Information provided in part by the US Access Board

Medical Care and Long-Term Care facilities must comply with the Americans with Disabilities Act (ADA). The sections of the 2010 ADA Standards that specifically cover these facilities are §223 and §805. Covered facilities include hospitals, rehabilitation facilities, psychiatric facilities, detoxification facilities, and medical units in prisons, correction facilities, and detention centers. Long-term care facilities such as nursing homes and assisted living facilities are also covered. Skilled nursing facilities could be considered either a medical care facility or a long-term care facility, depending on the purpose of the facility, and the license the facility holds. The photo on the right is representative of a hospital.

Other regulations that apply to these facilities in a similar manner are Implementation Regulation 28 CFR 35.151(h) and Implementation Regulation 28 CFR 36.406(g). Please see below.

Implementation Regulation 28 CFR 35.151(h), [New Construction and Alterations] Medical care facilities, states, “Medical care facilities that are subject to this section shall comply with the provisions of the 2010 [ADA] Standards applicable to medical care facilities, including, but not limited to, sections 223 and 805. In addition, medical care facilities that do not specialize in the treatment of conditions that affect mobility shall disperse the accessible patient bedrooms required by section 223.2.1 of the 2010 [ADA] Standards in a manner that is proportionate by type of medical specialty.”

Implementation Regulation 28 CFR 36.406(g), [Standards for new construction and alterations] Medical care facilities, states, “Medical care facilities that are subject to this part shall comply with the provisions of the 2010 [ADA] Standards applicable to medical care facilities, including, but not limited to, sections 223 and 805. In addition, medical care facilities that do not specialize in the treatment of conditions that affect mobility shall disperse the accessible patient bedrooms required by section 223.2.1 of the 2010 [ADA] Standards in a manner that is proportionate by type of medical specialty.”

Professional offices of healthcare providers (Doctor’s Offices) are not included in Medical Care facilities, but these facilities still must comply with the requirements of the ADA in general. The photo on the left is representative of an office for a medical healthcare provider.

Patient or Resident Sleeping Rooms

2010 ADA Standard 223.1, [Medical Care and Long-Term Care Facilities] General, states, “In licensed medical care facilities and licensed long-term care facilities where the period of stay exceeds twenty-four [24] hours, patient or resident sleeping rooms shall be provided in accordance with [Standard] 223. EXCEPTION: Toilet rooms that are part of critical or intensive care patient sleeping rooms shall not be required to comply with [Standard] 603.”

Advisory 223.1, General, states, “Because medical facilities frequently reconfigure spaces to reflect changes in medical specialties, Section 223.1 does not include a provision for dispersion of accessible patient or resident sleeping rooms. The lack of a design requirement does not mean that covered entities are not required to provide services to people with disabilities where accessible rooms are not dispersed in specialty areas. Locate accessible rooms near core areas that are less likely to change over time. While dispersion is not required, the flexibility it provides can be a critical factor in ensuring cost effective compliance with applicable civil rights laws, including titles II and III of the ADA and Section 504 of the Rehabilitation Act of 1973, as amended. Additionally, all types of features and amenities should be dispersed among accessible sleeping rooms to ensure equal access to and a variety of choices for all patients and residents.”

2010 ADA Standard 223.2, [Medical Care and Long-Term Care Facilities] Hospitals, Rehabilitation Facilities, Psychiatric Facilities and Detoxification Facilities, states, “Hospitals, rehabilitation facilities, psychiatric facilities and detoxification facilities shall comply with [Standard] 223.2.

2010 ADA Standard 223.2.1, Facilities Not Specializing in Treating Conditions That Affect Mobility, states, “In facilities not specializing in treating conditions that affect mobility, at least 10 percent, but no fewer than one, of the patient sleeping rooms shall provide mobility features complying with [Standard] 805.” Examples of facilities that do not specialize in treating conditions of mobility could include Detoxification Facilities, Psychiatric Facilities, Prison Medical Wards, etc. Hospitals could specialize in treating many different conditions, including mobility.

2010 ADA Standard 223.2.2, Facilities Specializing in Treating Conditions That Affect Mobility, states, “In facilities specializing in treating conditions that affect mobility, 100 percent of the patient sleeping rooms shall provide mobility features complying with [Standard] 805.

