**Palm Tran Incorporated (Palm Tran)**

**Assessment of ADA Complementary**

**Paratransit Service Capacity Constraints**

**April 17-20, 2000**

***Summary of Observations***

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, D.C.**

**Prepared by**

**Planners Collaborative Inc.**

**January, 2001**

**CONTENTS**

Purpose of the Assessment 1

Background 2

Overview of the Assessment 4

Observations Regarding ADA Complementary Paratransit Eligibility
Determination 8

Observations Regarding the Reservation Process and Telephone Capacity 16

Observations Regarding On-Time Performance, Service Capacity, and
Scheduling 22

Observations Regarding Trip Duration 35

Summary of Findings and Recommendations 37

Attachment 1: SpecTran "Rider's Guide"

Attachment 2: Palm Tran ADA Complementary Paratransit Eligibility Forms
and Brochures

Attachment 3: SpecTran Complaints Process and Records

Attachment 4: ATC Scheduling Parameters

Attachment 5: Palm Tran Response to the Draft Report, November 7, 2000

# Purpose of the Assessment

Public entities which operate fixed route transportation services for
the general public are required by the U. S. Department of
Transportation (USDOT) regulations implementing the Americans with
Disabilities Act of 1990 (ADA) to also provide Complementary Paratransit
service for persons who, because of their disability, are unable to use
the fixed route system. These regulations (49 CFR Parts 27, 37, and 38)
include six service criteria which must be met by ADA Complementary
Paratransit service programs. Section 37.135(d) of the regulations
requires that ADA Complementary Paratransit services meet these criteria
by January 26, 1997.

The Federal Transit Administration (FTA) is responsible for ensuring
compliance with the ADA and the USDOT regulations which implement this
civil rights law. As part of its compliance efforts, FTA, through the
FTA Office of Civil Rights, conducts periodic assessments of fixed route
transit and complementary ADA Complementary Paratransit services
operated by grantees.

An on-site assessment of complementary ADA Complementary Paratransit
service provided by Palm Tran Incorporated (Palm Tran) was conducted
from April 17 through 20, 2000. Palm Tran provides ADA Complementary
Paratransit service throughout Palm Beach County with a concentration on
the eastern area of the county. The assessment was conducted for the FTA
Office of Civil Rights by Planners Collaborative Inc. of Boston,
Massachusetts. The assessment focused primarily on compliance of the
Palm Tran ADA Complementary Paratransit service, known as SpecTran, with
one specific regulatory service criteria - the "capacity constraints"
criteria. Section 37.131(f) of the regulations requires that
complementary ADA Complementary Paratransit services be operated without
capacity constraints.

This report summarizes the observations and findings of the on-site
assessment of Palm Tran's ADA Complementary Paratransit service. A
description of key features of the Palm Tran's ADA Complementary
Paratransit service is first provided. A description of the approach and
methodology used to conduct the assessment is then provided.
Observations and findings related to each element of the capacity
constraint criteria are then summarized.

Finally, the major findings of the assessment are summarized in the last
section of this report. Recommendations of the review team for
addressing issues identified are also provided.

# Background

## General

Palm Tran Incorporated (Palm Tran) provides public transit services
throughout Palm Beach County, Florida. Services include both fixed route
and demand responsive service.

Palm Tran's demand responsive service, called SpecTran, serves ADA
Complementary Paratransit trips, Transportation Disadvantaged (TD)
trips, and Older Americans Act Department of Senior Services (DOSS)
trips. The state of Florida provides TD service to people who because of
physical, or mental disability income status or age are dependent upon
others for access to certain activities. DOSS transportation is
available to seniors who are registered with Florida's Department of
Senior Services. Approximately two thirds of the trips served by
SpecTran are ADA Complementary Paratransit trips. The remainder are TD
and DOSS trips. In the year ending September 30, 1999, SpecTran served a
total of 310,000 passenger trips.

SpecTran service is provided largely through contracts between
transportation companies and Palm Tran. Palm Tran staff makes customer
eligibility determinations with the assistance of contract services
provided by Gulfstream Goodwill Industries. Management services are
provided through a contract with Comsis Mobility Services d/b/a
Intelitran ATC Vancom Inc. (ATC). The contract scope includes making
trip reservations and scheduling service. Dispatch and transportation
services are provided through three additional Palm Tran contracts with
service providers:

-   AAA Wheelchair Wagon Services, Inc. d/b/a Ambulette of the Palm
    Beaches (AAA) with R.C. Services, Inc. (RCS), a sub-contractor;

-   Two Wheels Transportation (TWT), Inc.; and

-   Palm Beach Transportation (PBT), Inc.

All three carriers provide service throughout Palm Beach County. AAA,
RCS and TWT provide service for scheduled runs with vehicles and drivers
dedicated to SpecTran service. PBT provides service for individually
dispatched passenger trips for both ambulatory and wheelchair
passengers. PBT uses vehicles and drivers who are not exclusively
dedicated to SpecTran services. PBT, a division of Yellow Cab, shares
facilities, vehicles, drivers, and dispatching with Yellow Cab taxi
services. In addition to SpecTran and taxi services, PBT also uses its
resources to provide Medicaid transportation services under a separate
contract with Palm Beach County.

SpecTran ADA Complementary Paratransit service criteria and policies are
as follows:

**Service Area**: ADA Complementary Paratransit service is provided to
all trips with origins and destinations within three quarters of a mile
Palm Tran fixed bus routes. This service area is generally in the
eastern area of the county from the Broward County line on the south to
Palm Beach Gardens and North Beach on the north and from Route 109 on
the west to the Atlantic Ocean on the east.

**Service Period**: ADA Complementary Paratransit service is provided
during the same service period as the fixed route system. Specifically,
service hours are 6:00 AM to 9:00 PM Monday through Friday and from 6:00
AM to 7:00 PM on Saturdays and from 9:00 AM to 3:00 PM on Sundays. ADA
service is not provided on New Year's Day, Memorial Day, Independence
Day, Labor Day, Thanksgiving Day, or Christmas Day.

**Response Time**: Trip requests are taken by Intelitran ATC between the
hours of 7:00 AM and 5:00 PM seven days a week. Reservations can be
placed up to seven days in advance. Trips must be requested no later
than 5:00 PM on the day preceding the trip.

**Fares**: The SpecTran ADA Complementary Paratrnsit fare is \$1.50 per
one way trip. One companion may accompany an ADA-certified rider.
Companions are required to pay the same \$1.50 fare. Personal attendants
ride at no charge*.*

**Trip Purposes**: All trip purposes are served without prioritization.

A copy of the [SpecTran Paratransit Rider's Guide]{.underline} is
provided as Attachment 1.

## Policies and Service Standards Related to Capacity Issues

Palm Tran has established several service standards and policies related
to phone capacity, on-time performance, and travel time for the SpecTran
service. Standards are described below.

**Phone Capacity**: Palm Tran has established a standard of 95% of calls
not ringing busy and, 95% of callers not being placed on hold for more
than three minutes.

**Trip Denials**: Palm Tran's goal is no trip denials.

**On-Time Performance**: Vehicles are considered to be "on-time" if they
arrive within 15 minutes of the scheduled pick-up time. Palm Tran's
standard is 90% for on-time performance*.*

**Travel Time**: Palm Tran's travel time goals are one hour for trips of
less than 15 miles, and two hours for trips greater than 15 miles. Palm
Tran considers a SpecTran trip to be too long if the elapsed time from
trip origin to destination exceeds the time required for the same trip
if made using the fixed route transit system.

# Overview of the Assessment

As noted above, this assessment focused on compliance with the ADA
Complementary Paratransit capacity constraints requirements of the
regulations. Several possible types of capacity constraints are
identified in 49 CFR Parts 27,37, and 38. These include:

-   "trip caps" (a maximum number of trips that are provided overall or
    to individual riders);

-   "wait listing" trips; or

-   patterns or practices which result in a significant number of trip
    denials, untimely pick-ups, or excessively long trips.

Capacity constraints also include other operating policies or practices
which tend to significantly limit the amount of service to persons who
are ADA Complementary Paratransit eligible.

To assess each of these potential types of capacity constraints, the
assessment focused on observations and findings regarding:

-   trip denials, trip caps, and "wait listing" of trips;

-   on-time performance; and

-   on-board travel times.

Observations and findings related to two other practices and policies
that can affect ADA Complementary Paratransit use were also developed.
These included:

-   determinations of ADA Complementary Paratransit eligibility; and

-   reservations and telephone capacity.

ADA Complementary Paratransit eligibility determinations were assessed
to ensure that potential riders were able to access the system and were
not impacted by inappropriate denials of eligibility for the service.
Reservations and telephone capacity was assessed because access to
reservations and customer service staff is a critical part of using a
ADA Complementary Paratransit service.

The assessment first involved the collection and review of key service
information prior to the on-site visit. This information included:

-   a description of how Palm Tran's ADA Complementary Paratransit
    service is structured;

-   copies of current service provider contracts, including service
    policies and practices for drivers and employees;

-   the "Rider's Guide," which details service policies to customers;

-   a description of the service standards adopted by Palm Tran related
    to telephone service, on-time performance, trip denials, and travel
    times;

-   a sample driver manifest;

-   ADA Complementary capital and operating budget; and

-   Number of ADA Complementary Paratransit trips served and denied
    during the most recent three years.

Additional information was requested to be available during the on-site
visit. This included:

-   copies of completed driver manifests for recent months;

-   six months of service data, including the number of trips requested,
    scheduled, denied, canceled, no-shows, missed trips, and trips
    provided;

-   a breakdown of trips requested, scheduled, and provided in defined
    areas served by the Palm Tran;

-   detailed information about any trips denied in the last six months
    including origin and destination information, day and time
    information, and customer information;

-   detailed information about trips in the last six months that
    exceeded the travel time standard set by the Palm Tran;

-   telephone call management records; and

-   a listing of recent customer complaints related to capacity issues
    (trip denials, on-time performance, travel time, phone access).

In addition to reviewing this data provided by Palm Tran, the assessment
team also conducted telephone interviews with five human service and
advocacy agencies and one advocate for ADA Complementary Paratransit
service users.

