United States General Accounting Office Briefing Report to GAO Congressional Requesters JalutaIy1990 PERSONSWITH DISABILITIES Reports on Costs of Accommodations United States GAO General Accounting office Washington, D.C. 20548 Human Resources Division B-237003 January 4,1996 The Honorable Bill McCollum House of Representatives The Honorable Larry E. Craig House of Representatives This briefing report responds to your requests for information on the potential cost of implementing the proposed Americans With Disabilities Act (ADA) of 1989 (El. 933 and H.R. 2273), particularly to the private sector. The ADA would prohibit discrimination based on disability against any qualified person in employment and in programs and activi- ties operated by state governments. It would also prohibit discrimina- tion based on disability in public accommodations and services, public transportation, and telecommunications relay services.’ Federal law prohibits federal contractors and recipients of federal assis- Background tance from discriminating against persons with disabilities. The Rehabil- itation Act of 1973 (section 503) requires government contractors with contracts greater than $2,500 to take affirmative action to hire persons with disabilities.’ Section 504 of the act prohibits excluding persons with disabilities solely because of their disabilities from federal pro- grams or activities receiving federal financial assistance. The proposed AM would extend the prohibitions of discrimination to private sector employment, state and local governments not receiving federal assis- tance, public transit and telephone services, and many private busi- nesses or entities used by the general public. Also, the ADA would incorporate the enforcement provisions of the Rehabilitation Act of 1973, the Civil Rights Act of 1964, and the Fair Housing Act of 1968.” ‘Telecommunicationsrelay serviceslet personswith hearingand speechimpairmentsusetelephones or radios in ways that are functionally equivalent to the ways unimpairedpeopleusethem. “Throughout this report, we usepersonswith disabilities to refer to thosewith mental or physlcal disabilities or handicapswithin the meanmgof the Rehabilitation Act of 1973. “The Cwil Right?,Act of 1964bansdiscrimination on the basisof race,color, religion, or national origin in public accommodationsand programsreceivingfederal assistance,and in employment,also on the basisof sex. The Fair HousingAct of 1968prohibits discrimination in the saleor rental of housingother than single family housessold or rented by owners,or in the caseof a small landlord (one who owns and residesin a property that is occupiedby not morethan three families). Page I GAO/IiRD-9044BR Costa of Accommodations for Disabled 5237003 on buildings, 1 on employment, 3 on transportation, and 1 on telecom- munications (see app. II). Only certain specific building types are covered in the seven reports on building accessibility,” discussed in app. III. For example, they variously estimate costs of making accessible vocational schools; colleges, elemen- tary , and secondary schools; a mixture of residential buildings and office buildings; and a library. The impact of section 504 of the Rehabilitation Act of 1973, which is limited to recipients of federal assistance, is the subject of the three reports on school building accessibility. They provide no current infor- mation on the extent to which modifications have been completed to comply with section 504 nor on additional schools that may require modifications to comply with the ADA. The three reports use different methodologies to derive their cost estimates. In two reports, the assump- tions differ on the amount of space needing modification and the type of modifications needed. A third report does not fully discuss its assump- tions. This latter report estimates the cost of making 45 percent and 100 percent of all buildings first-floor-accessible. However, it does not fully explain its derivation of the cost estimates, and bases these estimates on information from only four colleges. Such a small sample may not be representative of the universe to which it is projected. The other four reports on building accessibility differ widely in what they examine. For example, one looks at a federal office building, another at Pennsylvania vocational schools. A third examines apart- ment buildings, a town hall, and a convention hall. Two of the reports compare the costs of initially designing buildings to provide accessibility for persons with disabilities with the costs of renovating already com- pleted buildings. Not surprisingly, they conclude that the former is less expensive. All four reports have limitations. One points out that its use of new con- struction cost estimating manuals to determine renovation cost is ques- tionable. A second does not give the date of the cost data it uses, and a third does not state how it estimates costs. The last relies on information from only one state government’s department of insurance, which may or may not be representative. “Ruldmg accessibilitymeanshow easyIt is for personswith disabilities to get to, enter, and we a facility. This includes appropriateentrances,exits, doorways,rest rooms,and elevators.Making buildings accessiblecan involve prwiding curb cuts, rampedentrances,braille markings,and the like. Page 3 GAO/BRD9044BR Costaof Accommodationsfor Disabled B-237003 Please call me on (202) 275-1655 if you or your staff have any questions about it. Other major contributors to the report are listed in appendix VII. Linda G. Morra Director, Intergovernmental and Management Issues Page 5 GAO/HRB9044BR Costs of Accommodationsfor Disabled contents Appendix V 21 Costs of Making Transportation Options for Persons With Disabilities Evaluated 21 Transit Systems Cost Impact of DOT Rule on Transportation Services for 22 Accessible to Persons the Disabled Calculated With Disabilities: Costs of Rail Transit Accessibility Evaluated 23 Brief Descriptions of Three Reports Appendix VI 25 Costs of Making Description of Cost Data Cost Data for Relay System 25 25 Telecommunications Cost Data for Amplified Handsets for