Americans With Disabilities Act: Effects of the Law on Access to Goods
and Services (Letter Report, 06/21/94, GAO/PEMD-94-14).

This report looks at the extent to which the Americans With Disabilities
Act has improved the access for persons with disabilities to goods and
services provided by businesses and state and local governments.
Overall, GAO found steady improvement in both accessibility and
awareness during the initial 15 months that the act was in effect.
However, enough areas of concern remain to suggest a need for continuing
educational outreach and technical assistance to business and government
agencies covered by the act, as well as continued monitoring by the
Congress.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  PEMD-94-14
     TITLE:  Americans With Disabilities Act: Effects of the Law on 
             Access to Goods and Services
      DATE:  06/21/94
   SUBJECT:  Handicapped persons
             Disabilities or handicaps
             Civil rights
             Compliance
             Federal legislation
             Government facilities
             Service industry
             Retail facilities
             Building codes

             
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Cover
================================================================ COVER


Report to the Chairman, Subcommittee on Select Education and Civil
Rights, Committee on Education and Labor, House of Representatives

June 1994

AMERICANS WITH DISABILITIES ACT -
EFFECTS OF THE LAW ON ACCESS TO
GOODS AND SERVICES

GAO/PEMD-94-14

ADA:  Effects of the Law on Access


Abbreviations
=============================================================== ABBREV

  ADA - Americans With Disabilities Act
  ADAAG - ADA Accessibility Guidelines
  TDD -
  TTY -
  ANSI - American National Standards Institute
  UFAS - Uniform Facilities Accessibility Standards
  USA-ABLE -

Letter
=============================================================== LETTER


B-246667

June 21, 1994

The Honorable Major R.  Owens
Chairman, Subcommittee on Select Education
 and Civil Rights
Committee on Education and Labor
House of Representatives

Dear Mr.  Chairman: 

This report discusses the extent to which one of the main objectives
of the Americans With Disabilities Act (ADA) has been met.\1
Specifically, the Subcommittee wanted to know if access by persons
with disabilities to goods and services provided by businesses and
state and local governments had increased compared to the situation
before the effective dates of the law.  This report compares such
accessibility just before the effective date of these parts of the
law (January 1992), as previously reported, to accessibility at two
later dates, August 1992 and April 1993.\2

In brief, we found that the ADA has had some notable effects:  both
accessibility for persons with disabilities, and owners' and
managers' awareness about the ADA considerably and steadily increased
from January 1992 to April 1993.  Nevertheless, we identified some
areas where improvements could still be made and, therefore, the
attention of the Congress continues to be helpful. 

For example: 

  In the facilities we observed, the percentage of features that were
     consistent with the ADA Accessibility Guidelines (ADAAG)
     increased by 7 points from January 1992 to April 1993.\3
     Similarly, with regard to barriers that persons with
     disabilities had reported to us in our survey, we found a
     decrease of 10 percentage points during that same period. 

  According to both our observations and the reported experiences of
     persons with disabilities, a number of important barriers
     remained in April 1993 even though the number of such barriers
     had decreased by nearly 50 percent compared to those observed in
     January 1992. 

  Managers and owners of establishments covered by the ADA and in our
     sample reported greater awareness of the law and their specific
     responsibilities under it as time passed. 

  By April 1993, approximately half of the owners and managers
     interviewed still had not made any barrier-removal efforts and
     half did not have any specific plans to do so in the future. 
     Nevertheless, barrier-removal efforts, both completed and
     planned, increased by 26 and 24 percentage points, respectively,
     from January 1992 to April 1993. 

  By April 1993, a greater number of owners and managers reported
     that completed barrier-removal efforts were beneficial and fewer
     mentioned burdens, compared to those in January 1992. 

  In the facilities we visited, completed barrier-removal efforts
     were more consistent with the standards than they had been:  the
     number of completed efforts that resulted in features still not
     consistent with the ADAAG had decreased by 39 percentage points
     from January 1992 to April 1993. 

  In contrast, a sizable minority of planned barrier-removal efforts
     are not necessary, in that we judged the features they targeted
     to be already consistent with the ADAAG.  This percentage of
     unnecessary planned changes increased slightly from 28 percent
     in January 1992 to 35 percent in April 1993. 

Overall, we observed steady improvement in both accessibility and
awareness during the initial 15 months that the ADA was in effect. 
However, enough areas of concern remain to suggest a need for
continuing educational outreach and technical assistance to
businesses and government agencies covered by the act and continued
monitoring by the Congress.  Specifically, the ongoing presence of
common and important barriers, the failure of half of those visited
to remove architectural barriers or develop plans to do so in the
future, and the lack of fully informed planned barrier-removal
efforts indicate that the goal of the ADA to increase accessibility
to persons with disabilities has not yet been completely fulfilled. 
With 15 months available to complete barrier-removal efforts in areas
where little difficulty or expense would have been involved, we
believe that the facilities we observed could have done more.\4


--------------------
\1 Public Law 101-336. 

\2 U.S.  General Accounting Office, Americans With Disabilities Act: 
Initial Accessibility Good But Important Barriers Remain
(GAO/PEMD-93-16; May 19, 1993). 

\3 The ADA required that minimum guidelines be issued by the
Architectural and Transportation Barriers Compliance Board (ATBCB), a
federal agency.  The ADA Accessibility Guidelines were subsequently
adopted by the Department of Justice as standards to define new
construction and alteration requirements. 

\4 Neither the ADA nor Justice regulations specify a date by which
barrier-removal efforts must be completed.  Rather, such efforts by
businesses are a continuing obligation in that barrier removal that
is not readily achievable at this time may be readily achievable in
the future. 


   BACKGROUND
------------------------------------------------------------ Letter :1

In passing the ADA in 1990, the Congress estimated that there were 43
million Americans with disabilities and that these individuals had
been isolated and segregated, faced restrictions and limitations,
occupied an inferior status, and had been seriously disadvantaged. 
The ADA defines disability as (a) a physical or mental impairment
that substantially limits one or more of the major life activities,
(b) a record of such an impairment, or (c) being regarded as having
such an impairment.  The act prohibits discrimination in employment,
public services (including transportation), public accommodations,
and telecommunications and was designed with a phased implementation
schedule. 