The on-site assessment began with an opening conference, held on Monday,
April 17 at 1:00 pm. In attendance representing Palm Tran were: Mr.
Vincent Bonvento, Assistant County Administrator for Palm Beach County;
Mr. Perry J. Maull, Executive Director Palm Tran, Mr. Dennis Dee,
Director of Paratransit Programs Palm Tran; and Ms. Karen West, ADA
Coordinator Palm Tran. FTA review team members in attendance included
Mr. Roger Peralta of FTA Office of Civil Rights, and Mr. Don Kidston,
Brian Barber, and Tim Reardon of Planners Collaborative. Ms. Cheryl
Hershey, FTA Office of Civil Rights ADA Team Leader participated by
conference call.

Ms. Hershey opened the meeting by explaining the purpose of the ADA
assessments being conducted by FTA. She noted that assessments were
being conducted across the country as part of FTA's efforts to monitor
implementation of the ADA. Ms. Hershey noted that assessments were being
conducted as cooperative reviews. Issue would be identified and
recommendations developed in an effort to work with Palm Tran to improve
services. She thanked Palm Tran staff for their assistance in providing
the information requested and with on-site visit arrangements.

Don Kidston of Planners Collaborative thanked Palm Tran for providing
information requested in advance by the review team. He then reviewed
the review team's on-site schedule.

Mr. Maull indicated that both he and Mr. Dee were new to Palm Tran. Mr.
Maull indicated that he had been with the agency for 5 months. Mr. Dee
joined Palm Tran 3 weeks before the meeting. Mr. Maull indicated that
Palm Tran is changing its method for providing ADA Complementary
Paratransit service to an approach based on that used in Broward County,
FL.

Following the opening conference, the assessment team continued to
discuss service structure and data availability with Palm Tran staff.
Most of the data that had been requested was available at the site of
Palm Tran's contractor, ATC. The team was then taken to ATC's offices
and given a tour of the ATC operations center by ATC staff. The tour
included the reservations and scheduling areas, and introductions to
administrative staff*.*

Following the tour of the operations center, the review team observed
the reservations and dispatch operation. A peak afternoon call time
(from 3:30-5:30 PM) was observed. Information was collected about the
handling of trip requests and inquiries on service*.*

The review of the reservations and trip requests handling process
continued on the morning of Tuesday, April 18. The peak morning call
time (from 7:30-10:00AM) was observed. During the mid-day the review
team interviewed staff and collected information about scheduling,
on-time performance and telephone monitoring and records. At the end of
the day, the dispatch operation for three of the carriers, RCS, TWT and
PBT, was observed

On Wednesday, April 19, the morning ADA Complementary Paratransit
pull-out and dispatch was observed at three of the carriers, AAA, RCS
and TWT. Information about available drivers and vehicles and the
ability to cover scheduled runs was collected. Procedures for
communicating last minute schedule changes and rider cancellations was
also gathered. During the mid-day, the review team gathered and reviewed
information about on-time performance and trip duration from ACT records
and driver manifests. The team also reviewed eligibility records and
customer complaint procedures.

On Thursday morning, the review team tabulated and organized data in
preparation for the exit conference.

The exit conference was held at 1:00 pm on Thursday, April 20. In
attendance representing Palm Tran were: Mr. Perry J. Maull, Executive
Director, Mr. Dennis Dee, Director of Paratransit Programrs; Mr. Dennis
Krajec, Office of Management and Budget*.* FTA review team members in
attendance included Mr. Don Kidston, Brian Barber and Tim Reardon of
Planners Collaborative. Mr. Roger Peralta of FTA Office of Civil Rights
participated in the opening of the meeting. Ms. Cheryl Hershey, FTA
Office of Civil Rights ADA Team Leader participated by conference call.

Preliminary findings were presented by the assessment team and these
findings were discussed with Palm Tran staff. It was explained that a
draft report would be prepared and forwarded to Palm Tran for review.
FTA would then work with Palm Tran to resolve any issues raised in the
report.

Subsequent to the Palm Tran site visit a report was drafted. On
September 19, FTA transmitted the draft report to Palm Tran for review
and identification of corrective actions. On November 7 Palm Tran
provided its response to the report. A copy of the response appears in
Attachment 5 of this report.

# Observations Regarding ADA Complementary Paratransit Eligibility Determination

The process used to determine ADA Complementary Paratransit eligibility
was reviewed to assess whether determinations were being made in a
timely way and to assess whether determinations appeared to accurately
reflect the functional abilities of applicants. The process was assessed
as follows:

-   An understanding of the handling and review of applications was
    developed through a review of records;

-   Issues with the current process were identified from interviews with
    riders and recent applicants;

-   Accuracy of determinations was assessed by reviewing recent
    decisions and overall process outcomes;

-   The timely processing of applications was assessed by comparing the
    dates on determination letter to the dates of receipt for several
    randomly selected applications.

## Overview of the Eligibility Determination Process and Materials

It is Palm Tran's policy to offer ADA Complementary Paratransit Service
eligibility to people who are travelling between points within 3/4 miles
of Palm Tran's regular fixed routes and who are unable to:

-   travel from the starting point of their trip to the nearest Palm
    Tran bus stop,

-   locate the bus stop,

-   identify the correct Palm Tran bus to board,

-   board the bus, or

-   ride the bus while sitting in a seat or while being properly secured
    in a mobility device.

-   Travel from the Palm Tran bus stop to their final destination

Palm Tran's policy is further described in the SpecTran Paratransit
Rider's Guide, Attacment 1.

Palm Tran instituted a new eligibility review procedure in February
2000. In accordance with the new procedure, the ADA Complementary
Paratransit eligibility determination process is overseen by Palm Tran's
Eligibility Coordinator. This person is responsible for reviewing
applicants and making a determination of eligibility. Palm Tran
contracts with Gulfstream Goodwill Industries to provide functional
assessments, as needed.

The Eligibility Coordinator is also responsible for making
determinations on applicant eligibility for Florida's Transportation
Disadvantaged (TD) Program. The TD Program provides transit service to
people who are elderly or have low incomes as well as people who have
disabilities. Unlike ADA Complementary Paratransit Service, TD service
is provided throughout Palm Beach County, including areas outside of
Palm Tran's fixed route service area. TD service may be limited by trip
purpose with some trip purposes receiving priority over others. ADA
Complementary Paratransit Service may not be restricted by trip purpose
(49 CFR ss 37.131(d).

The processing of SpecTran service applications is conducted as follows:

1)  Individuals seeking certification to use the service call the
    SpecTran office and are scheduled for an interview with SpecTran
    staff. Interviews are scheduled, usually within a few days of the
    call, at Gulfstream Goodwill Industries at 1715 Tiffany Drive, E. in
    West Palm Beach. In some cases, when eligibility is clearly
    indicated, provision is made with residential or day-program
    facility managers for off-site eligibility determinations. If the
    applicant needs SpecTran service to travel to the interview,
    SpecTran staff schedules the service for the applicant.

2)  The applicant is sent a form letter, confirming the eligibility
    determination appointment time and location; confirmation of
    SpecTran service to the appointment or a Palm Tran bus pass or
    directions by automobile. The applicant's SpecTran trip is scheduled
    to accomodate a Personal Care Attendant, mobility aid, or service
    animal if applicable.

3)  Enclosed with the form letter are a brochure containing eligibility
    information; and an Eligibility Application. Copies of these
    documents appear in Attachment 2. Applicants are encouraged to bring
    to the appointment documentation which may assist the interviewer in
    making the eligibility determination, such as information from a
    licensed medical professional explaining how the applicant's
    condition effects his ability to use transit service. TD applicants
    are asked to bring financial documentation.

4)  The application form used by Palm Tran is twelve pages long. The
    application is divided into seven sections:

> I: Identifying Information (address, etc.)
>
> II: Nature of limitations in using fixed route service
>
> III: Applicant's mobility aids and assistance needs
>
> IV: Functional Abilities
>
> V: Current Travel Characteristics (trip origin, destination, mode of
> travel and route)
>
> VI: Additional Information (professionals who can provide additional
> information)
>
> VII: Certification (applicant's signature)
>
> A copy of the SpecTran application form is provided in Attachment 2.
> Applicants are advised in advance of the interview that the SpecTran
> Eligibility Specialist will assist them in completing the application
> during the interview.

5)  At the eligibility interview the SpecTran Eligibility Specialist
    assists the applicant in completing the application, or reviews the
    application if completed in advance and interviews the applicant.
    The specialist also takes a photograph for the applicant's picture
    ID. At the conclusion of the interview the Specialist makes a
    determination that the applicant is eligible for service or refers
    the applicant for a functional assessment.

6)  Functional assessments are performed by Gulfstream Goodwill
    Industries on the same day and at the same location as the
    eligibility interview. The functional assessment consists of two
    parts, a physical evaluation and a cognitive assessment. The
    physical evaluation measures balance, strength, coordination, and
    range of motion. The cognitive functional assessment consists of
    standardized tests to measure skills such as memory, attention span,
    and route finding ability.

7)  SpecTran staff makes a determination of eligibility and, by letter,
    notifies the applicant of the determination within three weeks of
    the eligibility interview. An applicant is notified that he or she
    is unconditionally eligible, conditionally eligible, or ineligible
    for service. A SpecTran photo ID card is included with the letter
    notifying applicants of either unconditional or conditional
    eligiblity.

8)  If an applicant is determined to be ineligible for ADA Complementary
    Paratransit services, their notification letter cites the basis for
    the determination and notifies the applicant of their rights to
    appeal the determination. A copy of the Palm Trans appeal procedures
    are included with the letter. A copy of both the letter and the
    appeal procedures appears in Attachment 2.

9)  Palm Tran's appeals process is summarized as follows:

-   The applicant must file an appeal in writing within 60 days of Palm
    Tran's eligibility determination.

-   Palm Tran's ADA Coordinator reviews the appeal and either upholds or
    reverses the initial determination.

-   If the coordinator upholds the initial decision a hearing is
    scheduled before the Palm Tran Paratransit Appeals Board. The Board
    consists of a Palm Tran rider, a SpecTran rider, a professional
    familiar with the disability of the applicant, an uninvolved Palm
    Tran employee, and an uninvolved Palm Beach County employee.

-   At the appeal hearing the appellant may present his/her position to
    the appeals board, provide additional information, and may be
    accompanied by one advocate who can either represent the appellant
    or provide additional information. Palm Tran may present its
    position and board members may ask questions of either party.