Public Telephones 25 Accessible to Persons Comments 26 With Disabilities: Brief Description of One Report Appendix VII 27 Major Contributors to This Report Tables Table V.l: Annual Cost Estimates for Transportation System Modifications in Seven Cities Table V.2: Annual Costs of Transportation System 23 Modifications in Average-Sized Cities Abbreviations ADA Americans With Disabilities Act ANSI American National Standards Institute cl30 Congressional Budget Office Dm Department of Transportation FCC Federal Communications Commission HEW Department of Health, Education, and Welfare IKTD Department of Housing and Urban Development TDD Telecommunications Devices for the Deaf LJFAS Uniform Federal Accessibility Standards Page 7 GAO/HRD-9044BR Costs of Accommodations for Disabled Appendix I Private Industry end Interest Groups and Government Agencies C!ontacted for Study Department of Labor, Employment Standards Administration Department of Transportation Federal Communications Commission Internal Revenue Service Office of Technology Assessment President’s Commission on Employment of the Handicapped Small Business Administration Page 9 GAO/HRD-9944BR Costa of Accommodations for Disabled Costs of Making Buildings Accessible to Persons With Disabilities: Brief Descriptions of Seven Reports These reports on building accessibility costs, identified through our literature search and contacts with various organizations, were pub- lished between 1975 and 1979. Our comments on each report are included O’Neill, D. M., Discrimination Against Handicapped Persons; The Costs, Transportation Benefits and Economic Impact of Implementing Section 504 of the Reha- Options Evaluated bilitation Act of 1973 Covering Recipients of HEW Financial Assistance. for Persons Washington, DC.: Department of Health, Education, and Welfare (HEW), May 4,1977. With Disabilities The report investigates employment practices, program accessibility, and elementary and secondary education in terms of implementing sec- tion 504 of the Rehabilitation Act of 1973 (p. i).’ HEW’S Office of Facili- ties, Engineering, and Property Management recommends estimating the cost of new barrier-free construction at one-half of 1 percent of total project costs (pp. 18-19). The report is a revised version of an impact statement published in the Federal Register on May 17, 1976. Description of Cost Data The report estimates the capital cost of altering existing higher educa- tion, elementary, and secondary education facilities by multiplying the estimated value of all buildings at the end of the school years 1974-75 (higher education) and 1973-74 (elementary and secondary education) by estimated cost factors (pp. 24 and 28). The report multiplies the cost factor of .0056 .by the estimated value of higher education buildings to estimate the cost of achieving accessibil- ity. Here, accessibility is achieved at least cost by using reasonable alter- natives to expensive renovation where possible. 2 The report uses cost factors of .0089 for renovation and .0018 and .0028 for making one- third to one-half of elementary and secondary school buildings first- floor-accessible (pp. 28-34). ‘Numbersin parenthesisrefer to pagenumbersof the reports ‘For example,the stacksin the libraries of someuniversities have narrow halls and aislesand are locatedon upper floors of bulldings built many years ago.Elevatorsare either nonexistent or of such tiny dimensionsas to makeaccessvia a wheelchair impossiblewithout extensiverenovation.In this case,a reasonablealternative to renovation would bethe assignmentof personnelto supply individu- alized “stack searchs”for personswith disabilities. Page 11 GAO/HR@90443R tits of Accommodations for Disabled Appendix III Costs of Making Buildings Accessible to Persons With Disabilities: Brief Desctiptions of Seven Reports These include providing auxiliary aids, relocating classes or services, and maintaining structural modifications such as elevators (p. 5). The study estimates costs for 3,083 colleges and universities (p. 15), 15,891 public school districts (p. 17), 4,755 postsecondary vocational schools (pp. 20 and SS), 7,271 hospitals (p. ZO), 26,748 residential health facilities (p. 22), 7,002 outpatient health and other social service pro- grams (pp. 23 and 91) 8,930 libraries (pp. 24,98, and 99), and 76 wel- fare agencies (p. 24). Cost Data The cost estimates (in millions of dollars) are: l Structural modifications - $1,200-1,500 (p. 5). . One-time nonstructural costs - $173 (p. 5). l Annual continuing costs - $152-198 (p. 5). l Kew construction and renovation - $25-43 (p. 5). Comments Chapter 5 (pp. 139-148) cites limitations on the cost data from noncol- lege HEW recipients. These include: ignorance of section 504 require- ments, overestimates of costs (pp. 139 and 140), incomplete plans for modifications (p. 142), and incomplete lists of recipients used for the survey (p. 147). The college and university questionnaire was based on one that has been administered repeatedly since 1968. Wulfsberg, R. M., and R. J. Petersen, The Impact of Section 504 of the Collegesand Rehabilitation Act of 1973 on American Colleges and Universities. Universities Surveyed Washington, DC.: National Center for Education Statistics, HEW, June as to Impact 1979. of New Legislation The report details the results of a 1978 survey that studied modifica- tions required to make colleges and universities accessible to people with mobility impairments (p. 3). Of 700 schools contacted, 607 responded. - Description of Cost Data Costs given for accessibility include such changes to the buildings as modified walkways, stairs, and entrances, but exclude costs for auxil- iary aids and services, such as readers for the blind (p. 3). Costs incurred before September 15, 1978 (p. 3) are excluded. Page 13 GAO/RlUN&44BR Casts of Accommodations for Disabled - Appendix ID Costs of Making Buildings Accessible to Persons With Disabilities: Brief Descriptions of seven Rqmts Description of Cost Data The study compares costs to remove architectural barriers by alteration and initial construction (pp. 47 and 89). It says that the cost of accessi- bility