Attached Comment

We are opposed to this proposal, as we understand it. Imposing NTD-level reporting requirements on Coordinated Human Services Transportation providers is onerous and impractical; it would be impossible to implement for the 2008 year. It would increase the cost of operations for community-based low income, elderly and disabled transportation, most of which receive no FTA funding to do what they do. This means that to fulfill this requirement we would have to provide fewer rides. There is no way around this. We already collect ridership, cost and mileage data from each of our providers for coordination purposes and are not opposed to providing that information to FTA. Understand that there are over 80 community-based providers of door-to-door transportation for low income individuals and elders and people with disabilities in our service area that are coordinated by TriMet through Ride Connection and the Medicaid brokerage. Many of these providers are tiny non-profit charitable organizations and churches that often use volunteer drivers to provide the service. Many of these organizations are in the transportation business to get people to services they provide, so transportation is not a primary focus of their operation. Most others are small owner operated medical transportation operations with only 2-3 operators. Some are just provided with a vehicle and pay for the operations from their funds. Some providers receive only a retired transit district cutaway vehicle and pay for the operations from their own funds. Only a handful of these operations receive FTA funds for operations. Funding sources are: Medicaid, state funds, charitable donations, TriMet funds, New Freedom, JARC, other. New Freedom and JARC funds provide less than 5% of funding. For our own coordination purposes, we collect data from each of these operations on monthly ridership, miles and costs, but it is not NTD compliant. Furthermore, data derived from the 2710A sampling method required for NTD reporting is not useful to us, so the NTD level reporting would have to be in addition to what providers are already reporting. You can view our monthly performance report for coordinated elderly and disabled transportation services at: http://www.trimet.org/meetings/stfac/index.htm and click on E and D Monthly Performance Reports. These organizations provide a valuable community service at little expense. Imposing NTD reporting would require new computer systems, additional reporting and sampling requirements and additional staff, processing and compliance auditing costs. In TriMet’s region, the Medicaid brokerage includes both medical trips and some waivered non-medical trips. Community organizations and county governments in our region and in the rest of Oregon with no connection to FTA provide waivered non-medical programs. These programs already have significant reporting requirements to meet Medicaid standards. Adding FTA reporting requirements on top of these would diminish their ability to operate efficiently and to focus on the goal of their Medicaid funding organizations. A couple years ago WSDOT requested this type of data from any agency in Washington State that received FTA funding. Much of the Medicaid info was simply not reported, as the data was not available. The way a demand response business is handled by a transit agency is significantly different from the way it is handled by brokered Medicaid programs, so Medicaid data would not help FTA achieve their goal of accurately reporting on Coordinated Human Service Transportation. If FTA allowed reporting of data that was meaningful to Medicaid, we would be more likely to be able to collect and report it accurately. Here, for example, is what this new requirement looks like from the Medicaid perspective: Here is what we might need to report: And here is what is collected: Total service miles for weekday Saturday, Sunday Not currently collected, but possible with a major billing system upgrade Total revenue miles for weekday, Saturday and Sunday Not currently collected, but possible with a major billing system upgrade Total service hours for weekday, Saturday and Sunday Not currently collected, and not meaningful for Medicaid Total revenue hours for weekday, Saturday and Sunday Not currently collected and not meaningful for Medicaid Unlinked passenger trips for weekday, Saturday and Sunday Ridership data is currently collected but does not meet NTD 2710A requirements. Average vehicles in service for weekday, Saturday and Sunday Data not currently available and not meaningful for Medicaid Vehicles operated in maximum service Data not currently available and not meaningful for Medicaid There is no way around the fact that because it would increase costs, imposing NTD level reporting would result in fewer rides. It would also mean losing service providers because they couldn’t collect the FTA compliant data. It would be counter productive to the goals of community-based transportation because it would take management focus away from innovation and coordination and providing low cost rides. It would be great if FTA could promote coordination at the federal level. For example, why can’t the nation adopt the DOT drug testing requirement instead of continuing the confusing and wasteful practice of two different drug testing requirements based on whether the ride was provided with FTA or with DHS funds? We are not opposed to providing FTA with data on ridership and costs. Many organizations can also provide miles. But imposing NTD level requirements would be an onerous nightmare for tiny providers of human services transportation in our area. Sincerely, Claire Potter, Susan Florentino, Gail Bauhs.