ADA Paratransit Services: Demand Has Increased, but Little is Known about Compliance
Published: 2012-11-15T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.
section_title: What GAO Recommends
paragraphs: 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.

section_title: Letter
paragraphs: 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.” 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. U.S. Senate and House of Representative reports  accompanying the ADA stated that paratransit service was often  inadequate; 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.ADA established requirements for who was eligible for ADA paratransit   Regulations issued under the  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   As a result, many transit agencies are  growing paratransit ridership.pursuing methods to contain paratransit costs while maintaining ADA  compliance.
In this context, you asked us to review the provision of ADA paratransit  service. We addressed the following questions:   (1)  What is known about the extent of compliance with ADA  paratransit requirements?   (2)  What changes have occurred in ADA paratransit demand and  costs since 2007?   (3)  What actions are transit agencies taking to help address changes  in the demand for and costs of ADA paratransit service?
To determine what is known about the extent of compliance with ADA  paratransit requirements, we reviewed ADA regulations, FTA guidance on  the regulations, and FTA’s ADA compliance reports from 2005 to 2011. In  addition, we examined FTA’s National Transit Database (NTD) to assess  the extent to which it contains data related to ADA paratransit services  and transit agencies’ compliance with ADA paratransit requirements. We  also interviewed FTA officials about how the agency assesses  compliance and consulted our prior work on transportation accessibility.  To identify changes that have occurred in ADA paratransit demand and  costs, we examined data from the NTD on the number of ADA paratransit  trips provided annually and total annual expenditures attributable to ADA  complementary paratransit requirements. In reviewing NTD data on ADA  paratransit services, we determined that they were not reliable for our  purpose, which was to assess changes in ADA paratransit demand and  costs. Appendix II contains a more detailed discussion of our data  reliability assessment. To identify changes that have occurred in ADA  paratransit demand and costs since 2007 and to determine what actions  agencies are taking to help address such changes, we conducted a  generalizable Web-based survey of transit agencies from May through  July 2012. We identified 546 transit agencies that provided demand-  response service in 2010 and sampled 145 of these agencies for  participation in the survey. 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. 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. To  address our second and third objectives, we conducted semi-structured  interviews with 20 transit agencies regarding their provision of ADA  paratransit services. We selected transit agencies to interview based on  the size of the agency (small and large, measured according to the  number of ADA paratransit trips provided in 2010); geographic diversity;  and other factors. We also interviewed representatives from relevant  industry and disability advocacy groups. In addition, to identify the actions  that transit agencies are taking to help address changes in demand for  and costs of ADA paratransit service, we reviewed relevant literature  pertaining to leading practices for addressing demand for and costs of  paratransit services. Appendix I contains a more detailed discussion of  our objectives, scope, and methodology.
We conducted this performance audit from September 2011 to November  2012 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: 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. 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.
subsections: section_title: ADA Paratransit Requirements
paragraphs: DOT issued final regulations to implement the ADA’s public transportation  provisions on August 22, 1991.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.
The regulations do not explicitly state  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).
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.are allowed to establish whether they will provide door-to-door service,  wherein the driver offers assistance from the rider’s door to the vehicle  (and comparable assistance at the destination), or curb-to-curb service,  wherein assistance is not provided until the rider reaches the vehicle.  According to DOT guidance, if the base model of service chosen is curb- to-curb, it may still be necessary to provide door-to-door service for those   Transit agencies  persons who require it in order to travel from their point of origin to their  point of destination.
section_title: ADA Paratransit Eligibility Process
paragraphs: 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. 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. 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.
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. 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.
section_title: Providing ADA Paratransit Service
paragraphs: 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. 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).
Two federal agencies, DOT and the Department of Justice (DOJ), have  key roles in monitoring, overseeing, and enforcing ADA requirements and  providing technical assistance. Their general roles and responsibilities  are as follows:
Regulations. The Secretary of Transportation has sole authority to  issue regulations to carry out the section of the ADA governing  paratransit as a complement to fixed-route service.  FTA has primary  responsibility for administering these regulations.
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. Civil rights reviews are one  of five types of special reviews. 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,  and can be  targeted to one of three specific ADA areas: fixed-route compliance,  rail station compliance, and ADA paratransit service compliance.  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. Transit agencies reporting to NTD are required to provide  two data points related to ADA paratransit services: the number of  ADA paratransit trips provided annually and total annual expenditures  for paratransit services that are attributable to ADA requirements.