is negligible when it is incorporated in the design phase. Further- more, the study concludes that the cost of altering existing buildings is relatively small when compared to total construction cost (p. 87). Cost Data Estimates obtained from government contractors of the costs of remov- ing barriers by alteration versus original design are listed for selected buildings (p. 89), as follows: Navy - Petty officers club - $10,800 vs. $2,880 Navy - Weapons engineering facility - $282,000 vs. $65,300 nnw - Horizon House, Philadelphia, PA - $11,130 vs. $5,315 HEW - Medical college - $39,138 vs. $10,853 nuo Germantown House. Philadelphia, PA - $3,000 vs. $500 HUD - Compton Towers, Wilmington, DE - $9,000 vs. $500 General Services Administration - Federal office building - $16,605 vs. $2,605 Comments The report does not state clearly how these cost estimates were obtained. Although issued on July 15, 1975, the report does not clarify the year of the cost data. Schroeder, S., and E. Steinfeld, The Estimated Cost of Accessible Build- Costs of Accessibility ings. Syracuse University; sponsored by HUD. Washington, D.C.: U.S. for Nine Buildings Government Printing Office, Apr. 1979. Estimated The report assesses construction costs for redesigning new buildings and renovating existing buildings to make them accessible to persons with physical disabilities. Nine buildings are analyzed. They include a high- rise tower, garden apartments, a single-family house, a college dormi- tory, a convention hall, a public branch library, a town hall, a college classroom, and a retail shopping center. Eight of the buildings were located in Syracuse, North Syracuse, Clarkstown, or Glen Falls, New York; the ninth in Detroit, Michigan (pp. 141-142). The authors conclude that it is much less expensive to design for acces- sibility than to renovate existing structures. From the data, the authors estimate that designing for accessibility generally adds from less than 1 to 15 percent to the cost of a new facility. Renovating existing buildings Page 16 GAO/HRD4044BR Costs of Accommodations for Disabled Appendix ID Costs of Making Buildings Accessible to Persona With Disabilities: Brief Descriptions of seven Report.9 6. Divide the total cost of renovation and redesign for each building by the construction cost to give the percentage increase in cost to meet barrier-free design criteria. Unit costs were obtained from reference estimating manuals, which pro- ject costs for new construction (pp. 4-5). The report notes that “The applicability of using [new construction cost] estimating manuals to determine construction costs for renovation work is of questionable validity ... [because] renovation costs may vary substantially from new construction costs depending on the specific project conditions, the quantities of materials required, and removal and demolition costs” (P. 5). Associated Educational Consultants, Inc., Physical Accessibility of Pub- Costs of Modifying lit Supported Vocational Schools for Handicapped Students. Sponsored Vocational Schools for b y HEW, National Institute of Education. Pittsburgh, PA.: 1978. Handicapped The report estimates costs of structural modifications to make Penn- Projected sylvania vocational programs accessible to the disabled under standards of the American National Standards Institute (pp. l-3). Description of Cost Data Costs are estimated for 78 area vocational technical schools, 12 high schools in Pittsburgh that offer vocational programs, and 15 community colleges that offer occupational education courses (pp. 2,3, and 10). The year of the cost data is not clearly stated. Cost Data Total estimated costs for structural modifications for vocational schools are $1,228,903; for Pittsburgh high schools, $834,550; and for commu- nity colleges, $499,468. Total for all categories is $2,562,921 (pp. 2, 3, 37, and 38). The report summarizes costs for the following structural features: park- ing lots, walks, ramps, entrances and exits, doors and doorways, stairs and steps, rest rooms, water fountains, elevators, controls, identifica- tion, and warning signals (pp. 37-38). Comments Teams of architects and educational consultants obtained data through on-site visits (p. 7). They pretested the data collection instrument at three area vocational schools (p. 5). The report presents nonrecurring Page 17 GAO/HRD9044BR Costs of Accommodations for Disabled Appendix IV Costs of Employment Accommodations for PersonsWith Disabilities: Brief Description of One Report We located only one report on costs of employment accommodations for persons with disabilities. Berkeley Planning Associates, A Study of Accommodations Provided to Handicapped Employees by Federal Contractors: Vol. I, Study Findings; Vol. II, Ten Case Studies. Sponsored by the Employment Standards Administration, Department of Labor. Berkeley, CA: June 17, 1982. This is a study of job accommodations provided to employees with disa- bilities by federal contractors covered by section 503 of the Rehabilita- tion Act of 1973. The authors surveyed 2,000 contractors, of which 367 responded (pp. i and 7). They estimated that about 3.5 percent of the workers employed by the respondents had disabilities (p. ii and 16). Of the workers with disabilities, 22 percent received some form of accom- modation, generally inexpensive (pp. 20 and 29). Accommodations for individual workers included adapting the physical environment, providing transportation, special equipment or aids, or retraining or selective placement of the worker (pp. ii, 22, and 23). No particular type of accommodation dominated (p. ii). Among the most frequent accessibility modifications were parking, curb cuts, ramped entrances, and wheelchair access to work areas (pp. 26 and 27). The report does not state the year of cost data obtained. The report does not show total costs or costs of individual accommoda- Description of tions. It provides tables showing the percentage distribution of total Cost Data costs of accommodations by accommodation and disability type (pp. 30 and 66). Of the accommodations reported, 51 percent cost nothing and another Cost Data 