ADA PARATRANSIT 

SERVICES

Demand Has 

Increased, but Little is 

Known about 

Compliance

Report to the Committee on Banking, 

Housing, and Urban Affairs, U.S. Senate

November 2012

GAO-13-17

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-17, a report to the 

Committee on Banking, Housing, and Urban 

Affairs, U.S. Senate

November 2012

ADA PARATRANSIT SERVICES

Demand Has Increased, but Little is Known about 

Compliance 

Why GAO Did This Study

The ADA, a civil rights law enacted in 

1990, provided that it shall be 

considered discrimination for a public 

entity that operates a fixed-route transit

system to fail to offer paratransit 

service to disabled individuals that is 

comparable to services provided to 

those without disabilities. FTA is 

responsible for overseeing compliance 

with ADA requirements for paratransit 

services. As requested, GAO 

examined: (1) the extent of compliance 

with ADA paratransit requirements, (2)

changes in ADA paratransit demand 

and costs since 2007, and (3) actions 

transit agencies are taking to help 

address changes in the demand for 

and costs of ADA paratransit service. 

GAO analyzed FTA’s ADA compliance 

reports; conducted a generalizable 

web-based survey of 145 transit 

agencies; interviewed federal officials; 

and interviewed officials from 20 transit 

agencies, chosen based on a variety of 

characteristics, including geographic 

diversity.

What GAO Recommends

The Secretary of Transportation should 

direct the FTA Administrator to (1) 

document and make publicly available 

a formal approach for selecting transit 

agencies for ADA paratransit 

compliance reviews, (2) post the 

backlog of ADA’s compliance-review 

final reports and establish a process 

for the timely posting of future reports, 

and (3) provide guidance to transit 

agencies on how to accurately 

complete existing ADA paratransit data 

fields in the NTD. The Department of 

Transportation neither agreed nor 

disagreed with the recommendations 

and provided clarifying comments, 

which GAO incorporated.

What GAO Found

Little is known about the extent of transit agencies’ compliance with the 

Americans with Disabilities Act (ADA) paratransit service requirements. FTA 

does receive some assurance that agencies are complying with federal statutes 

and regulations, including ADA paratransit requirements, because transit 

agencies that receive FTA funding are required to self-certify and assure that 

they are complying with the Department of Transportation’s ADA regulations. 

Additionally, FTA conducts specialized ADA paratransit compliance reviews that 

examine multiple aspects of an agency’s paratransit services; however, few 

transit agencies are selected for review each year. FTA generally relies on 

complaints, media reports, experience with an agency, and other information to 

select agencies for review, but does not have documented criteria for selecting 

agencies. This informal selection process does not align with federal guidance on 

internal controls related to communication, documentation, and monitoring. 

Lastly, according to FTA officials, all finalized ADA paratransit compliance review 

reports are to be available on FTA’s website, but GAO identified nine final review 

reports—conducted from 2004 to 2010—that have not been posted to FTA’s 

website. 

Based on GAO’s survey, the demand for ADA paratransit trips increased, since 

2007 for some transit agencies, and costs for providing the trips remain high. The 

average number of annual ADA paratransit trips provided by a transit agency 

increased 7 percent from 2007 to 2010; from 172,481 trips in 2007 to 184,856 

trips in 2010. Increases in demand for ADA paratransit services were driven by 

the 10 largest transit agencies, measured according to the population size of 

their service areas. Also, ADA paratransit trips are much more costly to provide 

than fixed-route trips. Similarly, the average cost of providing an ADA paratransit 

trip in 2010 was $29.30, an estimated three and a half times more expensive 

than the average cost of $8.15 to provide a fixed-route trip. The average cost of 

providing an ADA paratransit trip increased 10 percent from 2007 to 2010. GAO’s 

analysis of ADA paratransit data available in FTA’s National Transit Database 

(NTD) found that, according to GAO standards for data reliability, the data are 

not sufficiently reliable for the purpose of assessing changes in ADA paratransit 

demand and costs. For example, GAO found discrepancies, such as incomplete 

data, that may understate or overstate the number of ADA trips and amount of 

ADA expenses. According to FTA officials, some transit agencies fail to report 

these data, while others misunderstand the data fields and make reporting errors 

as a result. 

Transit agencies are taking actions such as coordinating with other transportation 

providers, offering travel training, and improving accessibility to address changes 

in ADA paratransit demand and costs. According to GAO’s survey, about 59 

percent of transit agencies are coordinating with health and human services 

providers to improve ADA paratransit services or address the costs of providing 

such services. About 44 percent of transit agencies are coordinating with other 

local transportation providers. Additionally, about 55 percent are using travel 

training to help paratransit riders’ transition to fixed-route services. Furthermore,

GAO’s survey results showed that over 62 percent of transit agencies have made

accessibility improvements to their fixed-route systems since 2007. 

View GAO-13-17. For more information, 

contact David J. Wise at (202) 512-2834 or 

wised@gao.gov. 
Page i GAO-13-17 ADA Paratransit Services

Letter 1 

Background 4

Little Is Known about ADA Compliance for Paratransit 10

Demand for ADA Paratransit Has Increased for Some Transit 

Agencies, and Costs Remain High 16

Transit Agencies Are Taking a Number of Actions to Address 

Paratransit Demand and Costs 23

Conclusions 28

Recommendations for Executive Action 29

Agency Comments 30

Appendix I Objectives, Scope, and Methodology 31

Appendix II Reliability of ADA Paratransit Data in FTA’s National Transit Database 36

Appendix III GAO Contact and Staff Acknowledgments 40

Tables

Table 1: ADA Minimum Paratransit Service Requirements for 

Comparability to Fixed-Route Service 5

Table 2: Types of ADA Paratransit Eligibility Determination 

Processes Used by Transit Agencies 6

Table 3: Transit Agency Interviews 32

Table 4: Percentage of Transit Agencies Reporting ADA Trips and 

ADA Expenses in NTD, 2005 through 2010 38

Table 5: Percentage of Transit Agencies Reporting DemandResponse Service, ADA Trips, and ADA Expenses in NTD, 

2005 through 2010 39

Figures

Figure 1: Basic Scheduling and Dispatching Operation of a 

Paratransit System 8

Figure 2: Major Steps in the Compliance Review Process 12

Figure 3: Average Number of Individuals Registered to Use ADA 

Paratransit Services at a Transit Agency and Average 

Contents
Page ii GAO-13-17 ADA Paratransit Services

Number of ADA Paratransit Trips Provided by a Transit 

Agency, 2007 and 2010 17

Figure 4: Average Reported ADA Paratransit and Fixed-Route PerTrip Costs, 2010 19

Figure 5: Percentage of Transit Agencies Reporting the Following 

as Major Contributors to Cost Increases in ADA 

Paratransit Services 21

Figure 6: Average Reported ADA Paratransit and Fixed-Route 

Costs and Fares Per Trip, 2010 22

Abbreviations

ADA Americans with Disabilities Act 

DOJ Department of Justice

DOT U.S. Department of Transportation

FTA Federal Transit Administration

NTD National Transit Database

TCRP Transit Cooperative Research Program

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Page 1 GAO-13-17 ADA Paratransit Services

United States Government Accountability Office

Washington, DC 20548

November 15, 2012

The Honorable Tim Johnson

Chairman

The Honorable Richard C. Shelby

Ranking Member

Committee on Banking, Housing, and Urban Affairs

United States Senate

Since 1970, it has been our nation’s policy that individuals with disabilities 

have the same right as other individuals to use public transportation 

service, that special efforts be made in planning and designing public 

transportation service to ensure that it can be used by individuals with 

disabilities, and that all government programs assisting public 

transportation “shall carry out this policy.”1 In 1990, the Americans with 

Disabilities Act (ADA), a civil rights law, prohibited discrimination against 

individuals with disabilities in several areas, including public transit, and 

applied to public entities whether or not they receive federal financial 

assistance.2 U.S. Senate and House of Representative reports 

accompanying the ADA stated that paratransit service was often 

inadequate;3 in addition to requiring accessibility of regular fixed-route 

bus and rail transit systems, the ADA provided that it shall be considered 

discrimination for a public entity that operates a fixed-route system to fail 

to provide paratransit service to individuals with disabilities that is 

comparable to the level of service provided to individuals without 

disabilities who use the fixed-route system.4

 

1 Formerly at 49 U.S.C. § 5301(d). The new surface reauthorization act has modified this 

provision. See Section 20003 of Moving Ahead for Progress in the 21st Century Act, Pub. 

L. No. 112-141 (July 6, 2012).

Regulations issued under the 

ADA established requirements for who was eligible for ADA paratransit 

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

3 Paratransit service, broadly defined, is accessible, origin-to-destination transportation 

service that operates in response to calls or requests from riders. It is an alternative to 

fixed-route transit service, which operates according to regular schedules along 

prescribed routes with designated stops. Paratransit service is defined in Department of 

Transportation regulations as “comparable transportation service required by the ADA for 

individuals with disabilities who are unable to use fixed route transportation systems”. 49 

C.F.R. § 37.3

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

 
 

Page 2 GAO-13-17 ADA Paratransit Services

service and the minimum requirements for what ADA paratransit service 

must entail.

The Federal Transit Administration (FTA) within the Department of 

Transportation (DOT) is responsible for overseeing federal grants for 

public transportation, a responsibility that includes overseeing compliance 

with ADA requirements for paratransit service. In 2007, we reported that 

although there are indications that the accessibility of public transit is 

improving, less is known specifically about the extent of compliance with 

ADA paratransit requirements. We also reported that as more individuals 

are being served by ADA paratransit, transit agencies are struggling to 

balance the provision of these services with the increased costs of a 

growing paratransit ridership.5

In this context, you asked us to review the provision of ADA paratransit 

service. We addressed the following questions: 

As a result, many transit agencies are 

pursuing methods to contain paratransit costs while maintaining ADA 

compliance.

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

paratransit requirements? 

(2) What changes have occurred in ADA paratransit demand and 

costs since 2007? 

(3) What actions are transit agencies taking to help address changes 

in the demand for and costs of ADA paratransit service?