2010 ADA Standard Advisory 223.2.2, Facilities Specializing in Treating Conditions That Affect Mobility, states, “Conditions that affect mobility include conditions requiring the use or assistance of a brace, cane, crutch, prosthetic device, wheelchair, or powered mobility aid; arthritic, neurological, or orthopedic conditions that severely limit one's ability to walk; respiratory diseases and other conditions which may require the use of portable oxygen; and cardiac conditions that impose significant functional limitations. Facilities that may provide treatment for, but that do not specialize in treatment of such conditions, such as general rehabilitation hospitals, are not subject to this requirement but are subject to Section [Standard] 223.2.1.”

2010 ADA Standard 223.3, Long-Term Care Facilities, states, “In licensed long-term care facilities, at least 50 percent, but no fewer than one, of each type of resident sleeping room shall provide mobility features complying with [Standard] 805.” Note that what constitutes a licensed long-term care facility is commonly determined at the state or local level. When evaluating a facility, first verify what classification of the facility exists in order to determine which Standard applies. The photo on the right is representative of a long-term care facility resident sleeping room.

2010 ADA Standard 223.1.1, [Medical Care and Long-Term Care Facilities, General] Alterations, states, “Where sleeping rooms are altered or added, the requirements of [Standard] 223 shall apply only to the sleeping rooms being altered or added until the number of sleeping rooms complies with the minimum number required for new construction.”

2010 ADA Standard Advisory 223.1.1, Alterations, states, “In alterations and additions, the minimum required number is based on the total number of sleeping rooms altered or added instead of on the total number of sleeping rooms provided in a facility. As a facility is altered over time, every effort should be made to disperse accessible sleeping rooms among patient care areas such as pediatrics, cardiac care, maternity, and other units. In this way, people with disabilities can have access to the full-range of services provided by a medical care facility.” The photo below is representative of a hospital corridor with entrances to multiple patient sleeping rooms.

Mobility Features Required by 2010 ADA Standard 805

There are three (3) specific features covered in 2010 ADA Standard 805. These include turning space, clear floor space or ground space, and toilet/bathing rooms. Although only these three features are specifically mentioned in Standard 805, the requirement for other elements in these facilities to be compliant also applies. These other elements could include entry/exit doors, communication equipment, fire alarms, kitchens and kitchenettes, parking, passenger loading zones, accessible routes, protruding objects, signs, employee work areas, counters, public and common use areas, dining and work surfaces, recreation/rehabilitation facilities, medical diagnostic equipment, wall mounted features such as paper towel dispensers and electrical outlets, and websites. However, there are exceptions for these elements, most notably in specialty sleeping rooms found in intensive care units or similar situations.

2010 ADA Standard 805.2, [Medical Care and Long-Term Care Facilities] Turning Space, states, “Turning space complying with [Standard] 304 shall be provided within the room.” 2010 ADA Standard 304.3, [Turning Space] Size, states, “Turning space shall comply with [Standards] 304.3.1 or 304.3.2.”

2010 ADA Standard 304.3.1, Circular Space, states, “The turning space shall be a space of 60 inches (1525 mm) diameter minimum. The space shall be permitted to include knee and toe clearance complying with [Standard] 306.”

2010 ADA Standard 304.3.2, T-Shaped Space, states, “The turning space shall be a T-shaped space within a 60 inch (1525 mm) square minimum with arms and base 36 inches (915 mm) wide minimum. Each arm of the T shall be clear of obstructions 12 inches (305 mm) minimum in each direction and the base shall be clear of obstructions 24 inches (610 mm) minimum. The space shall be permitted to include knee and toe clearance complying with [Standard] 306 only at the end of either the base or one arm.” The graphic below is representative of these Standards.

Remember, these turning space requirements are minimum dimensions only. Some equipment in hospitals and long-term care facilities may require larger turning spaces. Note also that Standard 304 requires that the turning space floor be mostly level and the turning space floor should be stable, firm, and slip resistant. Doors shall be permitted to swing into turning spaces. For additional information please see Medical Room Clear Space and Turning Space. For a video animation please see Animation, then select the video for wheelchair maneuvering.

2010 ADA Standard 805.3, [Medical Care and Long-Term Care Facilities] Clear Floor or Ground Space, states, “A clear floor space complying with [Standard] 305 shall be provided on each side of the [patient] bed. The clear floor space shall be positioned for parallel approach to the side of the bed.” The photo below is representative of a bed in a hospital patient room.