30 percent cost less than $500, the study concluded. Only 8 percent of the workers received accommodations costing more than $2,000 (pp. ii and 28). The greatest costs incurred were on behalf of persons receiving audio- visual aids. The lowest costs were associated with relocating worksites; changing hours, work procedures, and task assignments; transferring the workers to a new job; and orienting coworkers (p. 31). Page 19 GAO/HRD.9O44BR Costs of Accommodations for Disabled Appendix V Costs of Making Transit Systems Accessible to PersonsWith Disabilities: Brief Descriptions of Three Reports We identified three reports on the cost of making transportation services accessible to persons with disabilities. IJS. Congressional Budget Office, Urban Transportation for Handi- Transportation capped Persons: Alternative Federal Approaches. Washington, DC.: Options for Persons Nov. 1979. With Disabilities CROevaluated three options for providing transportation services to dis- Evaluated abled people living in urban areas of the United States (p. xii). A transit plan includes adding wheelchair lifts to buses, elevators in rail stations, and at least one wheelchair-adapted car per train. A taxi plan calls for small modifications to existing cabs and door-to-door public transporta- tion for the severely disabled. An auto plan offers disabled people financial aid to buy modified cars, as well as door-to-door public trans- portation for those unable to drive cars (p. xii). Description of Cost Data The report-gives total capital and operating costs over the years 1980 to 2010 in 1979 dollars for each of the three plans for providing transpor- tation services to persons with disabilities in urban areas (pp. 70 and 46). The transit changes would serve about 7 percent of all persons with severe disabilities living in 17,s. urban areas, the taxi plan 26 percent, and the auto plan 30 percent (p. xv). Cost Data l Transit plan - $6.8 billion . Taxi plan - $4.4 billion . Auto plan - $6.3 billion (p. 70) Comments Each cost estimate is net of estimated fare revenue from passengers with disabilities (note a, table 17, p. 70). The report does not clearly explain the methodology used to generate these estimates. The corre- sponding gross cost estimates (table 10, p. 46) appear to have been obtained inappropriately by adding nonrecurring capital costs to recur- ring operating costs. The correct method for obtaining each estimate would have been to add each plan’s estimated nonrecurring costs to the discounted present value of the stream of operating costs incurred through the life of the plan. Computed in this manner, the estimated total cost of each plan would be less than the amount reported (tables 10 Page 21 GAO/~904BR Costs of Accommodations for Disabled Appendix V Costa of Making Transit Systems Accessible to Persons With Disabilities: Brief Descriptions of Three Reports did not, however, require a specific percentage of buses to be lift- equipped. Table V.l: Annual Cost Estimates for Transportation System Modifications in Flaures are in thousands Seven Cities Current Adjusted cost to meet total program section 504 City costs implementing rules Cleveland $3.900” $3.119” Pittsburgh 2,793” 2,69ab Seattle 1,218 1,200 Kansas City, MO 1,079” 555b Akron, OH 1,145 242 Hampton, VA 93” 103b Brockton, MA 585” 245” '1982 dollars "1982.83 dollars Table V.2: Annual Costs of Transportation System Modifications in Figures are in thousands of 1983 dollars Average-Sized Cities Population Paratransit User-side taxi 50% lift bus Fewer than 250,000 $247 $92 $35 250,000-500.000 393 126 160 500 000-1.000.000 515 155 300 Over 1.OOO,OOO 1,016 196 960 Comments The report makes so many assumptions and adjustments (detailed in app. B) that extensive sensitivity analysis would be needed to assess the reported estimates. A consultant developed the second cost estimation method, an econometric model, which was not included in the report. U.S. Department of Transportation, An Evaluation of Making Rail Costs of Rail Transit Transit Systems Accessible to Handicapped Persons. Washington, D.C.: Accessibility Jan. 1981. Evaluated Section 321 of the Surface Transportation Assistance Act of 1978 required this report. It concluded that the cost of making rail mass transportation accessible to persons with disabilities could not be accu- rately estimated at that time (p. 2). Estimates of costs to comply with parts of DOT’S regulation under section 504 of the Rehabilitation Act of Page 23 GAO/HRINO44BR Costs of Accommodations for Disabled Costs of Making Telecommunications Accessible to PersonsWith Disabilities: Brief Description of One Report We identified only one report on telecommunications accessibility cost in our literature search and from contacts with various organizations. Federal Communications Commission, Order Completing Inquiry and Providing Further Notice of Proposed Rulemaking - FCC 89-242. Wash- ington, DC.: released July 27, 1989. In this document, the FCC solicited comments on two proposed plans (pp. 3,4, 16, 20,21, and 47) presenting different options for the design, organization, operation, and funding of an interstate telecommunica- tions relay system (pp. 17 and 21). Additionally, the FCC requested com- ments on cost estimates of different components (pp. 16 and 21). FCC’S analysis uses the California intrastate relay system as a model Description (p. 15). PCCestimates startup and annual operating costs for systems of Cost Data with one and two relay centers (pp. 16,21, and 23). IJsing estimates provided by parties who commented on its earlier notice, the FCC estimates the cost of requiring 25 percent of public tele- phones to be equipped with amplified handsets (pp. 40 and 35). The report presumably expresses costs in 1989 dollars, but does not explicitly state this, Startup cost (in millions of dollars): Cost Data for Relay System n 1 center - $1.5 l 2 centers - $3 Annual operating cost (in millions of dollars): l 1 center - $15 . 