Slide 1:
ADA Audio Conference Series
February 18, 2014
This session is scheduled to begin at 2:00pm Eastern Time
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Slide 2:
Listening to the Session
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Slide 3:
Listening to the Webinar, continued
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Slide 5:
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If you are connected via a mobile device you may submit questions in the chat area within the App                                                                                                       
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Slide 7:
Customize Your View continued
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Slide 8:
Technical Assistance
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Slide 9:
WHAT’S YOUR PLAN?
Part Two: A Hands-On Approach 
to Self-Evaluations
Irene Bowen, J.D. President, ADA One, L.L.C.
James Terry, AIA CEO, Evan Terry Associates, P.C
February 18, 2014

Slide 10:
Caution
The content provided in this presentation is for informational purposes only.  Neither the content nor delivery of the content is or shall be deemed to be legal advice or a legal opinion.  The audience cannot rely on the content delivered as applicable to any circumstance or fact pattern. The information provided is not a substitute for professional legal advice.

Slide 11:
Overview of sessions
Part One: Getting Started
Part Two: A Hands-on Approach to Self-Evaluations
Part Three: Bringing It All Together: Transition Plans, Barrier Removal Plans, and Action Plans

Slide 12:
Refresh (1)
Goal: compliance
Evaluations and plans: one means of assessing and reaching compliance
Look to the regulations for requirements
Substance
Procedure

Slide 13:
Refresh (2)
Benefits of self-evaluation
Regulatory requirements

Slide 14:
Two areas of assessment (1)
Equal opportunity – includes communication, policies, practices  “Policies and practices”

Slide 15:
Two areas of assessment (2)
Physical access – buildings, facilities, equipment  “Program accessibility”

Slide 16:
Preliminary decisions
Preliminary decisions
Alternatives
Level of detail
What will work and how will you make it work?

Slide 17:
Preview
Critical decisions
Stages of self-evaluation
Groundwork for a transition plan/barrier-removal plan

Slide 18:
CRITICAL DECISIONS

Slide 19:
Bottom line
How can you do all this?
Collect information quickly and accurately
Evaluate it
Implement a plan while the information is current

Slide 20:
Match your entity with the task (1)
The task
Identify all programs, activities, and services
Review all policies and practices that govern administration of these
DOJ’s ADA Technical Assistance Manual, Section II-8.2000, Self-evaluation
http://www.ada.gov/taman2.html 

See ADA Tool Kit, http://www.ada.gov/pcatoolkit/toolkitmain.htm :
How to identify red flags and fix common problems:  Administrative requirements, communication, 911, websites, curb ramps and pedestrian crossings, emergencies
Slide 21:
Match your entity with the task (2)
Examine a wide range of programs/activities as to full participation of individuals with disabilities – examples:
Physical barriers
Limitations on participation
Communication
Emergencies
Portrayal of individuals with disabilities
Historic preservation
Decisions re: fundamental alteration, undue burdens
Public meetings

Slide 22:
Some pitfalls
Getting just the big picture
Examining policies and missing the practices
TMI
Lack of capacity
Data analysis

Slide 23:
Each entity is unique: 
What will work for you?
Consider your “culture”
How does your entity work?
How does change happen?
How does disability compliance fit within the compliance structure?
Consider your constituency
Input from people with disabilities: when, who, how
Input from program managers, facilities, ADA/504 coordinator
Input from the public

Slide 24:
Reality check
How deep?
How broad?
How much time?
How much in budget?
How much in human resources?

