THERAPEUTIC FACILITY NEEDS ASSESSMENT

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Rochelle Callis CRPD Therapeutic Recreation Program Final Report and Recommendations September 8, 2017 page 38 Consideration 1: what is the required minimum commitment or floor for Therapeutic Recreation? The District is required to make its programs and services accessible to and usable by people with disabilities. The ADA requires the District to provide services in the most integrated setting. These concepts are discussed earlier in the report. The "floor" here is that the services shall be effective. Therapeutic Recreation programs are another of the wide range of recreation and leisure options that districts, cities, and counties can choose to provide. The District chooses to conduct teen programs, senior programs, outreach programs, outdoor recreation, aquatics, sports ... and it chooses to conduct therapeutic recreation programs. None of these are mandated services ... the District does not have to offer senior programs, for example. These are choices made to serve the community... all of it. Consideration 2: when did the inclusion mandate arise, and what is its authority? The comprehensive Americans with Disabilities Act mandates that the District make services available in the most integrated setting. This is discussed elsewhere in this report in more detail. This mandate became effective January 26, 1992. This black -and -white requirement does have some room for the District to make some interpretations on, for example, just what is a reasonable modification. Find this mandate at section 35.130(d) of the title II regulation We note that at the request of CRPD staffs that we met, in our very first day in Thousand Oaks, with recreation program leadership to review the inclusion mandate and how entities from California to Connecticut are implementing this portion of the ADA. Consideration 3: what is the physical commitment required by the ADA? The ADA requires the District to have evaluated its existing sites and facilities for compliance with the most current minimum design requirements. This is to occur whether those sites and facilities were being altered or not. The ADA then requires the development of a transition plan that phases retrofits at sites so that the "programs" it offers (teen programs, senior programs outreach programs, outdoor recreation, aquatics, sports, therapeutic recreation, playgrounds, and more) are accessible. This test is described by the Department of Justice as one that each entity implements, weighing resources, needs, program locations, and other factors. There is no formula to this test. This approach to facilities and sites is the "program access test", defined in section 35.150. As to the "commitment", in our experience with entities comparable to CRPD, we have seen retrofit costs range from $3,000,000 to $6,000,000, depending on the number and types of facilities, age of infrastructure, aggressiveness of maintenance programs, and other factors. These costs are typically spread over a six to ten year schedule. r-' THE W -T GRO DBA RECREATION ACCESSIBILITY CONSULT _C ONE SOURCE. INFINITE SOLUTIONS.