2 centers - $30 (pp. 16,21, and 23) FCCreports that the cost to install amplified handsets to 25 percent of Cost Data for the phones of the companies commenting on this proposal exceeds $16 Amplified Handsets million (pp. 40 and 35). Individual companies/users estimate costs (in for Public Telephones millions of dollars) as follows: l Ameritech Operating Companies - $4.3 Page 25 GAO/HRD-9044BR Costs of Accommodations for Disabled Appendix VII Major Contributors to This Report William J. Kruvant, Assistant Director, (202) 275-5186 Human Resources Catherine V. Pardee, Evaluator-in-Charge Division, Washington, Veronica Scott, Evaluator D.C. - (118280) Page 27 GAO/HRD9044BR Cmta of Accommodations for Disabled Appendix VI Costs of Making Telecommunicatioxw Accessible to Persons With Disabilities: Brief Description of One Report l Bell Atlantic Telephone Companies - $2.0 . New York Telephone - $2.0 l New England Telephone - $1 .O(p. 37) l Pacific Bell - $3.7 (p. 38) l Southwestern Bell Telephone Company - $4.86 (p. 38) Ameritech estimates a cost of $2.9 to convert its remaining convertible stations to be wheelchair-accessible (p. 42). The FCC estimates the operating cost of a relay system to permit the deaf Comments to use telephones by extrapolating the experience of California, which operates an intrastate network, the California relay system. Such appa- ratus is called “telecommunications devices for the deaf” (TDDS). The FCC assumes that the California TDD user population is, in terms of its calling habits, representative of the nation’s TDD user population. Given this assumption, the FCC estimates the average monthly number of intrastate and interstate TDD calls to be 2,265,OOOand the interstate component of this to be 271,800 (p. 16). In California, the average TDD call costs $7.00 (p. 13). If this cost is applied to the estimated monthly number of inter- state TDD calls, the estimated total operating cost of a national TDD relay system would be $1,902,600 ($7.00 X 271,800) per month or $22,831,200 annually. FCC estimates the annual cost to be $15 to $30 million. Page 26 GAO/HRD9644BR Costs of Accommodations for Disabled Appendix V Casts of Making Transit Systems Accessible to Persons With Disabilities: Brief Descriptions of Three Reports 1973 are included but not costs of interim and connector services, acces- sible bus systems, and other nonrail requirements (p. 6). Description of Cost Data The study presents transit authority cost estimates to make urban rail transit systems in 10 areas accessible to persons with disabilities. The study estimates are in constant 1979 dollars over a 30-year period for rapid and commuter rail and 20 years for light rail (p. 9 and 10). They include cumulative sums of capital and operating costs incurred to make the systems accessible. Cost Data The total cost estimates (in millions of dollars) for the 10 areas are: . Boston - $ 96.3 . Chicago - $ 828.6 . Cleveland - $ 40.6 . Detroit - $7.1 . New Jersey - $24.1 . New York - $2,710.0 . Philadelphia - $251.2 . Pittsburgh - $15.3 . San Francisco - $18.3 . Washington/Baltimore - $10.3 . Total - $4,201.8 (p. 11) DOT’Searlier estimate, developed at the time its section 504 regulation was issued, was $1.1 billion (p. 2). Comments The $4.2 billion cost estimate is misleading. Instead of summing the pro- jected annual costs, the study should have discounted each stream of annual costs back to a present value, in accordance with Office of Man- agement and Budget Circular A-94. If computed according to the guide- lines laid out in A-94, the estimated total cost would be less than $4.2 billion. Aside from the issue of how to compute the estimated total cost, the accuracy of the estimates provided by the transit operators is ques- tionable. Groups representing persons with disabilities and a group of extramural reviewers claimed that these estimates were, for a variety of reasons, overstated (pp. 14-19). Page 24 GAO/HFKHO44BR Costs of Accommodations for Disabled Appendix V Costs of Making Transit Systems Accessible to Persons With Disabilities: Brief Descriptions of Three Reports and 17). Despite the report’s assertion (n. 1, p. 47), costs of alternative options must be discounted to select the least costly option. Simply add- ing up each option’s future annual costs assumes that the discount rate is zero. If one option has relatively near-term costs and low out-year costs, assuming a zero discount rate will bias the choice in favor of that option. U.S. Department of Transportation (nor), Final Regulatory Impact Anal- Cost Impact ysis - The Department of Transportation’s Regulation Implementing of DOI’ Rule on Section 504 of the Rehabilitation Act of 1973 in the Urban Mass Transit Transportation Program. Washington, DC.: Dec. 1985. (Rev. May 13, 1986.) Services for the This report presents national and local cost estimates of compliance Disabled Calculated with the rules implementing section 504, in two ways. DOTestimates l the cost to adjust existing services for disabled persons in seven selected cities to comply with the rule, and . the annual costs of meeting the rule for transit systems in average-sized cities, using a computer model. The model is based on data from 53 Urban Mass Transit Administration funding recipients that provide special services to persons with disabilities. Description of Cost Data Costs cited for seven selected cities include all capital costs incurred since DOT’S1979 rule implementing section 504. The computer model estimates costs for averaged-sized cities for transit authority-operated transportation and taxi subsidies. Included in the taxi subsidy are costs for supplementary lift-equipped vehicle service for persons unable to use taxis (p. vii). Cost Data Current cost figures shown in table V. 1 are the total costs supporting existing service for elderly persons and persons with disabilities in the seven cities. Whether or not the service fully meets the criteria and eligi- bility of rules implementing section 504 is not a factor. The adjusted costs shown in the table are nor’s estimate of what it would cost each system to comply with all service criteria and the eligibility requirements. The lift-bus costs shown in table V.2 assume 50-percent accessibility over a 6-year phase-in period and a 20-percent spare ratio. The