2010 ADA Standard 305.3, [Clear Floor or Ground Space] Size, states, “The clear floor or ground space shall be 30 inches (760 mm) minimum by 48 inches (1220 mm) minimum.” The graphic below is representative of a clear space.

Note that Standard 305 also requires that the clear space floor be mostly level and the clear space should join an accessible route or another clear space. The clear space floor should also be stable, firm, and slip resistant.

2010 ADA Standard 805.4, [Medical Care and Long-Term Care Facilities] Toilet and Bathing Rooms, states, “Toilet and bathing rooms that are provided as part of a patient or resident sleeping room shall comply with [Standard] 603. Where provided, no fewer than one water closet, one lavatory, and one bathtub or shower shall comply with the applicable requirements of [Standards] 603 through 610.” The graphic on the right is a plan view of a typical toilet/bathing room in a hospital patient room with a toilet, shower, and sink. Note the clear spaces, a turning space, and the door swing into the space.

Per ADA Standard 223.1 discussed above, those toilet and bathing rooms serving patient rooms are required to be accessible except for toilet rooms that are part of critical or intensive care patient sleeping rooms, which are not be required to comply with 2010 ADA Standard 603 [Toilet and Bathing Rooms]. Standard 603 covers clearances such as turning spaces, overlap of turning spaces, clear spaces, and door swings, as well as requirements for mirrors, coat hooks, and shelving.

Additional exceptions in Standard 213.2 are for ADA compliance of toilet rooms in new construction, where all toilet and bathing facilities must be accessible, except:

• clustered portable units in a single location, where no more than 5% are required to be accessible,

• clustered single-user toilet rooms in a single location where no more than 50% are required to be accessible.

Specifically, with respect to portable units, it is important that not only at least 5% of the portable units be accessible units, but the route to the accessible portable units must be accessible as well. Also, clustered units would be where there are 2 or more similar units in a single location. For example, two unisex toilet rooms located in a single area are considered similar and clustered, but a Men’s and Women’s toilet rooms located in a single location are not similar and therefore not clustered. For a video animation please see Animation, then select the video for bathing facilities or toilet rooms.

Other ADA Requirements for Medical and Long-Term Care Facilities

As was mentioned above, there are other elements in medical and long-term care facilities and sleeping rooms that need to be fully accessible. These elements could include entry/exit doors, communication equipment, fire alarms, kitchens and kitchenettes, parking, passenger loading zones, accessible routes, protruding objects, signs, employee work areas, counters, public and common use areas, dining and work surfaces, recreation/rehabilitation facilities, medical diagnostic equipment, wall mounted features such as paper towel dispensers and electrical outlets, and websites. These items will be discussed below.

Accessible Doors for Medical and Long-Term Care Facilities

2010 ADA Standard 404 covers doors for ADA compliance. The graphic below is representative of many of the requirements for doors.

One particular requirement of door compliance is maneuvering clearance. 2010 ADA Standard 404.2.4, [Manual Doors, Doorways, and Manual Gates] Maneuvering Clearances, states, “Minimum maneuvering clearances at doors and gates shall comply with [Standard] 404.2.4. Maneuvering clearances shall extend the full width of the doorway and the required latch side or hinge side clearance. EXCEPTION: Entry doors to hospital patient rooms shall not be required to provide the clearance beyond the latch side of the door.” The photo on the right is representative of a hospital exam room with an entry door that swings into the exam room. Note the built-in desk and exam table adjacent to the entry/exit door. Clearance from the latch side of the door to the corner of the room is visible. This Standard applies to doors for exam rooms, toilet rooms, and patient rooms, unless an exception applies.

2010 ADA Standard 404.2.4.1, Swinging Doors and Gates, states, “Swinging doors and gates shall have maneuvering clearances complying with Table 404.2.4.1.” Table 404.2.4.1 for this door installation in the photo above requires specific door maneuvering space on both sides of the door. On the inside/pull side of the door, the Table requires maneuvering space the full width of the door plus 18 inches parallel to the doorway on the latch side, and the maneuvering space is required to be 60 inches in depth measured perpendicular to the doorway. The graphic above is representative. This maneuvering clearance must not be obstructed. In the exam room photo above, the 60 inch depth requirement measured perpendicular to the doorway may be compromised by the desk and overhead storage installation.