To determine what is known about the extent of compliance with ADA 

paratransit requirements, we reviewed ADA regulations, FTA guidance on 

the regulations, and FTA’s ADA compliance reports from 2005 to 2011. In 

addition, we examined FTA’s National Transit Database (NTD) to assess 

the extent to which it contains data related to ADA paratransit services 

and transit agencies’ compliance with ADA paratransit requirements. We 

also interviewed FTA officials about how the agency assesses 

compliance and consulted our prior work on transportation accessibility. 

To identify changes that have occurred in ADA paratransit demand and 

 

5 GAO, Transportation Accessibility: Lack of Data and Limited Enforcement Options Limit 

Federal Oversight, GAO-07-1126 (Washington, D.C.: Sept. 19, 2007).
 

Page 3 GAO-13-17 ADA Paratransit Services

costs, we examined data from the NTD on the number of ADA paratransit 

trips provided annually and total annual expenditures attributable to ADA 

complementary paratransit requirements. In reviewing NTD data on ADA 

paratransit services, we determined that they were not reliable for our 

purpose, which was to assess changes in ADA paratransit demand and 

costs. Appendix II contains a more detailed discussion of our data 

reliability assessment. To identify changes that have occurred in ADA 

paratransit demand and costs since 2007 and to determine what actions 

agencies are taking to help address such changes, we conducted a 

generalizable Web-based survey of transit agencies from May through 

July 2012. We identified 546 transit agencies that provided demandresponse service in 2010 and sampled 145 of these agencies for 

participation in the survey.6 To identify the 145 transit agencies to be 

sampled, we first selected the 10 largest transit agencies in the United 

States, measured according to the population size of their service areas. 

These 10 agencies represent 29 percent of the total service area 

population in our total sample. We then randomly selected an additional 

135 transit agencies to survey, ordered by size as measured by the 

population size of their service areas. About 77 percent of our sample 

(112 respondents) completed the survey, including all 10 of the largest 

transit agencies.7 This report does not contain all of the results from the 

survey; our questionnaire and a more comprehensive tabulation of the 

results can be viewed in an electronic supplement to this report.8

 

6 Demand-response service is service in which vehicles operate in response to calls or 

requests from passengers. Demand response service includes ADA paratransit service 

and other generic demand responsive services that are unrelated to ADA requirements. 

Transit agencies that report providing demand response services to the NTD do not 

necessarily provide ADA paratransit service. However, the demand response field in NTD 

is most closely associated with provision of ADA paratransit service, according to FTA 

officials. Our first ADA paratransit survey question establishes whether or not an agency 

provided ADA paratransit service.

To 

address our second and third objectives, we conducted semi-structured 

interviews with 20 transit agencies regarding their provision of ADA 

paratransit services. We selected transit agencies to interview based on 

the size of the agency (small and large, measured according to the 

7 Unless otherwise noted, all percentage estimates based on this survey have 95 percent 

confidence intervals of within +/- 10 percentage points of the estimate itself. See Appendix 

I for additional information on sampling error of estimates. 

8 GAO, ADA Paratransit Services: Survey of Public Transit Agency Officials on Services 

and Costs, an E-supplement to GAO-13-17, GAO-13-18SP (Washington, D.C.: Nov. 15, 

2012).
 

Page 4 GAO-13-17 ADA Paratransit Services

number of ADA paratransit trips provided in 2010); geographic diversity; 

and other factors. We also interviewed representatives from relevant 

industry and disability advocacy groups. In addition, to identify the actions 

that transit agencies are taking to help address changes in demand for 

and costs of ADA paratransit service, we reviewed relevant literature 

pertaining to leading practices for addressing demand for and costs of 

paratransit services. Appendix I contains a more detailed discussion of 

our objectives, scope, and methodology.

We conducted this performance audit from September 2011 to November 

2012 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

The ADA requires that fixed-route transit systems be made accessible to 

persons with disabilities—for example, by having lift and ramp equipped 

vehicles and announcing transit stops—but acknowledges that some 

disabled individuals are not able to use fixed-route services even with 

such accessibility features.9 To ensure that these individuals have equal 

access to public transportation, the ADA introduced a requirement that all 

public entities operating a fixed-route transit system must provide 

complementary and comparable ADA paratransit service.

DOT issued final regulations to implement the ADA’s public transportation 

provisions on August 22, 1991.10

 

9 The ADA regulations require that all newly purchased or leased vehicles used in fixedroute service must be accessible. Additionally, vehicles which are remanufactured to 

extend their useful life beyond a given number of years must include accessibility features. 

Moreover, new transit facilities must be accessible and alterations to older transit facilities 

must include features to make them accessible.

The regulations do not explicitly state 

how transit agencies are to provide paratransit service; rather, they 

require such agencies to offer a level of service that is “comparable” to 

the level of service offered to the general public without disabilities. 

10 56 Fed. Reg. 45584 (Sept. 6, 1991). DOT regulations for paratransit as a complement 

to fixed-route service are at 49 C.F.R. Part 37, Subpart F. 

Background 

ADA Paratransit 

Requirements
 

Page 5 GAO-13-17 ADA Paratransit Services

Comparability is defined using six ADA minimum service requirements: 

service area, hours and days of service, fares, response time, trip 

purpose restrictions, and capacity constraints (see table 1).

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

ADA paratransit requirement Description

Service areaa Generally within 3⁄4 mile of a fixed route.

Hours and days of serviceb Same hours and days as fixed route.

Faresc Fares may not exceed twice the fare that would be charged to an individual paying full fare for a 

trip of similar length, at a similar time of day on the fixed route. A personal care attendant shall 

not be charged.

Response timed Paratransit service must be provided at any requested time on a particular day in response to a 

request for service made the previous day. Real time scheduling, in which a call to the transit 

provider would result in pickup the same day, is explicitly allowed but not mandated.

Trip purpose restrictionse No restrictions or priorities based on trip purpose are allowed.

Capacity constraintsf The following are not allowed: restrictions on the number of trips per eligible individual; waiting 

lists for access to the service; substantial numbers of significantly untimely pickups for initial or 

return trips; substantial numbers of trip denials or missed trips; and substantial numbers of trips 

with excessive trip lengths. 

Source: GAO analysis of ADA requirements.

a

49 C.F.R. § 37.131(a)

b

49 C.F.R. § 37.131(e)

c

49 C.F.R. § 37.131(c)

d

49 C.F.R. § 37.131(b)

e

49 C.F.R. § 37.131(d)

f

49 C.F.R. § 37.131(f)

ADA paratransit service is generally an origin-to-destination service, 

meaning that paratransit vehicles pick up riders at their homes or other 

locations and take them to their desired destinations.11

 

11 49 C.F.R. § 37.129(a).

Transit agencies 

are allowed to establish whether they will provide door-to-door service, 

wherein the driver offers assistance from the rider’s door to the vehicle 

(and comparable assistance at the destination), or curb-to-curb service, 

wherein assistance is not provided until the rider reaches the vehicle. 

According to DOT guidance, if the base model of service chosen is curbto-curb, it may still be necessary to provide door-to-door service for those 
 

Page 6 GAO-13-17 ADA Paratransit Services

persons who require it in order to travel from their point of origin to their 

point of destination.12

All public transit agencies required to provide ADA paratransit services 

must establish a process for certifying individuals (including both local 

residents and visitors in the transit agencies’ respective service area) as 

ADA paratransit eligible.13 The ADA does not specify a process for how 

transit agencies determine eligibility, but it states the criteria that must be 

used to make the determination.14 A Transit Cooperative Research 

Program (TCRP) report on ADA paratransit eligibility certification 

practices found that most included a combination of the processes 

identified in table 2.15

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

ADA eligibility determination processes Description

Self-certification by the applicant Requires the applicant to fill out an application form, with verification by a 

medical professional on an as-needed basis.

Professional verification via written documentation 

and/or telephone conversation

Requires a medical professional to independently verify and document the 

physical condition and mobility needs of the applicant. Additionally, 

professional verification interviews may be conducted by telephone or in 

person, depending on the situation.

In-person interview Requires that some or all applicants receive a face-to-face interview to 

determine the level of service for which the applicant does or does not 

qualify. 

In-person functional assessment Requires some or all applicants to undergo observation or testing of their 

specific abilities, skills, or limitations to accurately determine their functional 

ability to access the fixed-route system. 

In-person cognitive assessment If the information provided by the applicant and professional is not sufficient 

to make a determination, the transit agency may ask the applicant to 

participate in a cognitive assessment.

Source: GAO analysis of information from the TCRP.

 

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

13 49 C.F.R. § § 37.125, 37.127.

14 49 C.F.R. § 37.123(e). Individuals may be paratransit eligible on the basis of a 

permanent or temporary disability.

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

ADA Paratransit Eligibility 

Process
 

Page 7 GAO-13-17 ADA Paratransit Services

While the ADA establishes minimum requirements for ADA paratransit, 

transit agencies are free to provide any additional level of service that 

they or their communities find appropriate.16 Types of additional services 

could include operating paratransit service beyond the fixed-route service 

area (which may include collecting fares for such trips in excess of twice 

the fixed-route service fare); providing service when the fixed-route 

system is not operating; and allowing same-day trip requests.

According to the Center for Transportation Research, scheduling trips and 

dispatching vehicles are critical functions in providing ADA paratransit 

service. Scheduling ADA paratransit trips requires providers to match 

available vehicles to riders’ trip time and destination requests. In general, 

the process starts when a passenger calls to reserve a trip. At that time 

the passenger’s eligibility to receive the service is verified. Service must 

be provided on at least a next-day basis, though DOT’s ADA regulations 

permit transit agencies to accept advance reservations up to 14 days in 

advance.17 A destination request is then either entered into paratransit’s

scheduling software or scheduled manually. On the day of the trip, the 

dispatcher creates a log sheet or manifest with the trip information for the 

driver, and the passenger is then picked up and dropped off (see fig. 1).18

 

16 49 C.F.R. § 37.131(g).

17 49 C.F.R. § 37.131(b) (4).