DOTrule Page 22 GAO/HRB9044BR Costs of Acaxnmodations for Disabled Appendix IV Costs of Employment Accommodations for Persons With Disabilities: Brief Description of one Beport The survey included only employed persons with disabilities. Persons Comments with disabilities not in the labor force may require more or less costly accommodations. Employers may tend not to hire persons with disabili- ties who require more costly accommodations. Page 20 Appendix III Costs of Making Buildings Accessible to Persons With Disabilities: Brief Descriptions of Seven Reports cost estimates for “... the most practical method resulting in the least cost ... The advice of the architects and printed information by the North Carolina Department of Insurance, Special Office for the Handi- capped, were used as sources for determining costs of needed structural changes” (p. 8). William Cochran Associates, PC., The Cost of Accessibility : A Report Making Workplaces on the Costs of Making Places of Employment Accessible for Handi- Accessible to the capped People. Prepared for Mainstream, Inc. Washington, DC.: Mar. Handicapped: 1976. Cost Estimates After surveying the cost of making a wide assortment of 34 different commercial and industrial workplaces accessible, the authors conclude that workplaces can be made accessible without spending large sums of money. Surveys were done in the 6 months prior to March 1976 (pp. 2 and 6). Description of Cost Data The average cost of making all 34 facilities accessible was less than $.Ol per square foot. To make the 29 smaller facilities (less than 1 million square feet) accessible, the average cost was less than $.05 per square foot (p. 6). Cost Data The total cost of accessibility for 28,190,OOOsquare feet of facilities sur- veyed is $264,865 (p. 5). Some specific examples of accessibility costs include: . l,OOO-square-foot office - $1,655 l 100,000 square feet of 10 retail stores - $5,000 . 131,000 square feet of offices - $23,970 l 257,000-square-foot warehouse - $7,745 l 600,000-square-foot hospital - $11,125 l 11,261 ,OOO-square-foot petrochemical complex - $10,750 (p. 5) Comments The contractor generated the cost estimates by making on-site inspec- tions of potential barriers, The report does not explain how the contrac- tor derived the estimates to remove barriers. Page 18 GAO/HRD-9044BR Costs of Accommodations for Disabled Appendix lII Costs of Making Buildings Accessible to Persone With Disabilities: Brief Descriptions of Seven Report8 increases costs over original construction costs up to 21 percent (pp. 141 and 142). Costs were estimated to conform to a 1978 proposed standard (Al 17.1) of the American National Standards Institute (p. 141 and forward). Cost Data The report estimates renovation versus redesign costs, as follows: l High-rise multifamily tower - $60,894 vs. $14,639” l Garden apartments - $42,385 vs. $5,269” l Single-family house - $3,085 vs. $436 l College dormitory - $17,641 vs. $4,562:’ l Convention hall - $108,810 vs. $14,116 . Public library - $8,338 vs. $777 (no elevator) l Town hall - $2,304 vs. $774” . College classroom - $10,690 vs. $2,70gd l Shopping center - $4,068 vs. $127 (p. 142 and 150) Comments The study’s estimates for original design and renovation are in 1975 dol- lars. The methodology involved the following steps (pp. 3 and 4): 1. Select and review building plans and specifications; 2. Obtain data on construction cost and adjust to 1975 costs based on a 20-city average; 3. Identify architectural barriers in existing plans; 4. Develop design solutions to identified barriers; 5. Use the in-place unit cost method” to estimate the cost of renovation versus changed original design, and then select the least expensive design alternative for both design and renovation; and “Foiadapting 10 percentof structures’ units. “With certain waivers For rxample, requirementsfor specificnumbersof plumbing fixtures basedon occupanciesmight be waived sothat two nonaccessibletoilet seatscan becombinedto makeone accessiblestall. ‘In the in-placeunit methodof costestimating,unit costsare the total costof all materialsand labor, including allowancesfor location,time, overhead,and profit. Page 16 GA0/HRD9044BR Costs of Accommodations for Disabled Appendix J.U Costs of Making Buildings Accessible to Persona With Disabilities: Brief Descriptions of Seven Report6 The authors used standard costs based on average labor and material costs as of January 1, 1979, unless an institution had a firm cost esti- mate for a required modification (p. 42). Cost estimates are based on the survey’s finding that about 40 percent of college and university space was then accessible to the disabled, but 75 percent was needed for compliance (p. xi). Cost Data Costs of achieving accessibility are estimated at $0.47 per usable square foot for private institutions in the United States, and $0.34 for public institutions in the United States. Usable area excludes custodial, circula- tion, mechanical, and structural areas (p. 5). These costs average $151,100 for private institutions and $216,200 for public ones (p. 5). Costs of renovation increase with building age and campus size (p. xi). The total cost estimates are $245 million for 1,620 private institutions _ and $316 million for 1,463 public institutions (p. 5). Comments The study derived nonrecurring costs by (p. 41) constructing a stratified random sample of 700 schools and conducting a mail survey through a network of state agencies. In a second stage, specially trained state per- sonnel made on-site audits of 138 of the 607 (p. 61) responding institu- tions The audit data supplemented the data obtained in the mail survey. The mail survey instrument used first was based on another instrument that had been administered repeatedly since 1968. That fact, plus the use of a sound sample design (p. 43), lends credence to the report’s cost estimates. Further Action Needed To Make All Public Buildings Accessible To Costs of Remedying GAO, The Physically Handicapped (GAO/FED-75-166, July 15, 1975). Architectural Barriers in Federally Financed The report reviewed implementation of the Architectural Barriers