Slide 25:
Ten decisions
Conveying the word: support from the top
Internal team – who “owns” it?
Breadth and depth of analysis
Method of information gathering, analysis
Method/level of reporting findings
Public input – when and how
Implementation
Internal resources: time, money, expertise (volunteers?)
Timing – phases?
Consultants – yes, no, how involved

Slide 26:
Do it yourself or with consultant? 
Process can be 
Entity-driven
Consultant-driven
A mixture
Use or create “informed insiders”

Slide 27:
Areas for possible assistance
Consultant can lead or assist with -- 
Identifying “programs”
Developing survey tool or allowing use of its own
Training staff to assist with process or gather information
Gathering/assisting with public input
Reporting findings
Developing action plan

Slide 28:
FOUR STAGES

Slide 29:
Step by step --
comprehensive evaluation
Plan
Gather information
Analyze and report
Implement

Slide 30:
Step One: Planning

Slide 31:
A framework
Overall pan, schedule, guiding principles
Direction from the top
Identify teams, programs, facilities
Develop tools for services/activities, facilities, IT/AT
Develop data base
Training those gathering information
Public input

Slide 32:
Plan for reporting
Decide whether you’ll assess and report by – 
Town/city if small or
Department or
Each program, service or activity

Slide 33:
Identify programs and services
Recommendation: Analyze each program, service or activity even if reporting is by department or entity
Start with program overview
 Brief description of each program (numerical identifier)
 Population served
 How people find out about program
 Locations where public accesses program

Slide 34:
Examples of programs and activities:
Town/city/county
Meetings, hearings, conferences, events
Library services
Social services
Programs carried out mostly by contractors
Voting
Web sites, IT
Emergency preparedness
Housing
Recreation
Police and fire
Courts
Corrections
Procurement
Mass transit

Slide 35:
Examples of programs and activities:
College or university
Admissions
Financial assistance
Athletics
Academic departments
On-line learning
Housing
Recreation
Student activities
Alumni affairs
Web sites

Slide 36:
“Program” example: libraries (1)
Option A
Collections and circulation
Discussion sessions, events
Tutoring
Exhibits and displays
Research
Computer access
Volunteer opportunities

Slide 37:
“Program” example: libraries (2)
Option Z
Access to Korean collection at Main Library
Book sale at Library #2
Course-related instruction for Engineering Department
Information desks
And many more…..

Slide 38:
Phased approach? 
Programs/services: cross-cutting requirements (majority of programs)
Programs that require in-depth analysis 
Housing
Emergency preparedness
Voting
Law enforcement and corrections
Facilities: program accessibility
Pedestrian access: public R.O.W. and site facilities
Areas needing specialized expertise (mass transit, web accessibility, 911)

Slide 39:
Step Two: Information gathering

Slide 40:
Questions, answers, interviews
There is a place for checklists
Fill out survey form for each program, after training
Include those –
Carried out by contractors
To which you give “significant assistance”
Enter into data base/spreadsheet (code in advance)
  Consider interviews for “specialized” programs or where approach doesn’t fit
  Quality control

Slide 41:
Core topics (1)
Reasonable modifications and participation
Applications
Eligibility and continuing eligibility
Testing
Specialized programs (integration)
Volunteers and advisory committees
Service animals 
Mobility devices 

Slide 42:
Core topics (2)
Meetings/events
Communication
Infrastructure
Outside entities (vendors, contractors, grantees)
Furniture, equipment, purchasing
Evacuation from buildings

Slide 43:
First example of electronic checklist
Sample A: Survey Monkey
Actually several surveys, by topic
Each starts with basic requirements
Then asks, “Does the program do ___?”
If answer is yes, goes automatically to next question

Slide 44:
Sample A: Hearings, Meetings, Trainings, Classes, Tours, Fields Trips, and Special Events (1)
You say no to 1, goes to 9 (next slide) Graphic: ADA requirements: This section covers three types of gatherings:
Facility tours
Excursions or field trips
All other gatherings conducted or held by the program, such as meetings, hearings, information sessions, trainings, or classes.
Generally, these gatherings or events covered must be accessible to people with disabilities. This includes ensuring physical accessibility as well as effective communication with people with hearing, speech, or vision disabilities.
Note: allowing use of space for others' events is covered in Survey #6, Outside Entities or Partners.
1. Does the program offer tours of its facilities, for example, of a firehouse, historic building, or recycling plant?
Does the program offer tours of its facilities, for example, of a firehouse, historic building, or recycling plant?   Yes
No	

