the final reports we reviewed:

* Fourteen out of 15 agencies had findings of capacity constraints 
with their ADA paratransit service. For example, one agency was found 
to have polices around reservations and scheduling that lead to wait 
lists and difficulties ensuring scheduled ride times adhered to ADA 
requirements. Another agency had findings of non-compliance with its 
telephone access and hold times for trip scheduling because of 
inadequate staffing capacity.

* All 15 transit agencies reviewed also had findings related to their 
ADA paratransit eligibility processes. For example, one FTA compliance 
review found that a local transit agency was improperly denying ADA 
complementary paratransit service to some individuals who should be 
eligible. As a result, the agency proposed several changes to its 
eligibility determination process to correct the issues. In another 
final report, there were 24 findings or recommendations related to the 
transit agency's eligibility processes. These findings ranged from 
information forms containing insufficient eligibility process detail 
to findings of non-compliance related to rider-eligibility suspension 
policy.

These compliance reviews provide some information about how 
paratransit services are complying with ADA requirements, but they do 
not allow for a determination of the extent to which transit agencies 
overall are complying with ADA paratransit requirements. The findings 
of non- compliance in the reports discussed above are not 
generalizable to the 628 urbanized area fixed-route transit agencies, 
both because of the low number of reviews conducted and because the 
reviews were not conducted on a generalizable sample of transit 
agencies. Rather, FTA officials told us that the transit agencies that 
receive the specialized compliance reviews are specifically selected 
by FTA for review because FTA has reason to believe those agencies may 
be experiencing ADA paratransit compliance issues.

Although FTA uses a risk-based approach to determine which transit 
agencies are selected for compliance reviews, FTA does not have a 
formalized or transparent selection process. According to FTA 
officials, transit agencies may be selected for an ADA paratransit 
compliance review for any number of reasons including rider 
complaints, which, according to FTA officials, are the best indicators 
available for making the most effective use of compliance resources, 
media coverage, findings from triennial reviews, legal actions that do 
not involve FTA, information from the transportation industry, 
congressional interest, and input from FTA regional offices.[Footnote 
33] In selecting an agency for review, FTA may also consider the 
burden to a transit agency if it were to receive multiple oversight 
reviews, such as triennial reviews or state compliance reviews, in the 
same fiscal year. In those cases, FTA officials said they take steps 
to focus contractor and oversight resources to decrease burden on the 
transit agency, while still addressing possible compliance issues. FTA 
officials, however, could not provide documentation that outlines the 
compliance review selection criteria, and stated that there are no 
formalized criteria to guide the selection of transit agencies for 
review. As discussed above, the ADA paratransit compliance review 
process is documented, so the lack of documented selection criteria is 
notable. While the factors that FTA currently uses may be appropriate 
for selecting transit agencies for an ADA compliance review, FTA's 
informal process does not adhere to our guidance on internal control 
standards related to the communication of policy, documentation of 
results, and monitoring and reviewing of grantee activities and 
findings.[Footnote 34] We have previously reported that these 
standards are critical to maintaining the thoroughness and consistency 
of compliance reviews.[Footnote 35] The documentation should be 
readily available for examination and appear in management directives, 
administrative policies, or operating manuals. Additionally, grant 
accountability guidance states that as part of an agency's internal 
control system, preparing policies and procedures that outline what is 
expected in any particular program or process meets an important 
element of strong federal grant accountability best practices. 
[Footnote 36]

In the past, FTA examined its process for selecting agencies for 
compliance reviews but decided to retain its informal selection 
process. Specifically, in 2006, FTA commissioned a report to help 
develop a method to prioritize transit systems for ADA compliance 
reviews, but FTA did not adopt the proposed methodology.[Footnote 37] 
FTA officials told us that the proposed selection methodology was 
flawed because the selection criteria, such as select NTD data--fixed- 
route fleet size, ADA cost per trip, and changes in reported ADA 
expenses--were not indicators of non-compliance.[Footnote 38] FTA 
officials, however, said that the current selection factors bring 
problem agencies and other possible ADA compliance issues to their 
attention and serve as a good means for selecting agencies for review. 
Whatever criteria FTA deems appropriate to select transit agencies for 
review, it cannot ensure that those criteria will be consistently 
applied if they are not documented and communicated to FTA regional 
offices, contractors, and transit agencies.

In addition, FTA officials told us that all final ADA compliance 
review reports should be publicly available on FTA's website. However, 
no additional final ADA compliance review reports have been posted to 
FTA's website since April 2011, resulting in a lag in transit 
agencies' and others' access to reports and findings. As of September 
5, 2012, nine final ADA compliance review reports had not been posted 
on FTA's website. These final reports account for reviews conducted 
from February 2004 through July 2010. Even though there are no 
official FTA requirements for when a report must be completed and 
posted on the website, FTA officials acknowledged that timeliness of a 
report's completion and online posting is a problem area that they are 
actively working to address. FTA officials said the backlog of reports 
needing to be posted online was because of technical issues. According 
to FTA, all finalized ADA compliance review reports are publicly 
available documents. However, if the reports have not been posted to 
FTA's website, then the only way to access their content is through a 
Freedom of Information Act request, which requires time and financial 
resources. Transit agencies and industry groups told us that they look 
to these compliance reviews as a form of guidance on FTA's 
interpretation of ADA requirements. Particularly, because FTA conducts 
a limited number of ADA paratransit compliance reviews, both transit 
agencies and FTA would benefit from posting final compliance reports 
in a timely manner.

Demand for ADA Paratransit Has Increased for Some Transit Agencies, 
and Costs Remain High:

Demand:

According to our survey of transit agencies, demand for ADA 
paratransit trips increased from 2007 to 2010. [Footnote 39] Our 
survey indicates that demand increased across multiple measures, such 
as more riders registered to use ADA paratransit service and more ADA 
paratransit trips provided. Most transit agencies--about 73 percent--
experienced an increase in the number of individuals registered to use 
ADA paratransit service.[Footnote 40] In addition, about 64 percent of 
transit agencies provided more ADA paratransit trips in 2010 than in 
2007. From 2007 to 2010, the average number of individuals registered 
to use ADA paratransit service at a transit agency increased by 12 
percent, and the average number of ADA paratransit trips provided by a 
transit agency increased 7 percent (see figure 3).

Figure 3: Average Number of Individuals Registered to Use ADA 
Paratransit Services at a Transit Agency and Average Number of ADA 
Paratransit Trips Provided by a Transit Agency, 2007 and 2010:

[Refer to PDF for image: 2 horizontal bar graphs] 

Average number of individuals registered to use ADA paratransit 
services: 
2007: 5,203; 
2010: 5,831. 

Average number of ADA paratransit trips provided: 
2007: 172,481; 
2010: 184,856. 

Source: GAO analysis of survey of transit agency officials regarding 
ADA paratransit services. 

[End of figure]

Increases in demand for ADA paratransit services were driven by the 10 
largest transit agencies.[Footnote 41] ADA paratransit ridership at 
these transit agencies is substantially greater than at other transit 
agencies. The average number of individuals registered to use ADA 
paratransit services at the 10 largest transit agencies increased 22 
percent from 2007 to 2010, from an average of 34,758 individuals in 
2007 to 42,357 individuals in 2010, compared to a marginally 
significant average increase of 9 percent at other transit agencies 
not among the 10 largest agencies. For the 10 largest transit 
agencies, the average number of riders taking at least one ADA 
paratransit trip per year increased 27 percent, from an average of 
14,202 riders in 2007 to 18,095 riders in 2010. In addition, the 
average number of ADA paratransit trips provided by these 10 transit 
agencies increased 31 percent, from an average of 1,533,707 trips in 
2007 to 2,006,327 trips in 2010. Other transit agencies did not 
experience significant increases in the average number of riders 
taking at least one ADA paratransit trip per year or the number of ADA 
paratransit trips provided.