18 Center for Transportation Research, University of Texas at Austin, Transit Scheduling 

Data Integration: Paratransit Operations Review and Analysis (May 2000).

Providing ADA Paratransit 

Service
 

Page 8 GAO-13-17 ADA Paratransit Services

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

Two federal agencies, DOT and the Department of Justice (DOJ), have 

key roles in monitoring, overseeing, and enforcing ADA requirements and 

providing technical assistance.19

• Regulations. The Secretary of Transportation has sole authority to 

issue regulations to carry out the section of the ADA governing 

paratransit as a complement to fixed-route service.

Their general roles and responsibilities 

are as follows:

20 FTA has primary 

responsibility for administering these regulations.21

 

19 There is a memorandum of understanding established between DOJ and FTA to 

coordinate enforcement responsibility over the ADA. A copy of this memorandum can be 

found at http://www.fta.dot.gov/civilrights/12875_3898.html. Accessed September 21, 

2012.

20 42 U.S.C. 12143(b); Boose v. Tri-County Metro. Transp. Dist. Of Or., 587 F.3d 997, 

1001 (9th Cir. 2009); Abrahams v. MTA Long Island Bus, 644 F.3d 110, 115 (2d Cir. 2011).

21 FTA is a small agency within DOT, accounting for 568 staff in headquarters and 

regional offices. It has 10 regional offices to provide support to and oversight of transit 

agencies. FTA regional offices also work with local transit officials in developing and 

processing grant applications. FTA’s Office of Civil Rights has 28 staff in headquarters 

and regional offices, and 5 full time staff directly involved with compliance. 

Federal Roles and 

Responsibilities 
 

Page 9 GAO-13-17 ADA Paratransit Services

• Oversight. As part of DOT’s oversight, FTA conducts general and 

special oversight reviews to evaluate the use of funds and adherence 

to civil rights laws, among other things, by recipients of Urbanized 

Area Formula Program grants (grantee) use of funds and adherence 

to civil rights laws, among other things.22 Civil rights reviews are one 

of five types of special reviews.23 FTA’s Office of Civil Rights is 

responsible for civil rights compliance and monitoring to ensure 

nondiscriminatory provision of transit services. ADA compliance 

reviews are a subset of civil rights special reviews, 24 and can be 

targeted to one of three specific ADA areas: fixed-route compliance, 

rail station compliance, and ADA paratransit service compliance.25

FTA also provides technical assistance to transit agencies on fulfilling 

ADA requirements and investigates discrimination complaints filed by 

the public.

Data. FTA is also responsible for maintaining the NTD, which was 

established by Congress to be the primary source for information and 

statistics on the nation’s transit systems. Recipients or beneficiaries of 

certain grants from FTA are required to submit data to the NTD on 

information such as their operating expenses, revenue, and 

services.26

 

22 FTA Order 5400.1, Oversight Reviews, November 1, 1994. Formula grants, as the 

name suggests, are apportioned among urban areas by a statutory formula based on 

population data and statistics for transit service and ridership. 

Transit agencies reporting to NTD are required to provide 

two data points related to ADA paratransit services: the number of 

ADA paratransit trips provided annually and total annual expenditures 

for paratransit services that are attributable to ADA requirements.

23 The other special reviews are the Drug and Alcohol Abuse Program Review, Financial 

Management Oversight Review, Procurement System Review, and the State Safety 

Oversight Review.

24 Civil Rights Reviews began in the 1980s, according to officials in FTA’s Office of Civil 

Rights. They include four discretionary oversight reviews assessing grantees’ compliance 

with the Americans with Disabilities Act of 1990, Title VI regulations, Disadvantaged 

Business Enterprise requirements, and Equal Employment Opportunity requirements. 

25 FTA’s ADA fixed-route reviews focus on fixed-route bus lift or ramp maintenance and 

reliability, fixed-route bus-stop announcements, and route identification. FTA’s ADA rail 

station reviews focus on rail-stop announcements and route identification or key, new, or 

renovated rail station compliance.

26 Recipients and beneficiaries of grants from FTA under the Urbanized Area Formula 

Program (49 U.S.C. § 5307) or Other than Urbanized Area (Rural) Formula Program (49 

U.S.C. § 5311) are required by statute to submit data to the NTD. 49 U.S.C. § 5335.
 

Page 10 GAO-13-17 ADA Paratransit Services

• Enforcement. DOJ’s ADA enforcement responsibility generally 

involves either filing a federal lawsuit upon referral of a finding of 

noncompliance by DOT or by intervening in a privately filed lawsuit.

DOJ may also resolve complaints of ADA noncompliance through 

settlement agreements and consent decrees with public transit 

agencies aimed at obtaining ADA compliance.

There is no national level information to accurately measure the extent to 

which agencies providing ADA paratransit service are complying with 

ADA’s paratransit service requirements. However, as a condition of 

receiving federal funds, every transit agency has to self-certify and assure 

that it is complying with the DOT ADA regulations.27 According to FTA, 

this certification and assurance is its starting point for assessing transit 

agencies’ compliance with ADA requirements. Additionally, every 

Urbanized Area Formula Program grantee receives the general oversight 

FTA triennial review once every 3 years, which is one of the primary 

means FTA uses to evaluate whether grantees are meeting federal 

requirements. Although the triennial reviews include a review of the 

grantee’s compliance with ADA requirements, they provide no detailed 

information about ADA paratransit compliance because ADA compliance 

is 1 of 24 areas of transit operations covered in the review.

28 According to 

FTA officials, negative triennial review findings may be considered in 

selecting transit agencies for a specialized ADA paratransit review.

29

 

27 FTA Certifications and Assurances—before FTA awards transit assistance or funding to 

support a project, an applicant must provide certain certifications and assurances required 

by federal law or regulation. One area of certification and assurance is the “Assurance of 

Nondiscrimination on the Basis of Disability,” which includes assuring compliance with the 

requirements of the ADA. 76 Fed. Reg. 67534, 67537 (Nov. 1, 2011).

28 As of fiscal year 2012 there are 24 triennial review areas. They are: 1) legal, 2) 

financial, 3) technical, 4) satisfactory continuing control, 5) maintenance, 6) procurement, 

7) disadvantaged business enterprise, 8) Buy America, 9) debarment and suspension, 10) 

lobbying, 11) planning/program of projects, 12) Title VI, 13) public comment on fare and 

service changes, 14) half fare, 15) Americans with Disabilities Act, 16) charter bus, 17) 

school bus, 18) National Transit Database, 19) safety and security, and 20) drug-free 

workplace, 21) Drug and Alcohol Program, 22) equal employment opportunity, 23) ITS 

architecture, and 24) American Recovery and Reinvestment Act.

29 For more information about GAO analysis of FTA’s triennial review program, see GAO, 

Public Transportation: FTA’s Triennial Review Program Has Improved, but Assessments 

of Grantees’ Performance Could Be Enhanced, GAO-09-603, (Washington, D.C.: June 30, 

2009). 

Little Is Known about 

ADA Compliance for 

Paratransit 
 

Page 11 GAO-13-17 ADA Paratransit Services

FTA’s specialized ADA paratransit compliance reviews examine multiple 

aspects of a transit agency’s paratransit service. Compliance reviews 

include an examination of the selected transit agency’s policies and 

standards for providing ADA complementary paratransit services. 

Reviews also include a determination of whether capacity constraints or 

areas of non-compliance exist. For example, a capacity constraint 

determination can be made by reviewing data on the selected transit 

agency’s on-time performance, on-board travel time, telephone-hold 

times, and trip denials. The review also examines compliance related to 

eligibility determinations, fares, and other ADA paratransit service 

requirements.

FTA uses contractors to conduct the vast majority of its grantee oversight 

reviews, including specialized compliance reviews such as an ADA 

paratransit compliance review, although FTA is responsible for 

overseeing the work performed by its contractors.30

 

30U.S. Department of Transportation, Office of the Inspector General Audit Report: 

Improvements Needed in FTA Grant Oversight Program. Report MH-2012-168 

(Washington, D.C.: Aug. 2, 2012). 

The results of 

compliance reviews are documented in written reports. Data about review 

findings are entered into FTA’s electronic oversight-tracking system, 

OTRAK. If a deficiency is identified in the course a compliance review, 

FTA requires the transit agency to take steps to correct the deficiency and 

monitors the transit agency’s progress. FTA can keep compliance reviews 

open and delay final report publication until problems are resolved, a 

resolution that could occur quickly or take years. (See fig. 2 for a 

description of the major steps in the compliance review process.)
 

Page 12 GAO-13-17 ADA Paratransit Services

Figure 2: Major Steps in the Compliance Review Process

While compliance reviews represent an in-depth examination of a transit 

agency’s paratransit service, few transit agencies have been selected for 

an ADA paratransit compliance review. FTA’s most recent contract calls 

for only 10 compliance reviews of complementary paratransit services to 
 

Page 13 GAO-13-17 ADA Paratransit Services

be conducted from 2008 through 2011, or roughly 2 to 3 reviews per 

year.31 According to FTA officials, there are approximately 628 urbanized 

area fixed-route transit agencies that could be eligible for ADA 

compliance reviews. Officials told us that the limited number of ADA 

paratransit compliance reviews conducted each year is because of

resource constraints and the time needed to complete an in-depth review.

We analyzed 15 ADA paratransit compliance review final reports from 

January 2005 through April 2011 posted on the FTA website.32

• Fourteen out of 15 agencies had findings of capacity constraints with 

their ADA paratransit service. For example, one agency was found to 

have polices around reservations and scheduling that lead to wait lists 

and difficulties ensuring scheduled ride times adhered to ADA 

requirements. Another agency had findings of non-compliance with its 

telephone access and hold times for trip scheduling because of

inadequate staffing capacity. 

We found 

that all 15 transit agencies reviewed from 2005 to 2011 had findings of 

non-compliance or recommendations related to ADA paratransit service. 