We began our work on the provisions that went into effect
first--public services and public accommodations--and we plan to
evaluate the employment provisions later.  The law prohibits
discrimination by either state or local governments (referred to as
public services in title II, subtitle A) or by private businesses
(referred to as public accommodations and commercial facilities in
title III).  A major type of potential discrimination occurs when
access to goods and services offered by businesses and government
agencies is limited.  Thus the majority of the relevant ADA
regulations concerning accessibility focus on physical or
architectural barriers, such as the width of doorways, the slope of
ramps, the readability of signs, and the location of assistive
listening devices.  Our study therefore focused on the extent to
which businesses and government agencies had met these accessibility
standards.\5


--------------------
\5 Legal compliance is a separate issue and was beyond the scope of
our work, as discussed in detail in appendix I.  In brief,
determining legal compliance involves not only identifying barriers
but also, in the case of business, evaluating whether barrier removal
is readily achievable and, if not, whether the goods or services of
the public accommodation have been made available through alternative
methods (e.g., providing curb service or home delivery) or, in the
case of government, determining if barrier removal is required to
provide program access.  We did not attempt to reach conclusions in
this area. 


   OBJECTIVES AND METHODOLOGY
------------------------------------------------------------ Letter :2

We addressed four main questions: 

  To what extent did the accessibility of businesses and state and
     local government facilities to persons with disabilities change
     in the 15 months after the ADA took effect? 

  What were the most common barriers remaining? 

  To what extent did the level of owners' and managers' awareness of
     their responsibilities under the ADA change in the 15 months
     after the law took effect? 

  What was the nature of the barrier-removal efforts made by owners
     and managers from the passage of the ADA to 15 months after it
     took effect? 

We used three different methods to collect the data necessary to
answer these questions.  (A detailed description of our scope and
methodology is presented in appendix I.) Data were collected using
each of the three methods at three different times:  January 1992,
August 1992, and April 1993. 

First, we visited businesses and government facilities to evaluate
specific features of the establishments using the minimum
accessibility standards in the ADAAG.\6 In each of the 11 cities we
visited, we randomly selected up to four facilities representing each
of eight different kinds of businesses and state and local government
facilities.\7 In January 1992, we visited 231 such establishments; in
August 1992, we visited 322 different businesses and government
facilities; and in April 1993, we visited an additional 276. 

Second, we interviewed the owners or managers of the facilities we
visited to find out what they knew about the ADA and what actions, if
any, they had taken.  (We did not directly measure the extent or
accuracy of what they knew, but rather asked them to rate their own
level of knowledge.)\8

Finally, we surveyed persons with mobility and sensory- related
disabilities about how often and where, in the 6 months before each
survey, they found specific barriers in trying to access public
services and public accommodations.\9 These surveys were conducted at
the same times as the observational assessments and interviews; that
is, in January 1992, August 1992, and April 1993.\10 The number of
valid responses to each survey was 1,193, 854, and 726, respectively,
representing adjusted response rates (after invalid cases were
removed) of 64 percent, 55 percent, and 49 percent.\11

The primary strength of our method was our ability to repeat these
assessments at three different times.  This allowed us to test for
changes from a baseline as the law was implemented.  In addition, our
use of both on-site observations and our survey of the experiences of
persons with disabilities permitted us to corroborate the
accessibility status of facilities.  This helps us have more
confidence in our findings than would otherwise be the case. 


--------------------
\6 The ADA requires that government facilities provide program access
to all, which may or may not require structural change.  Our work
however, focused only on the physical accessibility of government
facilities. 

\7 We included in our review only those businesses immediately
subject to civil penalties; that is, those with 25 or more employees
or more than $1 million in gross receipts. 

\8 We are grateful to all the owners and managers who assisted with
the observations and interviews, not only giving of their time, but
also opening their establishments to us. 

\9 Persons surveyed were on the mailing lists of certain
disability-specific organizations and may not be representative of
all persons with disabilities.  We greatly appreciate the cooperation
we received from all of the organizations that assisted with this
data collection task.  We are especially indebted to the individuals
with disabilities who completed our survey. 

\10 The survey was initially sent to more than 2,200 individuals, but
many did not have a disability or were otherwise inappropriate to
include.  These individuals were excluded from the subsequent
mailings. 

\11 We have no reason to believe that there is any systematic bias
introduced by differences between respondents and nonrespondents. 
First, the pattern of response rates across the members of the
different organizations is similar at all three assessment periods,
as shown in appendix I.  Second, also illustrated in appendix I,
there are no differences based on employment status, gender, or age
of the respondents at the three assessment periods.  Finally, most of
the feedback we received from respondents at the third assessment
period suggests that some felt overly burdened.  Specifically, many
reported that they had already responded on more than one occasion
and could not respond again. 


   PRINCIPAL FINDINGS
------------------------------------------------------------ Letter :3


      ACCESSIBILITY IMPROVED AFTER
      IMPLEMENTATION OF THE ADA
---------------------------------------------------------- Letter :3.1

We found that 67 percent of the features we observed in businesses
and government facilities were consistent with the accessibility
standards by January 1992, and the level of the accessibility further
improved by 7 points by April 1993.  Our survey yielded similar
findings from the viewpoint of persons with disabilities, showing a
10-percentage-point increase.  The full results of our observations
and surveys are presented in appendixes II and III. 

We judged each establishment on as many as 431 different features. 
We also surveyed persons with disabilities about their experiences
with 97 different potential barriers.  Specifically, we found a
slight improvement in accessibility from January 1992 to April 1993. 
(See figure 1.)

   Figure 1:  Accessibility of
   Facilities

   (See figure in printed
   edition.)

  When looking at the performance of each establishment we visited,
     we found the percentage of the observed features that were
     consistent with the ADA Accessibility Guidelines increased from
     an average of 67 percent to 74 percent in the first 15 months
     the ADA was effective. 

