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Public Transit

Reasonable Modification Policy

How Meigs County Public Transit makes reasonable modifications to its policies, practices and procedures so riders with disabilities have equal access.

About this policy

This is an accessible version of the Meigs County Public Transit (MCPT) Reasonable Modification Policy (effective August 3, 2023; revised February 12, 2024). The full content is retained below.

1. Purpose

The purpose of the reasonable modification policy is to ensure that Meigs County Public Transit offers equal and effective opportunities and access to public transportation services for persons with disabilities, and full compliance with Title II of the Americans with Disabilities Act of 1990 and Section 504 of the Rehabilitation Act of 1973.

2. Policy

Meigs County Public Transit is committed to providing equal access and opportunity to qualified individuals with disabilities in all programs, services and activities. MCPT recognizes that, to have equally effective opportunities and benefits, individuals with disabilities may need reasonable modifications to policies and procedures. MCPT will adhere to all applicable federal and state laws, regulations and guidelines with respect to providing reasonable modifications, as necessary, to afford equal access to programs for persons with disabilities. MCPT does not discriminate on the basis of disability in admission to, participation in, or receipt of services and benefits under any transit program or activity, and will take appropriate steps to ensure that persons with disabilities have an equal opportunity to participate.

No qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of MCPT, or be subject to discrimination by MCPT.

3. What is a reasonable modification?

A reasonable modification is a change or exception to a policy, practice, or procedure that allows disabled individuals to have equal access to programs, services, and activities. MCPT will make reasonable modifications when necessary to ensure access to transit services for qualified individuals with disabilities, unless:

  • Making the modification would fundamentally alter the nature of the public transportation service;
  • Making the modification would create a direct threat to the health or safety of other passengers; or
  • The individual with a disability is able to fully use MCPT service without the modification being made.

The term "reasonable accommodation" is interpreted consistently with "reasonable modifications" as set forth in the ADA Title II regulations at 28 CFR 35.130(b)(7), and not as defined for employment discrimination under Title I of the ADA.

4. Who is eligible

An individual is eligible to be considered for a reasonable modification if that individual has:

  • a physical or mental impairment that substantially limits one or more major life activities;
  • a record of such impairment; or
  • been regarded as having such impairment.

How to request a modification

  1. Describe what you need

    Tell us what you need in order to use the service. You do not have to use the term "reasonable modification" — our staff will determine whether your request is a reasonable modification and accommodate it accordingly. Requests may be made orally or in writing, and the process begins as soon as you make the request.

  2. Request in advance when possible

    Whenever feasible, please make your request before MCPT is expected to provide the modified service. Where a request can't practicably be made in advance (for example, a barrier at your destination you weren't aware of), operating personnel will decide at the time of the request, and may consult MCPT management.

  3. We work with you

    MCPT and the individual engage in a good-faith interactive process — communicating about the request, the process, and potential modifications. Alternative ways to make a request (personal interview, phone call, or recorded request) are available for people with disabilities who can't communicate in writing, or upon request.

  4. Decision & timing

    MCPT processes requests and provides accommodations, where appropriate, in as short a time frame as reasonably possible. The time needed depends on the nature of the modification and whether supporting information is required.

More about the policy

Granting a request

As soon as MCPT determines a reasonable modification will be provided, that decision is immediately communicated to the individual, in writing (alternative formats available upon request). When choosing among ways to meet nondiscrimination and accessibility requirements, MCPT gives priority to methods that offer services in the most integrated setting appropriate to the needs of individuals with disabilities.

Denying a request

As soon as MCPT determines a request will be denied, MCPT communicates the basis for the decision in writing. The explanation clearly states: (a) the specific reasons for the denial; (b) any alternative accommodation that may create the same access to transit services; and (c) the opportunity to file a complaint relative to MCPT’s decision.

Complaint process

MCPT has a process for investigating and tracking complaints, posted on its website and provided to anyone whose modification request is denied. Anyone who believes they were discriminated against in obtaining a reasonable modification may file a Reasonable Modification Complaint Form. Alternative means of filing (personal interview, phone call, recorded request) are available.

MCPT investigates complaints within 30 days of receipt and acknowledges receipt to the complainant. If more information is needed, the complainant has 30 business days to respond; otherwise MCPT may administratively close the complaint (also closed if the complainant no longer wishes to pursue it). After investigation, MCPT issues a written decision — either a Letter of Finding (summarizing the complaint, interviews, and actions MCPT will take) or a Letter of Closure (explaining why the complaint does not merit accommodation under the ADA).

If the complainant disagrees, they may appeal by filing notice of appeal within 21 days of MCPT’s initial decision. On appeal, the complainant is granted full due process — including presenting additional evidence, presenting their case in person at an appeal hearing, and being represented by counsel.

Designated employee & record retention

Designated official: Julie Scherfel, Civil Rights Coordinator, 175 Race Street, Middleport OH 45760, (740) 444-7647, Julie.Scherfel@jfs.ohio.gov — responsible for processing reasonable modification requests and handling complaints.

Record retention: MCPT maintains all records related to reasonable modification requests and denials for at least three (3) years.

Effective August 3, 2023; revised February 12, 2024. Approved by Adam Warden, Transportation Administrator, and Theresa Lavender, Director.

Request a modification or file a complaint

Contact our Civil Rights Coordinator, Julie Scherfel. Requests and complaints may be made by phone, in person, in writing, or in an alternative format upon request.

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