-   The appeals board makes its decision within 30 days of the hearing
    and notifies the appellant by certified mail.

Prior to expiration of a customers ADA Complementary Paratransit
eligibility, SpecTran Representatives telephone customers to schedule an
appointment for a recertification interview. The procedure for
recertification is the same as the procedure for initial certification.
SpecTran has recently initiated a new comprehensive eligibility
procedure which is currently being used for all certifications.

## 

## Consumer Comments

Consumer representatives who were interviewed generally cited no
problems with the eligibility process. One person interviewed described
the process as good and the application form now being used as an
improvement over the previous form. One interviewee indicated that a
travel trainer would be helpful. Two of the six people interviewed
commented on a recent change to the service ADA service area. In past
years, SpecTran had accepted some ADA Complementary Paratransit trips
beginning and/or ending outside of the ADA Complementary Paratransit
service area. Beginning April 1, 2000, SpecTran began limiting ADA
Complementary Paratransit service to the service area. Since ADA
Complementary Paratransit eligible customers are also be eligible for
Florida TD service, concern was raised that certified ADA Complementary
Paratransit customers may not be certified as eligible for TD services
and were not provided sufficient time to obtain TD eligibility before
the April 1^st^ date. One commentor expressed concern that the change in
service area was made with only 10 days notice. Since the service area
as defined by Palm Tran and discussed with the commentors appears to
conform to the regulatory service criteria (49 CFR ss 37.131 (a)), the
assessment team took no further action to address this concern.

## Observations Regarding ADA Complementary Paratransit Eligibility Determination

### Procedures

SpecTran's policies and procedures for determining eligibility of ADA
Complementary Paratransit applicants appear to be quite complete and
effective with one possible exception. The SpecTran Paratransit Rider's
Guide (Attachment 1, pps. 20, 21) places limitations on travel on
SpecTran services, including a requirement that children under the age
of 14 are required to travel with a parent or guardian. Interviews with
Palm Tran staff indicated that no such limitations were placed on travel
on fixed route Palm Tran Service. Subsection 37.121 (a) of 49 CFR
Subtitle A provides that "...each public entity operating a fixed route
system shall provide ADA Complementary Paratransit... service to
individuals with disabilities that is comparable to the level of service
provided to individuals without disabilities who used the fixed route
system." SpecTran's service limitations, as cited in the Rider's Guide,
might be construed as providing a service level that is not comparable
to that provided on the fixed route system.

Also while on site the assessment team observed SpecTran staff making
calls to customers to schedule interviews for recertification.

### Eligibility Determinations

Since institution of new eligibility procedures SpecTran has denied
eligibility to SpecTran ADA Complementary Paratransit services to nine
applicants. Each of the denied applications were reviewed by the Palm
Tran ADA Coordinator and the Gulfstream Goodwill Industries
representative. Each applicant underwent a physical evaluation and a
standardized cognitive evaluation. The reason for the denials was a
determination that each of the applicants could use a fixed route bus.
None of the nine applicants has requested an appeal of the
determination. The documentation for two of the denials did not fully
explain the reasons for the determination. In one instance an applicant
was unable to ascend stairs without support from railings on both sides.
It was unclear from review of the documentation as to whether this
condition would prevent the individual from travelling to or from a
boarding location in accordance with ADA Complementary Paratransit
eligibility standards (subsection 37.123 (e)(3) of 49 CFR Subtitle A).

In a second case the applicant had a variable condition which affected
his ability to walk at certain times. It was unclear from review of the
documentation as to whether this condition would prevent the individual
from travelling on fixed route service at certain times. If so such a
condition at those times may be a variable disability as described in
the ADA Complementary Paratransit eligibility standards (subsection
37.123 (c) of 49 CFR Subtitle A).

### Review of Application Processing Records

Applicant records are kept in one location in the SpecTran office.
Records for eligible SpecTran riders are filed in alphabetical order in
three file cabinets. Palm Tran's current eligibility process has been
recently implemented. As a result the records available on file were
from early February to the date of the on-site review. Records for
eligibility denials and appeals were located in a separate file cabinet.

A review of the records indicates that the normal practice is for an
applicant to make a reservation for an interview and complete the
application with the assistance of Palm Tran staff at the interview. It
appeared that interviews were usually scheduled within one week of the
initial communication between the ADA Complementary Paratransit service
candidate and SpecTran staff.

To check the timing of application processing the assessment team
reviewed 23 rider files and recorded the time from completion of the
application to Palm Tran's issuance of the letter certifying the
applicant's eligibility for SpecTran service. The applications were
randomly selected from SpecTran's alphabetical rider files.
Approximately 2 applications were taken from each of approximately 12
file drawers. All applications were initiated subsequent to
implementation of SpecTran's new eligibility procedures in February
2000. Application dates ranged from February 2 to April 14, 2000.
Results of the review are presented in Table 1.

The result of this review was that the time for processing applications
ranged from 1 to 20 days with an average time of 6 days and a median of
only 3 days. The date of the application and determination letters were
the same for 14 of the 23 records indicating that most applications were
completed with the assistance of SpecTran staff. Combining the interview
with completion of the application appears to contribute to a short
review period.

Section 37.125 (c) of 49 CFR Subtitle A establishes a standard of 21
days for making a determination of eligibility from the date of
submittal of a completed application. If the service provider fails to
act on the application within the 21 day period, the applicant is to be
considered eligible for ADA Complementary Paratransit service until the
application for service is denied. For the applications reviewed, the
application process exceeded the 21 day period in one instance. In that
case the application was submitted in two parts, with information from
the applicant's physician submitted subsequent to the initial submittal.
This two part submittal may have delayed scheduling of the interview,
and contributed to an extended review. This applicant was determined to
be eligible for ADA Complementary Paratransit service.

#### Table 1: Certification Performance

  -------------- --------------- -------------- ----------------- -----------------
  **Record**     **Application   **Interview    **Certification   **Certification
                 Date**          Date**         Date**            Period (days)**

  1              March 21        March 21       March 23          2

  2              March 21        March 28       March 29          8

  3              March 24        March 24       March 27          3

  4              March 20        March 23       March 28          8

  5              March 27        March 27       March 28          1

  6              March 23        March 23       March 28          5

  7              March 29        N/A            March 31          2

  8              February 29     February 29    March 2           2

  9              February 9      February 16    February 29       20

  10             February 14     February 15    February 17       3

  11             N/A             February 17    February 18       N/A

  12             February 14     March 14       March 17          32

  13             March 31        March 31       April 7           7

  14             March 31        March 31       April 7           7

  15             March 31        March 31       April 7           7

  16             March 1         March 1        March 3           2

  17             March 6         March 6        March 7           1

  18             March 28        March 28       March 29          1

  19             April 3         April 3        April 4           1

  20             March 16        March 24       March 27          11

  21             March 4         March 6        March 7           3

  22             March 13        March 13       March 15          2

  23             March 21        March 21       March 23          2

  Mean                                                            5.9

  Mode                                                            3
  -------------- --------------- -------------- ----------------- -----------------

## Findings

1)  SpecTran's process for making eligibility determinations appears to
    be well organized, consumer oriented, and structured to provide
    expeditious ADA Complementary Paratransit eligibility
    determinations. Providing customer assistance in completion of the
    application, taking photos for IDs, and scheduling same-day
    functional assessments, all during the interview process allows
    customers to complete the application process with one visit to
    SpecTran/Goodwill Offices. This approach appears to both facilitate
    the process for the applicant and expedite SpecTran's review of the
    application.

2)  Access to SpecTran service does not appear to be limited by adverse
    eligibility determinations.

3)  The SpecTran Paratransit Rider's Guide (Attachment A, pps. 20, 21)
    places limitations on travel on SpecTran services, including a
    requirement that children under the age of 14 must travel with a
    parent or guardian. The service limitations cited in the Rider's
    Guide might be construed as providing service not comparable to that
    provided on fixed route system.

4)  The documentation for two of the denials of ADA Complementary
    Paratransit eligibility did not fully explain the reasons for the
    determination. In one instance an applicant was unable to ascend
    stairs without support from railings on both sides. It was unclear
    from review of the documentation as to whether this condition would
    prevent the individual from travelling to or from a boarding
    location in accordance with ADA Complementary Paratransit
    eligibility standards (subsection 37.123 (e)(3) of 49 CFR Subtitle
    A). In a second case the applicant had a variable condition which
    affected his ability to walk at certain times. It was unclear from
    review of the documentation as to whether this condition would
    prevent the individual from travelling on fixed route service at
    certain times. If so such a condition at those times may be a
    variable disability as described in the ADA Complementary
    Paratransit eligibility standards (subsection 37.123 (c) of 49 CFR
    Subtitle A).

5)  Applications for ADA Complementary Paratransit service appear to be
    processed expeditiously with 21 of 22 applications processed in less
    than 21 days with a mean time of 5.9 days and a mode of 3 days to
    make an eligibility determination.

## Recommendations

1)  SpecTran should review age limitations for SpecTran services to
    assure that service levels provided on SpecTran riders are
    comparable to those provided on the fixed route system.

2)  SpecTran should review its method of ADA Complementary Paratransit
    application review to assure that an individual's ability to travel
    to or from a boarding location, and/or variable disabilities are
    properly addressed in making eligibility determinations in
    accordance with ADA Complementary Paratransit standards.

3)  SpecTran should clearly document the reasons for eligibility
    denials, particularly when an accessible travel path or variable
    disability may be considerations.

# Observations Regarding Telephone Capacity and the Reservation Process 

The ability of customers to access the trip reservations process and
have requests handled in an accurate way was assessed in the following
way:

-   Input from customers and advocates was obtained through interviews
    and through a review of the SpecTran complaint/comment records;

-   The performance standard established by SpecTran for handling
    telephone calls was reviewed;

-   The reservations process was observed at various times, including
    the peak afternoon and morning times on Monday, April 17 from 3:30
    to 5:30 PM and Tuesday, April 18 from 7:30 to 10:00 AM.

## Overview of the Phone System and Reservation Process and Staffing

Telephone reservations are taken by Palm Tran's contractor, ATC, at
their offices at 3040 Military Trail in Lake Worth.