Enforcement. DOJ’s ADA enforcement responsibility generally  involves either filing a federal lawsuit upon referral of a finding of  noncompliance by DOT or by intervening in a privately filed lawsuit.  DOJ may also resolve complaints of ADA noncompliance through  settlement agreements and consent decrees with public transit  agencies aimed at obtaining ADA compliance.
section_title: Little Is Known about ADA Compliance for Paratransit
paragraphs: 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.  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. According to  FTA officials, negative triennial review findings may be considered in selecting transit agencies for a specialized ADA paratransit review.
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. 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.)
While compliance reviews represent an in-depth examination of a transit  agency’s paratransit service, few transit agencies have been selected for  an ADA paratransit compliance review. FTA’s most recent contract calls  for only 10 compliance reviews of complementary paratransit services to  be conducted from 2008 through 2011, or roughly 2 to 3 reviews per  year. 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. We found  that all 15 transit agencies reviewed from 2005 to 2011 had findings of  non-compliance or recommendations related to ADA paratransit service.  The following are examples of non-compliance findings and  recommendations from the final reports we reviewed:
Fourteen out of 15 agencies had findings of capacity constraints with  their ADA paratransit service. For example, one agency was found to  have polices around reservations and scheduling that lead to wait lists  and difficulties ensuring scheduled ride times adhered to ADA  requirements. Another agency had findings of non-compliance with its  telephone access and hold times for trip scheduling because of  inadequate staffing capacity.
All 15 transit agencies reviewed also had findings related to their ADA  paratransit eligibility processes. For example, one FTA compliance  review found that a local transit agency was improperly denying ADA  complementary paratransit service to some individuals who should be  eligible. As a result, the agency proposed several changes to its  eligibility determination process to correct the issues. In another final  report, there were 24 findings or recommendations related to the  transit agency’s eligibility processes. These findings ranged from  information forms containing insufficient eligibility process detail to  findings of non-compliance related to rider-eligibility suspension  policy.
These compliance reviews provide some information about how  paratransit services are complying with ADA requirements, but they do  not allow for a determination of the extent to which transit agencies  overall are complying with ADA paratransit requirements. The findings of  non-compliance in the reports discussed above are not generalizable to  the 628 urbanized area fixed-route transit agencies, both because of the  low number of reviews conducted and because the reviews were not  conducted on a generalizable sample of transit agencies. Rather, FTA  officials told us that the transit agencies that receive the specialized  compliance reviews are specifically selected by FTA for review because  FTA has reason to believe those agencies may be experiencing ADA  paratransit compliance issues.
Although FTA uses a risk-based approach to determine which transit  agencies are selected for compliance reviews, FTA does not have a  formalized or transparent selection process. According to FTA officials,  transit agencies may be selected for an ADA paratransit compliance  review for any number of reasons including rider complaints, which,  according to FTA officials, are the best indicators available for making the  most effective use of compliance resources, media coverage, findings  from triennial reviews, legal actions that do not involve FTA, information  from the transportation industry, congressional interest, and input from  FTA regional offices. 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   We have previously  and reviewing of grantee activities and findings.reported that these standards are critical to maintaining the thoroughness  and consistency of compliance reviews. 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.
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. proposed selection methodology was flawed because the selection  criteria, such as select NTD data—fixed-route fleet size, ADA cost per  trip, and changes in reported ADA expenses—were not indicators of non- compliance. 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.
Federal Transit Administration, Team MAC Final Report on ADA Program Management  Support Contract No. DTFT60-05-R-00013 (October 31, 2006). 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.
section_title: Demand for ADA Paratransit Has Increased for Some Transit Agencies, and Costs Remain High
subsections: section_title: Demand
paragraphs: According to our survey of transit agencies, demand for ADA paratransit  trips increased from 2007 to 2010.  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.addition, about 64 percent of transit agencies provided more ADA   In  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).
Increases in demand for ADA paratransit services were driven by the 10  largest transit agencies. ADA paratransit ridership at these transit  agencies is substantially greater than at other transit agencies. The  average number of individuals registered to use ADA paratransit services  at the 10 largest transit agencies increased 22 percent from 2007 to  2010, from an average of 34,758 individuals in 2007 to 42,357 individuals  in 2010, compared to a marginally significant average increase of 9  percent at other transit agencies not among the 10 largest agencies. For  the 10 largest transit agencies, the average number of riders taking at  least one ADA paratransit trip per year increased 27 percent, from an  average of 14,202 riders in 2007 to 18,095 riders in 2010. In addition, the  average number of ADA paratransit trips provided by these 10 transit  agencies increased 31 percent, from an average of 1,533,707 trips in  2007 to 2,006,327 trips in 2010. Other transit agencies did not experience  significant increases in the average number of riders taking at least one  ADA paratransit trip per year or the number of ADA paratransit trips  provided.
