NEHES CONFERENCE 2012: ADA and the DOJ

NEHES CONFERENCE 2012

ADA and the DOJ

This discussion was geared towards Healthcare, but had a lot of interesting tidbits that could relate to any institution. The talk, given by the facilities rep at Beth Israel Deaconess focused on how they responded to the Department of Justice’s ADA compliance survey of their entire city campus.

BIG CONCEPTS FOR HOLT

· Department of Justice is starting to expand ADA compliance surveys into the healthcare realm. They are primarily targeting large urban campuses, but could be moving into the smaller more regional facilities in the future.

· DOJ feels that it is discriminatory not to have public, patient and staff spaces ADA compliant. This means hospital departments should not be allowed to use the excuse of “people in wheelchairs can’t do this job”. Example: in a lab, there must be a percentage of accessible sinks and countertops. Percentage was not clear.

· The DOJ is asking large HC campuses for list of all renovations in the past 20 years along with the % of cost associated with ADA updates (i.e. They want to know how much the hospitals spend on their ADA compliance with each project. If they see an organization with a lot of profit not making ADA upgrades, they will “ding” you).

HOW TO BECOME ADA COMPLIANT, ACCORDING TO DOJ
(ie. What Beth Israel Deaconess had to do to come into compliance. They have already spent $10million on this project and its not complete)

· General Access:

o Beth Israel had to create and maintain access plans for all on and off campus facilities. This included listing all accessible routes, bathrooms, exam rooms, patient rooms, as well as all accessible public transportation routes to the hospital.

· Toilets

o Post 1994 – all toilets need to be ADA accessible.

o Clear directional signage to the nearest ADA bathroom along with standard directional signage to restrooms.

o If a bathroom is not ADA accessible, there should be a sign on the door detailing how to get to a compliant bathroom.

o Need to make sure that your locations of paper towel dispensers, toilet paper dispensers are all ADA compliant.

o Bariatric toilets: to make a toilet both ADA compliant and bariatric compliant, use the 24” off wall to center line of toilet bariatric requirement and then add a drop-down grab bar 6” off the wall to meet the 18” ADA requirement.

· Exam Rooms

o DOJ is pushing for 20% of all exam rooms – new and old to be ADA compliant

o ensure 1 accessible exam table in each clinical service area

o exam room must have 2’-10” high sink

o AD access to all miscellaneous items like soap dispenser, paper towels

o Visual strobe light in every exam room to alert patient in emergency

o Purchase scales that can be used be used by wheelchairs.

· Patient rooms

o Beth Israel is putting patient lifts in all of its patient rooms (didn’t sound like that was required in more than 10%)

o If you’re involved in purchasing ADA accessible beds, make sure you take into account the thickness of the mattress. Many hospital beds will advertise as being ADA accessible, but they become non-compliant as soon as you put the mattress on (too high off the ground when the bed is lowered).

· Other Specific Spaces:

o Corridors – 6” deep alcohol dispensers are not acceptable by DOJ (they project further than 4” into corridors). Beth Israel is working with manufacturers to make a 4” deep dispenser.

o Cafeteria must be ADA compliant- confirm that some of the tables that you purchase are accessible (apparently round tables need to be 42” high so a wheelchair can fit fully underneath).

o Staff lounges

§ These should be ADA compliant

§ Our standard detail of putting the microwave in a wall hung niche is not ADA compliant. They suggest putting the microwave on the countertop.

· Parking

o provide hi-top van accessible parking

o Valet parking did not change the # of ADA spots required

o Beth Israel did some long term parking studies of use of ADA spots and was granted a reduction of required spots by the DOJ after it was found that a lot of their spots were never used.

· Signage:

o location of any services like Sorensen Video System for the Deaf and Hearing Impaired, had to clearly shown through directional signage

· Electronic and Equipment upgrades:

o Use of vibrating flashers hockey pucks (like you get at restaurants) to alert deaf/hard of hearing in waiting room. Side benefit is that this helps deal with confidentiality issue.

o create a database of all accessible medical equipment

o Website has to be ADA accessible

o Computerized room reservation system that ensures access to ADA accessible room.

· Misc.

o Beth Israel employs “mystery shoppers” regularly to confirm that hospital is ADA compliant.

For more info:

http://www.ada.gov/

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