The following are examples of non-compliance findings and 

recommendations from the final reports we reviewed: 

• All 15 transit agencies reviewed also had findings related to their ADA 

paratransit eligibility processes. For example, one FTA compliance 

review found that a local transit agency was improperly denying ADA 

complementary paratransit service to some individuals who should be 

eligible. As a result, the agency proposed several changes to its 

eligibility determination process to correct the issues. In another final 

report, there were 24 findings or recommendations related to the 

transit agency’s eligibility processes. These findings ranged from 

information forms containing insufficient eligibility process detail to 

findings of non-compliance related to rider-eligibility suspension 

policy.

These compliance reviews provide some information about how 

paratransit services are complying with ADA requirements, but they do 

 

31FTA has issued a request for proposals for a new contract for conducting ADA 

compliance reviews. According to FTA officials, the new contract will provide FTA with 

more flexibility in selecting locations and transit agencies for review. 

32As of September 5, 2012, there are a total of 38 ADA compliance reviews publicly 

available on FTA’s website. They account for final reviews posted from August 2000 

through April 2011.
 

Page 14 GAO-13-17 ADA Paratransit Services

not allow for a determination of the extent to which transit agencies 

overall are complying with ADA paratransit requirements. The findings of 

non-compliance in the reports discussed above are not generalizable to 

the 628 urbanized area fixed-route transit agencies, both because of the 

low number of reviews conducted and because the reviews were not 

conducted on a generalizable sample of transit agencies. Rather, FTA 

officials told us that the transit agencies that receive the specialized 

compliance reviews are specifically selected by FTA for review because 

FTA has reason to believe those agencies may be experiencing ADA 

paratransit compliance issues.

Although FTA uses a risk-based approach to determine which transit 

agencies are selected for compliance reviews, FTA does not have a 

formalized or transparent selection process. According to FTA officials, 

transit agencies may be selected for an ADA paratransit compliance 

review for any number of reasons including rider complaints, which, 

according to FTA officials, are the best indicators available for making the 

most effective use of compliance resources, media coverage, findings 

from triennial reviews, legal actions that do not involve FTA, information 

from the transportation industry, congressional interest, and input from 

FTA regional offices.33 In selecting an agency for review, FTA may also

consider the burden to a transit agency if it were to receive multiple 

oversight reviews, such as triennial reviews or state compliance reviews, 

in the same fiscal year. In those cases, FTA officials said they take steps 

to focus contractor and oversight resources to decrease burden on the 

transit agency, while still addressing possible compliance issues. FTA 

officials, however, could not provide documentation that outlines the 

compliance review selection criteria, and stated that there are no 

formalized criteria to guide the selection of transit agencies for review. As 

discussed above, the ADA paratransit compliance review process is 

documented, so the lack of documented selection criteria is notable. 

While the factors that FTA currently uses may be appropriate for selecting 

transit agencies for an ADA compliance review, FTA’s informal process 

does not adhere to our guidance on internal control standards related to 

the communication of policy, documentation of results, and monitoring 

and reviewing of grantee activities and findings.34

 

33 General program information and policy is set at the FTA Headquarters in Washington, 

D.C. 

We have previously 

34 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1, 

p. 15.
 

Page 15 GAO-13-17 ADA Paratransit Services

reported that these standards are critical to maintaining the thoroughness 

and consistency of compliance reviews.35 The documentation should be 

readily available for examination and appear in management directives, 

administrative policies, or operating manuals. Additionally, grant 

accountability guidance states that as part of an agency’s internal control 

system, preparing policies and procedures that outline what is expected 

in any particular program or process meets an important element of 

strong federal grant accountability best practices.36

In the past, FTA examined its process for selecting agencies for 

compliance reviews but decided to retain its informal selection process. 

Specifically, in 2006, FTA commissioned a report to help develop a 

method to prioritize transit systems for ADA compliance reviews, but FTA 

did not adopt the proposed methodology.37 FTA officials told us that the 

proposed selection methodology was flawed because the selection 

criteria, such as select NTD data—fixed-route fleet size, ADA cost per 

trip, and changes in reported ADA expenses—were not indicators of noncompliance.38

In addition, FTA officials told us that all final ADA compliance review 

reports should be publicly available on FTA’s website. However, no 

additional final ADA compliance review reports have been posted to 

FTA’s website since April 2011, resulting in a lag in transit agencies’ and 

others’ access to reports and findings. As of September 5, 2012, nine

final ADA compliance review reports had not been posted on FTA’s 

FTA officials, however, said that the current selection 

factors bring problem agencies and other possible ADA compliance 

issues to their attention and serve as a good means for selecting 

agencies for review. Whatever criteria FTA deems appropriate to select 

transit agencies for review, it cannot ensure that those criteria will be 

consistently applied if they are not documented and communicated to 

FTA regional offices, contractors, and transit agencies.

 

35 GAO, Motor Carrier Safety: Federal Safety Agency Identifies Many High-Risk Carriers 

but Does Not Assess Maximum Fines as Often as Required by Law, GAO-07-584

(Washington, D.C.: Aug. 29, 2007).

36 Grant Accountability Project, Guide to Opportunities for Improving Grant Accountability, 

(Washington, D.C.: 2005). 

37 Federal Transit Administration, Team MAC Final Report on ADA Program Management 

Support Contract No. DTFT60-05-R-00013 (October 31, 2006). 

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

Page 16 GAO-13-17 ADA Paratransit Services

website. These final reports account for reviews conducted from February 

2004 through July 2010. Even though there are no official FTA 

requirements for when a report must be completed and posted on the 

website, FTA officials acknowledged that timeliness of a report’s 

completion and online posting is a problem area that they are actively 

working to address. FTA officials said the backlog of reports needing to 

be posted online was because of technical issues. According to FTA, all 

finalized ADA compliance review reports are publicly available 

documents. However, if the reports have not been posted to FTA’s 

website, then the only way to access their content is through a Freedom 

of Information Act request, which requires time and financial resources. 

Transit agencies and industry groups told us that they look to these 

compliance reviews as a form of guidance on FTA’s interpretation of ADA 

requirements. Particularly, because FTA conducts a limited number of 

ADA paratransit compliance reviews, both transit agencies and FTA 

would benefit from posting final compliance reports in a timely manner.

According to our survey of transit agencies, demand for ADA paratransit 

trips increased from 2007 to 2010. 39 Our survey indicates that demand 

increased across multiple measures, such as more riders registered to 

use ADA paratransit service and more ADA paratransit trips provided. 

Most transit agencies—about 73 percent—experienced an increase in the 

number of individuals registered to use ADA paratransit service.40

 

39 We attempted to use FTA’s NTD to obtain information regarding ADA paratransit 

demand and costs. However, we determined that it contained limited and unreliable 

information (see app. II). To collect information on ADA paratransit demand and costs, we 

surveyed a generalizable sample of transit agencies (see app. I).

In 

addition, about 64 percent of transit agencies provided more ADA 

40 This estimate has a 95 percent confidence interval of within +/- 12 percentage points of 

the estimate itself.

Demand for ADA 

Paratransit Has 

Increased for Some 

Transit Agencies, and 

Costs Remain High

Demand
 

Page 17 GAO-13-17 ADA Paratransit Services

paratransit trips in 2010 than in 2007. From 2007 to 2010, the average 

number of individuals registered to use ADA paratransit service at a 

transit agency increased by 12 percent, and the average number of ADA 

paratransit trips provided by a transit agency increased 7 percent (see 

fig. 3).

Figure 3: Average Number of Individuals Registered to Use ADA Paratransit 

Services at a Transit Agency and Average Number of ADA Paratransit Trips 

Provided by a Transit Agency, 2007 and 2010
 

Page 18 GAO-13-17 ADA Paratransit Services

Increases in demand for ADA paratransit services were driven by the 10 

largest transit agencies.41

According to transit agency officials we spoke with, demand for ADA 

paratransit trips has increased for several reasons. One frequently cited 

reason was that other organizations that provide or previously provided 

transportation services for individuals with disabilities have increasingly 

relied on ADA paratransit services for transportation—a trend sometimes 

referred to as “ride shedding.” For example, one transit agency official 

said that demand for ADA paratransit trips increased dramatically when 

local nonprofit organizations discontinued their dial-a-ride transportation 

services. Riders who formerly used the dial-a-ride services now use the 

ADA paratransit system.

ADA paratransit ridership at these transit 

agencies is substantially greater than at other transit agencies. The 

average number of individuals registered to use ADA paratransit services

at the 10 largest transit agencies increased 22 percent from 2007 to 

2010, from an average of 34,758 individuals in 2007 to 42,357 individuals 

in 2010, compared to a marginally significant average increase of 9 

percent at other transit agencies not among the 10 largest agencies. For 

the 10 largest transit agencies, the average number of riders taking at 

least one ADA paratransit trip per year increased 27 percent, from an 

average of 14,202 riders in 2007 to 18,095 riders in 2010. In addition, the 

average number of ADA paratransit trips provided by these 10 transit 

agencies increased 31 percent, from an average of 1,533,707 trips in 

2007 to 2,006,327 trips in 2010. Other transit agencies did not experience 

significant increases in the average number of riders taking at least one 

ADA paratransit trip per year or the number of ADA paratransit trips 

provided.

In addition, many transit agency officials we spoke with told us that ADA 

paratransit demand has increased because of the growing elderly 

 

41 We sent surveys to and received responses from the 10 largest transit agencies, 

measured according to the population size of their service areas. These 10 agencies 

represent 29 percent of the population in the United States served by transit. The 10 

largest transit agencies include New Jersey Transit Corporation (Newark, New Jersey), 

Access Services (El Monte, California), MTA New York City Transit (New York City, New 

York), Pace-Suburban Bus Division (Arlington Heights, Illinois), Massachusetts Bay 

Transportation Authority (Boston, Massachusetts), Southeastern Pennsylvania 

Transportation Authority (Philadelphia, Pennsylvania), Washington Metropolitan Area 

Transit Authority (Washington, D.C.), Suburban Mobility Authority for Regional 

Transportation (Detroit, Michigan), Orange County Transportation Authority (Orange, 

California), and Metropolitan Transit Authority of Harris County, Texas (Houston, Texas).
 