On the other side of the exam room door, the push-to-open side, and assuming an approach from the latch side of the door, the Table requires maneuvering space the full width of the door plus 24 inches parallel to the doorway on the latch side, and the maneuvering space is required to be 42 inches in depth measured perpendicular to the doorway, unless a door closer is installed, in which case the requirement is for 48 inches in depth measured perpendicular to the doorway. The graphic on the left is representative of this requirement for a door without a closer. Again, this maneuvering space needs to remain clear.

However, for hospital patient rooms only, the exception above for Table 404.2.4.1 applies and states “the entry doors to hospital patient rooms shall not be required to provide the clearance beyond the latch side of the door.” This exception does not apply to exam rooms. For additional information about doors please see Manual Doors and the ADA. For a video animation please see Animation, then select the video preferred.

Communication Features

Although public pay telephones are becoming less common in facilities, the need for teletypewriter phones (TTYs) still exists and must comply with the ADA Standards. 2010 ADA Standard 217.4.6, [TTYs] Hospitals, states, “Where at least one public pay telephone is provided serving a hospital emergency room, hospital recovery room, or hospital waiting room, at least one public TTY shall be provided at each location.” This requirement exists for coin-operated public pay telephones, coinless public pay telephones, public closed-circuit telephones, public courtesy phones, or other types of public telephones provided at these locations. The graphic on the right is representative of a TTY installation in a hospital waiting room. The ADA requirements for accessible phones in general are significant. Additional information can be found at Accessible Phones.

Fire Alarms Systems

2010 ADA Standard 702.1, covers Fire Alarm Systems for accessible facilities. Standard 702.1, General, states, “Fire alarm systems shall have permanently installed audible and visible alarms complying with NFPA 72 (1999 or 2002 edition). Exception: Fire alarm systems in medical care facilities shall be permitted to be provided in accordance with industry practice.” The graphic on the right is representative of the Cover of National Fire Alarm Code (NFPA 72).

There is an exception for fire alarm systems in medical care facilities that are permitted to be provided in accordance with industry practice where an alarm is not sounded in some locations but hospital staff and public are alerted. In these locations patients are not alerted because their evacuation will require staff assistance, so the location of the alarms can be reduced. Examples could be an operating room or intensive care ward.

Kitchens and Kitchenettes

Kitchens and Kitchenettes may be found in medical care and long-term care facilities. Kitchenettes typically do not have a cook-top or range, so they are more likely to be found in a medical care facility, perhaps in an employee break room. Kitchens are more likely to be found in long-term care facilities. When installed, these spaces should comply with the ADA Standards. The 2010 ADA Standards that cover primarily kitchens and kitchenettes are 212, 606, and 804. The photo on the right is representative of a kitchenette. For additional information please see Accessible Kitchens and Kitchenettes.

Accessible Parking and Passenger Loading Zones

Parking requirements are covered primarily in 2010 ADA Standards 208 and 502. All Title II and Title III facilities that have parking spaces must have ADA compliant parking as well, with a few exceptions such as for law enforcement parking, vehicle impound, and commercial vehicle storage. In new construction accessible parking applies to visitor, patron, and employee parking. The minimum number of required accessible parking spaces is calculated separately for each parking facility (e.g., lot, garage, etc.). And if accessible parking is provided, at least one van accessible parking space must be provided and thereafter one van accessible parking space for every 6 or fraction of 6 ADA accessible parking spaces. The graphic above is representative of accessible parking spaces. Note that the International Symbol of Accessibility that is painted on the surface of these accessible parking spaces is not required by the ADA, but is commonly required by local codes.

For most Title II and Title III facilities the number of required accessible parking spaces is covered by 2010 ADA Standard 208.2 and presented in Table 208.2. However, there are special rules for hospital outpatient facilities, rehabilitation facilities, and outpatient physical therapy facilities. Please see below.

2010 ADA Standard 208.2.1, [Parking] Hospital Outpatient Facilities, states, “Ten percent [10%] of patient and visitor parking spaces provided to serve hospital outpatient facilities shall comply with [Standard] 502.” The term “outpatient facility” is not defined in the ADA but is intended to cover facilities or units that are located in hospitals and that provide regular and continuing medical treatment without an overnight stay. Note that this Standard only applies to hospital outpatient facilities. Doctors' offices, independent clinics, medical equipment retail facilities, or other facilities not located in hospitals are not considered hospital outpatient facilities with respect to the ADA. These facilities should use Table 208.2 to determine the minimum required ADA parking spaces.