According to transit agency officials we spoke with, demand for ADA  paratransit trips has increased for several reasons. One frequently cited  reason was that other organizations that provide or previously provided  transportation services for individuals with disabilities have increasingly  relied on ADA paratransit services for transportation—a trend sometimes  referred to as “ride shedding.” For example, one transit agency official  said that demand for ADA paratransit trips increased dramatically when  local nonprofit organizations discontinued their dial-a-ride transportation  services. Riders who formerly used the dial-a-ride services now use the  ADA paratransit system.
In addition, many transit agency officials we spoke with told us that ADA  paratransit demand has increased because of the growing elderly  population. Officials pointed to the growth in the elderly population as a  reason why more people are living with disabilities and need ADA  paratransit services. According to 2010 U.S. census data, the population  aged 65 and older grew 15 percent from 2000 to 2010, compared to  growth of about 10 percent in the overall population, and the prevalence  of disability increased with successively older age groups. Some transit  agency officials said that ADA paratransit demand has also increased  because of overall population growth, an increasing number of individuals  with disabilities living independently, and improvements in ADA  paratransit service that have made the service more attractive to riders.
section_title: Costs and Fares
paragraphs: 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). Survey respondents reported average per-trip costs for  ADA paratransit in 2010 ranging from $11.11 to $69.25.
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.
section_title: Transit Agencies Are Taking a Number of Actions to Address Paratransit Demand and Costs
paragraphs: 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.
subsections: section_title: Coordinating Efforts among Various Service Providers
paragraphs: 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.
section_title: Transitioning Passengers from ADA Paratransit to Fixed-Route Service
paragraphs: 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   This improved  by persons with disabilities, including wheelchair users.accessibility makes it possible to transition some passengers from  paratransit to fixed-route services. Based on our literature review, one of  the most effective and long-lasting techniques that can be employed to  reduce the demand for ADA paratransit is transitioning paratransit  passengers to fixed-route service through travel training and offering  incentives to encourage existing paratransit passengers to use the fixed- route transit service, where possible, which we explain more fully below.  One source described this as a “win-win” proposition for both the transit  agency and the individual. The transit agency is able to use excess  capacity on its fixed-route system at minimal cost to the agency. By using  the fixed-route system, the passenger may be able to access a wider  variety of services and destinations, does not have to pre-schedule travel  on paratransit vehicles, and could save money by paying lower fares for  fixed-route trips.
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  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.
section_title: Improving the Accessibility of Fixed- Route Service
paragraphs: Our survey results showed that over 62 percent of transit agencies  reported making accessibility improvements to their fixed-route systems  since 2007. Additionally, one transit agency that we spoke with said that it  has made changes to its vehicles to accommodate larger wheelchairs or  mobility devices. Others have implemented feeder service as a way to  transport passengers from their homes or other pick-up locations to fixed- route bus or train stops. However, according to FTA officials, one of the  biggest challenges to using fixed route is the inaccessibility (or  nonexistence) of sidewalks and pedestrian infrastructure. For example,  lack of sidewalks may prevent persons with disabilities from traveling to  fixed-route bus stops, thereby increasing the need for ADA paratransit  services. However, such pedestrian improvements rarely fall under the  transit system’s direct influence or control. To assist transit agencies in  addressing these improvements, FTA issued a policy in 2011 that  simplifies the process for grantees to qualify for FTA funding for  pedestrian improvements that are related to transit service. Additionally,  transit agencies are required to maintain accessibility features (e.g.,  elevators and bus lifts) in good working order and to follow ADA policies,  such as making stop announcements, needed to make the fixed route  usable to persons with disabilities.
section_title: Ensuring More Accurate Eligibility Determinations
paragraphs: A number of transit agencies are seeking to more accurately determine  riders’ eligibility for ADA paratransit trips to manage changes in  paratransit demand and costs. According to the National Council on  Disability, determining eligibility for each specific trip request is one  strategy that transit agencies are using to have at least some paratransit  riders’ trips accommodated on the fixed-route system rather than through  ADA paratransit.