Page 19 GAO-13-17 ADA Paratransit Services

population. Officials pointed to the growth in the elderly population as a 

reason why more people are living with disabilities and need ADA 

paratransit services. According to 2010 U.S. census data, the population 

aged 65 and older grew 15 percent from 2000 to 2010, compared to 

growth of about 10 percent in the overall population, and the prevalence 

of disability increased with successively older age groups. Some transit 

agency officials said that ADA paratransit demand has also increased 

because of overall population growth, an increasing number of individuals 

with disabilities living independently, and improvements in ADA 

paratransit service that have made the service more attractive to riders.

ADA paratransit trips are much more costly to provide than fixed-route 

trips. Based on our survey results, the average cost of providing an ADA 

paratransit trip in 2010 was $29.30, an estimated three and a half times 

more expensive than the average cost of $8.15 to provide a fixed-route 

trip (see fig. 4).42

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

Survey respondents reported average per-trip costs for 

ADA paratransit in 2010 ranging from $11.11 to $69.25.

 

42 Cost and fare estimates are in nominal terms, unadjusted for inflation. The estimated 

costs of ADA paratransit trips ($29.30) and fixed-route trips ($8.15) are statistically 

different at the 5 percent significance level. Survey respondents reported including 

different costs in their estimates. Of the 80 survey respondents who answered a question 

about estimating ADA paratransit costs, about 93 percent of respondents reported 

including fuel costs; about 91 percent reported including vehicle maintenance costs; about 

90 percent reported including administrative costs; about 81 percent reported including

vehicle insurance costs; about 73 percent reported including information technology costs; 

about 66 percent reported including non-contractor operator wages and benefits; about 59 

percent reported including contractor operator wages and benefits; about 50 percent 

reported including other contractor costs; about 21 percent reported including vehicle 

rental and lease costs; and about 18 percent reported including other costs. 

Costs and Fares
 

Page 20 GAO-13-17 ADA Paratransit Services

The costs of providing ADA paratransit and fixed-route services differed 

between the largest transit agencies and other transit agencies. On 

average, an ADA paratransit trip cost $42.23 in 2010 for the 10 largest 

transit agencies, compared to $28.94 per trip for other transit agencies. 

For fixed-route trips, average costs in 2010 were lower for the 10 largest 

transit agencies than for other transit agencies: $3.82 for the largest 

transit agencies compared to $8.24 for others. Despite these differences, 

the 10 largest transit agencies and other transit agencies spent similar 

portions of their budgets on providing ADA paratransit services in 2010, 

14 percent and 18 percent on average, respectively.

The average costs of providing ADA paratransit and fixed-route services 

increased 10 percent and 9 percent, respectively, from 2007 to 2010. In 

our survey, transit agencies reporting increases in total costs to provide 

ADA paratransit attributed rising ADA paratransit costs to several factors. 

About 71 percent of transit agencies reported that changes in costs to 

operate vehicles—such as fuel, insurance, and vehicle maintenance 

costs—have been a major contributor to overall cost increases. At least a 

third of transit agencies cited other reasons as being major contributors to 

rising costs, including changes in labor and benefit costs,43 changes in 

the number of ADA paratransit riders, and ride shedding (see fig. 5).

 

43 This estimate has a 95 percent confidence interval of within +/- 11 percentage points of 

the estimate itself.
 

Page 21 GAO-13-17 ADA Paratransit Services

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

Services

Note: Percentages represent transit agency responses of a “major reason” for increases in the total 

cost to provide ADA paratransit services since fiscal year 2007.

Transit agency officials we spoke with identified reasons similar to survey 

respondents for rising ADA paratransit costs. More than half of the transit 

agency officials we interviewed identified rising fuel costs as a contributor 

to increasing ADA paratransit costs. For example, an official at one transit 

agency told us that although the agency has been aggressive in keeping 

ADA paratransit costs static since 2009, it is still trying to identify a good 

strategy to address high fuel costs. The official told us that fuel costs 

currently account for about 15 percent of the agency’s per-trip cost for 

ADA paratransit. In addition, almost half of the transit agency officials said 

that rising wages and benefits for employees have caused ADA 

paratransit costs to increase. Specifically, officials identified rising health 

insurance costs as contributing to overall cost increases. Officials from 

two transit agencies also told us that ride shedding has increased 

demand, resulting in overall cost increases. For example, transit agency 

officials in one location told us that a state-level agency serving 

developmentally disabled individuals went from providing transportation 

for its clients to purchasing tickets from the transit agency for ADA 

paratransit trips. For every $1 million in ADA paratransit tickets the state-
 

Page 22 GAO-13-17 ADA Paratransit Services

level agency purchases from the transit agency, it costs the transit 

agency $13 million to provide ADA paratransit services.

According to our survey, the average ADA paratransit fare was $2.09 in 

2010, far below the average cost of providing a trip (see fig. 6). This is not 

surprising given that transit agencies cannot base ADA paratransit fares 

on paratransit costs. Rather, one of the ADA requirements for 

complementary paratransit service is that transit agencies may not charge 

more than twice the average fixed-route fare for paratransit. The average

fare collected for a fixed-route trip was $1.13. Fares for ADA paratransit 

and fixed-route increased about 12 percent and 17 percent, respectively 

from 2007 to 2010.

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

Trip, 2010 

FTA’s NTD contains two fields related to ADA paratransit demand and 

costs. However, our analysis of these data found that, according to our 

standards for data reliability, they are not sufficiently reliable for the 

ADA Paratransit Data in 

NTD
 

Page 23 GAO-13-17 ADA Paratransit Services

purpose of assessing changes in ADA paratransit demand and costs.44

Transit agencies reporting to NTD are required to provide data on the 

number of ADA paratransit trips provided annually (ADA trips) and total 

annual expenditures attributable to ADA complementary paratransit 

requirements (ADA expenses). In analyzing these data, we found data 

discrepancies, such as incomplete data, that may understate or overstate 

the number of ADA trips and amount of ADA expenses. Specifically, we 

found that about one-third of transit agencies did not report these data in 

the years of data we analyzed. According to FTA officials, some transit 

agencies that should report data on ADA paratransit services did not do 

so. FTA officials also noted that of the transit agencies that do report 

data, some misunderstand the definition of ADA paratransit services and 

make reporting errors as a result. We could not determine what effect the 

non-reporting transit agencies had on the ADA paratransit services’ data 

because we could not determine how many transit agencies should have 

reported these data, but did not do so, and how many had valid reasons 

for not reporting. We also could not determine how many may have 

erroneously reported ADA paratransit data based on a misunderstanding 

of the definition of ADA paratransit trips or ADA paratransit expenses. 

The NTD is intended to provide timely, accurate information to help 

Congress and FTA apportion funding and assess the continued progress 

of the nation’s public transportation systems.

Transit agencies have implemented a number of actions aimed at 

addressing the growing demand for ADA paratransit trips and reducing 

the costs of ADA paratransit services. Types of actions agencies are 

taking include coordinating efforts among various service providers, 

transitioning passengers from ADA paratransit to fixed-route service, 

improving the accessibility of fixed-route service, ensuring more accurate 

eligibility determinations, realigning paratransit service with minimum ADA 

paratransit requirements, and improving technology for scheduling and 

dispatch.

 

44 Government auditing standards require that auditors assess the sufficiency and 

appropriateness of computer-processed information. According to GAO standards for 

assessing the reliability of computer-processed data, reliability means that data are 

reasonably complete and accurate, meet the audit’s intended purposes, and are not 

subject to inappropriate alteration. For more information about GAO’s data reliability 

standards, see GAO, Applied Research and Methods: Assessing the Reliability of 

Computer-Processed Data, GAO-09-680G (Washington, D.C.: July 2009). See appendix II 

for more information about our assessment of ADA paratransit services data in NTD. 

Transit Agencies Are 

Taking a Number of 

Actions to Address 

Paratransit Demand 

and Costs
 

Page 24 GAO-13-17 ADA Paratransit Services

To meet the needs of ADA paratransit-eligible riders, numerous transit 

agencies that we surveyed and interviewed reported that they are 

coordinating with health and human services, and other local 

transportation providers. According to our survey of transit agencies, 

about 59 percent of transit agencies are coordinating with health and 

human services providers in order to improve ADA paratransit services or 

address the costs of providing service. Also, about 44 percent of transit 

agencies are coordinating with other local transit agencies, including 6 of 

the 10 largest transit agencies. Some transit agency officials we 

interviewed also told us that they coordinate transportation services. For 

example, Lane Transit District (Lane County, Oregon) operates a one-call 

center. The call center coordinates a variety of transportation services, 

including ADA paratransit service and transportation for seniors and 

people with low incomes. According to an official, the one-call center 

makes it easier for people to access services and the agency benefits 

from efficiencies associated with providing more group trips.

Two of the transit agency officials that we spoke with said that they would 

like to implement coordination efforts, but have been unable to get 

various parties to come together. In June 2012, we reported several 

challenges that state and local entities face in their efforts to coordinate 

services for the transportation disadvantaged (a broader group than ADA 

paratransit riders), including insufficient federal leadership, changes to 

state legislation and policies, and limited financial resources in the face of 

growing unmet needs.45

Some transit agencies are transitioning passengers from ADA paratransit 

services to fixed-route service in an effort to manage demand and contain 

a portion of their costs. According to FTA officials and others, fixed-route 

systems have become much more accessible since the enactment of the 

ADA, and nearly all fixed-route buses are now accessible to and usable 

by persons with disabilities, including wheelchair users.46

 

45 GAO, Transportation Disadvantaged Populations: Federal Coordination Efforts Could 

Be Further Strengthened, 

This improved 

accessibility makes it possible to transition some passengers from 

paratransit to fixed-route services. Based on our literature review, one of 

GAO-12-647 (Washington, D.C.: June 20, 2012).

46 In some cases, the inaccessibility of sidewalks could prevent the use of fixed-route 

systems.

Coordinating Efforts 

among Various Service 

Providers

Transitioning Passengers 

from ADA Paratransit to 

Fixed-Route Service
 

Page 25 GAO-13-17 ADA Paratransit Services

the most effective and long-lasting techniques that can be employed to 

reduce the demand for ADA paratransit is transitioning paratransit 

passengers to fixed-route service through travel training and offering 

incentives to encourage existing paratransit passengers to use the fixedroute transit service, where possible, which we explain more fully below. 