2010 ADA Standard 208.2.2, [Parking] Rehabilitation Facilities and Outpatient Physical Therapy Facilities, states, “Twenty percent [20%] of patient and visitor parking spaces provided to serve rehabilitation facilities specializing in treating conditions that affect mobility and outpatient physical therapy facilities shall comply with [Standard] 502.”

Conditions that affect mobility include conditions requiring the use or assistance of a brace, cane, crutch, prosthetic device, wheelchair, or powered mobility aid; arthritic, neurological, or orthopedic conditions that severely limit one's ability to walk; respiratory diseases and other conditions which may require the use of portable oxygen; and cardiac conditions that impose significant functional limitations.

For mixed use facilities where a medical or long-term care facility is co-located with other types of facilities such as restaurants and retail outlets, the number of parking spaces dedicated to the medical or long-term care facility is usually based on the square footage or occupancy loads of the different facilities. So, it would be necessary to consult with local codes to determine the measurements used to decide how many parking spaces are dedicated to a specific facility. The graphic below is representative of a mixed use facility where there is a hospital co-located with an outpatient clinic.

For additional information regarding ADA parking spaces installed correctly see ADA Parking Done Right. For a video animation please see Animation, then select the video for parking.

Passenger loading zones at facility entrances are covered primarily in 2010 ADA Standards 209 and 503. 2010 ADA Standard 209.3, [Passenger Loading Zones and Bus Stops] Medical Care and Long-Term Care Facilities, states, “At least one passenger loading zone complying with [Standard] 503 shall be provided at an accessible entrance to licensed medical care and licensed long-term care facilities where the period of stay exceeds twenty-four hours.” So this requirement does not apply to facilities with outpatient services only. The graphic on the right is representative of a passenger loading/unloading zone at a facility. Note that the canopy is not required, but if it is present, must comply with the ADA. For additional information please see Passenger Loading/Unloading Zone. Note also that facilities that provide valet parking also must provide an accessible passenger loading/unloading zone.

Accessible Routes

Exterior and interior accessible routes are required at medical and long-term care facilities. Accessible routes are covered primarily in 2010 ADA Standards 206 and 402-410. Accessible routes shall consist of one or more of the following components: walking surfaces with a running slope not steeper than 1:20, doorways, ramps, curb ramps excluding the flared sides, elevators, and platform lifts. All components of an accessible route shall comply with the applicable requirements of 2010 ADA Chapter 4.

2010 ADA Standard 206.2.1, [Accessible Route, Where Provided] Site Arrival Points, states, “At least one accessible route shall be provided within the site from accessible parking spaces and accessible passenger loading zones; public streets and sidewalks; and public transportation stops to the accessible building or facility entrance they serve.” The graphic below is representative of exterior accessible routes. Each (all) site arrival point(s) must be connected by an accessible route to the accessible building entrance or entrances served. Where two or more similar site arrival points, such as bus stops, serve the same accessible entrance or entrances, both bus stops must be on accessible routes. In addition, the accessible routes must serve all of the accessible entrances on the site.

Note that for exterior accessible routes, a vehicular way can be included as part of the route from a site arrival point, as long as that portion of the vehicular way complies with Chapter 4 of the ADA. Also, at least one accessible route shall connect accessible buildings, accessible facilities, accessible elements, and accessible spaces that are on the same site, unless the route includes a vehicular way that does not comply with Chapter 4 in the ADA. The graphic on the left shows two buildings on a site connected by raised and enclosed walking surfaces, sometimes referred to as skyways.

For interior accessible routes, 2010 ADA Standard 206.2.4, [Accessible Route, Where Provided] Spaces and Elements, states, “At least one accessible route shall connect accessible building or facility entrances with all accessible spaces and elements within the building or facility which are otherwise connected by a circulation path unless exempted by [Standard] 206.2.3 Exceptions 1 through 7.” The graphic on the right is representative of an interior accessible route. So those interior features that need to be connected include rooms, spaces, levels, stories, and elements. And as is always the case, the accessible routes should coincide with the general circulation paths. Note that accessible routes should include the circulation paths, but circulation paths may not always include an accessible route.