ATC's office has approximately 28 telephone workstations. Workstations
can generally be used for any activity, but their formal assignments are
as follows:

-   Reservations: 10

-   Customer Service: 4

-   Medicaid: 4

-   Data Entry: 3

-   Proactive: 2

-   Complaints: 2

-   Unassigned: 2

-   Supervisor: 1

Telephone capacity is monitored by ATC through an automated telephone
management and monitoring system. The monitoring system produces daily
summary reports that record the number of incoming calls, the number of
abandoned calls, the average talk time, average hold time, average
abandonment time, and call wait time performance, among other
information.

There are 19 staff members assigned to call intake, reservation and
customer service. Telephone monitoring records indicate that the number
of reservation and customer service agents logged on to the system and
available to answer calls at any one time ranges from 4 to 12, with the
largest numbers of agents logged on during peak periods. This number
does not include complaint agents, a receptionist, or supervisors. All
staff members are cross-trained to accept customer service, SpecTran,
and Medicaid calls, although they do have priority assignments during
their shift. Two staff members at the 'proactive' desk focus on
resolving ride check inquiries and addressing same-day service requests.

Palm Tran publishes a single phone number for SpecTran reservations,
ride checks, and complaints. Reservations are accepted from 7:00 AM to
5:00 PM, seven days a week. Reservations are accepted from 14 days in
advance of the requested trip up to 5:00 PM on the day preceding the
trip. Telephone records indicate that reservations and customer service
receive an average of 1,280 calls during an average weekday.

Incoming callers are routed to a recorded menu of five choices:

-   Report a late vehicle or confirm a trip

-   Medicaid reservations and eligibility

-   All other trips

-   Bus pass

-   Complaints and commendations

## Consumer Comments

Six consumer representatives identified no problems with using the
SpecTran telephone system for making trip reservations during interviews
with the assessment team before the site visit. However 4 of the 6
representatives interviewed problems in getting information during calls
to check on rides. Four cited long hold times; one mentioned 40 minute
hold times, another 45 minutes. One consumer noted that hold times were
longest during peak service periods. Two of those interviewed indicated
that they received a stock answer that 'the vehicle will be there in 15
minutes' in response to ride checks. Two of the interviewees encountered
unresponsiveness and rudeness in response to ride checks.

## SpecTran Telephone Performance Standard

In a letter to the review team dated April 3, 2000 which provided
service standard information, SpecTran described its telephone
performance standard as follows:

> "Telephone standards, which must be met 95 % of the time, include:

2.  calls do not ring busy and

3.  calls are not on hold awaiting assistance for more than three
    minutes. (*Invitation for Bid, IFB #99-089R/PP, Section VIII.
    G.1.2., pg.43: Telephone System*.)"

The referenced section of the Invitation for Bid (IFB) was revised by
amendment number 4 to delete the requirement that "calls do not ring
busy." However the requirement was not deleted from Section XVII. A. 5.
A. of the IFB. Section XVII addresses performance standards. The
assessment team reviewed SpecTran's contract with ATC and found no
telephone performance standard.

## Observations of the Trip Reservation Process

The ADA review team observed 113 incoming calls during the site visit.

Reservations agents accept all trip requests by entering trip
information directly into a computerized scheduling program as open
trips. No trips are denied or "wait-listed." Pertinent information for
eligible, enrolled clients is maintained in a client record; agents
develop a new trip record for each requested round trip. Information
requested by agents includes the following: date of trip; origin,
destination, purpose of trip, requested pick-up time or appointment
time, ambulatory status, accompanying riders, and return time. It was
generally observed that reservation agents confirmed the most important
information by reading it back to the client prior to ending the phone
call.

Reservation agents were also observed making notes within the trip
record as to the date the reservation was made, the pickup window stated
to the client, and the initials of the reservation agent.

If the client asks to be dropped off at his or her destination at a
specific time, the computer program will calculate a pickup time
(generally around 45 minutes to one hour prior to the appointment), and
the reservation agent will provide the client with a pickup window 15
minutes to either side of that time.

Trip origins and destinations were automatically geocoded by the
computer program. Some difficulties with geocoding were observed if the
reservation agent did not have the zip code of the destination or did
not enter the address in a format recognized by the program.
Reservationists were generally aware of many of these problems. When an
incorrectly geocoded location was encountered by reservationists they
were observed notifying their supervisor, and proceeding to schedule the
trip. ATC staff indicated that geocoding errors were reported to an ATC
programmer for correction.

The return trips for clients travelling to a doctor's appointment or
similar appointment were generally scheduled as a "will call," meaning
that the client should call the service provider to schedule a return
trip once his business is complete.

The calls observed by purpose of the call are summarized in Table 2.

#### Table 2: Summary of Call Monitoring

  ------------------------------------------------------ ----------------
  **Reason for Call**                                    **\# of Calls**

  Placing a new trip reservation (ADA)                   31

  Placing a new trip reservation (Medicaid, TD, DOSS)    22

  Change or cancel an existing reservation (ADA)         11

  Change or cancel an existing reservation (Medicaid,    2
  TD, DOSS)                                              

  Verify/confirm an existing reservation (ADA)           11

  Verify/confirm an existing reservation (Medicaid, TD,  0
  DOSS)                                                  

  Where's my Ride? (ADA)                                 22

  Where's my Ride? (Medicaid, TD, DOSS)                  7

  General/Eligibility/Other                              6

  Complaint                                              1

  **TOTAL CALLS MONITORED**                              **113**
  ------------------------------------------------------ ----------------

The automated telephone management and monitoring system used by ATC
produces a number of reports. In addition to daily summary reports, the
system produces cumulative hourly reports that summarize total call
activity (incoming calls, answered calls, abandoned calls, average hold
time, and average abandonment time) by hour of day for periods of up to
a month. The monitoring system also displays the current number of
active agents, the current number of callers on hold, and the current
longest hold time. This information is updated every five seconds and is
recorded manually by complaint agents on the half hour.

The assessment team reviewed SpecTran's telephone reports for the period
from Friday April 7 through Tuesday April 18. These reports are
summarized in tables *a, y, and z.* During the hours reservations are
accepted (7:00 AM to 5:00 PM) the hourly average of incoming calls
ranges from approximately 35 between 7:00 and 8:00 AM to 80 between 9:00
and 10:00 AM.

For this same period the average daily hold times during reservation
hours ranges from 85 seconds between 2:00 and 3:00 PM to 2:25 seconds
between 7:00 and 8:00 AM. A review of the telephone records for this
same period indicated that 12 % of the time calls wait on hold for more
than 3 minutes. This is 7 % more calls on hold for more than 3 minutes
than Palm Tran's standard. Additionally, 3 % of calls wait on hold for
more than 5 minutes. During the observations of the telephone
reservations some reservation agents were observed answering one call
before completing entry of information for the previous call. Callers
were asked to wait a minute or more while the reservation agent
completed data entry or notes associated with the previous call. This
practice may result in understating the actual hold times appearing in
ATC's reports since the hold time after the call has been answered is
not reflected in the reports. Additionally, avoiding an interruption by
completing all actions on one call before addressing a second call
should be more efficient and reduce potential for distraction and error.

During the period April 7 through April 18^th^, the average hourly
percentage of calls abandoned between 7:00 AM and 5:00 PM ranged from 4
% between 1:00 and 2:00 PM to 16 % between 7:00 and 8:00 AM. Overall, 8%
of calls are abandoned after average hold times of approximately 90
seconds.

## Ride Checks

When customers call to check their rides, the telephone staff checks
with the carrier to determine the status of the ride. ATC telephone
staff will first refer to a flip chart in the ATC office to see if the
particular carrier's rides are running late, and if so by how much. If
the information appears on the chart it is reported to the customer.
This may be in the form that rides are running about 15 minutes late,
or, if there has been an incident such as an accident or traffic tie up,
that information will be reported to the customer. If there is no
applicable note on the flip chart, the telephone staff calls the
carrier's dispatcher by a direct cell phone line. The dispatcher in turn
contacts the driver and responds with the expected pick-up time. The
telephone staff then advises the customer. During the site visit the
assessment team observed a response time for ride checks of from 5 to 15
minutes. Some telephone staff noted that the carrier's dispatchers
seemed unusually responsive while we were visiting and noted that on
some occasions the dispatchers do not respond to their calls.

## Findings

1)  ADA Complementary Paratransit customers' ability to reserve rides
    through SpecTran's Telephone system as operated by ATC does not
    appear to limit access to service. The assessment team observed no
    denials or "wait listing' of trip requests.

2)  According to ATC records for the period April 7 to April 18, hold
    times for incoming calls exceeded three minutes approximately 12 %
    of the time. The incidence of long hold times is more than double
    Palm Tran's standard of 5 %. Overall, 8 % of calls were abandoned
    after average hold times of 90 seconds. Between 7:00 AM and 8:00 AM,
    16 % of calls were abandoned.

3)  Telephone staff were observed responding to calls and placing the
    caller on hold, de facto, by asking them to wait while conducting
    other business. As a result the reported hold times understate the
    period the customer spends waiting for service from telephone staff.

4)  Some trip origins or destinations were incorrectly identified as
    being out of the service area due to errors in the GIS component of
    the reservations/scheduling software. Telephone staff identified
    these problems and scheduled the requested trips. ATC staff
    indicated that corrections to the GIS coding are being addressed.

5)  Responses to ride checks appeared to be reasonable during the
    on-site observations by the assessment team. However, consumer
    representatives indicated that responses to ride checks could take
    as much as 45 minutes. Telephone staff also noted that they were
    receiving faster responses on ride checks from dispatchers during
    the assessment team's visit than normal.

## Recommendations

1)  Palm Trans should work with ATC to reduce hold times. Additional
    telephone staffing should be considered, particularly at the
    beginning and end of the work day, as a means of reducing hold times
    and abandoned calls.

2)  ATC telephone staff should be instructed to complete one call,
    including associated activity, before beginning the next call. Doing
    so could reduce the potential for distraction and error, and produce
    automated reports which more accurately reflect the time customers
    spend waiting for telephone service.

3)  ATC staff should continue to correct GIS errors
    reservations/scheduling software.

4)  Palm Trans and ATC should consider assigning one Palm Tran or ATC
    staff person to coordinate ride status and schedule changes on a
    real time basis with the dispatchers for the four carriers. Such
    real time coordination could improve response times on ride check
    calls by making current field information available to telephone
    staff on a timely basis. The staff person could also improve
    schedule coordination between ATC and the service providers.