According to transit agency officials we spoke with, demand for ADA 
paratransit trips has increased for several reasons. One frequently 
cited reason was that other organizations that provide or previously 
provided transportation services for individuals with disabilities 
have increasingly relied on ADA paratransit services for 
transportation--a trend sometimes referred to as "ride shedding." For 
example, one transit agency official said that demand for ADA 
paratransit trips increased dramatically when local nonprofit 
organizations discontinued their dial-a-ride transportation services. 
Riders who formerly used the dial-a-ride services now use the ADA 
paratransit system.

In addition, many transit agency officials we spoke with told us that 
ADA paratransit demand has increased because of the growing elderly 
population. Officials pointed to the growth in the elderly population 
as a reason why more people are living with disabilities and need ADA 
paratransit services. According to 2010 U.S. census data, the 
population aged 65 and older grew 15 percent from 2000 to 2010, 
compared to growth of about 10 percent in the overall population, and 
the prevalence of disability increased with successively older age 
groups. Some transit agency officials said that ADA paratransit demand 
has also increased because of overall population growth, an increasing 
number of individuals with disabilities living independently, and 
improvements in ADA paratransit service that have made the service 
more attractive to riders.

Costs and Fares:

ADA paratransit trips are much more costly to provide than fixed-route 
trips. Based on our survey results, the average cost of providing an 
ADA paratransit trip in 2010 was $29.30, an estimated three and a half 
times more expensive than the average cost of $8.15 to provide a 
fixed- route trip (see figure 4).[Footnote 42] Survey respondents 
reported average per-trip costs for ADA paratransit in 2010 ranging 
from $11.11 to $69.25.

Figure 4: Average Reported ADA Paratransit and Fixed-Route Per-Trip 
Costs, 2010:

[Refer to PDF for image: horizontal bar graph] 

ADA Paratransit: $29.30; 
Fixed-Route: $8.15. 

Source: GAO analysis of survey of transit agency officials regarding 
ADA paratransit services. 

[End of figure]

The costs of providing ADA paratransit and fixed-route services 
differed between the largest transit agencies and other transit 
agencies. On average, an ADA paratransit trip cost $42.23 in 2010 for 
the 10 largest transit agencies, compared to $28.94 per trip for other 
transit agencies. For fixed-route trips, average costs in 2010 were 
lower for the 10 largest transit agencies than for other transit 
agencies: $3.82 for the largest transit agencies compared to $8.24 for 
others. Despite these differences, the 10 largest transit agencies and 
other transit agencies spent similar portions of their budgets on 
providing ADA paratransit services in 2010, 14 percent and 18 percent 
on average, respectively.

The average costs of providing ADA paratransit and fixed-route 
services increased 10 percent and 9 percent, respectively, from 2007 
to 2010. In our survey, transit agencies reporting increases in total 
costs to provide ADA paratransit attributed rising ADA paratransit 
costs to several factors. About 71 percent of transit agencies 
reported that changes in costs to operate vehicles--such as fuel, 
insurance, and vehicle maintenance costs--have been a major 
contributor to overall cost increases. At least a third of transit 
agencies cited other reasons as being major contributors to rising 
costs, including changes in labor and benefit costs,[Footnote 43] 
changes in the number of ADA paratransit riders, and ride shedding 
(see figure 5).

Figure 5: Percentage of Transit Agencies Reporting the Following as 
Major Contributors to Cost Increases in ADA Paratransit Services:

[Refer to PDF for image: illustrated vertical bar graph] 

Changes in costs to operate vehicles (such as fuel, insurance, and 
maintenance: 71%; 
Changes in costs of labor and benefits for drivers and administrative 
staff: 39%; 
Changes in the number of ADA paratransit riders: 34%; 
Ride shedding (other entities' reliance on ADA paratransit for 
transportation: 33%. 

Source: GAO analysis of survey of transit agency officials regarding 
ADA paratransit services. 

Note: Percentages represent transit agency responses of a "major 
reason" for increases in the total cost to provide ADA paratransit 
services since fiscal year 2007. 

[End of figure] 

Transit agency officials we spoke with identified reasons similar to 
survey respondents for rising ADA paratransit costs. More than half of 
the transit agency officials we interviewed identified rising fuel 
costs as a contributor to increasing ADA paratransit costs. For 
example, an official at one transit agency told us that although the 
agency has been aggressive in keeping ADA paratransit costs static 
since 2009, it is still trying to identify a good strategy to address 
high fuel costs. The official told us that fuel costs currently 
account for about 15 percent of the agency's per-trip cost for ADA 
paratransit. In addition, almost half of the transit agency officials 
said that rising wages and benefits for employees have caused ADA 
paratransit costs to increase. Specifically, officials identified 
rising health insurance costs as contributing to overall cost 
increases. Officials from two transit agencies also told us that ride 
shedding has increased demand, resulting in overall cost increases. 
For example, transit agency officials in one location told us that a 
state-level agency serving developmentally disabled individuals went 
from providing transportation for its clients to purchasing tickets 
from the transit agency for ADA paratransit trips. For every $1 
million in ADA paratransit tickets the state-level agency purchases 
from the transit agency, it costs the transit agency $13 million to 
provide ADA paratransit services.

According to our survey, the average ADA paratransit fare was $2.09 in 
2010, far below the average cost of providing a trip (see figure 6). 
This is not surprising given that transit agencies cannot base ADA 
paratransit fares on paratransit costs. Rather, one of the ADA 
requirements for complementary paratransit service is that transit 
agencies may not charge more than twice the average fixed-route fare 
for paratransit. The average fare collected for a fixed-route trip was 
$1.13. Fares for ADA paratransit and fixed-route increased about 12 
percent and 17 percent, respectively from 2007 to 2010.

Figure 6: Average Reported ADA Paratransit and Fixed-Route Costs and 
Fares Per Trip, 2010:

[Refer to PDF for image: horizontal bar graph] 

ADA Paratransit: 
Average cost: $29.30; 
Average fare: $2.09. 

Fixed-Route: 
Average cost: $8.15; 
Average fare: $1.13. 

Source: GAO analysis of survey of transit agency officials regarding 
ADA paratransit services. 

[End of figure]

ADA Paratransit Data in NTD:

FTA's NTD contains two fields related to ADA paratransit demand and 
costs. However, our analysis of these data found that, according to 
our standards for data reliability, they are not sufficiently reliable 
for the purpose of assessing changes in ADA paratransit demand and 
costs.[Footnote 44] Transit agencies reporting to NTD are required to 
provide data on the number of ADA paratransit trips provided annually 
(ADA trips) and total annual expenditures attributable to ADA 
complementary paratransit requirements (ADA expenses). In analyzing 
these data, we found data discrepancies, such as incomplete data, that 
may understate or overstate the number of ADA trips and amount of ADA 
expenses. Specifically, we found that about one-third of transit 
agencies did not report these data in the years of data we analyzed. 
According to FTA officials, some transit agencies that should report 
data on ADA paratransit services did not do so. FTA officials also 
noted that of the transit agencies that do report data, some 
misunderstand the definition of ADA paratransit services and make 
reporting errors as a result. We could not determine what effect the 
non-reporting transit agencies had on the ADA paratransit services' 
data because we could not determine how many transit agencies should 
have reported these data, but did not do so, and how many had valid 
reasons for not reporting. We also could not determine how many may 
have erroneously reported ADA paratransit data based on a 
misunderstanding of the definition of ADA paratransit trips or ADA 
paratransit expenses. The NTD is intended to provide timely, accurate 
information to help Congress and FTA apportion funding and assess the 
continued progress of the nation's public transportation systems.