In multi-story buildings and facilities, accessible routes are required to each story and mezzanine of the building or facility unless there is an exception to the Standards. For example, some Title III buildings and facilities may have an elevator exemption, however, if there is an office of a health care provider on other than the main story where the entrances are located, these exceptions do not apply and an accessible route will always be required. Remember, stairs and escalators are not considered an accessible route. The graphic above is representative of a building with an office of a health care provider on other than the main story where the entrances are located, so an elevator is installed as part of the accessible route to the upper story.

In medical and long-term care facilities, there are often handrails installed along walking surfaces, which is part of the accessible route. Normally, walking surfaces do not require handrails because the slope of the walking surface does not exceed 5%. But, where handrails are provided along walking surfaces, 2010 ADA Standard 403.6, [Walking Surfaces] Handrails, states, “Where handrails are provided along walking surfaces with running slopes not steeper than 1:20 [5%] they shall comply with [Standard] 505.” This Standard excludes elevator cars and lifts. So if handrails are provided, they must comply with the ADA Standards. It is also common for these handrails that are installed along walkways in hospitals and long-term care facilities, that the handrails are incorporated with crash rails that attach to the walls completely along the bottom of the rail, similar to those shown in the photo above. Normally, 2010 ADA Standard 505.6, [Handrails], Gripping Surface, only allows no more than 20% of the bottom of handrail gripping surfaces to be obstructed. However, there is an exception in Standard 505.6 that allows these crash rail installations to be obstructed along their entire length if the slope of the walking surface does not exceed 1:20, or 5%.

For a video animation please see Animation, then select the video for wheelchair maneuvering.

Protruding Objects

Protruding objects are covered in the 2010 ADA Standards 204 and 307. As with any building or facility, the requirements for protruding objects in circulation paths will apply to medical and long-term care facilities. The graphic on the right is representative of a protruding object impacting a disabled individual. Additional information is available at Protruding Objects. For a video animation please see Animation, then select the video for Protruding Objects.

Assembly Areas

The 2010 ADA Standards defines Assembly Area as “A building or facility, or portion thereof, used for the purpose of entertainment, educational or civic gatherings, or similar purposes. For the purposes of these requirements, assembly areas include, but are not limited to, classrooms, lecture halls, courtrooms, public meeting rooms, public hearing rooms, legislative chambers, motion picture houses, auditoria, theaters, playhouses, dinner theaters, concert halls, centers for the performing arts, amphitheaters, arenas, stadiums, grandstands, or convention centers.” If the hospital is a teaching hospital, such as a university medical center, or the long-term care facility has a gathering room such as a theatre room, perhaps to show movies or make presentations, then the ADA laws for assembly areas will apply. The ADA laws for assembly areas are covered primarily in 2010 ADA Standards 221 and 802. The graphic on the right is representative of an assembly area. For additional information please Accessible Assembly Areas.

Signs

Signs are covered primarily in the 2010 ADA Standards 216 and 703. Signs can be tactile, visual only, or a combination of tactile and visual. Visual-only signs are normally installed as directional or informational signs. Tactile/visual signs are normally installed at permanent rooms and spaces and at exits. Examples of tactile sign installations includes: restroom labels (at entry), room numbers and names (not likely to change), floor levels (elevators), exit access/discharge points, areas of rescue assistance. The graphic on the left is representative of a tactile/visual sign.

2010 ADA Standard 216 requires signs at the following locations:

• Means of egress

• Parking

• Entrances

• Elevators

• Toilet and bathing rooms

• TTYs

• Assistive listening systems

• Check-out aisles

For a video animation please see Animation, then select the video for Signs. For additional information please see Signs.

Employee Work Areas

Employee work areas are defined in the 2010 ADA Standard 106.5 as “All or any portion of a space used only by employees and used only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.” The primary focus of the 2010 ADA Standards regarding employee work areas is on the pedestrian entry/exit door(s) to these spaces, an accessible circulation path for employee work areas of 1000 SF or greater, an accessible means of egress, and an audible and/or visual emergency alarm system. Note that within the Architectural Barriers Act (ABA) for federal buildings and facilities, the employee work areas must be fully ABA compliant.

2010 ADA Standard Advisory 203.9, Employee Work Areas, states, “Although areas used exclusively by employees for work are not required to be fully accessible, consider designing such areas to include non-required turning spaces, and provide accessible elements whenever possible. Under the ADA, employees with disabilities are entitled to reasonable accommodations in the workplace; accommodations can include alterations to spaces within the facility. Designing employee work areas to be more accessible at the outset will avoid more costly retrofits when current employees become temporarily or permanently disabled, or when new employees with disabilities are hired.”