  When considering a wide range of potential barriers listed in our
     survey, we found the percentage of persons with disabilities
     reporting that the features we asked about did not often create
     barriers increased from 72 percent to 82 percent in the 15
     months after the ADA was implemented.\12

These findings are consistent with a nationwide set of observations
made by the United Cerebral Palsy Associations in the summer of 1993. 
Scores for their assessment averaged a "B" for basically
barrier-free; few rated an "A" for accessible.\13


--------------------
\12 The rate at which respondents reported encountering barriers may
underrepresent the actual presence of barriers.  Individuals with
disabilities more than likely frequent establishments they know to be
accessible and try to avoid those they know will present barriers. 

\13 United Cerebral Palsy Associations, ADA Report Card on America: 
1993 Progress Report on ADA in American Businesses (Washington, D.C.: 
August 1993). 


      SOME IMPORTANT BARRIERS
      REMAIN
---------------------------------------------------------- Letter :3.2

To determine the most common barriers remaining, we noted any
features that met two criteria:  our survey respondents reported
encountering the barrier at least "often" and we frequently observed
the problem in our visits (in more than 50 percent of the
facilities).  Fifteen months after the ADA was implemented, we found
seven items that met these criteria.  This compares to the 13 items
we found meeting the criteria just before the law went into effect. 
However, frequent barriers may or may not be important ones.  We
therefore reviewed our findings using priorities set by the
Department of Justice for barrier removal in businesses.  Where
scarce resources set limits on barrier removal, Justice recommended
that top priority be given to improving access to a facility,
followed by access to the goods and services within; that is, doing
what one comes to do in that facility.  Access to rest room
facilities ranked third, followed by the fourth category of all
remaining access matters. 

Of the seven common barriers we found, five, or 71 percent, were in
the second highest Justice priority area--access to goods and
services--as shown in table 1.\14 Thus we concluded that despite the
relatively high level of accessibility of many of the establishments,
important barriers remain. 



                           Table 1
           
            Important Barriers Remaining in April
                  1993 by Priority Category

                                                    Features
                                                    observed
                                                   that were
                                          Mean           not
                                        survey    consistent
Category      Barrier                  score\a    with ADAAG
------------  ----------------------  --------  ------------
Entry         None
Access to     Not enough signs with       3.15           82%
 goods and     raised print or
 services      Braille
              Lack of required            3.56            81
               number of assistive
               devices for the deaf
               in hotel rooms
              Inaccessible showers        3.51            65
               or tubs in hotel
               rooms
              Inaccessible toilets        3.06            52
               in hotel rooms
              Inaccessible sinks in       3.04            66
               hotel rooms
Rest Rooms    None
Other access  Pay phones without          3.57            80
               text telephones (TTYs
               or TDDs)
              Pay phones without          3.16            77
               amplification systems
------------------------------------------------------------
\a Our survey asked persons with disabilities how often they found
specific features to be a problem.  A response of "seldom if ever"
was given a score of 1; "sometimes," 2; "often," 3; "very often," 4;
and "always or almost always," 5.  Thus a higher score indicates more
frequent encountering of the barrier. 

Frequent barriers to reaching goods and services (the second Justice
barrier-removal priority) included the following: 

  There were not enough signs with raised print or Braille, thus
     making it difficult for persons who are visually impaired to
     locate rooms on their own. 

  Hotels lacked enough assistive devices for the deaf; for example,
     devices allowing them to know that someone is knocking at the
     door or calling on the phone, that a smoke or fire alarm is
     ringing, or that the alarm clock is ringing.  This restricts the
     extent to which persons with hearing impairments can fully use
     the services and features of hotel accommodations. 

  Hotel room showers or bathtubs, toilets, and sinks were not
     accessible for wheelchairs, thus impeding access for persons who
     use wheelchairs to the rest room provided as part of normal
     hotel accommodations.\15

Other barriers included the following: 

  Public telephones lacked text telephones (telecommunication devices
     for the deaf, TDDs, TTYs). 

  Public telephones lacked amplification systems for the hearing
     impaired.\16

We also examined the individual features for which the most work
still needed to be done as of our last assessment; in other words,
those features that were frequently not consistent with the ADA
Accessibility Guidelines or that people told us often created a
barrier.  Of those, most were also in the second highest Justice
priority area.  Figure 2 illustrates this distribution for items in
our observation checklist and in our survey.  The specific items are
shown in the complete results in appendixes II and III. 

   Figure 2:  Features That Were
   Often Barriers as of April 1993

   (See figure in printed
   edition.)


--------------------
\14 We included barriers in hotel room bathrooms in the second
Justice priority category as those are barriers to the basic use of
the hotel guest room.  Barriers we found in rest rooms elsewhere,
such as in shopping malls or even the common lobby areas of hotels,
were placed in the third Justice priority category, related to rest
room access in general. 

\15 We believe that, generally, persons with disabilities may choose
to frequent facilities that are most accessible for them.  Doing so
is easier in their own community than it is out of town.  Because
they almost always use hotels in a community other than their own,
people would find it more difficult to select an accessible hotel out
of town than to select an accessible local grocery store.  For this
reason, hotels may have received particularly high scores (indicating
more barriers) from our survey respondents. 

\16 Text telephones and amplification systems are auxiliary aids. 
They are required only if the facility customarily offers telephone
service to its customers on more than an incidental convenience basis
and providing them does not create an undue burden (significant
difficulty or expense). 


      FAMILIARITY WITH ADA
      REQUIREMENTS INCREASED
---------------------------------------------------------- Letter :3.3

We found a notable increase in the level of awareness of the ADA by
owners and managers.  (See figure 3.) Specifically, we found the
following: 

  The percentage of owners and managers interviewed who reported that
     they were familiar with the ADA increased from 69 percent just
     before the law went into effect to 92 percent 15 months later. 

  Of those owners and managers who were familiar with the ADA, the
     percentage who reported that they knew they had been expected to
     remove barriers before the effective date of January 26, 1992,
     increased from 77 percent in January 1992 to 88 percent by April
     1993. 

   Figure 3:  Owner and Manager
   Awareness of the ADA\a

   (See figure in printed
   edition.)