Transit Agencies Are Taking a Number of Actions to Address Paratransit 
Demand and Costs:

Transit agencies have implemented a number of actions aimed at 
addressing the growing demand for ADA paratransit trips and reducing 
the costs of ADA paratransit services. Types of actions agencies are 
taking include coordinating efforts among various service providers, 
transitioning passengers from ADA paratransit to fixed-route service, 
improving the accessibility of fixed-route service, ensuring more 
accurate eligibility determinations, realigning paratransit service 
with minimum ADA paratransit requirements, and improving technology 
for scheduling and dispatch.

Coordinating Efforts among Various Service Providers:

To meet the needs of ADA paratransit-eligible riders, numerous transit 
agencies that we surveyed and interviewed reported that they are 
coordinating with health and human services, and other local 
transportation providers. According to our survey of transit agencies, 
about 59 percent of transit agencies are coordinating with health and 
human services providers in order to improve ADA paratransit services 
or address the costs of providing service. Also, about 44 percent of 
transit agencies are coordinating with other local transit agencies, 
including 6 of the 10 largest transit agencies. Some transit agency 
officials we interviewed also told us that they coordinate 
transportation services. For example, Lane Transit District (Lane 
County, Oregon) operates a one-call center. The call center 
coordinates a variety of transportation services, including ADA 
paratransit service and transportation for seniors and people with low 
incomes. According to an official, the one-call center makes it easier 
for people to access services and the agency benefits from 
efficiencies associated with providing more group trips.

Two of the transit agency officials that we spoke with said that they 
would like to implement coordination efforts, but have been unable to 
get various parties to come together. In June 2012, we reported 
several challenges that state and local entities face in their efforts 
to coordinate services for the transportation disadvantaged (a broader 
group than ADA paratransit riders), including insufficient federal 
leadership, changes to state legislation and policies, and limited 
financial resources in the face of growing unmet needs.[Footnote 45]

Transitioning Passengers from ADA Paratransit to Fixed-Route Service:

Some transit agencies are transitioning passengers from ADA 
paratransit services to fixed-route service in an effort to manage 
demand and contain a portion of their costs. According to FTA 
officials and others, fixed-route systems have become much more 
accessible since the enactment of the ADA, and nearly all fixed-route 
buses are now accessible to and usable by persons with disabilities, 
including wheelchair users.[Footnote 46] This improved accessibility 
makes it possible to transition some passengers from paratransit to 
fixed-route services. Based on our literature review, one of the most 
effective and long-lasting techniques that can be employed to reduce 
the demand for ADA paratransit is transitioning paratransit passengers 
to fixed-route service through travel training and offering incentives 
to encourage existing paratransit passengers to use the fixed-route 
transit service, where possible, which we explain more fully below. 
One source described this as a "win-win" proposition for both the 
transit agency and the individual. The transit agency is able to use 
excess capacity on its fixed-route system at minimal cost to the 
agency. By using the fixed- route system, the passenger may be able to 
access a wider variety of services and destinations, does not have to 
pre-schedule travel on paratransit vehicles, and could save money by 
paying lower fares for fixed-route trips.[Footnote 47]

To assist ADA paratransit riders in transitioning to fixed-route 
service, several transit agencies are using travel-training programs 
that help show riders on how they can use the fixed-route system. Our 
survey results show that about 55 percent of transit agencies use 
travel training as a demand management and cost containment strategy. 
Some transit agency officials stated that travel training may reduce 
costs. For example, King County Metro (Seattle, Washington) reported 
spending about $573,000 in 2011 to provide travel training to over 300 
individuals, but estimated it saved about $1,290,000 in paratransit 
costs by successfully transitioning paratransit patrons to the fixed- 
route system. Similarly, officials from New Jersey Transit (Newark, 
New Jersey) told us that they have been successful in getting riders 
to use the fixed-route system by offering travel training. They have 
not quantified how many trips are being diverted from paratransit, but 
told us that surveys of those who have taken travel training show that 
many are using the fixed-route system.

Some transit agencies offer financial incentives to ADA paratransit 
eligible individuals to use fixed-route transit services. These 
incentives are also sometimes extended to persons accompanying the ADA 
paratransit eligible rider, which may encourage use of the fixed-route 
system by persons who cannot use it independently. Some (5 of the 20) 
transit agencies we interviewed said that they offer fixed-route fare 
incentives. For example, Access Services (Los Angeles County, 
California) offers paratransit riders free fixed-route trips on fixed- 
route systems throughout the county. According to Access Services, in 
July 2012, ADA paratransit registrants took 2.1 million trips on Los 
Angeles County fixed-route systems. On an annual basis--assuming that 
over 25 million trips will be taken per year at a cost of $20 per 
trip--this represents a cost savings of $500 million, according to 
Access Services. Officials from Bay Area Rapid Transit (Oakland, 
California) also told us that they offer fare incentives to get ADA 
paratransit riders to use the fixed-route system.

Improving the Accessibility of Fixed-Route Service:

Our survey results showed that over 62 percent of transit agencies 
reported making accessibility improvements to their fixed-route 
systems since 2007. Additionally, one transit agency that we spoke 
with said that it has made changes to its vehicles to accommodate 
larger wheelchairs or mobility devices. Others have implemented feeder 
service as a way to transport passengers from their homes or other 
pick-up locations to fixed-route bus or train stops. However, 
according to FTA officials, one of the biggest challenges to using 
fixed route is the inaccessibility (or nonexistence) of sidewalks and 
pedestrian infrastructure. For example, lack of sidewalks may prevent 
persons with disabilities from traveling to fixed-route bus stops, 
thereby increasing the need for ADA paratransit services. However, 
such pedestrian improvements rarely fall under the transit system's 
direct influence or control. To assist transit agencies in addressing 
these improvements, FTA issued a policy in 2011 that simplifies the 
process for grantees to qualify for FTA funding for pedestrian 
improvements that are related to transit service. Additionally, 
transit agencies are required to maintain accessibility features 
(e.g., elevators and bus lifts) in good working order and to follow 
ADA policies, such as making stop announcements, needed to make the 
fixed route usable to persons with disabilities.

Ensuring More Accurate Eligibility Determinations:

A number of transit agencies are seeking to more accurately determine 
riders' eligibility for ADA paratransit trips to manage changes in 
paratransit demand and costs. According to the National Council on 
Disability, determining eligibility for each specific trip request is 
one strategy that transit agencies are using to have at least some 
paratransit riders' trips accommodated on the fixed-route system 
rather than through ADA paratransit.

According to our survey, almost 49 percent of transit agencies have 
implemented a more rigorous eligibility process in an effort to manage 
costs. About 36 percent of survey respondents use an in-person 
functional assessment, including 9 of the 10 largest transit agencies. 
[Footnote 48] Additionally, some of the transit agency officials we 
spoke with use the eligibility process to manage demand for 
paratransit service and help ensure that the service remains available 
for those passengers who need it. These transit agencies are using in-
person interviews or functional assessments to determine whether a 
disability prevents the applicant from using the fixed-route system. 
For example:

* Washington Metropolitan Area Transit Authority (Washington, D.C. 
area) certifies its riders' eligibility using in-person interviews and 
functional assessments. According to an official, the process begins 
with a staff consultation in which the customer's travel needs and 
transit knowledge are evaluated. The eligibility determination is then 
made based on: application data (including medical diagnoses from the 
customer's health care provider), the interview, and a functional 
assessment with physical and, when needed, cognitive components.

* Metro Mobility (St. Paul, Minnesota) uses a two-part paper 
application, with an in-person functional assessment and interview, if 
needed. The application includes a self-reported questionnaire and a 
professional verification of disability.