Slide 45:
Sample A: Hearings, Meetings, Trainings, Classes, Tours, Fields Trips, and Special Events (2)
Graphic: 9.  Does the program CONDUCT other types of gatherings open to the public or part of the public, such as meetings, hearings, information session, trainings, or classes: yes, no.  10.  Does the program require that all meetings, hearings, trainings, classes and events be held in accessible locations? Note: This does not include facility tours, excursions, or field trips.  Yes No.  11.  Is the accessibility of potential event locations evaluated prior to selecting the location?  Yes No
11 is followed by a list of what is evaluated

Slide 46:
Sample A: Infrastructure
Graphic: 13.  What topics are included in training provided to members of program staff?  Select all that apply.  ADA requirements.  Implementing the ADA.  Interacting with people with disabilities.  The process for handling complaints or grievances.  14.  Is the training provided at orientation/beginning of employments? Yes no.  15.  Is the training given annually? Yes No.
If you’ve said before 13 that you provide ADA training, answer 13-15 automatically

Slide 47:
Second example of electronic survey
Sample B: Excel
One spreadsheet
Each section starts with basic requirements
Then instructs user to complete section if …
User answers according to instructions
Graphic indications of when to supplement answers, skip questions

Slide 48:
Excerpt from table of contents
Graphic: I. OVERVIEW I.A. Introduction IB. Description of program  II. INFRASTRUCTURE  II.A.  Commitment, general practices, training.  II.B. Notice and Grievance Procedures.  III. ELIGIBILITY AND PARTICIPATION.  III.A.  Applications, registration, interviews  III. B.  Initial eligibility requirements  III.C.  Termination of eligibility or services  III.D. Testing.  III. E.  Hearings, meetings.  III.  Modification of policies  III. G. Specialized programs for people with disabilities

Slide 49:
Sample B: Hearings, meetings (1)
Graphic: I. OVERVIEW I.A. Introduction IB. Description of program  II. INFRASTRUCTURE  II.A.  Commitment, general practices, training.  II.B. Notice and Grievance Procedures.  III. ELIGIBILITY AND PARTICIPATION.  III.A.  Applications, registration, interviews  III. B.  Initial eligibility requirements  III.C.  Termination of eligibility or services  III.D. Testing.  III. E.  Hearings, meetings.  III.  Modification of policies  III. G. Specialized programs for people with disabilities

Slide 50:
Example – Hearings, meetings (3)
Graphic (spread sheet) 3.  If a person’s disability makes it impossible for them to attend a meeting, hearing, training, class or event in person are they permitted to attend remotely? (e.g., conference call, video conference, webcast, voice over)  If Y, please specify in comments.  To right Y, N.  4.  If a person’s disability makes it impossible for them to attend or participate in tours in person, are they permitted to attend remotely or is the same content provided in a alternate way? (e.g., video tour, webcast, etc.)  Y, N.  If Y, please specify in comments.

Slide 51:
Example – hearings, meetings (2)
Graphic (spread sheet): II.D.  Hearings, meetings, trainings, classes, tours, and special events.  6. How do people register for your events, hearings, meetings, trainings, classes and tours?  A.  Can people with disabilities register in alternate ways?  (e.g. in person, via mail, email, fax, phone, internet).  Y, N    7.  Is your staff trained on the policies and procedures discussed in this section, as to people with disabilities? Y N.  If Y, please respond: A.  Which staff members are trained?