# Observations Regarding On-Time Performance, Service Capacity, and Scheduling

Information about on time performance,service capacity, and scheduling
was developed as follows:

-   Palm Tran policies and procedures for on-time performance were
    reviewed;

-   Observations about service availability were obtained from consumer
    representatives through telephone interviews;

-   SpecTran on-time performance reports were reviewed;

-   Carrier dispatch operations were reviewed;

-   Carrier personnel and fleet capacity was reviewed;

-   Ridership and budget information for recent years was reviewed; and

-   Trip scheduling procedures and information were reviewed.

## Palm Tran On-Time Performance Standard

As stated in an April 3, 2000 letter to Planners Collaborative, Palm
Tran's standard for on-time performance is as follows:

-   A vehicle is considered "on-time" if it arrives within 15 minutes of
    the **scheduled** pick-up time as shown on the vehicle
    manifest/schedule.

-   Palm Tran has established a goal of being on-time 90 % of the time.

Drop-off time is not considered in the determination of on-time
performance. Also the on-time performance standard is determined based
on the scheduled time rather than on the pick-up time negotiated with
customers.

The Palm Tran contracts with its three service operators incorporate
Palm Tran's Invitation for Bids (IFB) into the contracts. Section A of
Article XVII of the IFB as amended by Amendment number 4 establishes an
on time pick-up window of within 10 minutes of the **scheduled** pick-up
time as shown on the vehicle manifest/schedule. The IFB also provides an
incentive payment of 2 % of the invoice value for on-time performance of
95 % or greater. Failure to achieve 90 % on-time performance for three
consecutive months can result in breach of contract. Palm Tran staff
indicated that the 15 minute pick-up window, as cited in their letter,
is the standard being used to measure on-time performance.

Sections XVII.A.1.f. and B.2. of the IFB establishes a standard of 1 %
for missed trips. For this purpose, a missed trip is defined as a
vehicle arrival more than 60 minutes after the close of the pick-up
window scheduled on the vehicle manifest. Failure to achieve the
standard for missed trips for three consecutive months can result in
breach of contract.

According to ATC schedulers information appearing on the manifest
includes both a 30 minute pick-up window and a scheduled pick-up time.
The 30 minute pick-up window is the period from 15 minutes before to 15
minutes after the pick-up time negotiated with the customer. The
scheduled pick-up time is the time the driver is scheduled to pick-up
the customer. For the purpose of developing efficient driver manifests
it is the practice of the scheduler to vary the scheduled pick-up from
the negotiated pick-up time by no more than 15 minutes, within the
pick-up window.

## Consumer/Advocate Interviews

Of the six consumer representatives interviewed, four identified
problems with vehicle no-shows and three cited problems with late
pick-ups. One person said pick-ups were as much as two and one half
hours late and another had observed a pick-up that was four hours late.
Two of those interviewed had observed vehicles showing up in the wrong
location. Two people indicated that customers were encouraged to board
the vehicle before the beginning of the scheduled pick-up window.

Five of the six people interviewed cited schedule or information
problems as contributing to late or missed service. Three people
indicated that schedules were changed without notice to the customer.
Two people indicated that customers were sometimes counted as no-shows
when the vehicle did not arrive within the pick-up window and 1 person
indicated that incorrectly reported no-shows have had their return trip
cancelled. One person indicated that several vehicles have been
scheduled to serve the same trip. One of those interviewed indicated
that changes for subscription trips often resulted in schedule errors
that lasted over a period of time.

## Observations Regarding On-Time Performance and Missed Trips

### Data Analysis

Palm Tran provided summary performance data for the period October 1999
through January 2000. Palm Tran's data tracking does not differentiate
between Customer no-shows and trips not provided by the carrier. As a
result, the summary data presented in Table 3 provides no explicit
information on trips missed by the service provider but instead includes
both trips missed by the service provider, "vehicle no-shows," and
customer no shows in the category called "no shows." For the period
October 1999 through January 2000 approximately 6% of trips scheduled,
as adjusted for cancellations, were carrier or customer no shows.

#### Table 3: Historic Trip Data

  ----------- --------- ---------- ---------- --------- --------- ----------- -----------
              October   November   December   January   Total     \% of       \% of
              1999      1999       1999       2000                Requested   Adjusted
                                                                  Trips       Trips
                                                                              Scheduled

  Trips       29,990    28,743     28,894     28,555    116,182               
  Requested                                                                   

  Trips       0         0          0          0         0                     
  Denied                                                                      

  Trips       4,689     4,875      4,889      3,515     17,968    15%         
  Cancelled                                                                   

  Trips       25,301    23,868     24,005     25,040    98,214    85%         100%
  Scheduled                                                                   

  No Shows    2,108     1,394      1,366      1,101     5,969     5%          6%

  Missed      N/A       N/A        N/A        N/A       N/A       N/A         N/A
  Trips by                                                                    
  Carrier                                                                     

  Trips       23,193    22,474     22,639     23,939    92,245    79%         94%
  Provided                                                                    
  ----------- --------- ---------- ---------- --------- --------- ----------- -----------

### ATC Data

ATC provided the assessment team with their data file for service
performance for the period Monday, March 20 through Saturday, March 25.
The data file included scheduled and actual pick-up times for each
completed passenger trip for each day in the time period. Trips were
grouped by carrier and included one group of unassigned trips. According
to ATC staff, the unassigned trips were trips that were cancelled by the
customer. Trips which were not completed were not included in ATC's data
file.

#### Table 4: On-Time Performance---Completed Trips Only

  ---------------- ------------- -------- -------- --------- --------- ---------
                   **Carrier**                                         

                   AAA           PBT      TW       RCS       WC        TOTALS

  **Number of                                                          
  Trips**                                                              

  Early trips      276           4        143      89        0         512

  On Time          1653          324      1290     523       76        3866

  Late Trips       268           6        138      43        0         455

  Missed Trips     29            1        1        1         0         32

  Unknown                        138                                   138

  **Total          2226          473      1572     656       76        5003
  Observations**                                                       

                                                                       

  **Percentage of                                                      
  Trips**                                                              

  Early trips      12.4%         0.8%     9.1%     13.6%     0.0%      10.2%

  On Time          74.3%         68.5%    82.1%    79.7%     100.0%    77.3%

  Late Trips       12.0%         1.3%     8.8%     6.6%      0.0%      9.1%

  Missed Trips     1.3%          0.2%     0.1%     0.2%      0.0%      0.6%

  Unknown                        29.2%                                 2.8%

  **Total          100.0%        100.0%   100.0%   100.0%    100.0%    100.0%
  Observations**                                                       
  ---------------- ------------- -------- -------- --------- --------- ---------

According to the ATC data of the completed trips, passengers were picked
up either early or on time 87.5 % of the time. Passengers were picked up
more than 15 minutes after the agreed upon pick-up time 9.7 % of the
time including 0.6 % of the passengers who were picked up more than 75
minutes after the agreed upon pick up time. Requested pick-up times were
not available for 29 % of the trips served by PBT.

The ATC reports included a number of trips which had been requested but
were not assigned to a carrier and were not completed. Adding these
requested trips to the completed trips produced the information
appearing in Table 5.

#### Table 5: On-Time Performance---All Scheduled Trips

  --------------------------------------- --------------- ---------------
                                          **Trips**       **%**

  Early trips                             512             10.1%

  On Time                                 3,866           76.4%

  Late Trips                              455             9.0%

  Missed Trips                            32              0.6%

  Trips Not Completed                     195             3.9%

  **Total Observations**                  5,060           100.0%
  --------------------------------------- --------------- ---------------

According to ATC staff the trips not completed category represents trips
cancelled by customers. The 3.9% figure in the above table is
inconsistent with the 15 % cancelled trips in Palm Tran's monthly
reports cited above. Assessment team requests to ATC for data on
requested trips not completed by the carrier were unsuccessful. The only
information provided by Palm Trans on trips not performed by the carrier
is the 6 % in the monthly reports which ATC staff indicated includes
both carrier missed trips and customer no-shows.

Consumer complaints as summarized in Attachment 3, were reviewed for the
month of March. Of 378 complaints deemed to be valid by ATC, 332 (88 %),
were for late vehicles or missed trips. This represents a valid late or
missed trip complaint for approximately 1 of every 100 completed trips.
204 (54%) complaints were for late pick-ups and 128 (34 %) were for
missed trips. The distribution of late or missed complaints by carrier
is presented in the following table.

#### Table 6: Late and No-Show complaints deemed valid by ATC

  ------------ --------- --------- --------- ------------ ------------- -------------
  Carrier      Late      Vehicle   Total     Percentage   Estimated     Complaints as
               Vehicle   No Show   Late or   of Total     Trip          Percentage of
                                   Missed    Complaints   Assignments   Assigned
                                   Trips                                Trips

  AAA          49        40        89        27%          11,250        .8%

  RC Services  10        2         12        4%           3,500         .3%

  Two Wheels   15        1         16        5%           8,250         .2%

  PBT          129       84        137       42%          2,000         6.8%.

  Total        203       127       330       N/A          25,000        1.3%

  Percentage   62%       38%       100%      N/A          N/A           N/A
  ------------ --------- --------- --------- ------------ ------------- -------------

The estimated trip assignment for each carrier is based on an assumption
of 25,000 completed trips per month as indicated in Palm Tran's monthly
reports and the distribution of completed trips among carriers based on
ATC's performance data base. The distribution is AAA 45%, RC Services 14
%, Two Wheels 33% and PBT 8 %. Trips assigned PBT accounted for a
significantly higher proportion of late and missed trip complaints than
the other carriers. Complaints were also measurably higher for AAA than
RC Services and Two Wheels.

It should be noted that for every 1.6 complaints for late service there
was 1 complaint for a vehicle no show.

### Observations of Dispatch

Dispatch of vehicles were observed by the assessment team on the
afternoon of Tuesday, April 18 and the morning of Wednesday April 19. On
Tuesday afternoon team members observed dispatch at R.C. Services, Palm
Beach Transportation, and Two Wheels Transportation. On Thursday morning
the team observed dispatch at AAA, R.C. Services, and Palm Beach
Transportation.