\a The level of knowledge about the implementation date of the ADA
slightly decreased since August 1992, perhaps because after the law
was implemented and the immediate publicity about it was over, the
exact date of its effectiveness became less relevant. 

These figures may slightly understate the degree of familiarity with
the law.  That is, there may have been officials very familiar with
the ADA in the business or government agency headquarters while the
local managers we spoke with were less knowledgeable. 

Those who were familiar with the ADA received information about the
law most frequently from their corporate headquarters and the media. 
Only 10 percent reported receiving information directly from federal
agencies in April 1993, the assessment period with the highest
percentage receiving information from this source.\17 Sixteen percent
of the owners and managers interviewed in August 1992 and 19 percent
of those interviewed in April 1993 reported being approached,
unsolicited, by a vendor, contractor, architect, or similar person. 
(This question was not asked in January 1992.)


--------------------
\17 This may understate the involvement of federal agencies in
providing information about the ADA.  The owners and managers we
spoke with may have been unaware that the sources they used had
received federal funding to provide information or had developed
their materials from information provided by federal agencies.  Some
federally funded resources for information about the ADA are listed
in appendix IV. 


      BARRIER-REMOVAL EFFORTS
      INCOMPLETE DESPITE INCREASE
---------------------------------------------------------- Letter :3.4

At our third assessment period in April 1993, 45 percent of the
facilities had yet to remove an architectural barrier and 50 percent
had no plans to do so in the future.  However, at that time, 15
months after the ADA went into effect, only one establishment was
free of all barriers.  Therefore, nearly all could have had such
plans.  We believe that many businesses may simply be waiting to
remove barriers until someone complains. 

Nevertheless, the number of facilities in which an architectural
barrier was removed increased from 29 percent just before the
implementation of the ADA to 55 percent 15 months later.  Of those
establishments we visited where the owner or manager reported
recently removing a barrier, the percentage who said they had done so
because of the ADA increased from 39 percent to 75 percent.  Further,
the percentage of owners and managers who reported any specific plans
for future barrier removal at their facility increased from 26
percent just before the law went into effect to 50 percent in April
1993. 

Figure 4 illustrates that most of this improvement occurred in the
period immediately following the effective date of the law, between
January and August 1992, with little additional improvement by April
1993.  These findings, combined with a similarly initial sharp
increase and then a leveling off or slight decline in familiarity
with the ADA, may reflect the intensive educational efforts and media
attention during the period when the law was first implemented. 

   Figure 4:  Barrier-Removal
   Efforts

   (See figure in printed
   edition.)


      BARRIER-REMOVAL EFFORTS
      BENEFICIAL BUT NOT ALWAYS
      CONSISTENT WITH STANDARDS
---------------------------------------------------------- Letter :3.5

In addition, of those who removed architectural barriers, the
percentage who reported burdens related to such efforts decreased
from 41 percent in January 1992 to 27 percent in April 1993, while
the percentage who cited specific benefits--most often improved
accessibility, an increase in business, or improved customer
satisfaction--increased from 75 percent to 87 percent.  (See figure
5.)

   Figure 5:  Burdens and Benefits
   Associated With Barrier-Removal
   Efforts

   (See figure in printed
   edition.)

We found, however, that while the completed barrier-removal efforts
were more consistent with the ADA Accessibility Guidelines than they
had been, the proportion of unnecessary planned barrier-removal
efforts had increased. 

  The percentage of the barriers removed after the ADA was passed
     that did not result in features consistent with the ADAAG
     decreased from 63 percent in January 1992 to 24 percent by April
     1993.\18 For example, an owner reported widening doorways, yet
     we observed that the doorways were still too narrow.\19

  The percentage of planned changes that were not necessary, since we
     judged those features to be already consistent with the ADAAG,
     increased from 28 percent in January 1992 to 35 percent in April
     1993.\20


--------------------
\18 The number of situations for which this consistency was examined
was 54 for January 1992, 146 for August 1992, and 115 for April 1993. 

\19 The facility thus lacked full accessibility according to the
guidelines.  Note, however, that lack of information on the standards
is not the only possible interpretation.  The facility may have done
as much as necessary to comply with the law if the nature of the
facility made it virtually impossible to comply fully with
accessibility standards. 

\20 The number of situations for which this consistency was examined
was 39 for January 1992, 57 for August 1992, and 37 for April 1993. 


   CONCLUSIONS
------------------------------------------------------------ Letter :4

Together, these findings suggest that businesses have begun to
respond to the Americans With Disabilities Act, changing the lives of
persons with disabilities by increasing their access to goods and
services.  Nevertheless, while accessibility for persons with
disabilities is steadily improving, there remains a need for
continuing educational outreach and technical assistance for
businesses and government agencies covered by the ADA and therefore
the continued attention of a watchful Congress. 

First, we found important barriers remaining.  Second, we found that
half of the businesses and government facilities we visited had yet
to remove any barrier and half had no specific plans to do so in the
future.  Finally, we also found that many of the barrier-removal
efforts that were being planned did not appear to be accompanied by
adequate guidance.  Despite the availability of information and
guidance from the Department of Justice and Regional Disability and
Business Technical Assistance Centers, it is difficult for businesses
to get complete assurance that they are in compliance with the ADA. 
This leads to their continuing uncertainty about how--and especially,
how much--to comply with the act. 

This final conclusion echoes recent concerns of the National Council
on Disability that the demand for technical assistance is exceeding
the resources of federal or local governments.\21 It is also
consistent with another finding from that same report and others that
businesses and government facilities lack the certainty that they
desire, with respect to compliance under the ADA.\22


--------------------
\21 National Council on Disability, ADA Watch--Year One:  Report to
the President and the Congress on Progress in Implementing the
Americans With Disabilities Act (Washington, D.C.:  April 1993). 

\22 Andrew I.  Batavia, "Implementation of ADA Title III:  Progress
Toward a Fully Accessible Nation," Milbank Project on ADA
Implementation, Milbank Memorial Fund.  In press. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :5

Responsible officials of the Department of Justice, the Architectural
and Transportation Barriers Compliance Board, and organizations we
had consulted in doing our work provided comments on a draft of this
report, which have been incorporated in the text where appropriate. 