One source described this as a “win-win” proposition for both the transit 

agency and the individual. The transit agency is able to use excess 

capacity on its fixed-route system at minimal cost to the agency. By using 

the fixed-route system, the passenger may be able to access a wider 

variety of services and destinations, does not have to pre-schedule travel 

on paratransit vehicles, and could save money by paying lower fares for 

fixed-route trips.47

To assist ADA paratransit riders in transitioning to fixed-route service, 

several transit agencies are using travel-training programs that help show 

riders on how they can use the fixed-route system. Our survey results 

show that about 55 percent of transit agencies use travel training as a 

demand management and cost containment strategy. Some transit 

agency officials stated that travel training may reduce costs. For example, 

King County Metro (Seattle, Washington) reported spending about 

$573,000 in 2011 to provide travel training to over 300 individuals, but 

estimated it saved about $1,290,000 in paratransit costs by successfully 

transitioning paratransit patrons to the fixed-route system. Similarly, 

officials from New Jersey Transit (Newark, New Jersey) told us that they 

have been successful in getting riders to use the fixed-route system by 

offering travel training. They have not quantified how many trips are being 

diverted from paratransit, but told us that surveys of those who have 

taken travel training show that many are using the fixed-route system.

Some transit agencies offer financial incentives to ADA paratransit eligible 

individuals to use fixed-route transit services. These incentives are also 

sometimes extended to persons accompanying the ADA paratransit 

eligible rider, which may encourage use of the fixe-route system by 

persons who cannot use it independently. Some (5 of the 20) transit 

agencies we interviewed said that they offer fixed-route fare incentives. 

For example, Access Services (Los Angeles County, California) offers 

paratransit riders free fixed-route trips on fixed-route systems throughout 

 

47 National Center for Transit Research, Center for Urban Transportation Research, 

University of South Florida, Impacts of More Rigorous ADA Paratransit Eligibility 

Assessments on Riders with Disabilities (May 2009).
 

Page 26 GAO-13-17 ADA Paratransit Services

the county. According to Access Services, in July 2012, ADA paratransit 

registrants took 2.1 million trips on Los Angeles County fixed-route 

systems. On an annual basis—assuming that over 25 million trips will be 

taken per year at a cost of $20 per trip—this represents a cost savings of 

$500 million, according to Access Services. Officials from Bay Area Rapid 

Transit (Oakland, California) also told us that they offer fare incentives to 

get ADA paratransit riders to use the fixed-route system.

Our survey results showed that over 62 percent of transit agencies 

reported making accessibility improvements to their fixed-route systems 

since 2007. Additionally, one transit agency that we spoke with said that it

has made changes to its vehicles to accommodate larger wheelchairs or 

mobility devices. Others have implemented feeder service as a way to 

transport passengers from their homes or other pick-up locations to fixedroute bus or train stops. However, according to FTA officials, one of the 

biggest challenges to using fixed route is the inaccessibility (or 

nonexistence) of sidewalks and pedestrian infrastructure. For example, 

lack of sidewalks may prevent persons with disabilities from traveling to 

fixed-route bus stops, thereby increasing the need for ADA paratransit 

services. However, such pedestrian improvements rarely fall under the 

transit system’s direct influence or control. To assist transit agencies in 

addressing these improvements, FTA issued a policy in 2011 that 

simplifies the process for grantees to qualify for FTA funding for 

pedestrian improvements that are related to transit service. Additionally, 

transit agencies are required to maintain accessibility features (e.g., 

elevators and bus lifts) in good working order and to follow ADA policies, 

such as making stop announcements, needed to make the fixed route 

usable to persons with disabilities.

A number of transit agencies are seeking to more accurately determine 

riders’ eligibility for ADA paratransit trips to manage changes in 

paratransit demand and costs. According to the National Council on 

Disability, determining eligibility for each specific trip request is one 

strategy that transit agencies are using to have at least some paratransit 

riders’ trips accommodated on the fixed-route system rather than through 

ADA paratransit.

Improving the 

Accessibility of FixedRoute Service

Ensuring More Accurate 

Eligibility Determinations
 

Page 27 GAO-13-17 ADA Paratransit Services

According to our survey, almost 49 percent of transit agencies have 

implemented a more rigorous eligibility process in an effort to manage 

costs. About 36 percent of survey respondents use an in-person 

functional assessment, including 9 of the 10 largest transit agencies.48

• Washington Metropolitan Area Transit Authority (Washington, D.C. 

area) certifies its riders’ eligibility using in-person interviews and 

functional assessments. According to an official, the process begins 

with a staff consultation in which the customer’s travel needs and 

transit knowledge are evaluated. The eligibility determination is then 

made based on: application data (including medical diagnoses from 

the customer’s health care provider), the interview, and a functional 

assessment with physical and, when needed, cognitive components.

Additionally, some of the transit agency officials we spoke with use the 

eligibility process to manage demand for paratransit service and help 

ensure that the service remains available for those passengers who need 

it. These transit agencies are using in-person interviews or functional 

assessments to determine whether a disability prevents the applicant 

from using the fixed-route system. For example:

• Metro Mobility (St. Paul, Minnesota) uses a two-part paper 

application, with an in-person functional assessment and interview, if 

needed. The application includes a self-reported questionnaire and a 

professional verification of disability.

In order to reduce costs, over 18 percent of the transit agencies we 

surveyed have realigned their paratransit service area to better match the 

minimum ADA paratransit requirement. Additionally, about 22 percent 

have realigned their paratransit service hours to better match the 

minimum ADA paratransit requirements. Officials at StarTran (Lincoln, 

Nebraska) told us that they are proposing to reduce their paratransit 

service area to the required 3⁄4 mile of fixed-route service and said that 

reducing the paratransit service area would result in considerable cost 

savings. In 2010, King County Metro projected the estimated savings if 

the agency aligned its service area, hours, service level, and fares with 

the ADA paratransit minimums. The estimated savings included $2.1 

million if the ADA minimum service area was adopted; $700,000 if service 

 

48 Functional assessments consist of specific observation or testing of a person’s abilities, 

skills, or limitations.

Realigning Paratransit 

Service with Minimum 

ADA Paratransit 

Requirements
 

Page 28 GAO-13-17 ADA Paratransit Services

hours were adjusted; $1.5 million for moving from a door-to-door to a 

curb-to-curb policy; and a savings of $1.2 million in addition to $741,000 

increased revenues if fares were adjusted to the basic adult fixed-route 

fare.49

Using available technologies such as computerized scheduling and 

dispatching software can help lower ADA paratransit service costs by 

increasing service efficiency, according to transit agency officials we 

spoke with and various studies. Officials at a majority of the transit 

agencies we spoke with (14 of 20) said that they are using available 

technologies.

• For example, Dallas Area Rapid Transit (Dallas, Texas) is using 

technology to help handle an increasing number of trips, clients, and 

vehicles. It has an automated system that allows riders to request and 

confirm trips over the phone without the need of a call taker. This 

approach makes trip requests more convenient for riders and less 

labor-intensive for the agency, thereby improving effectiveness and 

efficiency, according to transit officials.

• In 2007, New York City Transit made improvements to its automatic 

scheduling and dispatching system which schedules up to 22,500 

paratransit trips on weekdays. The improvements feature an 

intelligent transportation-system automatic-vehicle-location and 

monitoring project to equip all vehicles with vehicle-location and 

mobile-data computers, thus freeing dispatchers to take corrective 

action based on accurate data and to communicate scheduling 

changes to drivers in real-time.50

The ADA’s mandate for paratransit services has been an important 

catalyst for progress in providing equal access to public transportation for 

all individuals. Overseeing the provision of these services at hundreds of 

transit agencies is an important responsibility for FTA. ADA paratransit 

 

49 King County Auditor’s Office, Performance Audit of Transit, Report No. 2009-01D, 

(Seattle, WA: Sept. 15, 2009).

50 Implementing ITS at New York City for Para-Transit Service, William Ho and Brian 

Altschul, 15th World Congress on Intelligent Transport Systems and ITS America’s 2008 

Annual Meeting, November 16-20, 2008.

Improving Technology for 

Scheduling and Dispatch

Conclusions 
 

Page 29 GAO-13-17 ADA Paratransit Services

compliance reviews—although limited in number—examine compliance 

with ADA paratransit service requirements. As we noted, FTA selects 

agencies for review for various reasons, including rider complaints, media 

coverage, and findings from triennial reviews. However, FTA has no 

formalized criteria to guide the selection of transit agencies for review. 

Without a formalized, documented process for selecting transit agencies 

for compliance reviews, FTA is not following GAO’s internal controls and 

grantee-oversight best practices. FTA cannot ensure an effective 

oversight process if critical elements of internal controls are not present.

FTA’s process is to make publicly available, via its website, final ADA 

compliance review reports that contain findings from completed 

compliance reviews. However, nine final review reports—conducted from 

2004 to 2010—have not been posted to FTA’s website. Even though 

there are no time frames governing when a report must be posted, 

timelier posting of these reviews would be beneficial to transit agencies 

and industry groups that use these compliance reviews as a form of 

guidance on FTA’s interpretation of ADA requirements. Having these 

publicly available, as soon as possible, could assist FTA in its oversight of 

transit agencies and assist transit agencies in their compliance efforts.

Finally, transit agencies reporting to NTD are required to provide limited 

data related to ADA paratransit services, including the number of ADA 

paratransit trips provided annually and total annual expenditures 

attributable to ADA paratransit requirements. We found that the required 

data fields were often incomplete. For example, for data from 2005 to 

2010, the most recent year available, about 32 percent of transit agencies 

reporting to NTD did not provide data in one or more years on the number 

of ADA trips provided. Because the NTD is intended to provide timely and 

accurate information to Congress and others, FTA would benefit from 

advising transit agencies on how to accurately and consistently provide 

the required data.