Realigning Paratransit Service with Minimum ADA Paratransit 
Requirements:

In order to reduce costs, over 18 percent of the transit agencies we 
surveyed have realigned their paratransit service area to better match 
the minimum ADA paratransit requirement. Additionally, about 22 
percent have realigned their paratransit service hours to better match 
the minimum ADA paratransit requirements. Officials at StarTran 
(Lincoln, Nebraska) told us that they are proposing to reduce their 
paratransit service area to the required ¾ mile of fixed-route service 
and said that reducing the paratransit service area would result in 
considerable cost savings. In 2010, King County Metro projected the 
estimated savings if the agency aligned its service area, hours, 
service level, and fares with the ADA paratransit minimums. The 
estimated savings included $2.1 million if the ADA minimum service 
area was adopted; $700,000 if service hours were adjusted; $1.5 
million for moving from a door-to-door to a curb-to-curb policy; and a 
savings of $1.2 million in addition to $741,000 increased revenues if 
fares were adjusted to the basic adult fixed-route fare.[Footnote 49]

Improving Technology for Scheduling and Dispatch:

Using available technologies such as computerized scheduling and 
dispatching software can help lower ADA paratransit service costs by 
increasing service efficiency, according to transit agency officials 
we spoke with and various studies. Officials at a majority of the 
transit agencies we spoke with (14 of 20) said that they are using 
available technologies.

* For example, Dallas Area Rapid Transit (Dallas, Texas) is using 
technology to help handle an increasing number of trips, clients, and 
vehicles. It has an automated system that allows riders to request and 
confirm trips over the phone without the need of a call taker. This 
approach makes trip requests more convenient for riders and less labor-
intensive for the agency, thereby improving effectiveness and 
efficiency, according to transit officials.

* In 2007, New York City Transit made improvements to its automatic 
scheduling and dispatching system which schedules up to 22,500 
paratransit trips on weekdays. The improvements feature an intelligent 
transportation-system automatic-vehicle-location and monitoring 
project to equip all vehicles with vehicle-location and mobile-data 
computers, thus freeing dispatchers to take corrective action based on 
accurate data and to communicate scheduling changes to drivers in real-
time.[Footnote 50]

Conclusions:

The ADA's mandate for paratransit services has been an important 
catalyst for progress in providing equal access to public 
transportation for all individuals. Overseeing the provision of these 
services at hundreds of transit agencies is an important 
responsibility for FTA. ADA paratransit compliance reviews--although 
limited in number--examine compliance with ADA paratransit service 
requirements. As we noted, FTA selects agencies for review for various 
reasons, including rider complaints, media coverage, and findings from 
triennial reviews. However, FTA has no formalized criteria to guide 
the selection of transit agencies for review. Without a formalized, 
documented process for selecting transit agencies for compliance 
reviews, FTA is not following GAO's internal controls and grantee-
oversight best practices. FTA cannot ensure an effective oversight 
process if critical elements of internal controls are not present.

FTA's process is to make publicly available, via its website, final 
ADA compliance review reports that contain findings from completed 
compliance reviews. However, nine final review reports--conducted from 
2004 to 2010--have not been posted to FTA's website. Even though there 
are no time frames governing when a report must be posted, timelier 
posting of these reviews would be beneficial to transit agencies and 
industry groups that use these compliance reviews as a form of 
guidance on FTA's interpretation of ADA requirements. Having these 
publicly available, as soon as possible, could assist FTA in its 
oversight of transit agencies and assist transit agencies in their 
compliance efforts.

Finally, transit agencies reporting to NTD are required to provide 
limited data related to ADA paratransit services, including the number 
of ADA paratransit trips provided annually and total annual 
expenditures attributable to ADA paratransit requirements. We found 
that the required data fields were often incomplete. For example, for 
data from 2005 to 2010, the most recent year available, about 32 
percent of transit agencies reporting to NTD did not provide data in 
one or more years on the number of ADA trips provided. Because the NTD 
is intended to provide timely and accurate information to Congress and 
others, FTA would benefit from advising transit agencies on how to 
accurately and consistently provide the required data.

Recommendations for Executive Action:

We recommend that the Secretary of Transportation direct the FTA 
Administrator to take the following actions:

1. To help ensure that FTA's ADA paratransit compliance reviews adhere 
to GAO recommended internal controls and grantee oversight best 
practices, document and make publicly available a formal selection 
approach for selecting transit agencies for review.

2. To help transit agencies and stakeholders have access to up-to-date 
ADA paratransit compliance reviews and compliance findings, post the 
backlog of ADA compliance review final reports on FTA's website and 
establish processes for the timely posting of future compliance review 
reports.

3. To improve NTD data collection for ADA paratransit, provide 
guidance to transit agencies on how to accurately complete existing 
ADA paratransit fields.

Agency Comments:

We provided DOT with a draft of this report and the e-supplement for 
review and comment. DOT officials neither agreed nor disagreed with 
our recommendations, but provided technical comments, which we 
incorporated as appropriate. DOT did not have any comments on the e-
supplement. DOT officials stated that FTA uses consumer complaints as 
programmatic criteria to identify areas of potential noncompliance and 
considers complaints to be the best available indicator of where to 
target its limited investigative resources. DOT officials reiterated 
that paratransit data collected for the NTD are intended to provide 
information useful for FTA's monitoring of the size of ADA paratransit 
services relative to demand response services. According to DOT 
officials, these data are not intended to assess overall ADA 
paratransit compliance.

We are sending copies of this report to interested congressional 
committees, the Secretary of Transportation, and the Administrator of 
the Federal Transit Administration. We also will make copies available 
to others upon request. In addition, this report will be available at 
no charge on GAO's Web site at [hyperlink, http://www.gao.gov].

If you or your staff have any questions about this report, please 
contact David Wise at 202-512-2834 or wised@gao.gov. Contact points 
for our Offices of Congressional Relations and Public Affairs may be 
found on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix IV. 

Signed by: 

David Wise: 
Director, Physical Infrastructure: 

[End of section]

Appendix I: Objectives, Scope, and Methodology:

This report addresses the following three objectives:

What is known about the extent of compliance with the Americans with 
Disabilities Act of 1990 (ADA) paratransit requirements?

What changes have occurred in ADA paratransit demand and costs since 
2007?

What actions are agencies taking to help address changes in the demand 
for and costs of ADA paratransit service?

To determine what is known about the extent of compliance with ADA 
paratransit requirements, we reviewed ADA regulations, the Federal 
Transit Administration (FTA) guidance on the regulations, and FTA's 
ADA compliance reports from 2005 to 2011. In addition, we examined 
FTA's National Transit Database to assess the extent to which it 
contains data related to ADA paratransit services and transit 
agencies' compliance with ADA paratransit requirements. We also 
interviewed FTA officials about the various processes it uses to 
assess compliance and consulted our prior work on transportation 
accessibility and FTA's oversight processes.

To identify changes that have occurred in ADA paratransit demand and 
costs since 2007, we examined data from FTA's National Transit 
Database on the number of ADA paratransit trips provided annually and 
total annual expenditures attributable to ADA complementary 
paratransit requirements. In reviewing National Transit Database data, 
we determined that they were not reliable for our purposes. Appendix 
II contains a more detailed discussion of our data reliability 
assessment.

To address our second and third objectives, we conducted semi 
structured interviews with 20 transit agencies regarding their 
provision of ADA paratransit services. We based our selection of these 
transit agencies based on a variety of characteristics, including 
geographic diversity, size of ADA paratransit system, and transit 
agencies deemed notable for their ADA paratransit systems. Because we 
used a non-generalizable sample of transit agencies, findings from 
these interviews cannot be used to make inferences about other transit 
agencies. However, we determined that the selection of these transit 
agencies was appropriate for our design and objectives and that the 
selection would generate valid and reliable evidence to support our 
work. Table 1 provides more detailed information about the transit 
agencies we interviewed.

Table 3: Transit Agency Interviews:

FTA region: FTA Region 1; 
Transit agency: Massachusetts Bay Transportation Authority; 
Transit agency location: Boston, Massachusetts.

Transit agency: The Greater New Haven Transit District; 
Transit agency location: Hamden, Connecticut.