R. C. Services normally has 2 dispatchers on duty. One dispatches
drivers and the second does paper work. During the assessment team's
site visit only one dispatcher was on duty but appeared to have no
problems dispatching vehicles and responding to telephone calls. Two
Wheels Transportation employs three dispatchers with one on duty at a
time. During field observations the dispatcher appeared to have no
problems handling dispatch.

Observations included tracking of a sampling of trips. This was
accomplished by recording actual pick-up times as relayed by the
dispatchers onto copies of driver manifests. The result of this effort
resulted in observations of 43 trips. Of the trips observed 88.4% were
early or on time and 11.6% of the trips were late. On one of the late
trips, the customer abandoned the trip when the vehicle failed to arrive
within fifteen minutes of the scheduled pick-up time and on one on-time
trip, a customer did not show up. In general the dispatch observations
are consistent with the monthly reports and ATC data.

#### Table 7: Summary of Dispatch Observations

  ------------- --------- -------------- ---------- ------- ---------- ---------- --------- ----------
  Carrier       Date      Observations   Early      On Time Late Trips Missed     Service   Customer
                                         Trips              (15-75     Trips      No Show   No Show
                                         (\>15              minutes)   (\>75                
                                         minutes)                      minutes)             

                                                                                            

  AAA           4/18/00   8              0          5       3          0          1         0

                                                                                            

  RCS           4/17/00   12             0          11      1          0          0         0

                4/18/00   22             4          17      1          0          0         1

  *RCS Total*             34             4          28      2          0          0         1

                                                                                            

  TW            4/18/00   1              0          1       0          0          0         0

                                                                                            

  Totals                  43             4          34      5          0          1         1

                                                                                            

  Percentages                            9.3%       79.1%   11.6%      0.0%       2.3%      2.3%
  ------------- --------- -------------- ---------- ------- ---------- ---------- --------- ----------

### Summary

It appears from review of the foregoing data that approximately 9-10 %
of pick-ups are early, 77-80 % are on time, and 8-12 % are late and 2-6%
are not served.

## Operator Resources

In order to identify potential capacity constraints to service
performance the assessment team reviewed the resources of each of the
carriers. The equipment and drivers available for service are presented
in Table 8.

#### Table 8: Contractor Resources

  ---------- ------------------- --------- ------------ ---------- ------------------ ---------- ---------
                                 **AAA**   **R.C.       **Two      **Palm Beach                  
                                           Services**   Wheels**   Transportation**              

                                                                   SpecTran           Medicaid   Total

                                                                                                 

  Runs                           55        16           39         100-200            400-500    500-700

                                                                                                 

  Vehicles   Available           61        16           39         \-                 \-         50

             Spares              9         4            4          \-                 \-         220

             Total               70        20           43         \-                 \-         270

             Surplus/Shortfall   7         0            0          \-                 \-         0

                                                                                                 

  Drivers    Assigned            48        16           39         \-                 \-         42

             Extra Board         0         0            6-8        \-                 \-         8

             Total               48        16           45-47      \-                 \-         50

             Surplus/Shortfall   -5\*      0            6-8        \-                 \-         \-
  ---------- ------------------- --------- ------------ ---------- ------------------ ---------- ---------

\* 2 split runs can be covered by one driver each

The runs are the number of runs assigned each contractor each day in
schedules prepared by ATC. With the exception of PBT, the number of runs
assigned are consistent with each operators contract. The number of ADA
runs to be assigned to PBT, as per their contract, was estimated at
10,000 trips per year. This relates to 26 to 40 passenger trips per day.
PBT appears to be receiving daily assignments of more than twice what
was intended in its contract. It should be noted that each run assigned
to PBT represents an individual passenger trip whereas the runs assigned
to the other contractors represent a full work shift for an operator
with multiple passenger trips for each run. In addition to ADA trips PBT
uses the same fleet and drivers to serve the county's Medicaid trips.
These trips are provided through a separate contract with Palm Beach
County. PBT has 50 vehicles dedicated to ADA/Medicaid service with an
additional 220 taxis available to serve ambulatory passengers.

Each of the service providers appears to have sufficient fleet capacity
to serve the assigned runs.

Availability of drivers appears to be a problem for several carriers. Of
the dedicated services, AAA appears to have the most severe strain on
driver capacity. AAA currently has some drivers work two shifts and
covers other runs by reassigning trips to available drivers. The
limitation on the number of drivers is compounded by the absence of
"extra board," or spare drivers, available for assignment when scheduled
drivers are absent. AAA staff indicated that normally, approximately 5
drivers are absent, leaving 43 drivers to cover the runs on a normal
day. RC Services also cited drivers as a limitation. The lack of
"extraboard" creates problems when drivers are late or absent. Two
Wheels personnel indicated that they schedule 3 to 5 spare drivers as
extraboard to cover for absent drivers. They also indicated that they
have 3 additional clerical employees who can drive if needed. PBT
provides both Medicaid and SpecTran service with the same drivers. PBT's
contract provides for 10,000 trips per year (5,000 for ambulatory trip
makers and 5,000 for wheel chair users). Using conservative assumptions
of 100 trips per day and 250 service days per year, PBT will be assigned
25,000 trips per year, more than twice the number in the contract. PBT
has identified adding drivers as a major challenge in serving the trips
it is being assigned.

The location of AAA's facility may be contributing to limitations on the
number of available drivers. The AAA facility is located on Route 710
near the intersection of Route 706, more than 15 miles outside of the
service area. Site access may be an impediment to employment for people
seeking driver positions, particularly low income individuals who may
not have access to an automobile.

AAA indicated that they were increasing pay rates and offering
recruitment and employment bonuses to increase their driver roster.
Subsequent to the site visit they provided information that, as of May
1, they had increased the number of drivers from 48 to 51 by hiring 2
trained drivers and promoting 5 trainees. The increase was offset by the
a turnover of 4 drivers. AAA also increased the number of trainees from
12 to 16 with 9 new hires.

## Financial Capacity

The assessment team reviewed financial data and ridership information
provided by Palm Trans to assess the adequacy of financial resources
available for the ADA Complementary Paratransit Program . The
information is summarized in Table 9.

#### Table 9: Budget and Ridership History

  ------------ ---------------- ------------- ------------- ---------- ------------- ----------
                                **FY 1998**   **FY 1999**              **FY 2000**   
                                ^1^           ^1^                      ^1,\ 2,\ 3^   

                                Amount        Amount        \% Change  Amount        \% Change
                                                            from                     from
                                                            Previous                 Previous
                                                            Year                     Year

  Capital                                                                            

               Budgeted         \$114,610     \$141,108     23%        \$86,962      -38%

               Expended         \$48,783      \$71,016      46%                      -100%

                                                                                     

  Operations                                                                         

               Budgeted         \$3,758,970   \$5,052,836   34%        \$6,944,114   37%

               Expended         \$4,622,920   \$5,972,346   29%        \$6,163,474   3%

                                                                                     

  ADA                           200,138       247,138       23%        273,224       11%
  Passenger                                                                          
  Trips                                                                              

                                                                                     

  Operating                     \$23.10       \$24.17       5%         \$22.56       -7%
  Cost per                                                                           
  Rider                                                                              
  ------------ ---------------- ------------- ------------- ---------- ------------- ----------

^1^- FY is October 1 through September 30.

^2^- FY 2000 operating expenditures are projected by doubling
\$3,081,737 expenditures for the 1st 6 months of the fiscal year -
includes TD, DOSS and Dialysis Service.

^3^- FY 2000 passenger trips projected by quadrupling 68,306 trips for
the 1st quarter of the fiscal year.

Increase in both budgeted and expended amounts for ADA Complementary
Paratransit service operations of 34 and 29 % between FY 1998 and FY
1999 and a further budget increase of 37 % in FY 2000 indicates a
commitment on behalf of Palm Tran to improve this service. However,
projected operating expenditures for ADA Complementary Paratransit, TD,
DOSS and Dialysis service is projected to increase by only 3 % in FY
2000 over ADA Complementary Paratransit expenditures for FY 1999. This 3
% increase in expenditures is less than the projected increase of 11 %
in ADA passenger trips. In spite of this positive commitment, the actual
resources available to deliver SpecTran services may be insufficient as
indicated in the discussion on operator capacity.

## Schedules

Both customers and operators identified schedules as an impediment to
providing efficient, on-time service.

### Procedures

ATC is responsible for scheduling all ADA, TD and DOSS passenger trips
for SpecTran services in Palm Beach County, in accordance with their
contract with Palm Beach County. ATC's contract with Palm Tran provides
that ATC assign at least 85% of requested trips to vehicles dedicated to
provide SpecTran service. The contract provides that ATC post completed
schedules in a format that can be downloaded by the service providers,
by 8:00 PM on the evening preceding the service day. The contract
further provides that ATC assist the service providers in moving trips
during the service day to accommodate changes such as unanticipated
delays, cancellations, or add-ons.

ATC uses a computer system to prepare SpecTran schedules. According to
ATC staff, their procedure is to schedule standing order trips at least
two days in advance of the service day. During the day before service,
trips are drawn from "open runs" and assigned to dedicated runs. When
trip requests are entered into the scheduling software by
reservationists, they are placed in open runs. An open run is simply a
list of requested passenger trips that have not been assigned to a
vehicle. As passenger trips are assigned and runs are filled throughout
the day they are closed to additional trips. At mid-afternoon the
scheduling software is run to assign remaining trips. As trips are
assigned to the schedules the pick-up window (15 minutes before to 15
minutes after the requested pick-up time) is held constant and is
ultimately printed on the schedule manifest. In the scheduling process
the pick-up time provided to the driver (scheduled pick-up time) may
vary from the requested pick-up time as long as it remains within the
pick-up window. The batch run takes about one to two hours to run. At
5:00 PM when reservations are closed and after the batch run has been
completed remaining trips are assigned manually. Typically 50 to 70
wheelchair and 140 ambulatory trips remain to be assigned out of a total
of approximately 2,000 trips. Trips for wheelchair users are assigned
first since all dedicated vehicles can not accommodate wheel chairs. The
remaining trips for ambulatory riders are then assigned. Schedulers run
a feasibility check before finalizing the schedule. The feasibility
report identifies scheduling errors such as assigning wheel chair users
to a vehicle in excess of the vehicle's wheel chair capacity. Errors
identified by the feasibility report are corrected and the schedules are
finalized.