We recommend that the Secretary of Transportation direct the FTA 

Administrator to take the following actions:

1. To help ensure that FTA’s ADA paratransit compliance reviews 

adhere to GAO recommended internal controls and grantee oversight 

best practices, document and make publicly available a formal 

selection approach for selecting transit agencies for review. 

Recommendations for 

Executive Action
 

Page 30 GAO-13-17 ADA Paratransit Services

2. To help transit agencies and stakeholders have access to up-to-date 

ADA paratransit compliance reviews and compliance findings, post 

the backlog of ADA compliance review final reports on FTA’s website 

and establish processes for the timely posting of future compliance 

review reports.

3. To improve NTD data collection for ADA paratransit, provide guidance 

to transit agencies on how to accurately complete existing ADA 

paratransit fields.

We provided DOT with a draft of this report and the e-supplement for 

review and comment. DOT officials neither agreed nor disagreed with our 

recommendations, but provided technical comments, which we 

incorporated as appropriate. DOT did not have any comments on the esupplement. DOT officials stated that FTA uses consumer complaints as 

programmatic criteria to identify areas of potential noncompliance and 

considers complaints to be the best available indicator of where to target 

its limited investigative resources. DOT officials reiterated that paratransit 

data collected for the NTD are intended to provide information useful for 

FTA’s monitoring of the size of ADA paratransit services relative to 

demand response services. According to DOT officials, these data are not 

intended to assess overall ADA paratransit compliance.

We are sending copies of this report to interested congressional 

committees, the Secretary of Transportation, and the Administrator of the 

Federal Transit Administration. We also will make copies available to 

others upon request. In addition, this report will be available at no charge 

on GAO’s Web site at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

David Wise at 202-512-2834 or wised@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made major contributions to 

this report are listed in appendix IV.

David Wise

Director, Physical Infrastructure

Agency Comments
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-13-17 ADA Paratransit Services

This report addresses the following three objectives: 

(1) What is known about the extent of compliance with the Americans 

with Disabilities Act of 1990 (ADA) paratransit requirements? 

(2) What changes have occurred in ADA paratransit demand and 

costs since 2007?

(3) What actions are agencies taking to help address changes in the 

demand for and costs of ADA paratransit service?

To determine what is known about the extent of compliance with ADA 

paratransit requirements, we reviewed ADA regulations, the Federal 

Transit Administration (FTA) guidance on the regulations, and FTA’s ADA 

compliance reports from 2005 to 2011. In addition, we examined FTA’s 

National Transit Database to assess the extent to which it contains data 

related to ADA paratransit services and transit agencies’ compliance with 

ADA paratransit requirements. We also interviewed FTA officials about 

the various processes it uses to assess compliance and consulted our 

prior work on transportation accessibility and FTA’s oversight processes.

To identify changes that have occurred in ADA paratransit demand and 

costs since 2007, we examined data from FTA’s National Transit 

Database on the number of ADA paratransit trips provided annually and 

total annual expenditures attributable to ADA complementary paratransit 

requirements. In reviewing National Transit Database data, we 

determined that they were not reliable for our purposes. Appendix II 

contains a more detailed discussion of our data reliability assessment.

To address our second and third objectives, we conducted semi 

structured interviews with 20 transit agencies regarding their provision of 

ADA paratransit services. We based our selection of these transit 

agencies based on a variety of characteristics, including geographic 

diversity, size of ADA paratransit system, and transit agencies deemed 

notable for their ADA paratransit systems. Because we used a nongeneralizable sample of transit agencies, findings from these interviews 

cannot be used to make inferences about other transit agencies. 

However, we determined that the selection of these transit agencies was 

appropriate for our design and objectives and that the selection would 

generate valid and reliable evidence to support our work. Table 3

provides more detailed information about the transit agencies we 

interviewed.

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-13-17 ADA Paratransit Services

Table 3: Transit Agency Interviews

FTA region Transit agency Transit agency location

FTA Region 1 Massachusetts Bay Transportation Authority Boston, Massachusetts

The Greater New Haven Transit District Hamden, Connecticut

FTA Region 2 New Jersey Transit Corporation Newark, New Jersey

Niagara Frontier Transportation Authority Buffalo, New York

FTA Region 3 Washington Metropolitan Area Transit Authority Washington, D.C.

ACCESS Transportation Systems, Inc.a Pittsburg, Pennsylvania

FTA Region 4 Transit Authority of River City Louisville, Kentucky

Board of County Commissioners, Palm Beach County, PalmTran, Inc. West Palm Beach, Florida

FTA Region 5 Metropolitan Council - Metro Mobility St. Paul, Minnesota

Toledo Area Regional Transit Authority Toledo, Ohio

FTA Region 6 Dallas Area Rapid Transit Dallas, Texas

Capital Metropolitan Transportation Authority Austin, Texas

FTA Region 7 Bi-State Development Agency (METRO) St. Louis, Missouri

StarTran Lincoln, Nebraska

FTA Region 8 Utah Transit Authority Salt Lake City, Utah

Billings Metropolitan Transit Billings, Montana

FTA Region 9 Access Servicesb El Monte, California

San Francisco Bay Area Rapid Transit District / Alameda-Contra Costa 

Transit Districtc Oakland, California

FTA Region 10 King County Metro Seattle, Washington

Lane Transit District Eugene, Oregon

Source: GAO.

a

ACCESS Transportation Systems, Inc. is the ADA paratransit broker sponsored by the Port Authority 

of Allegheny County.

b

Access Services provides ADA paratransit services on the behalf of public transit agencies in Los 

Angeles County.

c

San Francisco Bay Area Rapid Transit and Alameda-Contra Costa Transit District partner to provide 

ADA paratransit services through a cooperative entity called East Bay Paratransit.

We also interviewed representatives from relevant industry and disability 

advocacy groups, including the following:

• American Public Transportation Association, 

• Community Transportation Association of America, 

• Disability Rights Education and Defense Fund, 

• Easter Seals Project ACTION, 

• National Independent Living Council, and

• Texas Statewide Council on Independent Living. 
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-13-17 ADA Paratransit Services

Moreover, to identify the actions that transit agencies are taking to help 

address changes in costs of and demand for ADA paratransit service, we 

reviewed relevant literature pertaining to leading practices for addressing 

costs and demand of paratransit services.

We conducted a Web-based survey of transit agencies from May through 

July, 2012 to address the second and third objectives questions. Results 

of this survey and the survey instrument have been published in 

GAO-13-18SP ADA PARATRANSIT SERVICES: Survey of Public Transit 

Agency Officials on Services and Costs, an E-supplement to GAO-13-17

and can be found at the GAO website.

We constructed our population of transit agencies for our survey sample 

using 2010 data in FTA’s National Transportation Database (NTD). Using 

NTD data, we determined that there were 546 agencies that provided 

demand response services, which according to FTA, was the mode of 

service most likely to correlate with provision of ADA paratransit 

services.1

 

1 We assessed NTD data on the transit agencies that provided demand response services 

in 2010 by reviewing documentation about the dataset, taking steps to check 

completeness of the data, and when discrepancies occurred, resolving issues by 

contacting FTA officials. We determined that the NTD data on transit agencies that 

provided demand response services in 2010 were sufficiently reliable for the purpose of 

constructing our sample.

The total survey sample was 145 transit agencies. The survey 

sample was composed of two strata. One was a certainty sample of 10 

transit agencies that, based on NTD data, were the top 10 transit 

agencies based on service area population in 2010, accounting for 29 

percent of the total service area population in our total sample. The 

second stratum was ordered by population size and selected randomly to 

obtain representation from agencies with populations of various sizes. For 

this stratum we randomly selected 135 transit agencies that provide 

demand-response service from the remaining population after the 

certainty sample, a population of 536 agencies. We obtained completed 

questionnaires from 112 respondents, or about 77 percent of our sample. 

The survey results can be generalized to the population of transit 

agencies that provide demand-response service. And as noted above, we 

are issuing an electronic supplement to this report that shows a more 

complete tabulation of our survey results.

ADA Paratransit 

Services Survey

Survey Population and 

Sample Design
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-13-17 ADA Paratransit Services

We developed a questionnaire to obtain information about transit 

agencies’ provision of ADA paratransit services. GAO identified potential 

survey recipients from a list provided by FTA on its Urban Agency CEO

Contact list. In early May 2012, an initial email alerting agency contacts to 

the upcoming web-based survey was sent and about a week later, the 

web-based survey was also delivered to recipients via email message.

The web-based survey questionnaire requested baseline information 

about service and eligibility processes as well as information related to 

the cost, demand, and policies and practices transit agencies use to 

improve provision of ADA paratransit service. To help increase our 

response rate, we sent two follow-up emails and called agency officials 

from May through July 2012. The survey was available to transit agency 

respondents from May 2012 through July 2012.

To pretest the questionnaire, we conducted cognitive interviews and held 

debriefing sessions with five local transit agency officials with knowledge 

about their ADA paratransit operations. Three pretests were conducted 

in-person with phone participants while two were conducted solely on the 

phone. We selected pretest respondents to represent different sizes and 

locations of transit agencies that provide ADA paratransit service. We 

conducted these pretest to determine if the questions were burdensome, 

understandable and measured what we intended. Additionally we asked 

officials in FTA’s Office of Civil Rights to review the questionnaire based 

on their expertise and knowledge of the program and interviewed them for 

their feedback on the survey questionnaire. On the basis of feedback 

from the pretests and expert review we modified the questions as 

appropriate.

To produce the estimates from this survey, answers from each 

responding case were weighted in the analysis to account statistically for 

all the members of the population, including those who were not selected 

or did not respond to the survey. Estimates produced from this sample 

are from the population of transit agencies that provided demand 

response services in the FTA’s 2010 National Transit Database.

Because our results are based on a sample and different samples could 

provide different estimates, we express our confidence in the precision of 

our particular sample’s results as a 95 percent confidence interval (for 

example, plus or minus 10 percentage points). We are 95 percent 

confident that each of the confidence intervals in this report include the 

true values in the study population. Unless we note otherwise, percentage 

estimates based on all transit agencies have 95 percent confidence 

Administration of Survey 

and Quality Assurance

Sampling Error and 

Estimation 
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-13-17 ADA Paratransit Services

intervals of within plus or minus 10 percentage points. Confidence 

intervals for other estimates are presented along with the estimate where 

used in the report.