As agreed with your office, unless you publicly announce the contents
of this report earlier, we plan no further distribution of it until
30 days from its date of issue.  We will then send copies to
interested parties and to others upon request.  If you have any
questions or would like additional information, please call me at
(202) 512-2900 or Robert L.  York, Director of Program Evaluation in
Human Services Areas, at (202) 512-5885.  Major contributors to this
report are listed in appendix V. 

Sincerely yours,

Eleanor Chelimsky
Assistant Comptroller General


SCOPE AND METHODOLOGY
=========================================================== Appendix I

In designing our study, we focused on the extent to which businesses
and government agencies met the accessibility standards outlined in
the Americans With Disabilities Act, rather than on strict legal
compliance.\1 The possible burden of making changes in businesses was
reflected in the law, which recognized that removing architectural
barriers can be a cumbersome and expensive proposition.  If removal
of an architectural or communications barrier is not "readily
achievable" (defined in the law as "easily accomplishable and able to
be carried out without much difficulty or expense"), the law allows
goods, services, and facilities to be made available through
alternative methods that are readily achievable.\2 Government
agencies must operate their programs and services so that when viewed
in their entirety, they are readily accessible and usable by
individuals with disabilities.\3 Further, barriers can be removed in
stages in existing facilities, while different rules apply to newly
constructed facilities. 

The flexibility in the law regarding "readily achievable" standards
and the alterations provisions allow a business to be in technical
compliance with the ADA and yet not be accessible to persons with
disabilities.\4

Therefore, rather than try to determine compliance with the ADA, our
study focused on the extent to which places of public services and
public accommodation met the accessibility guidelines for buildings
and facilities as outlined in the ADA regulations. 

To answer our four study questions, we used three kinds of data
collected at three different times (January 1992, August 1992, and
April 1993).  We made firsthand observations of accessibility in
businesses and government agencies; we interviewed owners and
managers of these establishments; and we asked persons with
disabilities about their experiences in trying to access similar
facilities. 

OBSERVATIONAL ASSESSMENT

Our method included identifying which types of establishments to
visit, deciding the cities in which we should conduct our visits, and
developing an accessibility checklist. 


--------------------
\1 Businesses and government facilities may not necessarily be
required to meet the ADAAG to be in compliance with the ADA. 

\2 For example, if a storefront does not have sufficient room for the
installation of a ramp or lift, the business may instead install an
accessible buzzer so that curbside service may be offered. 

\3 Our work, however, focused only on the physical accessibility of
government facilities. 

\4 Businesses are required to remove barriers if readily achievable. 
However, the Department of Justice recognizes the continuing
obligation of barrier removal; that is, barrier-removal efforts can
be phased in over several years.  Thus, a person with a disability
may not be able to independently access the company's goods and
services for a number of years. 


      TYPES OF ESTABLISHMENTS
      OBSERVED
------------------------------------------------------- Appendix I:0.1

Title III of the ADA applies to 12 broad categories of "places of
public accommodation," with many specific types under each
category.\5 Because we did not have the resources to assess examples
of all types of public accommodations, we asked persons with
disabilities to list the types of places in which they most often
found barriers.  For this purpose, we assembled discussion groups of
persons with different types of disabilities in three cities.  We
also asked each person in these discussion groups to select the two
types of establishments where they would like to see barriers removed
first.  We selected as those we would visit, the eight types of
establishments most frequently mentioned (clothing stores, department
stores, grocery stores, shopping malls, theaters, restaurants,
hotels, and government buildings).\6


--------------------
\5 The ADA includes many specific businesses in its definition of
public accommodations:  hotels, motels, inns, or places of lodging;
restaurants, bars, or other establishments serving food or drink;
movie theaters, concert halls, stadiums, or other places of
exhibition or entertainment; auditoriums, convention centers, lecture
halls, or other places of public gathering; bakeries, grocery stores,
clothing stores, shopping centers, or other sales or rental
establishments; banks, doctors' offices, lawyers' and accountants'
offices, laundromats, dry cleaners, barber shops, beauty shops,
travel services, shoe repair services, funeral parlors, gas stations,
pharmacies, insurance offices, hospitals, or other service
establishments; terminal, depot, or other station used for specified
public transportation; museum, library, gallery, or other place of
public display or collection; park, zoo, amusement park, or other
place of recreation; school or other place of education; day care
center, homeless shelter, food bank, adoption agency, or other social
service center establishment; gymnasium, health spa, bowling alley,
golf course, or other place of exercise or recreation. 

\6 During our initial assessment period, we also conducted
observations in three airports, another frequently mentioned place of
barriers to accessibility.  We judged the three airports to be too
small a set of observations to report separately, but we did include
the airport observations in aggregate analyses. 


      GEOGRAPHIC AREAS VISITED
------------------------------------------------------- Appendix I:0.2

To identify the geographic areas in which to conduct our
observations, we turned to research that has attempted to rate the
stringency of existing state laws protecting persons with
disabilities.  To determine if there was a change in accessibility
(the ultimate goal of our work), we wanted to obtain baseline data
from those communities that were thought to have the most barriers
before the implementation of the ADA.  We found no research comparing
the actual accessibility of various communities.  Using state laws as
a proxy is less than perfect, but we considered them the best
indicator available.  (The absence of state laws protecting persons
with disabilities does not guarantee there will be barriers.)

We drew on a study that identified those states with the least
protective laws on discrimination against persons with
disabilities.\7 The authors rated state laws on six dimensions:  the
population covered by employment protection laws, the proportion of
employers regulated by these laws, the comprehensiveness of the
definition used to define disability, the proportion of buildings
covered by architectural accessibility provisions, the extent of
protections offered in public accommodations, and the extent of
protections offered in housing.  States received total scores ranging
from 5.08 (most protective) to -9.61 (least protective). 