FTA region: FTA Region 2; 
Transit agency: New Jersey Transit Corporation; 
Transit agency location: Newark, New Jersey.

Transit agency: Niagara Frontier Transportation Authority; 
Transit agency location: Buffalo, New York.

FTA region: FTA Region 3; 
Transit agency: Washington Metropolitan Area Transit Authority; 
Transit agency location: Washington, D.C..

Transit agency: ACCESS Transportation Systems, Inc.[A]; 
Transit agency location: Pittsburgh, Pennsylvania.

FTA region: FTA Region 4; 
Transit agency: Transit Authority of River City; 
Transit agency location: Louisville, Kentucky.

Transit agency: Board of County Commissioners, Palm Beach County, 
PalmTran, Inc.; 
Transit agency location: West Palm Beach, Florida.

FTA region: FTA Region 5; 
Transit agency: Metropolitan Council - Metro Mobility; 
Transit agency location: St. Paul, Minnesota.

Transit agency: Toledo Area Regional Transit Authority; 
Transit agency location: Toledo, Ohio.

FTA region: FTA Region 6; 
Transit agency: Dallas Area Rapid Transit; 
Transit agency location: Dallas, Texas.

Transit agency: Capital Metropolitan Transportation Authority; 
Transit agency location: Austin, Texas.

FTA region: FTA Region 7; 
Transit agency: Bi-State Development Agency (METRO); 
Transit agency location: St. Louis, Missouri.

Transit agency: StarTran; 
Transit agency location: Lincoln, Nebraska.

FTA region: FTA Region 8; 
Transit agency: Utah Transit Authority; 
Transit agency location: Salt Lake City, Utah.

Transit agency: Billings Metropolitan Transit; 
Transit agency location: Billings, Montana.

FTA region: FTA Region 9; 
Transit agency: Access Services[B]; 
Transit agency location: El Monte, California.
Transit agency: San Francisco Bay Area Rapid Transit District/Alameda-
Contra Costa Transit District[C]; 
Transit agency location: Oakland, California.

FTA region: FTA Region 10; 
Transit agency: King County Metro; 
Transit agency location: Seattle, Washington.

Transit agency: Lane Transit District; 
Transit agency location: Eugene, Oregon.

Source: GAO.

[A] ACCESS Transportation Systems, Inc. is the ADA paratransit broker 
sponsored by the Port Authority of Allegheny County.

[B] Access Services provides ADA paratransit services on the behalf of 
public transit agencies in Los Angeles County.

[C] San Francisco Bay Area Rapid Transit and Alameda-Contra Costa 
Transit District partner to provide ADA paratransit services through a 
cooperative entity called East Bay Paratransit. 

[End of table] 

We also interviewed representatives from relevant industry and 
disability advocacy groups, including the following:

* American Public Transportation Association,

* Community Transportation Association of America,

* Disability Rights Education and Defense Fund,

* Easter Seals Project ACTION,

* National Independent Living Council, and:

* Texas Statewide Council on Independent Living.

Moreover, to identify the actions that transit agencies are taking to 
help address changes in costs of and demand for ADA paratransit 
service, we reviewed relevant literature pertaining to leading 
practices for addressing costs and demand of paratransit services.

ADA Paratransit Services Survey:

We conducted a Web-based survey of transit agencies from May through 
July, 2012 to address the second and third objectives questions. 
Results of this survey and the survey instrument have been published 
in GAO-13-18SP ADA Paratransit Services: Survey of Public Transit 
Agency Officials on Services and Costs, an E-supplement to GAO-13-17 
and can be found at the GAO website.

Survey Population and Sample Design:

We constructed our population of transit agencies for our survey 
sample using 2010 data in FTA's National Transportation Database 
(NTD). Using NTD data, we determined that there were 546 agencies that 
provided demand response services, which according to FTA, was the 
mode of service most likely to correlate with provision of ADA 
paratransit services.[Footnote 51] The total survey sample was 145 
transit agencies. The survey sample was composed of two strata. One 
was a certainty sample of 10 transit agencies that, based on NTD data, 
were the top 10 transit agencies based on service area population in 
2010, accounting for 29 percent of the total service area population 
in our total sample. The second stratum was ordered by population size 
and selected randomly to obtain representation from agencies with 
populations of various sizes. For this stratum we randomly selected 
135 transit agencies that provide demand-response service from the 
remaining population after the certainty sample, a population of 536 
agencies. We obtained completed questionnaires from 112 respondents, 
or about 77 percent of our sample. The survey results can be 
generalized to the population of transit agencies that provide demand-
response service. And as noted above, we are issuing an electronic 
supplement to this report that shows a more complete tabulation of our 
survey results.

Administration of Survey and Quality Assurance:

We developed a questionnaire to obtain information about transit 
agencies' provision of ADA paratransit services. GAO identified 
potential survey recipients from a list provided by FTA on its Urban 
Agency CEO Contact list. In early May 2012, an initial email alerting 
agency contacts to the upcoming web-based survey was sent and about a 
week later, the web-based survey was also delivered to recipients via 
email message. The web-based survey questionnaire requested baseline 
information about service and eligibility processes as well as 
information related to the cost, demand, and policies and practices 
transit agencies use to improve provision of ADA paratransit service. 
To help increase our response rate, we sent two follow-up emails and 
called agency officials from May through July 2012. The survey was 
available to transit agency respondents from May 2012 through July 2012.

To pretest the questionnaire, we conducted cognitive interviews and 
held debriefing sessions with five local transit agency officials with 
knowledge about their ADA paratransit operations. Three pretests were 
conducted in-person with phone participants while two were conducted 
solely on the phone. We selected pretest respondents to represent 
different sizes and locations of transit agencies that provide ADA 
paratransit service. We conducted these pretest to determine if the 
questions were burdensome, understandable and measured what we 
intended. Additionally we asked officials in FTA's Office of Civil 
Rights to review the questionnaire based on their expertise and 
knowledge of the program and interviewed them for their feedback on 
the survey questionnaire. On the basis of feedback from the pretests 
and expert review we modified the questions as appropriate.

Sampling Error and Estimation:

To produce the estimates from this survey, answers from each 
responding case were weighted in the analysis to account statistically 
for all the members of the population, including those who were not 
selected or did not respond to the survey. Estimates produced from 
this sample are from the population of transit agencies that provided 
demand response services in the FTA's 2010 National Transit Database.

Because our results are based on a sample and different samples could 
provide different estimates, we express our confidence in the 
precision of our particular sample's results as a 95 percent 
confidence interval (for example, plus or minus 10 percentage points). 
We are 95 percent confident that each of the confidence intervals in 
this report include the true values in the study population. Unless we 
note otherwise, percentage estimates based on all transit agencies 
have 95 percent confidence intervals of within plus or minus 10 
percentage points. Confidence intervals for other estimates are 
presented along with the estimate where used in the report.

Non-Sampling Error:

In addition to the reported sampling errors, the practical 
difficulties of conducting any survey may introduce other types of 
errors, commonly referred to as nonsampling errors. For example, 
differences in how a particular question is interpreted, the sources 
of information available to respondents, or the types of people who do 
not respond can introduce unwanted variability into the survey 
results. We included steps in both the data collection and data 
analysis stages for the purpose of minimizing such nonsampling errors.

We took the following steps to increase the response rate: developing 
the questionnaire, pretesting the questionnaires with transit agencies 
that provide ADA paratransit service, conducting multiple follow-ups 
to encourage responses to the survey and contacting respondents to 
clarify unclear responses.

We conducted this performance audit from September 2011 to November 
2012 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives.