In addition to the reported sampling errors, the practical difficulties of 

conducting any survey may introduce other types of errors, commonly 

referred to as nonsampling errors. For example, differences in how a 

particular question is interpreted, the sources of information available to 

respondents, or the types of people who do not respond can introduce 

unwanted variability into the survey results. We included steps in both the 

data collection and data analysis stages for the purpose of minimizing 

such nonsampling errors.

We took the following steps to increase the response rate: developing the 

questionnaire, pretesting the questionnaires with transit agencies that 

provide ADA paratransit service, conducting multiple follow-ups to 

encourage responses to the survey and contacting respondents to clarify 

unclear responses.

We conducted this performance audit from September 2011 to November 

2012 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

Non-Sampling Error
Appendix II: Reliability of ADA Paratransit Data 

in FTA’s National Transit Database

Page 36 GAO-13-17 ADA Paratransit Services

We conducted an analysis to determine whether ADA paratransit data in 

the NTD1 were sufficiently reliable for the purpose of identifying changes 

that have occurred in ADA paratransit demand and costs since 2007. We 

examined data on ADA paratransit trips and ADA paratransit expenses 

from 2005 to 2010 and interviewed FTA officials about the database. We 

found data discrepancies, such as incomplete data, that may understate 

or overstate the number of ADA trips and amount of ADA expenses. As a 

result, we determined that the ADA paratransit data in the NTD were not 

sufficiently reliable for the purposes of our review.2

To identify changes that have occurred in ADA paratransit demand and 

costs since 2007, we examined data from the NTD on the number of ADA 

paratransit trips provided annually (ADA trips) and total annual 

expenditures attributable to ADA complementary paratransit requirements 

(ADA expenses). We examined data for all transit agencies reporting 

these two data fields from 2005 through 2010, the most recent year of 

data available at the time of our review. We chose to assess data for 

2005 through 2010 because we wanted to identify the extent to which we 

could report trends in data over this series of years. In addition, we chose 

to analyze data for these two fields because they are the only two fields 

 

1 The National Transit Database was established by the Congress to be the nation’s 

primary source for information and statistics on transit systems in the United States. 

Recipients and beneficiaries of grants from FTA under the Urbanized Area Formula 

Program (49 U.S.C. § 5307) or Other than Urbanized Area (Rural) Formula Program (49 

U.S.C. § 5311) are required by statute to submit data to the NTD. 49 U.S.C. § 5335. Over 

690 urbanized-area transit providers currently report to NTD on a variety of variables, 

including information on operating expenses, revenue, services, and relationships with 

contractors.

2 Government auditing standards require that auditors assess the sufficiency and 

appropriateness of computer-processed information. According to GAO standards for 

assessing the reliability of computer-processed data, reliability means that data are 

reasonably complete and accurate, meet the audit’s intended purposes, and are not 

subject to inappropriate alteration. For more information about GAO’s data reliability 

standards, see GAO, Applied Research and Methods: Assessing the Reliability of 

Computer-Processed Data, GAO-09-680G (Washington, D.C.: July 2009). 

Appendix II: Reliability of ADA Paratransit 

Data in FTA’s National Transit Database

Methodology 
Appendix II: Reliability of ADA Paratransit Data 

in FTA’s National Transit Database

Page 37 GAO-13-17 ADA Paratransit Services

related to ADA paratransit in the NTD.3

To determine whether the NTD data on ADA trips and ADA expenses 

would be reliable for our purposes, we interviewed FTA officials who are 

knowledgeable about the design and uses of the NTD data. We also 

assessed the data’s accuracy and completeness by analyzing the extent 

to which transit agencies reported these two data fields for all 6 years of 

interest. In addition, we compared the NTD data to data from our 

generalizable survey of transit agencies.

We found that the NTD does not 

contain a data field that asks transit agencies whether they are required 

to provide ADA paratransit services.

Our analysis found that about one-third of transit agencies reporting ADA 

paratransit data did not report these data in all 6 years of data we 

analyzed. We found that, when analyzing data from transit agencies that 

reported providing ADA trips in at least one year from 2005 to 2010, 

about 32 percent of the agencies did not provide data in one or more of 

the years of interest. Similarly, about 30 percent of transit agencies 

reporting ADA expenses in at least one year from 2005 to 2010 did not 

report data for all 6 years of interest (see table 4). Some of the transit 

agencies that did not report data for all 6 years skipped years of 

reporting—for instance, an agency might have reported in 2005, 2009, 

and 2010. Other transit agencies reported data for consecutive years, but 

not for all of the 6 years—for instance, they reported data in 2005, 2006, 

and 2007. Since the NTD does not contain a field regarding whether 

transit agencies are required to provide ADA paratransit services in a 

particular year, we could not assess whether those transit agencies 

reporting for fewer than 6 years were in error. In addition, we found that 

although larger transit agencies were less likely than smaller transit 

agencies to have missing data, the missing data from larger transit 

agencies—because they provide more ADA paratransit trips than smaller 

transit agencies—would probably have a greater impact on the overall 

data.

 

3 The NTD primarily collects data by mode of public transportation, including modes such 

as commuter rail, light rail, ferryboat, bus, and demand response. The demand response 

mode includes ADA paratransit service and other generic demand-responsive services 

that are unrelated to ADA requirements. As part of the reporting requirements for the 

demand response mode, transit agencies are required to report on the number of ADA 

paratransit trips provided annually and the total annual expenditures attributable to ADA 

complementary paratransit requirements.

Results of Analysis
Appendix II: Reliability of ADA Paratransit Data 

in FTA’s National Transit Database

Page 38 GAO-13-17 ADA Paratransit Services

Table 4: Percentage of Transit Agencies Reporting ADA Trips and ADA Expenses in 

NTD, 2005 through 2010

Percentage of transit agencies

reporting data in all 6 years

Percentage of transit agencies

reporting data in less than 6 years

ADA Trips 67.7 32.3

ADA Expenses 69.6 30.4

Source: GAO analysis of NTD data.

We could not determine how many of the transit agencies that did not 

report data in all 6 years should have reported these data, and how many 

had legitimate reasons for not reporting in all years. FTA officials told us 

about cases in which transit agencies should report ADA paratransit data 

to NTD, but fail to do so. They also told us about cases in which valid 

reasons exist for transit agencies not to report data every year. Transit 

agencies may receive reporting waivers, for example because of

hurricanes or other natural disasters, that make the agencies exempt 

from reporting any data to NTD. Transit agencies may also introduce or 

discontinue ADA paratransit services for various reasons, which can lead 

to the appearance of missing data. It is not possible to tell from the data, 

however, whether these missing data are because of valid reasons, such 

as reporting waivers or changes in service or because of a transit 

agency’s failure to report. In addition, transit agencies may misunderstand 

the definition of ADA paratransit service and make reporting errors as a 

result—they may report ADA trips and ADA expenses erroneously one 

year because they think their specialized, demand-responsive service 

counts as ADA paratransit service, even though the service is not 

provided in order to comply with the ADA. When agencies correct the 

reporting error in subsequent years and do not report these data, it can 

appear that they have failed to report consistently. According to FTA 

officials, it is difficult to verify whether transit agencies that report ADA 

paratransit data are indeed reporting about ADA paratransit services, or 

whether they are reporting about generic demand-responsive services.

Without a field identifying those transit agencies that provide ADA 

paratransit, we attempted to use another field—those transit agencies 

that reported providing demand-response service—as a proxy to help 

determine which transit agencies should and should not report ADA 

paratransit data. Demand response is a broad service category that 

includes ADA paratransit service. Our analysis found that in each year 

from 2005 to 2010, 22 percent to 26 percent of transit agencies that 

reported providing demand-response service did not report providing ADA 

trips or having ADA expenses (see table 5).
Appendix II: Reliability of ADA Paratransit Data 

in FTA’s National Transit Database

Page 39 GAO-13-17 ADA Paratransit Services

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

through 2010

Percentage of transit

agencies reporting demand

response service, but not

ADA trips or ADA expenses

Percentage of transit

agencies reporting demand

response service and ADA

trips, but not ADA expenses

Percentage of transit

agencies reporting demand

response service and ADA

expenses, but not ADA trips

Percentage of transit

agencies reporting demand

response service, ADA

trips, and ADA expenses

2005 22.4 0.2 2.0 75.4

2006 21.6 0.4 2.9 75.1

2007 23.3 0.0 0.8 75.9

2008 25.7 0.6 0.2 73.7

2009 25.2 0.2 0.4 74.3

2010 26.2 0.4 0.5 72.9

Source: GAO analysis of NTD data.

Based on results from our survey of transit agencies, only about 9 percent 

of transit agencies reported providing demand-response service but not 

ADA paratransit service—a lower percentage than the 22 to 26 percent 

that were found to report demand response service but not ADA trips or 

ADA expenses to the NTD. This suggests that some of the transit 

agencies reporting demand response service but not ADA trips or ADA 

expenses do indeed provide ADA paratransit services—and should have 

reported ADA trips and ADA expenses.

We could not determine what effect the non-reporting transit agencies 

had on the ADA paratransit services data because we could not 

determine how many transit agencies should have reported, but did not 

do so; how many had valid reasons for not reporting; and how many may 

have over-reported based on misunderstanding the definition of ADA trips 

or ADA expenses. As a result, we determined that the ADA paratransit 

services data available in NTD were not sufficiently complete and 

therefore were not reliable for our purposes, which were to provide 

information on changes in ADA paratransit demand and costs since 2007.
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 40 GAO-13-17 ADA Paratransit Services

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

In addition to the individual named above, other key contributors to this 

report were Heather MacLeod, Assistant Director; Robert Alarapon; 

Dwayne Curry; Kathleen Gilhooly; Timothy Guinane; Delwen Jones; 

Katherine Killebrew; Luann Moy; Beverly Ross; Sonya Vartivarian; and 

Betsey Ward.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(542195)
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