We selected for our work the three GAO regions with the most
low-scoring states, producing a list of 11 states.  Five selected
states had scores in the negative numbers, three were in the bottom
half of the list but had positive scores, and three were at the
bottom of the top half of states.  We then selected one city to visit
per state, using two criteria.  First, we tried to identify older
communities, because we expected barriers to be most prevalent there. 
Second, we selected cities that were large enough to have a number of
businesses or government agencies of the types to be observed.  From
all these steps, our final sample included 11 cities in three
different geographic areas:  Southeast (Atlanta, Ga.; Tallahassee,
Fla.; Birmingham, Ala.; and Memphis, Tenn.), Rocky Mountains (Denver,
Colo.; Cheyenne, Wyo.; and Salt Lake City, Utah), and New England
(Boston, Mass.; Portland, Me., Burlington, Vt., and Providence,
R.I.). 


--------------------
\7 T.M.  Holbrook and S.L.  Percy, "Exploring Variations in State
Laws Providing Protections for Persons With Disabilities," Western
Political Quarterly, 45 (1992), pp.  291-320. 


      OBSERVATION CHECKLIST
------------------------------------------------------- Appendix I:0.3

To construct a data collection instrument to assess a facility's
accessibility, we turned to a number of sources.  First, we examined
an instrument previously used in a similar assessment of federally
funded public buildings.\8 Second, we examined the prior federal
standards for accessibility from the American National Standards
Institute (ANSI), the Uniform Facilities Accessibility Standards
(UFAS), and the ADA Accessibility Guidelines.\9

The ADAAG sets guidelines for accessibility in new construction and
alteration of covered businesses and government agencies.  These
guidelines therefore focus mostly on aspects of a facility that could
present physical or communication barriers.  We also reviewed
accessibility checklists developed by private consulting firms.  Our
accessibility checklist is reproduced in appendix II. 


--------------------
\8 U.S.  General Accounting Office, Further Action Needed to Make All
Public Buildings Accessible to the Physically Handicapped,
GAO/FPCD-75-166 (Washington, D.C.:  July 1975). 

\9 The UFAS standards are based on minimum guidelines developed by
the Architectural and Transportation Barriers Compliance Board and
were adopted, in consultation with the Secretary of Health and Human
Services, by all four standard-setting agencies (General Services
Administration, Housing and Urban Development, Postal Service, and
Defense) under the Architectural Barriers Act of 1968 (P.L.  90-480). 


      LOCAL SAMPLING AND SITE
      VISIT PROCEDURES
------------------------------------------------------- Appendix I:0.4

We identified the universe of entities to be sampled from the yellow
pages and government sections of the local telephone books in each of
the 11 cities.  We focused our work only on those businesses for
which title III had provided civil penalties in the first 6 months
after January 26, 1992; that is, businesses with more than 25
employees or gross receipts in excess of $1 million.  We believed
that most such businesses would be listed in the directories, and we
had no reason to believe that any systematic bias would be introduced
by the exclusion of those not so listed. 

For each assessment period, we randomly selected four examples of
each type of establishment to visit.  During our second and third
assessments, we eliminated from consideration any facility that we
had previously visited.  In the case of some businesses (such as
grocery stores, hotels, clothing stores, and restaurants), we
arranged our selection method to ensure that we visited examples of
both national chains and local or regional outlets, which we expected
to differ in the amount of resources available to devote to learning
about and responding to the requirements of the ADA. 

We contacted the managers or owners of all selected establishments,
described the purpose of our visit (and promised confidentiality),
and scheduled an appointment for the visit.  (In the initial contact,
we made sure the business was large enough to meet our eligibility
requirements.) Participation was voluntary, but the refusal rate was
low.  We have no reason to suspect a bias stemming from differences
between those who allowed our visit and those who did not.  We
completed as many of these visits as was possible in our 1-month
observation interval during each assessment period. 

INTERVIEWS OF OWNERS AND MANAGERS

At the same time we observed a facility, we also interviewed the
manager or owner about his or her knowledge about the ADA, the nature
and costs of barrier-removal efforts that the facility had recently
made, the burdens and benefits resulting from the removal of
architectural barriers, plans for further barrier removal, and any
assistance provided to the public in areas that are not fully
accessible.\10 Including the interview, our site visits lasted from 1
to 3 hours. 

We completed a total of 231 observational assessments and interviews
in January 1992, 322 in August 1992, and 276 in April 1993.  Table
I.1 describes three categories of characteristics of the facilities
we visited. 



                          Table I.1
           
              Characteristics of Establishments
                           Observed


                                 January    August     April
Category      Characteristic        1992      1992      1993
------------  ----------------  --------  --------  --------
Type of       Restaurant              37        44        42
 facility
              Shopping mall           36        35        11
              Grocery store           35        43        45
              State and local         34        40        44
               government
               office
              Hotel                   33        42        38
              Clothing store          21        32        38
              Theater                 18        40        18
              Department store        14        46        40
              Airport                  3         0         0
Nature of     National chain          71       128        88
 establishme
 nt
              Local or               153       194       174
               regional
              Unknown                  7         0        14
City          Atlanta, Ga.            15        34        32
              Tallahassee,            23        27        24
               Fla.
              Birmingham, Ala.        25        30        26
              Memphis, Tenn.          28        31        23
              Denver, Colo.           24        35        32
              Cheyenne, Wyo.          25        27        14
              Salt Lake City          27        28        29
              Boston, Mass.           16        30        31
              Portland, Me.           20        26        22
              Burlington, Vt.         17        27        17
              Providence, R.I.        11        27        26
------------------------------------------------------------
SURVEY OF PERSONS WITH
DISABILITIES

Finally, we also surveyed persons with disabilities.  Our survey
instrument, presented in appendix III, asked about both potential
barriers that are observable and those that are not.  Thus we drew
many survey items from barriers we looked for in our observations,
but we also included a number of items that persons with disabilities
had mentioned to us as creating barriers, especially those that are
not readily observable.  For example, we asked respondents if they
had ever been refused service (such as a blind person with a guide
dog being refused entry to a restaurant). 

