Self Evaluation Plan and Transition Plan: Part 8 - Action Plan
Information presented herein can also be found at Corada and the New England Action Guide.
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This is the eighth article in a series about Self Evaluation Plan and Transition Plan (SEPTP). Previous parts of this series covered the history of SEPTP, identified who is in charge of the SEPTP at an entity, sent out a public notice, discussed training options for those involved with the SEPTP, covered grievance procedures regarding compliance with the Americans with Disabilities Act (ADA), offered guidance on self-evaluation plans for entities, and discussed transition plans. Now it is time to complete the action plan in Part 8 - Develop an Action Plan.
After a comprehensive self-evaluation of all programs, activities, services, and facilities operated by the entity, an action plan should be created to list all items where non-structural changes are needed at the entity. Examples of non-structural changes could include:
the entity's website might need to be reviewed for accessibility
policies might need to change to accommodate individuals with disabilities
meetings might need to be moved to a different time or place
The action plan should include any discrepancy found within program access. Program accessibility includes facility accessibility, but also means that a person with a qualified disability receives the same benefits from a program or service and has an equal opportunity to participate as any other participant. The ADA requires all Title II programs, but not all Title II buildings, to be accessible. Unlike the transition plan, there is no formal planning mechanism to make sure the non-structural changes are made. A recommended table for the action plan should be created to list the following:
non-structural changes needed
what changes are recommended
who will be responsible for each item in the action plan
and a target date should be provided for when the action plan must be completed.
Note that physical access is not required to every facility where alternative methods are as effective in providing program access. Alternative methods for compliance in existing facilities may include:
Redesigning equipment
Reassigning services to accessible buildings
Assigning aides to beneficiaries or home visits
Delivery of services at alternate sites
Alteration of existing facilities
Construction of new, accessible facilities
Use of accessible rolling stock or other conveyances
Other methods to achieve “readily accessible to and usable by”
Throughout the process, the Consultant will develop and maintain a schedule detailing proposed meetings and frequency to provide the Consultant sufficient guidance, opportunity to gather information and ideas, and to provide updates on findings, progress, and plan development for future steps.
SEPTPs are living documents/plans that require periodic updating. It is recommended that the SEPTP be audited every three (3) years, or whenever a significant change is adopted for the ADA, or when the entity undergoes changes such as building renovations/modifications/additions, program revisions or additions, or mergers/acquisitions with other entities.
SUMMARY: Entities with SEPTP plans should include an action plan to list all items where non-structural changes are needed at the entity to comply with ADA laws. The action plan should include any discrepancy found within program access. The next and last article in this series is Part 9 - Budget and Implementation.
If you need help building a new SEPTP or auditing your existing SEPTP, please call Richard Acree at 615-752-0060, or email inspections4ada@gmail.com. For additional information please see SEPTP.
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