[End of section]

Appendix II: Reliability of ADA Paratransit Data in FTA's National 
Transit Database:

We conducted an analysis to determine whether ADA paratransit data in 
the NTD[Footnote 52] were sufficiently reliable for the purpose of 
identifying changes that have occurred in ADA paratransit demand and 
costs since 2007. We examined data on ADA paratransit trips and ADA 
paratransit expenses from 2005 to 2010 and interviewed FTA officials 
about the database. We found data discrepancies, such as incomplete 
data, that may understate or overstate the number of ADA trips and 
amount of ADA expenses. As a result, we determined that the ADA 
paratransit data in the NTD were not sufficiently reliable for the 
purposes of our review.[Footnote 53]

Methodology:

To identify changes that have occurred in ADA paratransit demand and 
costs since 2007, we examined data from the NTD on the number of ADA 
paratransit trips provided annually (ADA trips) and total annual 
expenditures attributable to ADA complementary paratransit 
requirements (ADA expenses). We examined data for all transit agencies 
reporting these two data fields from 2005 through 2010, the most 
recent year of data available at the time of our review. We chose to 
assess data for 2005 through 2010 because we wanted to identify the 
extent to which we could report trends in data over this series of 
years. In addition, we chose to analyze data for these two fields 
because they are the only two fields related to ADA paratransit in the 
NTD.[Footnote 54] We found that the NTD does not contain a data field 
that asks transit agencies whether they are required to provide ADA 
paratransit services.

To determine whether the NTD data on ADA trips and ADA expenses would 
be reliable for our purposes, we interviewed FTA officials who are 
knowledgeable about the design and uses of the NTD data. We also 
assessed the data's accuracy and completeness by analyzing the extent 
to which transit agencies reported these two data fields for all 6 
years of interest. In addition, we compared the NTD data to data from 
our generalizable survey of transit agencies.

Results of Analysis:

Our analysis found that about one-third of transit agencies reporting 
ADA paratransit data did not report these data in all 6 years of data 
we analyzed. We found that, when analyzing data from transit agencies 
that reported providing ADA trips in at least one year from 2005 to 
2010, about 32 percent of the agencies did not provide data in one or 
more of the years of interest. Similarly, about 30 percent of transit 
agencies reporting ADA expenses in at least one year from 2005 to 2010 
did not report data for all 6 years of interest (see table 1). Some of 
the transit agencies that did not report data for all 6 years skipped 
years of reporting--for instance, an agency might have reported in 
2005, 2009, and 2010. Other transit agencies reported data for 
consecutive years, but not for all of the 6 years--for instance, they 
reported data in 2005, 2006, and 2007. Since the NTD does not contain 
a field regarding whether transit agencies are required to provide ADA 
paratransit services in a particular year, we could not assess whether 
those transit agencies reporting for fewer than 6 years were in error. 
In addition, we found that although larger transit agencies were less 
likely than smaller transit agencies to have missing data, the missing 
data from larger transit agencies--because they provide more ADA 
paratransit trips than smaller transit agencies--would probably have a 
greater impact on the overall data.

Table 4: Percentage of Transit Agencies Reporting ADA Trips and ADA 
Expenses in NTD, 2005 through 2010:

ADA Trips; 
Percentage of transit agencies reporting data in all 6 years: 67.7%; 
Percentage of transit agencies reporting data in less than 6 years: 
32.3%.

ADA Expenses; 
Percentage of transit agencies reporting data in all 6 years: 69.6%; 
Percentage of transit agencies reporting data in less than 6 years: 
30.4%.

Source: GAO analysis of NTD data. 

[End of table] 

We could not determine how many of the transit agencies that did not 
report data in all 6 years should have reported these data, and how 
many had legitimate reasons for not reporting in all years. FTA 
officials told us about cases in which transit agencies should report 
ADA paratransit data to NTD, but fail to do so. They also told us 
about cases in which valid reasons exist for transit agencies not to 
report data every year. Transit agencies may receive reporting 
waivers, for example because of hurricanes or other natural disasters, 
that make the agencies exempt from reporting any data to NTD. Transit 
agencies may also introduce or discontinue ADA paratransit services 
for various reasons, which can lead to the appearance of missing data. 
It is not possible to tell from the data, however, whether these 
missing data are because of valid reasons, such as reporting waivers 
or changes in service or because of a transit agency's failure to 
report. In addition, transit agencies may misunderstand the definition 
of ADA paratransit service and make reporting errors as a result--they 
may report ADA trips and ADA expenses erroneously one year because 
they think their specialized, demand-responsive service counts as ADA 
paratransit service, even though the service is not provided in order 
to comply with the ADA. When agencies correct the reporting error in 
subsequent years and do not report these data, it can appear that they 
have failed to report consistently. According to FTA officials, it is 
difficult to verify whether transit agencies that report ADA 
paratransit data are indeed reporting about ADA paratransit services, 
or whether they are reporting about generic demand-responsive services.

Without a field identifying those transit agencies that provide ADA 
paratransit, we attempted to use another field--those transit agencies 
that reported providing demand-response service--as a proxy to help 
determine which transit agencies should and should not report ADA 
paratransit data. Demand response is a broad service category that 
includes ADA paratransit service. Our analysis found that in each year 
from 2005 to 2010, 22 percent to 26 percent of transit agencies that 
reported providing demand-response service did not report providing 
ADA trips or having ADA expenses (see table 2).

Table 5: Percentage of Transit Agencies Reporting Demand-Response 
Service, ADA Trips, and ADA Expenses in NTD, 2005 through 2010:

Year: 2005; 
Percentage of transit agencies reporting demand response service, but 
not ADA trips or ADA expenses: 22.4%; 
Percentage of transit agencies reporting demand response service and 
ADA trips, but not ADA expenses: 0.2%; 
Percentage of transit agencies reporting demand response service and 
ADA expenses, but not ADA trips: 2.0%; 
Percentage of transit agencies reporting demand response service, ADA 
trips, and ADA expenses: 75.4%.

Year: 2006; 
Percentage of transit agencies reporting demand response service, but 
not ADA trips or ADA expenses: 21.6%; 
Percentage of transit agencies reporting demand response service and 
ADA trips, but not ADA expenses: 0.4%; 
Percentage of transit agencies reporting demand response service and 
ADA expenses, but not ADA trips: 2.9%; 
Percentage of transit agencies reporting demand response service, ADA 
trips, and ADA expenses: 75.1%.

Year: 2007; 
Percentage of transit agencies reporting demand response service, but 
not ADA trips or ADA expenses: 23.3%; 
Percentage of transit agencies reporting demand response service and 
ADA trips, but not ADA expenses: 0.0%; 
Percentage of transit agencies reporting demand response service and 
ADA expenses, but not ADA trips: 0.8%; 
Percentage of transit agencies reporting demand response service, ADA 
trips, and ADA expenses: 75.9%.

Year: 2008; 
Percentage of transit agencies reporting demand response service, but 
not ADA trips or ADA expenses: 25.7%; 
Percentage of transit agencies reporting demand response service and 
ADA trips, but not ADA expenses: 0.6%; 
Percentage of transit agencies reporting demand response service and 
ADA expenses, but not ADA trips: 0.2%; 
Percentage of transit agencies reporting demand response service, ADA 
trips, and ADA expenses: 73.7%.

Year: 2009; 
Percentage of transit agencies reporting demand response service, but 
not ADA trips or ADA expenses: 25.2%; 
Percentage of transit agencies reporting demand response service and 
ADA trips, but not ADA expenses: 0.2%; 
Percentage of transit agencies reporting demand response service and 
ADA expenses, but not ADA trips: 0.4%; 
Percentage of transit agencies reporting demand response service, ADA 
trips, and ADA expenses: 74.3%.

Year: 2010; 
Percentage of transit agencies reporting demand response service, but 
not ADA trips or ADA expenses: 26.2%; 
Percentage of transit agencies reporting demand response service and 
ADA trips, but not ADA expenses: 0.4%; 
Percentage of transit agencies reporting demand response service and 
ADA expenses, but not ADA trips: 0.5%; 
Percentage of transit agencies reporting demand response service, ADA 
trips, and ADA expenses: 72.9%.