In deciding which individuals to survey, we focused our attention on
persons most likely to encounter the variety of barriers commonly
found in places of public service and public accommodation.  The
majority of these barriers are architectural; thus, we focused on
persons with such disabilities as spinal cord injury, multiple
sclerosis, cerebral palsy, blindness, low vision, deafness, and
hearing impairments.  While this list certainly does not include all
types of disabilities, it covers many of the larger groups of persons
with disabilities who encounter barriers to access.\11

We could find no comprehensive listing of persons with disabilities
to use in drawing a sample for our survey; as a substitute, we used
national organizations' mailing lists.\12 Most of the organizations
had agreements of confidentiality with their members and therefore
could not provide us with the names and addresses of those selected. 
However, each agreed to randomly select names, to make copies of
mailing labels, and to keep a record of these names (since we needed
to follow up with individuals if they did not respond and we also
planned two later surveys of these same individuals).  For those
organizations that could not release the names, we provided
pre-stuffed, sealed, and stamped envelopes containing the
questionnaires, and they applied the mailing labels.  We followed the
same procedures for those organizations that allowed us to conduct
the mailing directly. 

Where necessary, we sent a follow-up mailing 3 weeks after the first
mailing and a follow-up postcard 2 weeks after the second.  We
recorded a reading of the text of the survey on audio tape and sent a
cassette in addition to the printed survey to individuals contacted
through the American Council for the Blind.\13

By coding each questionnaire to indicate the organization through
which an individual was selected, we could track responses and also
be confident that the mailings were completed.  We could not,
however, ensure that the names were selected randomly. 

In early January 1992, we mailed questionnaires to 2,262 individuals
with disabilities, randomly selected from the membership and mailing
lists of relevant disability-specific organizations.\14 We received
1,596 responses, for a response rate of 71 percent.  However, 403 of
these were not valid for several reasons:  the individual did not
have a disability, had moved and could not be located, was unable to
complete the survey (either because of age or the severity of
disability), was housebound and therefore did not use public services
or accommodations, was deceased, or responded indicating a lack of
interest in participating.  Subtracting those numbers from the
original sample, we recalculated the response rate to be 64 percent. 
In August 1992, we mailed 1,772 questionnaires and received 1,086
responses, for a response rate of 61 percent.  After eliminating
invalid cases, our recalculated response rate was 55 percent.  In
April 1993, we mailed 1,672 questionnaires and received 909 responses
for a response rate of 54 percent.  After eliminating invalid cases,
our recalculated response rate was 49 percent.\15

The number of responses for each membership organization is presented
in table I.2 and the characteristics of the respondents with valid
questionnaires are listed in table I.3. 



                                    Table I.2
                     
                      Number of Responses Across Membership
                                  Organizations


Or
ga
ni
za                Percent of                Percent of                Percent of
ti       Number     adjusted       Number     adjusted       Number     adjusted
on        valid       sample        valid       sample        valid       sample
--  -----------  -----------  -----------  -----------  -----------  -----------
Na          150           84          116           68          112           65
 t
 i
 o
 n
 a
 l
 S
 p
 i
 n
 a
 l
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 o
 r
 d
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 n
 j
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 r
 y
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 s
 s
 o
 c
 i
 a
 t
 i
 o
 n
Am          136           74           89           50           \a
 e
 r
 i
 c
 a
 n
 P
 a
 r
 a
 l
 y
 s
 i
 s
 A
 s
 s
 o
 c
 i
 a
 t
 i
 o
 n
Pa          135           77          102           60           88           55
 r
 a
 l
 y
 z
 e
 d
 V
 e
 t
 e
 r
 a
 n
 s
 o
 f
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 m
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 r
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 c
 a
Un          254           57          172           40          134           32
 i
 t
 e
 d
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 e
 b
 r
 a
 l
 P
 a
 l
 s
 y
 A
 s
 s
 o
 c
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 a
 t
 i
 o
 n
 s
Na          174           62          124           56          132           57
 t
 i
 o
 n
 a
 l
 M
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 t
 i
 p
 l
 e
 S
 c
 l
 e
 r
 o
 s
 i
 s
 S
 o
 c
 i
 e
 t
 y
Am          122           61           99           61           78           56
 e
 r
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 c
 a
 n
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 c
 i
 l
 f
 o
 r
 t
 h
 e
 B
 l
 i
 n
 d
Na          112           86           95           74           84           66
 t
 i
 o
 n
 a
 l
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 s
 s
 o
 c
 i
 a
 t
 i
 o
 n
 o
 f
 t
 h
 e
 D
 e
 a
 f
Na           65           84           57           75           50           71
 t
 i
 o
 n
 a
 l
 F
 r
 a
 t
 e
 r
 n
 a
 l
 S
 o
 c
 i
 e
 t
 y
 f
 o
 r
 t
 h
 e
 D
 e
 a
 f
De           45           24           \a                        48           28
 a
 f
 p
 r
 i
 d
 e
--------------------------------------------------------------------------------
\a Owing to staffing problems, the organization was unable to
complete the mailing during this assessment period. 



                          Table I.3
           
               Characteristics of Persons With
                    Disabilities Surveyed


                                 January    August     April
Category  Characteristic            1992      1992      1993
--------  --------------------  --------  --------  --------
Employme  Not employed                57        59        58
 nt
 status
          Employed part-time          14        13        13
          Employed full-time          29        28        29
Gender    Male                        57        58        57
          Female                      43        42        43
Age       Under 20                     1         1         0
          From 20 to under 30         12        11         7
          From 30 to under 40         23        22        19
          From 40 to under 50         26        25        29
          From 50 to under 60         18        19        21
          Over 60                     19        22        25
------------------------------------------------------------

--------------------
\10 We present no findings on the costs of barrier removal because
few of those interviewed were able to report the actual costs of
completed barrier-removal efforts. 

\11 Assistant Secretary for Planning and Evaluation, Department of
Health and Human Services, Task I:  Population Profiles of Disability
(Washington, D.C.:  October 1989).  M.P.  LaPlante, Data on
Disability from the National Health Interview Survey, 1983-1985, An
Info Use Report (Washington, D.C.:  National Institute on Disability
and Rehabilitation Research, 1988). 