The approximately 2000 daily passenger trips are assigned to 110
dedicated runs and 2 open runs. Of the dedicated runs 55 are allocated
to AAA, 39 to Two Wheels and 16 to R.C. Services. The 2 open runs which
consist of passenger trips listed in chronological order, are assigned
to PBT. One open run is comprised of trip requests for ambulatory
passengers and one is for wheelchair users. The wheelchair user run is
limited to approximately 25 trips. Before 8:00 PM each of the carriers
are notified that their assignments are available to be downloaded. Each
carrier then reviews their assignments and modifies the runs to best fit
their operating parameters. If a carrier does not believe a trip can be
completed as assigned, it can be returned to ATC for review. If ATC
agrees that the trip assignment is incorrect, the trip is reassigned and
scheduling procedures are modified to prevent recurrence of the problem.

PBT schedules its trips from the two open runs that it is assigned
throughout the service day. For outlying areas trips are scheduled
approximately 45 minutes in advance. For the central part of the service
area trips are scheduled 15 minutes in advance.

Trip cancellations requested by customers during the service day are
received by ATC. Cancellations are recorded by ATC staff on a form and
faxed to the appropriate carrier.

### Scheduling Parameters

The scheduling parameters used by ATC in its scheduling system are
presented in Attachment 4. Among the scheduling parameters used by ATC
are peak travel speeds of 16 to 20 mph for trips up to 15 miles;
off-peak travel speeds of 18-22 mph and a squeeze factor of 5 minutes.
The peak travel speeds appear to be optimistic when compared to an
industry norm of 10 to 15 miles per hour. These optimistic speeds enable
ATC to schedule more trips than would be the case using lower speeds but
leaves the carriers with limited schedule flexibility. By way of example
a 7.5 mile trip scheduled at 15 mph would take 30 minutes to complete
whereas the same trip scheduled at 20 mph would schedule the carrier to
complete the trip in 22.5 minutes.

The 5 minute squeeze factor allows the scheduling program to schedule a
trip in 5 minutes less time than computed as above. When applied the 5
minute squeeze factor would permit the scheduling of a 22.5 minute trip
in 17.5 minutes. Application of both optimistic speeds and the squeeze
factor could result in trips with a 30 minute duration at 15 mph being
scheduled for 17.5 minutes. Use of these schedule parameters could
significantly limit carriers ability to perform trips on time.

### Carrier Comments

Carriers indicated that schedules had circuitous routing. Carriers
indicated that schedules sometimes do not provide sufficient time
between stops. Carriers indicated that slack time in runs was
insufficient to recover from delays and adjust for changes. Carriers
indicated that subscription trips were frequently assigned to different
runs making driver scheduling more complex and impeding drivers in
developing consistent routes and positive relationships with customers.
All carriers indicated that they had to reassign trips before the
service day to accommodate both tight schedules and availability of
drivers. All carriers indicated that customer phone numbers and
addresses were sometimes incorrect making adjustments difficult when
riders could not be located. One carrier indicated the absence of
directions or sufficiently detailed addresses often made it difficult to
locate customers. One carrier also cited problems in getting correct
schedules and associated reports after 8:00 PM on the evening before the
service day. Specifically, AAA indicated that they received schedules
with trips scheduled for the wrong day on April 17 and did not receive
supporting reports on the evening of April 23. Carriers also cited
computer problems in contributing to schedule errors, such as a
scheduler failing to close a file and holidays not being correctly
handled by the scheduling software. One carrier indicated that notice of
customer cancellations is sometimes provided after the vehicle has been
dispatched for the trip.

### Observations

During the site visit an absence of cooperation between schedulers and
carriers was observed. Each complained about the performance of the
other and communication between the schedulers and carriers seemed poor.

## Findings

1)  Palm Tran does not appear to maintain an accounting of trips missed
    by the carriers. In addition, Palm Tran does not appear to have
    records of on-time performance for a large portion of trips provided
    by one of its carriers, Palm Beach Transit. As a result it is not
    possible to accurately measure missed trips and on-time performance
    for all requested trips.

2)  It appears that a significant number of requested trips may not be
    served by the carriers. This finding is supported by both consumer
    comments and customer complaints. Based upon review of the available
    data, trips not performed by the Palm Trans carriers could range
    from 2 to 6 % of trips requested.

3)  Pick-up times for approximately 10 % of completed trips were early,
    80% were on time and 10 % were late.

4)  Customers may feel pressured to accept early departure times. Two
    consumer group representatives indicated that customers are
    pressured to accept early pick-ups and the portion of reported early
    pick-ups (one in ten) is high.

5)  Palm Tran carriers do not appear to have sufficient capacity to
    serve all of the scheduled trips on-time. Specifically, AAA does not
    appear to have a sufficient number of trained operators to cover its
    schedule and accommodate normal absenteeism. PBT appears to be
    assigned many more daily trips than reflected in its contract and
    more trips than it can serve on time. Palm Tran indicated that they
    have plans to add a carrier, in addition to reorganizing SpecTran
    services.

6)  The number of trip requests accepted and scheduled by
    reservationists appears to exceed the capacity of the carriers to
    serve those the trips with on-time pick ups.

7)  Schedule parameters appear to be optimistic and may contribute to
    untimely pick-ups.

8)  The apparent lack of cooperation between schedulers and the carrier
    may contribute to late pick-ups and missed trips.

## Recommendations

1)  Palm Tran should institute a procedure to account for all rrequested
    trips not served by the carriers. Palm Tran should also institute a
    procedure to measure on-time performance for all trips provided by
    its carriers including PBT.

2)  Palm Tran should instruct or reinstruct its carriers that drivers
    are not to request passengers to board the SpecTran vehicle before
    the beginning of the pick-up window.

3)  Palm Tran should advance efforts to expand carrier capacity. This
    could be done by adding a carrier, as planned, assisting its
    existing carriers in driver recruitment or expansion, or some
    combination of the two.

4)  Consideration should be given to having reservationists schedule
    trips to actual rather than open runs as trips are requested by
    customers to assure that accepted trip requests will be served in a
    timely fashion.

5)  Palm Tran should review schedule parameters used by ATC to assure
    that they are reasonable and are not contributing to late pick-ups.

6)  Palm Tran should consider actively promoting cooperation between ATC
    and the carriers to coordinate schedules. Consideration should be
    given to establishing a position within ATC to coordinate schedule
    development and service day schedule changes between ATC schedulers
    and telephone personnel and carrier schedulers and dispatchers.

# Observations Regarding Trip Duration

The observation and review of travel time/trip length was performed in
the following ways:

-   Representatives of consumers were interviewed;

-   Palm Trans policies and ADA Complementary Paratransit contracts were
    reviewed;

-   Data on service performance provided by ATC was analyzed; and

-   An analysis of typical fixed route travel times was performed.

## Customer/Advocate Interviews

Of six consumer representatives interviewed three indicated that trips
were long and one of the three identified routing as circuitous. Two
people had no comments and one interviewee indicated that his clients
had few complaints about trip duration.

## SpecTran Travel Time Standard

In a letter to the review team dated April 3, 2000 which provided
service standard information, SpecTran described its travel time
standard as follows:

> "The stated travel time goal for trips less than 15 miles is one (1)
> hour or less and for trips which are greater than 15.0 miles is two
> (2) hours. When the elapsed travel time between origin and destination
> exceeds the amount of time it takes to make the same trip by fixed
> route, a trip is considered too long. (*Contract for Management
> Services -- Comsis Mobility Services, Inc., d/b/a Intellitran ATC
> Vancom, Inc. Scope of Services, Section IX., Reservations and
> Scheduling of Service: E.1-2.a.b., pg. 36; Scheduling the Trip*)"

The referenced contract section, Section E addresses Scheduling the
Trip. The referenced sub-sections read:

> "2. If the rider requests a specific appointment time for an ADA trip,
> the Contractor must schedule the rider to be picked-up in sufficient
> time to reach his/her appointment, allowing for sufficient travel
> time, based on the following guidelines:
>
> a\. For trips less than 15.0 miles: one (1) hour or less; and
>
> b\. For trips of 15.0 miles or greater: two (2) hours."

## Observations

Data provided by ATC on ADA Complementary Paratransit passenger service
for Monday March 23 was analyzed. The ATC data base included pick up and
drop off times for 1,144 pasenger trips completed on that day. The
results of the analysis are as follows:

-   The average passenger trip duration was 40 minutes;

-   80.1 % of the trips were completed in 1 hour or less;

-   18.8 % of the trips were completed in more than 1 but less than 2
    hours;

-   0.9 % of the trips were completed in 2 to 3 hours; and

-   0.2 % of the trips were completed in 3 to 4 hours.

Trip distances were not readily available for the trips reviewed. Non
the less based upon the foregoing review, 1.1 % of the trips exceed Palm
Tran's goal of completing all passenger trips in less than 2 hours.

To provide an indication of comparable travel times on fixed route
service, the assessment team reviewed three representative trips. One
trip was short (7 miles no transfer), one medium length (8-9 miles one
transfer) and one long (20 miles one transfer). Assuming each trip began
at 9:00 AM on a weekday the stop to stop fixed route travel times would
be 1 hour 13 minutes for the short trip, 1 hour 40 minutes for the
medium trip and 3 hours 55 minutes for the long trip. These trip
durations were calculated based upon Palm Tran's schedules. Based upon
this limited analysis it appears that trip durations for SpecTran ADA
Complementary Paratransit Service are generally comparable to Palm Tran
fixed route service.

## Findings

1)  On March 23, 1.1 % of ADA Complementary Paratransit passenger trips
    exceeded Palm Tran's goal of completing all trips in 2 hours or
    less.

2)  Trip durations for ADA Complementary Paratransit service appear to
    be comparable to Palm Tran's fixed route service.

## Recommendations

1)  Palm Tran should review passenger trips that exceed its standard and
    consider corrective action to reduce the duration of these long
    trips.

#  

# Summary of Findings and Recommendations

Palm Tran appears to have made a significant financial commitment to
improving ADA Complementary Paratransit services with operating budget
increases of 34 % in 1999 and 37 % in 2000.

Additionally, Palm Tran's process for making eligibility determinations
appears to be consumer oriented, well organized, and structured to
provide expeditious ADA Complementary Paratransit eligibility
determinations.

