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Operational ADA Compliance for Transient Lodging Facilities

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Accessible transient lodging facilities must comply with the Americans with Disabilities Act (ADA). The 1991 ADA Standards apply to all hotels that began construction before March 15, 2012, provided that no alterations to guest rooms have taken place since that date. For all hotels built or which have undergone alterations to accessible guest rooms on or after March 15, 2012, the 2010 ADA Standards apply.

The following questions are applicable for assessment of transient lodging facility operational compliance with ADA (Americans with Disabilities Act) Regulations and Standards. References in brackets are from the Americans with Disabilities Act Title III Regulations or, the 1991 ADA Standards for Accessible Design or, the 2010 ADA Standards for Accessible Design.

1. Can persons with disabilities reserve accessible guestrooms/suites in the same ways and on the same terms that other persons can reserve guestrooms/suites? [28 CFR 36.302]

Yes __ No __ N/A __ Comments: ________________________________

2. Do all reservations staff (including staff located on-site at the lodging facility and staff located off-site at a reservations center) have ready access to information about the lodging facility's accessible guestrooms/suites (including specific information on types and sizes of accessible showers, bathtubs and other features such as, tub seats) for use in making reservations and answering questions? [28 CFR 36.302]

Yes __ No __ N/A __ Comments: ________________________________

3. Are accessible guestrooms/suites held for possible use by persons with disabilities until all other rooms in the same price category have been rented? [28 CFR 36.302]

Yes __ No __ N/A __ Comments: ________________________________

4. Are rates for accessible guestrooms/suites the same as rates for guestrooms/suites that are not designated accessible? [28 CFR 36.301(c)]

Yes __ No __ N/A __ Comments: ________________________________

5. Are accessible features inside and outside the lodging facility maintained in good working order? (For example, repairing cracks in sidewalks on exterior routes; placing portable display racks and potted plants so they do not impede exterior and interior routes; snow removal on exterior routes; replacing damaged or stolen room identification signs; tightening or adjusting accessible toilet seat fasteners, grab bars, handrails and door hardware; battery replacement for TTYs, portable visual smoke alarms and door-knock notification devices; trimming tree branches and shrubs that pose safety hazards for blind persons and persons with low vision) [28 CFR 36.211]

Yes __ No __ N/A __ Comments: ________________________________

6. Are fire-safety information, maximum room rate information, telephone and television information cards, guest services guides, restaurant menus, room service menus, and all other printed materials provided for use by guests also available in alternate formats so that blind persons and persons with low vision can read them? (Alternate formats include Braille, large print, and audio recordings) [28 CFR 36.303(b); 36.303(b)]

Yes __ No __ N/A __ Comments: ________________________________

7. Are accessible guestrooms arranged so that persons who use wheelchairs, crutches and other mobility aids can approach and use beds; bathrooms; closets; heating, air conditioning and drapery controls; lamps and light switches; telephones; computer outlets; mirrors; televisions; balconies; and other room features without moving furniture? (Note: wheelchairs need 36" of clear passage width) [28 CFR 36.304(b)(4)]

Yes __ No __ N/A __ Comments: ________________________________

8. Does the lodging facility allow persons with disabilities to use service animals, without imposing any extra charges or conditions, in guestroom/suites and all public areas of the facility (e.g.: restaurants, bar areas, facility grounds, vans/shuttle buses, and other areas for meeting or recreation)? [28 CFR 36.302(c)]

Yes __ No __ N/A __ Comments: ________________________________

9. Does the facility have a reasonable number of TTYs available for use by persons who are deaf or hard of hearing? [28 CFR 36.303(d)]

Yes __ No __ N/A __ Comments: ________________________________

10. Is there a TTY available at the front desk so that lodging facility personnel can communicate with persons who are deaf or have speech impairments (e.g.: taking room service orders, answering requests for assistance, etc.)? [28 CFR 36.303]

Yes __ No __ N/A __ Comments: ________________________________

11. If the lodging facility has televisions in guestrooms/suites, is a close-captioning decoder provided for use by persons who are deaf or hard of hearing or do televisions include built-in captioning features? [28 CFR 36.303(e)]

Yes __ No __ N/A __ Comments: ________________________________

12. Are hotel staff available to move furniture, and provide and adjust accessible features in guestrooms when features require installation or adjustment to ensure accessibility (e.g.: installing bathtub seats, lowering adjustable shower wands, placing folding seats in transfer showers in the down position, installing auxiliary fire alarm strobes into the building alarm system, activating the television's closed captioning system)? [28 CFR 36.302(a)]

Yes __ No __ N/A __ Comments: ________________________________

13. Is the hotel staff trained to offer assistance, upon request, to persons with disabilities who cannot transport their luggage to/from their guestrooms/suites and who may need assistance in locating guestrooms and hotel amenities? [28 CFR 36.302(a)]

Yes __ No __ N/A __ Comments: ________________________________

14. If the facility offers transportation services for guests, is accessible transportation readily available for guests who use wheelchairs and other mobility aids without additional charge? [28 CFR 36.310]

Yes __ No __ N/A __ Comments: ________________________________

15. If a portion of the lobby is used for breakfast service, is it approachable and usable by persons with disabilities who cannot climb steps or stairs? [ADA 1991 Stds. 4.3, 2010 Stds. 402]

Yes __ No __ N/A __ Comments: ________________________________

SUMMARY

The questions in this article are designed to evaluate the operational readiness for ADA compliance of a transient lodging facility. These questions only represent a small portion of a complete assessment of a transient lodging facility for ADA compliance.

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If you observe a hotel, motel or inn that is not ADA compliant and you would like to know how to proceed, please see the link at What To Do When A Building Is Not ADA Compliant or Accessible.

ADA Inspections Nationwide, LLC, offers ADA/ABA/FHA accessibility compliance inspections for buildings and facilities, as applicable to the different laws, and expert witness services with respect to ADA/ABA/FHA laws for building owners, tenants and managers. Also, ADAIN offers consulting for home modifications as a CAPS consultant for people wishing to age in place in their homes. For a complete list of services please see ADAIN Services.

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