\12 We recognize that individuals who are on such mailing lists may
not be representative of all persons with disabilities. 

\13 All individuals were invited to respond to the survey by
audiotape, in Braille, or by writing on separate pages if necessary. 

\14 We selected individuals from the following organizations (the
number of individuals selected follows in parentheses):  Paralyzed
Veterans of America (200), American Paralysis Association (200),
National Spinal Cord Injury Association (200), National Multiple
Sclerosis Society (400), United Cerebral Palsy Associations (471),
American Council for the Blind (300), National Association of the
Deaf (200), National Fraternal Society for the Deaf (91), and
Deafpride (200). 

\15 We have no reason to believe that there is any systematic bias
introduced by differences between respondents and nonrespondents. 
First, the pattern of response rates across the members of the
different organizations is similar at all three assessment periods,
as shown in table I.2.  Second, as illustrated in table I.3, there
are no differences based on employment status, gender, or age of the
respondents at the three assessment periods.  Finally, most of the
feedback we received from respondents at the third assessment period
suggests that some felt overly burdened.  Specifically, many reported
that they had already responded on more than one occasion and could
not respond again. 


OBSERVATIONAL FINDINGS
========================================================== Appendix II

All response frequencies are reported in percentages, rounded to the
nearest whole number.  These numbers represent the percentage of
facilities for which the feature was observed to be consistent with
the ADA Accessibility Guidelines. 

T1, T2, and T3 represent time 1 (January 1992), time 2 (August 1992),
and time 3 (April 1993) results, respectively.  Blanks indicate that
data were not available for that assessment period.  The figures
noted in our observation checklist refer to those in the ADAAG. 



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SURVEY FINDINGS
========================================================= Appendix III

The results presented are from part one of the survey instrument
only.  Scores are presented as means.  A response of "seldom if ever"
was given a score of 1, "sometimes," 2, "often," 3, "very often," 4,
and "always or almost always," 5.  Thus a higher score indicates more
frequent encountering of the barrier.  Time 1, time 2, and time 3
refer to January 1992, August 1992, and April 1993, respectively. 

The full survey in its original format can be found in our earlier
report, Americans With Disabilities Act:  Initial Accessibility Good
But Important Barriers Remain (GAO/PEMD-93-16; May 19, 1993). 



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FEDERALLY FUNDED RESOURCES
========================================================== Appendix IV

Questions about ADA compliance and requests for additional
information about the ADA may be directed to one of the federal
agency numbers listed below. 

U.S.  Department of Justice
Civil Rights Division
Coordination and Review Section
P.O.  Box 66118
Washington, DC 20035-6118
(202) 514-0301 Voice
(202) 514-0383 TDD

U.S.  Architectural and Transportation Barriers Compliance Board
Suite 1000
1331 F Street, N.W.
Washington, D.C.  20004-1111
(800) USA-ABLE Voice
(202) 272-5449 TDD

Regional Disability and Business Technical Assistance Centers
(800) 949-4232 Voice/TDD

Equal Employment Opportunity Commission
1801 L Street, N.W.
Washington, DC 20507
(800) 669-4000 Voice
(202) 275-7518 TDD

Federal Communications Commission
1919 M Street, N.W.
Washington, DC 20554
(202) 632-7260 Voice
(202) 632-0485 TDD

President's Committee on Employment of People With Disabilities
1331 F Street, N.W.
Washington, DC 20004
(202) 376-6200 Voice
(202) 376-6205 TDD


U.S.  Department of Labor
Office of Federal Contract Compliance
200 Constitution Ave., N.W.
Washington, DC 20210
(202) 219-9428 Voice
(800) 326-2577 TDD

U.S.  Department of Transportation
Federal Transit Administration
400 Seventh St., S.W., Room 9315
Washington, DC 20590
(202) 366-1656 Voice
(202) 366-2979 TDD


MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix V

PRINCIPAL AUTHORS AND
INVESTIGATORS


      PROGRAM EVALUATION AND
      METHODOLOGY DIVISION
------------------------------------------------------- Appendix V:0.1

Patrick Grasso, Assistant Director
Carolyn L.  Feis, Project Manager

PRINCIPAL ADVISERS


      PROGRAM EVALUATION AND
      METHODOLOGY DIVISION
------------------------------------------------------- Appendix V:0.2

Frederick V.  Mulhauser, Assistant Director
Dirk Albrecht, Management Research Assistant
Elizabeth Priaulx, Management Research Assistant

PRINCIPAL FIELD DATA COLLECTORS

The following regional office staff conducted the observational
assessments and interviews during one or more of our three 1-month
observation periods in January 1992, August 1992, and April 1993. 


      ATLANTA REGIONAL OFFICE
------------------------------------------------------- Appendix V:0.3

Robert V.  Arcenia, Site Senior
Johnny Barnes, Project Member
Michelle E.  Bowsky, Site Senior
Sherrill Y.  Caldwell, Site Senior
Kenneth A.  Davis, Project Member
Deena Devane, Project Member
Sylvia L.  Diaz, Project Member
Stacey E.  Harlow, Project Member
Anthony Kinsey, Project Member
Gerald L.  Winterlan, Project Member


      BOSTON REGIONAL OFFICE
------------------------------------------------------- Appendix V:0.4

Ellen M.  Bradley, Project Member
Sally J.  Coburn, Project Member
Thomas H.  Coder, Project Member
Denise D.  Hunter, Site Senior
Ellen B.  Massarsky, Project Member
Arthur T.  Merriam, Jr., Project Member
Lester P.  Slater, Jr., Project Member


      DENVER REGIONAL OFFICE
------------------------------------------------------- Appendix V:0.5

Debra J.  Carr, Regional Assignment Manager
Mary Cox, Project Member
Maria A.  Durant, Site Senior
Stephen P.  Gaty, Project Member
Michael L.  Gorin, Project Member
Miguel A.  Lujan, Project Member
James R.  Moore, Project Member
Christopher R.  Moos, Project Member
Renee Shirley, Project Member