Medical and long-term care facilities can have spaces that are a combination of employee work areas and public spaces. An example is a medical exam room where there can be a desk, counter/cabinet, and sink installation that is for employees only, but the exam table and the room in general can be used by the public or employees. The graphic below is representative.

In the graphic above, the room is a public and common-use space, but the desk, counter/cabinet, and sink installations are for employees only. Even though a patient could use the sink, the intent of the sink (and other elements) installation is for employee use only, which is how the ADA is applied to this installation.

Counters

Depending on the facility, there are commonly different counters installed at medical and long-term care buildings and facilities that may include sales, service, check-out aisles, and food service lines. These installations must comply with the ADA. Counters are covered primarily in the 2010 ADA Standards 227 and 904. 2010 ADA Standard 227.3, Counters, states, “Where provided, at least one of each type of sales counter and service counter shall comply with [Standard] 904.4. Where counters are dispersed throughout the building or facility, counters complying with [Standard] 904.4 also shall be dispersed.” The graphic on the right is representative of a service counter.

Types of counters that provide different services in the same facility include, but are not limited to, order, pick-up, express, and returns. One continuous counter can be used to provide different types of service. For example, order and pick-up are different services. It would not be acceptable to provide access only to the part of the counter where orders are taken when orders are picked-up at a different location on the same counter. Both the order and pick-up section of the counter must be accessible. The graphic below is representative. Additional information is available at Counters. For a video animation please see Animation, then select the video preferred.

Public and Common Use Areas

Public use areas are defined in the 2010 ADA Standards as “Interior or exterior rooms, spaces, or elements that are made available to the public. Public use may be provided at a building or facility that is privately or publicly owned.” Common use areas are defined in the 2010 ADA Standards as “Interior or exterior circulation paths, rooms, spaces, or elements that are not for public use and are made available for the shared use of two or more people.”

A Medical Care suite is an example of public and common use areas mixed with employee areas. See the graphic on the right. This suite can typically have dressing rooms, exam rooms, toilet rooms, an employee break room, a lobby/waiting room, doctor’s offices, and utility rooms.

Common use and public use spaces such as recovery rooms, examination rooms, and cafeterias are not exempt from ADA requirements and must be accessible. Other spaces may have exceptions that allow for a reduced number of accessible spaces or elements. For example, dressing rooms are only required to have 5% of each type accessible (222.1). Exam rooms should all (100%) be accessible as public access (206.2.4). Clustered toilet rooms are only required to have 50% as accessible (213.2.4). In a long-term care facility the common living room should be fully accessible (206.2.4). See the photo below.

Dining & Work Surfaces

ADA compliance for fixed dining and work surfaces is covered primarily in 2010 ADA Standards 226 and 902. 2010 ADA Standard 226.1, [Dining Surfaces and Work Surfaces] General, states, “Where dining surfaces are provided for the consumption of food or drink, at least 5 percent of the seating spaces and standing spaces at the dining surfaces shall comply with [Standard] 902. In addition, where work surfaces are provided for use by other than employees, at least 5 percent shall comply with [Standard] 902.” Again, this applies to fixed surfaces only. For additional information please see Accessible Dining Surfaces.

In facilities covered by the ADA, this requirement applies to work surfaces available to the public but it does not apply to work surfaces used only by employees. The graphic on the right is representative of work surfaces. However, the ADA and, where applicable, Section 504 of the Rehabilitation Act of 1973, as amended, provide that employees are entitled to “reasonable accommodations.” With respect to work surfaces, this means that employers may need to procure or adjust work stations such as desks, laboratory and work benches, fume hoods, reception counters, teller windows, study carrels, commercial kitchen counters, and conference tables to accommodate the individual needs of employees with disabilities on an “as needed” basis. Consider work surfaces that are flexible and permit installation at variable heights and clearances.

Recreation/Rehabilitation Facilities

The ADA requirements for Medical and Long-Term care buildings and facilities are not designed just for disabled patients. These requirements are also designed to accommodate the needs of disabled employees and visitors that access these locations. Recreation and rehabilitation equipment and facilities can include play areas, exercise rooms, exercise and rehabilitation equipment, locker rooms, swimming pools, spas, and saunas, etc. The photo on the right is representative of a play area. For additional information please see Accessible Play Areas and Play Area Ground Surfaces. Note that soft contained play structures are not considered play areas as defined in the ADA.