Slide 52:
Electronic surveys	
Any version requires – 
Careful programming in advance of use
Electronic input of information
Training
Quality control
Means of data analysis for useful findings
With either, can build in “red flags”

Slide 53:
Beyond checklists (1)
Some areas may need a different approach – interviews, narrative report, specific questionnaires:
Police/fire
Courts
Emergency preparedness
Housing
IT
Web
Voting

Slide 54:
Beyond checklists (2)
Where entity has responsibility via several partners/contractors, look at responsibility of entity as well as individual partners.
Examples:
Social services
Child care
Health care
Shelters

Slide 55:
Deciding where to start with facilities
Not every facility must be made fully accessible  
Chances are you won’t survey every facility at once – this is likely a long-term process
Plan your work in phases that can realistically be funded over time
How do you decide where to start and what to work on in later phases?
Slide 56:
Setting facility priorities
Which facilities and elements are the most important to review and fix first?
Highest use 
Most critical for people with disabilities and seniors
Those where corrective work has been requested by users
Facilities with frequent use without advanced notice
Facilities offering unique programs and services
Distributed locations 
Access to public transportation

Slide 57:
Factors to consider when setting facility priorities:
Programs offered
Geographic distribution
Communities served
Public transportation
Aerial photo map of City pools shows five locations: 1. Competitors, 2. Hot Bodies, 3. The Old Springs, 4. Campground Pool, and 5. Burbs Aquatic Center.
When setting priorities, these each must be evaluated for the programs they offer, communities they serve, geographic distribution, and access to public transportation

Slide 58:
Setting facility priorities  (one approach)
Chart showing ranking based on highest use, critical use, requested corrections, Frequent use without Notice, Unique Programs, Location and Transportation

Slide 59:
Setting facility priorities
Which curb ramps tend to have the highest priorities?
i.	Those where work has been requested by users
ii.	Curb ramps serving facilities for seniors and people with disabilities
iii.	Highest use
iv.	Closest to critical program facilities (like emergency shelters and healthcare)
v.	Areas where no curb ramps currently exist

Slide 60:
Logical approaches to identifying barriers and removing them for physical access
Identify every program offered and evaluate each program for barriers. Remove them, then:
•	Train program-setting employees to recognize and avoid barriers when moving and adding programs and services and when scheduling all public activities and events
•	Update transition plan, secure funding, and eliminate barriers every time programs move or are added to inaccessible facilities or areas within facilities

Slide 61:
Logical approaches to identifying barriers and removing them for physical access
Identify areas in every facility where programs are offered; identify barriers in those areas; remove them; then…
•	Train program-setting employees to schedule programs, services, public activities and events only in areas of facilities that are already physically accessible
•	Update transition plan, secure funding, and eliminate barriers only when programs move or are added to the few remaining inaccessible facilities or areas within facilities

Slide 62:
Select facilities where all programs will be offered to achieve program access
Verify that ALL programs, services, and activities will be accessible
If not all program offerings become accessible, geographically dispersed convenient locations
If not all accessible, consider how facilities are used
•	Example – two auditoriums in use: BOTH must be accessible
•	Example – twenty swimming pool facilities: SOME must be accessible
•	Swim meets must be held only at accessible pools
•	Swimming lessons must be offered at accessible pools

Slide 63:
Program vs. facility access
Alternative methods
Physical access is not required to every facility where alternative methods are as effective in providing program access, but, where structural changes are required, a transition plan is required.

Slide 64:
Alternative methods 
Alternative methods for compliance in existing facilities may include
•	Redesigning equipment
•	Reassigning services to accessible buildings
•	Assigning aides to beneficiaries or home visits
•	Delivery of services at alternate sites
•	Alteration of existing facilities
•	Construction of new, accessible facilities 
•	Use accessible rolling stock or other conveyances
•	Other methods to achieve “readily accessible to and usable by”

Slide 65:
What must be included in a transition plan (from the regulations):
•	Identify all physical obstacles (barriers) in the facilities that limit access
•	Detail the methods that will be used to make the (programs and/or) facilities accessible
•	Schedule the steps to be taken each year to achieve compliance
•	Name of official responsible for implementation
•	(In the next session we’ll look in detail at how to collect and manage this information)

Slide 66:
Public input
When
At beginning
As to tentative findings
As to recommendations
How
Public hearings
Meetings with constituencies
Online surveys/comments
Who
Advisory committees
Advocacy groups
Individuals