According to our survey, almost 49 percent of transit agencies have  implemented a more rigorous eligibility process in an effort to manage  costs. About 36 percent of survey respondents use an in-person functional assessment, including 9 of the 10 largest transit agencies.Additionally, some of the transit agency officials we spoke with use the  eligibility process to manage demand for paratransit service and help  ensure that the service remains available for those passengers who need  it. These transit agencies are using in-person interviews or functional  assessments to determine whether a disability prevents the applicant  from using the fixed-route system. For example:
Washington Metropolitan Area Transit Authority (Washington, D.C.  area) certifies its riders’ eligibility using in-person interviews and  functional assessments. According to an official, the process begins  with a staff consultation in which the customer’s travel needs and  transit knowledge are evaluated. The eligibility determination is then  made based on: application data (including medical diagnoses from  the customer’s health care provider), the interview, and a functional  assessment with physical and, when needed, cognitive components.
Metro Mobility (St. Paul, Minnesota) uses a two-part paper  application, with an in-person functional assessment and interview, if  needed. The application includes a self-reported questionnaire and a  professional verification of disability.
section_title: Realigning Paratransit Service with Minimum ADA Paratransit Requirements
paragraphs: In order to reduce costs, over 18 percent of the transit agencies we  surveyed have realigned their paratransit service area to better match the  minimum ADA paratransit requirement. Additionally, about 22 percent  have realigned their paratransit service hours to better match the  minimum ADA paratransit requirements. Officials at StarTran (Lincoln,  Nebraska) told us that they are proposing to reduce their paratransit  service area to the required ¾ mile of fixed-route service and said that  reducing the paratransit service area would result in considerable cost  savings. In 2010, King County Metro projected the estimated savings if  the agency aligned its service area, hours, service level, and fares with  the ADA paratransit minimums. The estimated savings included $2.1  million if the ADA minimum service area was adopted; $700,000 if service  hours were adjusted; $1.5 million for moving from a door-to-door to a  curb-to-curb policy; and a savings of $1.2 million in addition to $741,000  increased revenues if fares were adjusted to the basic adult fixed-route  fare.
section_title: Improving Technology for Scheduling and Dispatch
paragraphs: 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.
section_title: Conclusions
paragraphs: The ADA’s mandate for paratransit services has been an important  catalyst for progress in providing equal access to public transportation for  all individuals. Overseeing the provision of these services at hundreds of  transit agencies is an important responsibility for FTA. ADA paratransit  compliance reviews—although limited in number—examine compliance  with ADA paratransit service requirements. As we noted, FTA selects  agencies for review for various reasons, including rider complaints, media  coverage, and findings from triennial reviews. However, FTA has no  formalized criteria to guide the selection of transit agencies for review.  Without a formalized, documented process for selecting transit agencies  for compliance reviews, FTA is not following GAO’s internal controls and  grantee-oversight best practices. FTA cannot ensure an effective  oversight process if critical elements of internal controls are not present.
FTA’s process is to make publicly available, via its website, final ADA  compliance review reports that contain findings from completed  compliance reviews. However, nine final review reports—conducted from  2004 to 2010—have not been posted to FTA’s website. Even though  there are no time frames governing when a report must be posted,  timelier posting of these reviews would be beneficial to transit agencies  and industry groups that use these compliance reviews as a form of  guidance on FTA’s interpretation of ADA requirements. Having these  publicly available, as soon as possible, could assist FTA in its oversight of  transit agencies and assist transit agencies in their compliance efforts.
Finally, transit agencies reporting to NTD are required to provide limited  data related to ADA paratransit services, including the number of ADA  paratransit trips provided annually and total annual expenditures  attributable to ADA paratransit requirements. We found that the required  data fields were often incomplete. For example, for data from 2005 to  2010, the most recent year available, about 32 percent of transit agencies  reporting to NTD did not provide data in one or more years on the number  of ADA trips provided. Because the NTD is intended to provide timely and  accurate information to Congress and others, FTA would benefit from  advising transit agencies on how to accurately and consistently provide  the required data.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Secretary of Transportation direct the FTA  Administrator to take the following actions:  1.  To help ensure that FTA’s ADA paratransit compliance reviews  adhere to GAO recommended internal controls and grantee oversight  best practices, document and make publicly available a formal  selection approach for selecting transit agencies for review.  2.  To help transit agencies and stakeholders have access to up-to-date  ADA paratransit compliance reviews and compliance findings, post  the backlog of ADA compliance review final reports on FTA’s website  and establish processes for the timely posting of future compliance  review reports.  3.  To improve NTD data collection for ADA paratransit, provide guidance  to transit agencies on how to accurately complete existing ADA  paratransit fields.