Act of 1968 to ensure that federally financed public buildings were designed Buildings Reviewed and constructed to be accessible to persons with disabilities (letter and pp. 2-5). Page 14 GAO/HRD9@44BR Costs of Accommodations for Disabled Appendix III Costa of Malting Building8 Accessible to Persons With Disabilities: Brief Descriptions of seven Reports Cost Data Using reasonable alternatives to renovation, the specific cost estimates are: l For making 45 percent of higher education buildings first-floor- accessible, $117.4 million (p. 31), and for one-third of existing elemen- tary and secondary school buildings, $182 million (p. 34); . For making 100 percent of higher education buildings first-floor- accessible, $261 million, and for one-half of existing elementary and secondary school facilities, $238 million (p. 34). Comments The report does not discuss why the cost factors .0056 and .0089 were chosen, other than to say that they ‘I... were built up from information we obtained from four colleges that had done surveys to determine the cost of making their buildings accessible” (p. 24). The report’s cost esti- mates depend critically upon the choice of the cost factor. The reason- ableness of these cost estimates is not clear without knowing if the four colleges are representative of all higher education facilities. Lawrence Johnson & Associates, Inc., Preliminary Exploratory Eco- Costs for HEW-Funded nomic Analysis of the Impact of Section 504 Program Accessibility Schools,Health and Requirements, an Interim Evaluation of Section 504 Implementation. Social Services, Prepared for HEW. Washington, D.C.: Aug. 15, 1979. Libraries Projected The report estimates costs to institutions receiving HEW funds for com- plying with regulations for implementing section 504. It uses data from a postcard survey of 7,662 recipient schools, health, and social service institutions other than colleges and universities, and a questionnaire survey of 700 colleges and universities. Usable responses to the post- card survey came from 2,619 institutions and to the questionnaire sur- vey from 570 colleges and universities (pp. 113 and 116). The survey results form the basis for national cost estimates (pp. 111, 113, and 117). The study team obtained additional cost data mostly by telephone (p. 120) from a subsample of 360 of these respondents (pp. 111 and 137). HEWsupplied lists of recipient institutions other than colleges and universities (p. 112) and the National Center for Education Statistics supplied the data on colleges and universities (p. 117). Description of Cost Data Structural modification costs use 1978 prices for modifications. The report gives estimates in 1979 dollars of annual continuing costs (p. 3). Page 12 GAO/BRD4&44BR Costs of Accommodations for Disabled Appendix II Scopeof Reports on Costs of Accommodating PersonsWith Disabilities Type of accommodation Facility or service atfected Report source’ Year Burldrng accessrbrlrty Higher education, elementary, and secondary schools O’Neill 1977 HEW-funded educational, medrcal, and socral service Johnson and associates 1979 institutions (includes costs of aids, relocation of servrces, and marntenance) Colleges and unrversities Wulfsbergand _____ Petersen 1979 Federal office building, medical college, two apartments, GAO 1975 engmeenng facility, and officers’ club High-rise and garden apartments, single house, college Schroederand Seinfreld 1979 dormrtory, public Irbrary, town hall, shoppmg center, and classroom _____- Institutions in Pennsylvanra offering vocational educatron Assocrated Educational 1978 .~_ __-~-____~ ~- Consultants Workplaces (34) Cochrane Associates 1976 Employment Federal contractors (367) Berkeley Plannrng Associates 1982 Transportatron systems Urban rail, bus, auto, and taxi Con ressional Budget Office 1979 .____ (CBh Mass, paratransrtb and tax! Department of Transportation 1985 __-__.- __~- (DOT) Urban rail transrt in 10 areas DOT -__- __-. 1981 Telecommunrcatrons Interstate telecommunication relay system, Including servic=F- 1989 characteristics, user charges, amplified handsets, and wheelchair access to public telephones ‘Vefer to apps IIIthrough VI at the end of this report for complete sources. bParatranSltgenerally refers to special transportatron services provided for people unable to use public systems Examples would be door-to-door, dral-a-nde bus, and van servrce for elderly persons and per. sons wth disabrlrtres Page 10 GAO/HRD-9044BR Costs of Accommodations for Dimbled Appendix I Private Industry and Interest Groups and Government Agencies Contacted for Study Private Industry American Hotel/Motel Association American Institute of Architects American Retail Federation American Society for Personnel Administration American Telephone and Telegraph Company Barrier Free Environments Bell South Corporation Building Owners and Managers Association International Chamber of Commerce Champion International J.C. Penney McGuiness & Williams MCI Communications Corporation National Association of Broadcasters National Association of Manufacturers National Association of Theater Owners National Federation of Independent Business National Restaurant Association Parks/Recreation Association Washington Business Group on Health American Foundation for the Blind Disability Interest Association for Retarded Citizens, National Disability Council Groups Disability Rights Education and Defense Fund Eastern Paralyzed Veterans National Alliance of the Mentally Ill National Center for Law and the Deaf National Disability Action Center National Foundation for the Study of Employment Policy Paralyzed Veterans of America The Easter Seal Society for Disabled Children and Adults, Inc. Trace Center, University of Wisconsin IJnited Cerebral Palsy Architectural and Transportation Barriers Compliance Board Government Agencies Congressional Research Service Council of Economic Advisors Department of Commerce Department of Education Department of Housing and Urban Development (HUD) Page 8 GAO/HRD-!?04BR Costs of Accommodations for Disabled Contents Letter 1 Appendix I 8 Private Industry and Private Industry 8 Disability