Are paratransit service providers required to provide service beyond the curb?

Under Department of Transportation (DOT) Americans with Disabilities Act (ADA) regulations at 49 C.F.R. Section 37.129(a), complementary paratransit service for ADA paratransit eligible individuals must be “origin-to-destination” service. The goal behind use of this particular language, rather than characterizing the service as “curb-to-curb” or “door-to-door,” is to emphasize the obligation of transit providers to ensure that eligible passengers are able to travel from their point of origin to their point of destination. The particular factors involved will determine whether curb-to-curb or door-to-door service will be better for that individual or the location. During the local paratransit planning process, a transit provider may establish either door-to-door or curb-to-curb service as the basic mode of paratransit service. However, a paratransit policy must not be inflexible to the extent that service will not be provided beyond the curb under any circumstance. Paratransit providers must provide enhanced service on a case-by-case basis where necessary to meet the origin-to-destination requirement; some individuals or locations may require service that goes beyond curb-to-curb service. It should be recognized that transit providers are not required to accommodate individual passengers’ needs which would fundamentally alter the nature of the service or create an undue burden. Transit providers’ obligations do not extend to the provision of personal services, such as requiring a driver to go beyond a doorway into a building to assist a passenger or requiring a driver to lose visual contact with their vehicle. For further information, please see the following DOT guidance document.