Source: GAO analysis of NTD data. 

[End of table] 

Based on results from our survey of transit agencies, only about 9 
percent of transit agencies reported providing demand-response service 
but not ADA paratransit service--a lower percentage than the 22 to 26 
percent that were found to report demand response service but not ADA 
trips or ADA expenses to the NTD. This suggests that some of the 
transit agencies reporting demand response service but not ADA trips 
or ADA expenses do indeed provide ADA paratransit services--and should 
have reported ADA trips and ADA expenses.

We could not determine what effect the non-reporting transit agencies 
had on the ADA paratransit services data because we could not 
determine how many transit agencies should have reported, but did not 
do so; how many had valid reasons for not reporting; and how many may 
have over- reported based on misunderstanding the definition of ADA 
trips or ADA expenses. As a result, we determined that the ADA 
paratransit services data available in NTD were not sufficiently 
complete and therefore were not reliable for our purposes, which were 
to provide information on changes in ADA paratransit demand and costs 
since 2007.

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments:

GAO Contact:

David J. Wise, (202) 512-2834, wised@gao.gov:

Staff Acknowledgments:

In addition to the individual named above, other key contributors to 
this report were Heather MacLeod, Assistant Director; Robert Alarapon; 
Dwayne Curry; Kathleen Gilhooly; Timothy Guinane; Delwen Jones; 
Katherine Killebrew; Luann Moy; Beverly Ross; Sonya Vartivarian; and 
Betsey Ward.

[End of section] 

Footnotes: 

[1] Formerly at 49 U.S.C. § 5301(d). The new surface reauthorization 
act has modified this provision. See Section 20003 of Moving Ahead for 
Progress in the 21st Century Act, Pub. L. No. 112-141 (July 6, 2012).

[2] Pub. L. No. 101-336, 104 Stat. 327 (July 26, 1990).

[3] Paratransit service, broadly defined, is accessible, origin-to- 
destination transportation service that operates in response to calls 
or requests from riders. It is an alternative to fixed-route transit 
service, which operates according to regular schedules along 
prescribed routes with designated stops. Paratransit service is 
defined in Department of Transportation regulations as "comparable 
transportation service required by the ADA for individuals with 
disabilities who are unable to use fixed route transportation 
systems". 49 C.F.R. § 37.3

[4] Pub. L. No. 101-336, § 223(a), codified at 42 U.S.C. § 12143(a). 

[5] GAO, Transportation Accessibility: Lack of Data and Limited 
Enforcement Options Limit Federal Oversight, [hyperlink, 
http://www.gao.gov/products/GAO-07-1126 (Washington, D.C.: Sept. 19, 
2007).

[6] Demand-response service is service in which vehicles operate in 
response to calls or requests from passengers. Demand response service 
includes ADA paratransit service and other generic demand responsive 
services that are unrelated to ADA requirements. Transit agencies that 
report providing demand response services to the NTD do not 
necessarily provide ADA paratransit service. However, the demand 
response field in NTD is most closely associated with provision of ADA 
paratransit service, according to FTA officials. Our first ADA 
paratransit survey question establishes whether or not an agency 
provided ADA paratransit service.

[7] Unless otherwise noted, all percentage estimates based on this 
survey have 95 percent confidence intervals of within +/-10 percentage 
points of the estimate itself. See Appendix I for additional 
information on sampling error of estimates. 

[8] GAO, ADA Paratransit Services: Survey of Public Transit Agency 
Officials on Services and Costs, an E-supplement to [hyperlink, 
http://www.gao.gov/products/GAO-13-17], [hyperlink, 
http://www.gao.gov/products/GAO-1318SP] (Washington, D.C.: Nov. 15, 
2012).

[9] The ADA regulations require that all newly purchased or leased 
vehicles used in fixed-route service must be accessible. Additionally, 
vehicles which are remanufactured to extend their useful life beyond a 
given number of years must include accessibility features. Moreover, 
new transit facilities must be accessible and alterations to older 
transit facilities must include features to make them accessible.

[10] 56 Fed. Reg. 45584 (Sept. 6, 1991). DOT regulations for 
paratransit as a complement to fixed-route service are at 49 C.F.R. 
Part 37, Subpart F. 

[11] 49 C.F.R. § 37.129(a).

[12] U.S. DOT, Origin to Destination Guidance, Sept. 2005.

[13] 49 C.F.R. § § 37.125, 37.127.

[14] 49 C.F.R. § 37.123(e). Individuals may be paratransit eligible on 
the basis of a permanent or temporary disability.

[15] TCRP, ADA Paratransit Eligibility Certification Practices , TCRP 
Synthesis 30, 1998.

[16] 49 C.F.R. § 37.131(g).

[17] 49 C.F.R. § 37.131(b) (4).

[18] Center for Transportation Research, University of Texas at 
Austin, Transit Scheduling Data Integration: Paratransit Operations 
Review and Analysis (May 2000).

[19] There is a memorandum of understanding established between DOJ 
and FTA to coordinate enforcement responsibility over the ADA. A copy 
of this memorandum can be found at [hyperlink, 
http://www.fta.dot.gov/civilrights/12875_3898.html]. Accessed 
September 21, 2012.

[20] 42 U.S.C. 12143(b); Boose v. Tri-County Metro. Transp. Dist. Of 
Or., 587 F.3d 997, 1001 (9TH Cir. 2009); Abrahams v. MTA Long Island 
Bus, 644 F.3d 110, 115 (2d Cir. 2011).

[21] FTA is a small agency within DOT, accounting for 568 staff in 
headquarters and regional offices. It has 10 regional offices to 
provide support to and oversight of transit agencies. FTA regional 
offices also work with local transit officials in developing and 
processing grant applications. FTA's Office of Civil Rights has 28 
staff in headquarters and regional offices, and 5 full time staff 
directly involved with compliance. 

[22] FTA Order 5400.1, Oversight Reviews, November 1, 1994. Formula 
grants, as the name suggests, are apportioned among urban areas by a 
statutory formula based on population data and statistics for transit 
service and ridership. 

[23] The other special reviews are the Drug and Alcohol Abuse Program 
Review, Financial Management Oversight Review, Procurement System 
Review, and the State Safety Oversight Review.

[24] Civil Rights Reviews began in the 1980s, according to officials 
in FTA's Office of Civil Rights. They include four discretionary 
oversight reviews assessing grantees' compliance with the Americans 
with Disabilities Act of 1990, Title VI regulations, Disadvantaged 
Business Enterprise requirements, and Equal Employment Opportunity 
requirements. 

[25] FTA's ADA fixed-route reviews focus on fixed-route bus lift or 
ramp maintenance and reliability, fixed-route bus-stop announcements, 
and route identification. FTA's ADA rail station reviews focus on 
rail- stop announcements and route identification or key, new, or 
renovated rail station compliance.

[26] Recipients and beneficiaries of grants from FTA under the 
Urbanized Area Formula Program (49 U.S.C. § 5307) or Other than 
Urbanized Area (Rural) Formula Program (49 U.S.C. § 5311) are required 
by statute to submit data to the NTD. 49 U.S.C. § 5335.

[27] FTA Certifications and Assurances--before FTA awards transit 
assistance or funding to support a project, an applicant must provide 
certain certifications and assurances required by federal law or 
regulation. One area of certification and assurance is the "Assurance 
of Nondiscrimination on the Basis of Disability," which includes 
assuring compliance with the requirements of the ADA. 76 Fed. Reg. 
67534, 67537 (Nov. 1, 2011).