Interest Groups 8 Interest Groups and Government Agencies 8 Government Agencies Contacted for Study Appendix II 10 Scopeof Reports on Costs of Accommodating Persons With Disabilities Appendix III 11 Costs of Making Transportation Options Evaluated for Persons With Disabilities 11 Buildings Accessible Costs for HEW-Funded Schools, Health and Social 12 to Persons With Services, Libraries Projected Disabilities: Brief Colleges and Universities Surveyed as to Impact of New 13 Legislation Descriptions Costs of Remedying Architectural Barriers in Federally 14 of Seven Reports Financed Buildings Reviewed Costs of Accessibility for Nine Buildings Estimated 15 Costs of Modifying Vocational Schools for Handicapped 17 Projected Making Workplaces Accessible to the Handicapped: Cost 18 Estimates Appendix IV 19 Costs of Employment Description of Cost Data 19 Cost Data 19 Accommodations Comments 20 for Persons With Disabilities: Brief Description of One Report Page 6 GAO/HRD-9044BRCosts of Accommodations for Disabled 823’7003 Only one report addresses the cost of making accommodations to facili- tate employment of persons with disabilities. It is limited to accommoda- tions made by 367 federal contractors to comply with section 503 of the Rehabilitation Act of 1973. Employment accommodations possible or required today may differ due to changes in technology. The report esti- mated that 51 percent of the accommodations made cost nothing, 30 per- cent cost less than $500, and only 8 percent cost more than $2,000. (See app. IV for a brief description of this report.) We identified three reports on transportation system accessibility. One covers 10 geographic areas and includes transit operators’ cost esti- mates, which were disputed by groups representing persons with disa- bilities and a group of extramural reviewers.” Another does not fully explain its methodology and appears to inappropriately combine non- recurring capital costs with recurring operating costs in its computation of gross costs over 30 years. The third report on transportation accessi- bility makes so many adjustments and assumptions that assessing the reported estimates would take extensive sensitivity analysis. (See app. V for brief descriptions of these three reports.) The single report on telecommunications (described in app. VI) is a notice of proposed rulemaking by the Federal Communications Commis- sion (FCC) pursuant to the Telecommunications Accessibility Enhance- ment Act of 1988. It concerns telephone and other telecommunications accessibility by persons with hearing and speech impairments. The notice requests comment on cost estimates to establish a nationwide interstate telephone relay system based on California’s intrastate relay system. - We are sending copies of this briefing report to other congressional com- mittees, federal agencies and commissions, and other interested parties. “The report concludedthat accuratelyestimatingthe costof malangrail system accessiblewas not possibleat that time Page 4 B-237003 As agreed with your respective offices, we concentrated our work on Objectives, Scope, identifiing,and reviewing published reports on the costs of removing or and Methodology avoiding architectural, transportation, employment, and communication barriers to persons with disabilities and did not develop our own esti- mates of the cost of implementing the proposed law. We reviewed literature published from 1975 to the present to identify pertinent reports. In addition, we contacted organizations representing the general business community and construction, transportation, and communication industries; groups representing persons with disabilities; and cognizant federal agencies and commissions. Our purpose was to determine whether they had studied the proposed ADA and/or knew of earlier studies on the costs of removing or avoiding architectural, trans- portation, employment, and communication barriers to disabled people. (App. I lists our contacts.) In reviewing t,he reports we identified, we evaluated the soundness of the assumptions and procedures they used to estimate costs. We did not contact the authors of the reports for addi- tional information. Our work was performed between July and October 1989. This report elaborates on information we discussed with your offices in a briefing on August 28, 1989. We identified 12 reports that estimate costs of accommodating persons Results with disabilities by removing or avoiding architectural, employment, transportation. or communication barriers. But these reports are only marginally useful in evaluating the costs of implementing the .~DA. In addition to being outdated, the reports apply only to the cost of avoiding or removing selected barriers to accessibility by persons with disabilities in selected situations. In some cases, the studies use questionable or unexplained methodologies. The accommodations the reports deal with were seen as needed by the reports’ authors at the time the studies were done and under the accessi- bility standards and with technology then available.” Dating mostly from the 1970s or r,arly 198Os, the reports contain cost data from those years or earlier. None of the reports estimate the cost impacts of imple- menting the .4DA or any of its major provisions. Of the 12 reports, 7 focus “Many of the reports ~~st~mate the nnpact of lmplemenrmgregulationsunder section 603 and 504 of The RehabilitationAct of 197:)and the useof Amwican SaWmaStandardsInstitute (ANSI) stan- dardsproposedor in effect then. Thesestandxds WWPANSI standardAl 17.1,“Amencan National Standardfor Bmldm@and Farllitirs-Provtding Ac(.cs~~hd~ty and I’sablhty for Physically Handi- cappedPeople,”and the Ilnifonn FederalAccrss~bd~ty Standards(I JFAS).which we gwwrally consis- tent with the A&S1st;mdard.ANSI Al 17 1 wits publishedonginnlly in 1961and revisedm 1%) and 1$X36. IJFASwas rmbhshedin I9R4. Page 2 GAO/HRD9044BR Costs of Accommodationsfor Disabled
Persons With Disabilities: Reports on Costs of Accommodations
Published by the Government Accountability Office on 1990-01-04.
Below is a raw (and likely hideous) rendition of the original report. (PDF)