8/29/2018 Project Civic Access Practical Applications and Lessons Learned One County’s Experience Today's Session What is Project Civic Access? What was Montgomery County ‘s experience? What was the role of the ADA Compliance Manager? What did Montgomery County learn through this process? Are there take-away for other jurisdictions? 1
8/29/2018 Project Civic Access Department of Justice Initiative begun in 1999 Over 220 Agreements signed with jurisdictions throughout the US Overarching Goal: to ensure that people with disabilities can participate in, and benefit from, all State and local government programs, services and activities Includes policy reviews and on-site building surveys Most recent: City/County of Denver, Colorado and the City of Trinidad, Colorado-2018 Follow-up Action by DOJ: Humboldt County, California: 2008 Settlement Agreement, 2016 Consent Decree and City of Memphis: 2005 Settlement and 2013 Consent Decree Montgomery County, Maryland The County’s Project Civic Access review began in 2006 Findings received in 2009 Final Settlement Agreement in 2011 One of the first large County governments reviewed Over 110 buildings were surveyed Reviewed policies and procedures on a range of areas including emergency management, effective communication and law enforcement, employment, domestic violence programs, sidewalk and curb cuts, grievance policy, and more. 2
8/29/2018 What accomplishments had Montgomery County made in terms of ADA compliance before Project Civic Access? Long commitment the goals of the Americans with Disability Act- included discrimination based on disability in 1978 Completed self-evaluation and developed transition plans for compliance with the Rehabilitation Act and the ADA Very active and effective Commission for People with Disabilities ADA Compliance Officer and Grievance Policy in place since 1992 County-wide Sign Language contract in place, 24/7 and contracts for other auxiliary services Provided ADA training-Titles I and II on an on-going basis Included compliance with the ADA in the terms and conditions for all contracts First Steps Established a workgroup with Department Liaisons and an Executive Committee with the liaisons from key departments ADA Compliance Manager took the lead on coordinating the responses to DOJ questions and on arranging for ADA facility surveys Reviewed other PCA Agreements, reached out to those ADA Coordinators, shared findings with the Executive Committee Arranged for a presentation by DOJ for the workgroup County used an outside consultant to visit each site, review findings, take photos, and develop a cost estimate. ADA Compliance Manager reviewed facility findings 3
8/29/2018 Early Lessons Learned Maintain documentation of all compliance efforts Title II applies to ALL of your programs and services-directly provided by staff, contract, or partnerships. Title II applies your facilities both those that are owned and those that are leased or provided by others. Program Access solutions can be used but are also challenging to implement. Title II regulations and the ADA Standards need to work hand in hand. Understanding the programs and services housed in the buildings is a key. As programs change or move, review whether there are new accessibility issues. Title II is an ONGOING responsibility and process. Lessons Learned: Built Environment Early 1992 ADA remediation efforts often provided a minimal level of usability but not compliance. ADA errors are common even in new construction. Construction tolerances are generally not acceptable. Understand how DOJ takes measurements Getting “buy in” from everyone involved in the design, construction, project management, and facility maintenance is difficult to achieve. ADA remediation projects will often be more complex and be costlier than expected. Time lag between surveys and remediation work can complicate the project In leased space, common areas need to be compliant. 4
8/29/2018 Montgomery County Actions: Built Environment Expanded ADA compliance to a team and moved from the Department of Health and Human Services to the Department of General Services Established an “ADA Commissioning Process” that includes reviews of new construction and renovations by outside ADA experts. Plan reviews and surveys at key points from design development through post construction Technical assistance available throughout the process Completes surveys of remaining County buildings Provided training for project managers, architects and construction contractors. Identified ways to incorporate ADA remediation into other projects both-one-time projects and on-going level of effort projects. Trained maintenance and cleaning staff. ADA Compliance can easily be undone. Lessons Learned and Actions Taken: Effective Communication Key issue in ADA Compliance but often is not well-understood. Technology is changing rapidly. Make sure your jurisdiction can provide effective communication: CART? Video remote interpreting? Tactile interpreting as well as ASL? Certified Deaf Interpreters? Montgomery County Actions: Expanded our Sign Language interpreting contact to offer new services Procured a contract with an expert to design and install assisted listening systems Provided training and more training 5
8/29/2018 Lessons Learned: Challenging PCA actions to implement Emergency Operations Plan-much more awareness and guidance now available through FEMA; Pacific ADA Center; Brooklyn Center for Independence of the Disabled vs. City of New York and a similar case in Los Angeles as well as training sessions at the Update and on-line. Website accessibility challenges: Developing uniform accessibility standards Getting everyone on board Maps, data tables and graphs Captioning videos Addressing new features Lessons Learned: Challenging PCA actions to implement PCA Training requirement: two-hours of training for all staff who interact with the public on the Title II requirements and on how to interact with people with disabilities. Montgomery County offered this training each year since 1992 but it was not mandatory. Training Challenges: Sheer number of staff to be trained Computer based vs. in-person? Tailored to different job duties? Keeping it interesting and relevant Advanced training on more complex or specialized topics Training needs for contracted services 6
8/29/2018 Overall impact of PCA in Montgomery County Government Improved: Visibility of the ADA Team inside and outside the County government. Coordination between the ADA Team and the Building, Design, Facility and Leasing staff. Awareness that ADA Compliance is an on-going responsibility with issues that are still emerging. Ability to understand and respond to some of the more complex and gray areas. Use of the ADA Office as a resource for other County departments and agencies. Documentation of compliance efforts 7
8/29/2018 Project Civic Access as a tool for compliance Reviewing the Settlement Agreements and PCA resources can provide excellent guidance: The basics-ADA Coordinator, Grievance Procedure to make sure your jurisdiction has those in place Common problem areas for jurisdictions-as best practice review these areas in your own jurisdiction Review action steps required in the Settlement Agreements and see where your jurisdiction stands. Complaint driven Settlement Agreements and the PCA Agreements give a better understanding of expectations Project Civic Access/Self- Evaluations and Transition Plans Same goal: Ensure that people with disabilities can participate in, and benefit from, all of the programs and services provided by your jurisdiction. Pros/Cons of a Self-Evaluation Pro: Jurisdiction sets the time frame Pro: Ability to prioritize areas or do in manageable stages Pro: Can coordinate surveys and remediation work Con: May be more difficult to get buy-in and funding Pros/Cons of a Project Civic Access review Pros: Easier to get buy-in and funding Con: Time frame and priorities are mandated Con: Often a lag between survey and remediation work Con: Public perception 8
8/29/2018 Take-Aways and Issues to consider If your Self-Evaluation was done in the past, it may be time for a voluntary review. New 2010 requirements? New programs or services since your first Self-evaluations? Early decisions to think about: Do you have the basics in place? What is a program? Department? Division? Each individual program? Survey tool? In-house or contract? Train first? Resources? ADA Title II Action Guide at https://www.adaactionguide.org/ Jurisdictions often post their Self-evaluations and Transition plans on their websites Mid Atlantic Center and the National ADA Network, DOJ, Access Board Questions??? Montgomery County ADA Office 240-777-6197 (TTY 240-777-6196) adacompliance@montgomerycountymd.gov Presenter: Nancy Greene nancyggreene@yahoo.com 9
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