[28] As of fiscal year 2012 there are 24 triennial review areas. They 
are: 1) legal, 2) financial, 3) technical, 4) satisfactory continuing 
control, 5) maintenance, 6) procurement, 7) disadvantaged business 
enterprise, 8) Buy America, 9) debarment and suspension, 10) lobbying, 
11) planning/program of projects, 12) Title VI, 13) public comment on 
fare and service changes, 14) half fare, 15) Americans with 
Disabilities Act, 16) charter bus, 17) school bus, 18) National 
Transit Database, 19) safety and security, and 20) drug-free 
workplace, 21) Drug and Alcohol Program, 22) equal employment 
opportunity, 23) ITS architecture, and 24) American Recovery and 
Reinvestment Act.

[29] For more information about GAO analysis of FTA's triennial review 
program, see GAO, Public Transportation: FTA's Triennial Review 
Program Has Improved, but Assessments of Grantees' Performance Could 
Be Enhanced, [hyperlink, http://www.gao.gov/products/GAO-09-603], 
(Washington, D.C.: June 30, 2009). 

[30] U.S. Department of Transportation, Office of the Inspector 
General Audit Report: Improvements Needed in FTA Grant Oversight 
Program. Report MH-2012-168 (Washington, D.C.: Aug. 2, 2012). 

[31] FTA has issued a request for proposals for a new contract for 
conducting ADA compliance reviews. According to FTA officials, the new 
contract will provide FTA with more flexibility in selecting locations 
and transit agencies for review. 

[32] As of September 5, 2012, there are a total of 38 ADA compliance 
reviews publicly available on FTA's website. They account for final 
reviews posted from August 2000 through April 2011.

[33] General program information and policy is set at the FTA 
Headquarters in Washington, D.C. 

[34] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1], p. 15.

[35] GAO, Motor Carrier Safety: Federal Safety Agency Identifies Many 
High-Risk Carriers but Does Not Assess Maximum Fines as Often as 
Required by Law, [hyperlink, http://www.gao.gov/products/GAO-07-584] 
(Washington, D.C.: Aug. 29, 2007).

[36] Grant Accountability Project, Guide to Opportunities for 
Improving Grant Accountability, (Washington, D.C.: 2005). 

[37] Federal Transit Administration, Team MAC Final Report on ADA 
Program Management Support Contract No. DTFT60-05-R-00013 (October 31, 
2006). 

[38] See appendix II for more information about our analysis of NTD. 

[39] We attempted to use FTA's NTD to obtain information regarding ADA 
paratransit demand and costs. However, we determined that it contained 
limited and unreliable information (see appendix II). To collect 
information on ADA paratransit demand and costs, we surveyed a 
generalizable sample of transit agencies (see appendix I).

[40] This estimate has a 95 percent confidence interval of within +/-
12 percentage points of the estimate itself.

[41] We sent surveys to and received responses from the 10 largest 
transit agencies, measured according to the population size of their 
service areas. These 10 agencies represent 29 percent of the 
population in the United States served by transit. The 10 largest 
transit agencies include New Jersey Transit Corporation (Newark, New 
Jersey), Access Services (El Monte, California), MTA New York City 
Transit (New York City, New York), Pace-Suburban Bus Division 
(Arlington Heights, Illinois), Massachusetts Bay Transportation 
Authority (Boston, Massachusetts), Southeastern Pennsylvania 
Transportation Authority (Philadelphia, Pennsylvania), Washington 
Metropolitan Area Transit Authority (Washington, D.C.), Suburban 
Mobility Authority for Regional Transportation (Detroit, Michigan), 
Orange County Transportation Authority (Orange, California), and 
Metropolitan Transit Authority of Harris County, Texas (Houston, Texas).

[42] Cost and fare estimates are in nominal terms, unadjusted for 
inflation. The estimated costs of ADA paratransit trips ($29.30) and 
fixed-route trips ($8.15) are statistically different at the 5 percent 
significance level. Survey respondents reported including different 
costs in their estimates. Of the 80 survey respondents who answered a 
question about estimating ADA paratransit costs, about 93 percent of 
respondents reported including fuel costs; about 91 percent reported 
including vehicle maintenance costs; about 90 percent reported 
including administrative costs; about 81 percent reported including 
vehicle insurance costs; about 73 percent reported including 
information technology costs; about 66 percent reported including non- 
contractor operator wages and benefits; about 59 percent reported 
including contractor operator wages and benefits; about 50 percent 
reported including other contractor costs; about 21 percent reported 
including vehicle rental and lease costs; and about 18 percent 
reported including other costs. 

[43] This estimate has a 95 percent confidence interval of within +/-
11 percentage points of the estimate itself.

[44] Government auditing standards require that auditors assess the 
sufficiency and appropriateness of computer-processed information. 
According to GAO standards for assessing the reliability of computer- 
processed data, reliability means that data are reasonably complete 
and accurate, meet the audit's intended purposes, and are not subject 
to inappropriate alteration. For more information about GAO's data 
reliability standards, see GAO, Applied Research and Methods: 
Assessing the Reliability of Computer-Processed Data, [hyperlink, 
http://www.gao.gov/products/GAO-09-680G] (Washington, D.C.: July 
2009). See appendix II for more information about our assessment of 
ADA paratransit services data in NTD. 

[45] GAO, Transportation Disadvantaged Populations: Federal 
Coordination Efforts Could Be Further Strengthened, [hyperlink, 
http://www.gao.gov/products/GAO-12-647] (Washington, D.C.: June 20, 
2012).

[46] In some cases, the inaccessibility of sidewalks could prevent the 
use of fixed-route systems.

[47] National Center for Transit Research, Center for Urban 
Transportation Research, University of South Florida, Impacts of More 
Rigorous ADA Paratransit Eligibility Assessments on Riders with 
Disabilities (May 2009).

[48] Functional assessments consist of specific observation or testing 
of a person's abilities, skills, or limitations.

[49] King County Auditor's Office, Performance Audit of Transit, 
Report No. 2009-01D, (Seattle, WA: Sept. 15, 2009).

[50] Implementing ITS at New York City for Para-Transit Service, 
William Ho and Brian Altschul, 15th World Congress on Intelligent 
Transport Systems and ITS America's 2008 Annual Meeting, November 16- 
20, 2008.

[51] We assessed NTD data on the transit agencies that provided demand 
response services in 2010 by reviewing documentation about the 
dataset, taking steps to check completeness of the data, and when 
discrepancies occurred, resolving issues by contacting FTA officials. 
We determined that the NTD data on transit agencies that provided 
demand response services in 2010 were sufficiently reliable for the 
purpose of constructing our sample.

[52] The National Transit Database was established by the Congress to 
be the nation's primary source for information and statistics on 
transit systems in the United States. Recipients and beneficiaries of 
grants from FTA under the Urbanized Area Formula Program (49 U.S.C. § 
5307) or Other than Urbanized Area (Rural) Formula Program (49 U.S.C. 
§ 5311) are required by statute to submit data to the NTD. 49 U.S.C. § 
5335. Over 690 urbanized-area transit providers currently report to 
NTD on a variety of variables, including information on operating 
expenses, revenue, services, and relationships with contractors.

[53] Government auditing standards require that auditors assess the 
sufficiency and appropriateness of computer-processed information. 
According to GAO standards for assessing the reliability of computer- 
processed data, reliability means that data are reasonably complete 
and accurate, meet the audit's intended purposes, and are not subject 
to inappropriate alteration. For more information about GAO's data 
reliability standards, see GAO, Applied Research and Methods: 
Assessing the Reliability of Computer-Processed Data, [hyperlink, 
http://www.gao.gov/products/GAO-09-680G] (Washington, D.C.: July 2009). 

[54] The NTD primarily collects data by mode of public transportation, 
including modes such as commuter rail, light rail, ferryboat, bus, and 
demand response. The demand response mode includes ADA paratransit 
service and other generic demand-responsive services that are 
unrelated to ADA requirements. As part of the reporting requirements 
for the demand response mode, transit agencies are required to report 
on the number of ADA paratransit trips provided annually and the total 
annual expenditures attributable to ADA complementary paratransit 
requirements.

[End of section] 

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