Medical Diagnostic Equipment (MDE)

Recommended, but voluntary, standards for accessible Medical Diagnostic Equipment have been provided by the US Access Board, but these standards have not been adopted by an enforcement agency as of the date of this article. The graphic on the right is representative of MDE.

The Patient Protection and Affordable Care Act includes a provision to amend the Rehabilitation Act to address access to MDE, including examination tables and chairs, weight scales, x-ray machines and other radiological equipment, and mammography equipment. Under this amendment, the USAB is authorized to develop access standards for MDE in consultation with the Food and Drug Administration (FDA). The standards address independent access to, and use of, equipment by people with disabilities to the maximum extent possible. The USAB is also responsible for periodically reviewing and updating the standards. This amendment process has not been completed as of the date of this article.

When completed, these standards will include the minimum technical criteria for MDE used in (or in conjunction with) physician’s offices, clinics, emergency rooms, hospitals, and other medical settings. The standards shall ensure that such equipment is accessible to, and usable by, individuals with accessibility needs, and shall allow independent entry to, use of, and exit from the equipment by such individuals to the maximum extent possible.

This MDE standard shall apply to equipment that includes examination tables, examination chairs (including chairs used for eye examinations or procedures, and dental examinations or procedures), weight scales, mammography equipment, x-ray machines, and other radiological equipment commonly used for diagnostic purposes by health professionals. These standards do not apply to devices used for medical purposes. For additional information please see:

Medical Diagnostic Equipment Standards

Accessible Phototherapy Equipment

Accessible Medical Exam Rooms

MDE - Weight Scales

Radiologic Medical Equipment and the ADA

Medical Room Clear Space and Turning Space

ADA Settlement Agreement for Charlotte Radiology

Lincare Sued for Age Discrimination Against Deaf

Access to Medical Care for Individuals with Mobility Limitations

Wall Mounted Features

Wall mounted features such as electrical switches and outlets, hand sanitizers, fire extinguishers, paper towel dispensers, and thermostats, must also comply with ADA Standards for accessibility. Most of these features will be considered operable parts, and thus must comply with 2010 ADA Standard 309 for Operable Parts, 308 for Reach Ranges, 307 for Protruding Objects, and 305 for Clear Floor and Ground Space. The graphic on the right is representative of a wall mounted object accessed using a forward approach. For additional information please see Reach Ranges.

Websites

Website accessibility is not covered in the 2010 ADA Standards as of the date of this article but has nonetheless come under significant scrutiny recently as part of Title III and Title IV requirements for accessibility. The current guidance encourages owners of websites and mobile applications to be in substantial compliance with the WCAG 2.0 AA, or any subsequent version published by the World Wide Web Consortium (W3C). Basically, if an entity has a website and physical buildings and/or facilities, it is important that the website be accessible to individuals with disabilities. This issue is fluid and subject to change. Entities are encouraged to make every effort to ensure their website is accessible to all.

Maintenance of Accessible Features

It is important to provide access to medical and long-term care facilities and accessible features and equipment in medical and long-term care facilities. It is also important that the features and equipment are fully operational. Implementation regulation 28 CFR Part 35.133 and Part 36.211, Maintenance of Accessible Features, state, “A public entity (Part 35) or accommodation (Part 36) shall maintain in operable working condition those features of facilities and equipment that are required to be readily accessible to and usable by persons with disabilities by the Act or this part. These sections do not prohibit isolated or temporary interruptions in service or access due to maintenance or repairs.” Noteworthy is that these statements are not contained in the 2010 ADA Standards. So, when a building or facility is inspected to verify compliance with the ADA Standards, that inspection should also verify the operational capability of the features and equipment. For additional information please see Maintenance of Accessible Features.

SUMMARY: Medical Care and Long-Term Care facilities must comply with the ADA. Covered facilities include hospitals, rehabilitation facilities, psychiatric facilities, detoxification facilities, and medical units in prisons, correction facilities, and detention centers. Long-term Care facilities such as nursing homes, skilled nursing, and assisted living facilities are also covered. As this article has shown, there is a lot to it when it comes to inspecting and verifying ADA compliance.

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If you observe a facility or entity 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.

Thank you.