However, a significant number of requested ADA Complementary Paratransit
trips may not be served in a timely fashion. The absence of complete
records on passenger trips not served by Palm Tran's carriers made it
difficult to assess the extent of unserved trips.

There appear to be two significant factors contributing to timely
performance of service by the carriers, a limitation in carrier capacity
and poor coordination between the trip reservationists and schedulers
and the passenger carriers. The following findings and recommendations
generally address these and other areas of potential improvement in the
delivery of SpecTran service.

## Findings

1)  It appears that a significant number of requested trips may not be
    served by the carriers. This finding is supported by both consumer
    comments and customer complaints. Based upon review of the available
    data, trips not performed by the Palm Trans carriers could range
    from 2 to 6 % of trips requested.

2)  Pick-up times for approximately 10 % of completed trips were early,
    80% on time and 10 % were late.

3)  Palm Tran carriers do not appear to have sufficient capacity to
    serve all of the scheduled trips on-time. Specifically, AAA does not
    appear to have a sufficient number of trained operators to cover its
    schedule and accommodate normal absenteeism. PBT appears to be
    assigned many more daily trips than reflected in its contract and
    more trips than it can serve on-time. Palm Tran indicated that they
    have plans to add a carrier, in addition to reorganizing SpecTran
    services.

4)  The number of trips requests accepted and scheduled by
    reservationists appears to exceed the capacity of the carriers to
    serve those the trips with on-time pick ups.

5)  Schedule parameters appear to be optimistic and may contribute to
    late pick-ups

6)  Apparent lack of cooperation between schedulers and the carriers may
    contribute to late pick-ups and missed trips.

7)  Responses to ride checks appeared to be reasonable during the
    on-site observations by the assessment team. However, consumer
    representatives indicated that responses to ride checks could take
    as much as 45 minutes. Telephone staff also noted that they were
    receiving faster responses on ride checks from dispatchers during
    the assessment team's visit than normal.

8)  Palm Tran does not appear to maintain an accounting of trips missed
    by the carriers. In addition Palm Tran does not appear to have
    records of on-time performance for a large portion of trips provided
    by one of its carriers, Palm Beach Transit. As a result it is not
    possible to accurately measure missed trips and on-time performance
    for all requested trips.

9)  ADA Complementary Paratransit customers ability to reserve rides
    through SpecTran's Telephone system as operated by ATC does not
    appear to limit access to service. No trip requests appear to be
    denied or "wait-listed."

10) According to ATC records for the period April 7 to April 18, hold
    times for incoming calls exceeded three minutes approximately 12 %
    of the time. The incidence of long hold times is more than double
    Palm Tran's standard of 5 %. 8 % of calls were abandoned after
    average hold times of 90 seconds with 16 % of calls between 7:00 AM
    and 8:00 AM abandoned.

11) Telephone staff were observed responding to calls and placing the
    caller on hold, de facto, by asking them to wait while conducting
    other business. As a result the reported hold times may understate
    the period the customer spends waiting for service from telephone
    staff.

12) Some trip origins or destinations were incorrectly identified as
    being out of the service area due to errors in the GIS component of
    the reservations/scheduling software. ATC staff indicated that
    corrections to these problems are being addressed.

13) Access to the SpecTran service does not appear to be limited by
    adverse eligibility determinations.

14) SpecTran's process for making eligibilty determinations appears to
    be consumer oriented, well organized, and structured to provide
    expeditious ADA Complementary Paratransit eligibility determinations

15) The SpecTran Paratransit Rider's Guide (Attachment A, pps. 20, 21)
    places limitations on travel on SpecTran services, including a
    requirement that children under the age of 14 are required to travel
    with a parent or guardian. SpecTran's service limitations, as cited
    in the Rider's Guide, might be construed as providing a service
    level that is not comparable to that provided on the fixed route
    system.

16) The documentation for two of the denials of ADA Complementary
    Paratransit eligibility did not fully explain the reasons for the
    determination. It was unclear from review of the documentation as to
    whether the applicants' condition would prevent the individuals from
    travelling on fixed route service at certain times or from
    travelling to/from transit stops. If so, such conditions may support
    a determination of conditional eligibility.

17) Customers may feel pressured to accept early departure times. Two
    consumer group representatives indicated that customers are
    pressured to accept early pick-ups and the portion of reported early
    pick-ups (one in ten) is high.

18) Trip durations for ADA Complementary Paratransit service appear to
    be comparable to Palm Tran's fixed route service. During the
    assessment, 1.1 % of ADA Complementary Paratransit passenger trips
    exceeded Palm Tran's goal of completing all trips in 2 hours or
    less.

## Recommendations

1)  Palm Tran should advance efforts to expand carrier capacity. This
    could be done by adding a carrier, as planned, assisting its
    existing carriers in driver recruitment or expansion, or some
    combination of the two approaches.

2)  Consideration should be given to having reservationists schedule
    trips to actual rather than open runs, as trips are requested by
    customers, to assure that accepted trip requests will be served in a
    timely fashion.

3)  Palm Tran should consider actively promoting cooperation between ATC
    and the carriers to coordinate schedules. Consideration should be
    given to establishing a position within Palm Tran or ATC to
    coordinate schedule development and service day schedule changes
    between ATC and the carriers. With a focus on serving the carriers,
    such a person could improving schedule coordination between ATC and
    the service providers. In addition, real time coordination of
    schedule changes between ATC and the dispatchers for the four
    service providers could improve response times on ride check calls
    by making current field information available to telephone staff on
    a timely basis.

4)  Palm Tran should review schedule parameters used by ATC to assure
    that they are reasonable and are not contributing to untimely
    pick-ups.

5)  Palm Tran should institute a procedure to account for all requested
    trips not served by the carriers. Palm Tran should also institute a
    procedure to measure on-time performance for all trips provided by
    its carriers, including PBT.

6)  Palm Trans should work with ATC to reduce hold times. Additional
    telephone staffing should be considered, particularly at the
    beginning and end of the work day, as a means of reducing hold times
    and abandoned calls.

7)  ATC telephone staff should be instructed to complete one call,
    including associated activity, before beginning the next call. Doing
    so could reduce the potential for distraction and error, and produce
    automated reports which more accurately reflect the time customers
    spend waiting for telephone service.

8)  ATC staff should continue to correct GIS errors
    reservations/scheduling software.

9)  Palm Tran should review age limitations placed on travel on SpecTran
    services to assure that service levels provided on SpecTran riders
    are comparable to those provided on the fixed route system.

10) Palm Tran should review passenger trips that exceed its standard and
    consider corrective action to reduce the duration of these long
    trips.

11) Palm Tran should review its method of ADA Complementary Paratransit
    application review to assure that an individual's ability to travel
    to or from a boarding location, and/or variable disabilities are
    properly addressed in making eligibility determinations in
    accordance with ADA Complementary Paratransit standards. SpecTran
    should clearly document the reasons for eligibility denials.

12) Palm Tran should instruct or reinstruct its service contractors that
    drivers are not to request passengers to board the SpecTran vehicle
    before the beginning of the pick-up window.

# Attachment 1

## SpecTran Paratransit Rider's Guide

**Attachment 2**

######## *Palm Tran ADA Complementary Paratransit Eligibility* 

######## *Forms and Brochures*

####### Attachment 3

######## *SpecTran Complaints Process and Records*

#  {#section-2 .unnumbered}

# Observations Regarding SpecTran Complaints Process and Records

As part of the on-site review, the assessment team reviewed SpecTrans
complaint records and complaint review process. The purpose of this
element of the review was to obtian information on service performance
as relates to capacity.

ATC has two agents dedicated to responding to complaints and
commendations. Complaints can be made via phone, e-mail, or written
comment. If complaints are received by a method other than a phone call,
complaint agents will call the client back in order to take a statement
over the phone. All complaints calls are recorded.

Complaint agents classify complaints into 10 categories:

-   Reservations

-   Scheduling

-   Phone system

-   Discourteous employee

-   Late vehicle

-   Vehicle no show

-   Condition of vehicle

-   Unsafe vehicle operation

-   Policy

-   Other

Each complaint is assigned an identification number in order to track
progress. Complaint agents create a daily summary of complaints,
organized by carrier or other responsible party, in order to log
responses and record the determination of validity. Complaint agents
develop a complaint report and send it via fax to the potentially
responsible party (carriers, Palm Tran, or ATC). The potentially
responsible party has until the end of the following week to respond to
a complaint. The due date for complaint responses is written on the fax
cover sheet.

Following the response, if any, of the potentially responsible party,
complaint agents will make a validity determination of the complaint.
There are four potential validity determinations: valid, not valid, not
verifiable, and no response from potentially responsible party (assumed
to be valid).

Once a determination of validity has been made, complaint agents will
call back those clients whose complaints have been determined to be
valid or not valid. ATC has a goal of making return phone calls to
clients within 10 days of receiving a response from the provider (or a
maximum of 20 days from the date the complaint was made). Clients whose
complaints are not verifiable, or for which no response was received
from the potentially responsible party, do not receive a return phone
call.

Clients who do receive a return phone call have thirty days to submit an
appeal/complaint to the SpecTran Director. Of the 440 complaints
received during the month of March, complaint agents had responded with
193 return phone calls by April 18, a response rate of 44%. The response
rate for complaints viewed as true (valid or no response from provider)
was 51%.

#### Table 10: Complaint Summary

  ------------------ --------- -------------- ------------ ----------- ----------- ----------- -------------
  **Potentially      **Not     **Not          **Valid or                                       **(No
  responsible        valid**   verifiable**   no response                                      response)**
  party**                                     from                                             
                                              provider**                                       

                                              **Late       **Vehicle   **Other**   **Total**   
                                              Vehicle**    No Show**                           

  ATC                1         13             N/A          N/A         11          11          0

  Ambulette          15        7              49           40          17          106         49

  RC Services        3         2              10           2           1           13          4

  Two Wheels         4         1              15           1           3           19          7

  PBT                10        4              129          84          8           227         83

  PBM                0         0              1            1           0           2           0

  **Total**          33        27             204          128         39          378         143
  ------------------ --------- -------------- ------------ ----------- ----------- ----------- -------------

####### Attachment 4

***ATC Scheduling Parameters***

####### Attachment 5

***Palm Tran Response to the Draft Report***

***November 7, 2000***