section_title: Agency Comments
paragraphs: We provided DOT with a draft of this report and the e-supplement for  review and comment. DOT officials neither agreed nor disagreed with our  recommendations, but provided technical comments, which we  incorporated as appropriate. DOT did not have any comments on the e- supplement. DOT officials stated that FTA uses consumer complaints as  programmatic criteria to identify areas of potential noncompliance and  considers complaints to be the best available indicator of where to target  its limited investigative resources. DOT officials reiterated that paratransit  data collected for the NTD are intended to provide information useful for  FTA’s monitoring of the size of ADA paratransit services relative to  demand response services. According to DOT officials, these data are not  intended to assess overall ADA paratransit compliance.
We are sending copies of this report to interested congressional  committees, the Secretary of Transportation, and the Administrator of the  Federal Transit Administration. We also will make copies available to  others upon request. In addition, this report will be available at no charge  on GAO’s Web site at 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.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: 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 non- generalizable sample of transit agencies, findings from these interviews  cannot be used to make inferences about other transit agencies.  However, we determined that the selection of these transit agencies was  appropriate for our design and objectives and that the selection would  generate valid and reliable evidence to support our work. Table 3  provides more detailed information about the transit agencies we  interviewed.
We also interviewed representatives from relevant industry and disability  advocacy groups, including the following:
American Public Transportation Association,
Community Transportation Association of America,
Disability Rights Education and Defense Fund,
Easter Seals Project ACTION,
National Independent Living Council, and
Texas Statewide Council on Independent Living.
Moreover, to identify the actions that transit agencies are taking to help  address changes in costs of and demand for ADA paratransit service, we  reviewed relevant literature pertaining to leading practices for addressing  costs and demand of paratransit services.
subsections: section_title: ADA Paratransit Services Survey
paragraphs: 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.
subsections: section_title: Survey Population and Sample Design
paragraphs: 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. 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.
section_title: Administration of Survey and Quality Assurance
paragraphs: 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.
section_title: Sampling Error and Estimation
paragraphs: To produce the estimates from this survey, answers from each  responding case were weighted in the analysis to account statistically for  all the members of the population, including those who were not selected  or did not respond to the survey. Estimates produced from this sample  are from the population of transit agencies that provided demand  response services in the FTA’s 2010 National Transit Database.
Because our results are based on a sample and different samples could  provide different estimates, we express our confidence in the precision of  our particular sample’s results as a 95 percent confidence interval (for  example, plus or minus 10 percentage points). We are 95 percent  confident that each of the confidence intervals in this report include the  true values in the study population. Unless we note otherwise, percentage  estimates based on all transit agencies have 95 percent confidence  intervals of within plus or minus 10 percentage points. Confidence  intervals for other estimates are presented along with the estimate where  used in the report.
section_title: Non-Sampling Error
paragraphs: 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.
section_title: Appendix II: Reliability of ADA Paratransit Data in FTA’s National Transit Database
paragraphs: We conducted an analysis to determine whether ADA paratransit data in  the NTD 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.
subsections: section_title: Methodology
paragraphs: To identify changes that have occurred in ADA paratransit demand and  costs since 2007, we examined data from the NTD on the number of ADA  paratransit trips provided annually (ADA trips) and total annual  expenditures attributable to ADA complementary paratransit requirements  (ADA expenses). We examined data for all transit agencies reporting  these two data fields from 2005 through 2010, the most recent year of  data available at the time of our review. We chose to assess data for  2005 through 2010 because we wanted to identify the extent to which we  could report trends in data over this series of years. In addition, we chose  to analyze data for these two fields because they are the only two fields  related to ADA paratransit in the NTD. We found that the NTD does not  contain a data field that asks transit agencies whether they are required  to provide ADA paratransit services.
To determine whether the NTD data on ADA trips and ADA expenses  would be reliable for our purposes, we interviewed FTA officials who are  knowledgeable about the design and uses of the NTD data. We also  assessed the data’s accuracy and completeness by analyzing the extent  to which transit agencies reported these two data fields for all 6 years of  interest. In addition, we compared the NTD data to data from our  generalizable survey of transit agencies.
section_title: Results of Analysis
paragraphs: 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.
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).
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.
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: 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.