Slide 67:
Step Three: 
Analyzing and reporting

Slide 68:
Approaches
Several ways to analyze/summarize
Highlights or details
By entity, department, program, type of issue
Narrative
Summaries
Charts
Frequency of issues
Severity of issues
Distribution among departments/programs
Red flags
Raw data to individual programs or departments

Slide 69:
Tasks
Draft findings
Meet with departments/programs
Review by programs, departments, management
Final report

Slide 70:
Facilities - transition planning
Similar issues as with policies
What did your facility surveys reveal?
What are your phased priorities for physical barrier removal to provide program access?
What can be accomplished with existing staff and volunteers
Staff availability and expertise
Planning and budgeting cycle
Finding and building allies in your organization

Slide 71:
Step Four:  Implementation

Slide 72:
Bring it all together (1)
Create recommendations for change
Create specific action plans
By entity, department, program
Can be done by individual programs, departments

Slide 73:
Bring it all together (2)
Assign specific tasks to specific people, with deadlines
Consider an electronic tracking tool for milestones, reminders
Tie in to budget and planning process

Slide 74:
Coordination
Coordinate your physical facility access solutions with the operations, maintenance, procurement, and various program providers to assure consistent “program access” in practice
Don’t assume that fixing physical barriers will fix all of the problems, that part of your work only provides opportunities for your staff and to provide program access

Slide 75:
Communication
Determine how new solutions can best be communicated to all involved parties
Managers who will approve and assign responsibilities
Staff who will implement the changes
Employees who will do their work differently
People with disabilities who will be the beneficiaries and need to plan their activities and program participation
Use multiple communication methods
Modify existing materials and handouts
New Internet resources
Resource numbers and email addresses for answers

Slide 76:
CHECKLISTS AND EXAMPLES

Slide 77:
Examples (1)
City of Tacoma, Washington -- Self evaluation developed by staff
http://cms.cityoftacoma.org/hrhs/ada/FinalADAPlanJune08.pdf    

San Francisco -- Contractor-developed
http://www.sfgov2.org/index.aspx?page=546 

Sacramento approach (standard activities vs. unique services
http://www.cityofsacramento.org/adaweb/summary.html#sapproach

Slide 78:
Examples (2)
Fulton County, GA – county-wide report (contractor – ADA One) 
http://fultoncountyga.gov/images/stories/OEEO/FC_I_ADA_SEval.pdf 

Somerville, MA – self-evaluation as basis for transition plan (contractor) (mostly facilities)
http://www.somervillema.gov/sites/default/files/Somerville2013-Self-Evaluation.pdf 

Slide 79:
Other resources
DOJ’s Title II Technical Assistance Manual, at 
§ II-8.2000.  http://www.ada.gov/taman2.html
 DOJ’s Project Civil Access page and ADA Tool Kit 
http://www.ada.gov/civicac.htm 
Department of Education’s section 504 guide (outdated, 1978, but helpful guidance)
http://www.ahead.org/sigs/ada-coordinators 
(click on Self-evaluation Guide)
Checklists and Policies for Title II: Samples – in audio conference materials, by ADA One, February 2014

Slide 80:
Questions

Slide 81:
CONTACT
Irene Bowen, J.D.
President, ADA One, LLC
9 Montvale Court
Silver Spring, MD 20904
Web site: http://ADA-One.com
301.879.4542 (O)
301.236.0754 (F)

Slide 82:
CONTACT
James L.E. Terry, AIA, CASp
CEO, Evan Terry Associates, P.C.
One Perimeter Park So. #200S
Birmingham, AL 35243
www.EvanTerry.com 
jterry@evanterry.com
205.972.9100 (O)
205.972-9110 (F)

Slide 83:
Thank you for participating in today’s ADA-Audio Conference Session
The next scheduled session is:
“What’s Your Plan?  A three-part series on self-evaluations, barrier removal plans, and transition plans”
Part III:  Bringing It All Together: Transition Plans, Barrier Removal Plans, and Action Plans
March 18, 2014  www.ada-audio.org  877-232-1990 (V/TTY)