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ADA Physical Access: Physical Barriers Program HCA Capital Deployment HCACapitalDeployment.com
1 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
ADA Physical Access: Physical Barriers Program
HCA Capital DeploymentHCACapitalDeployment.com
2 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
ADA Background• What is the ADA?
• 1992 Civil Rights Legislation
• Statute: federal law, interpreted by a judge
• Code: local or state codes, interpreted by the authority having jurisdiction
• The keystone to ADA compliance is effective communication.
• What about the Department of Justice (DOJ)?
• They can only restate the code but cannot interpret it for you.
• Who is the Access Board?
• They write the code and offer guidance, but this is not binding.
3 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
ADA Background• ADA “risk” is equal to everyone in the design and construction process,
including the owner.
• Risk can be controlled via contract language and ADA skills. ADA training is essential.
• The risk CANNOT be contracted away, such as in a subrogation agreement (against public policy, see US v Days Inns of Am., Inc., 22 F. Supp. 2d 612, 615-16 (E.D. 1998)).
• Errors and Omissions and General Liability insurance may not cover you if you don’t follow the ADA.
• Barrier removal began in 1992 and everyone has an ongoing obligation to remove ADA barriers.
4 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
ADA Background• ADA has three codes:
– Pre 1992: Barrier removal– 1992-2012: 1992 code– 2013- to now: 2010 code
• Broken down into three Titles:– Title I: Employment– Title II: State and Local
Government Activities– Title III: Public
Accommodations
5 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
E&C ADA.002• ADA Compliance:
Removal of Physical Barriers Program
• Can be found on Atlas.
• Effective 5/1/2018.
• For more information, contact:
Jon FaillADA Program Director [email protected]: 615-344-2339C: 615-944-4722
6 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
E&C ADA.002New: ADA Compliance – Removal of Physical Barriers Program Policy (ADA.002)
The purpose of this new policy is to identify and remove physical accessibility barriers in accordance with the Americans with Disabilities Act (ADA).
The policy requires facilities to ensure that their physical plant and buildings are ADA compliant and that all new or renovation construction projects are ADA compliant.
The policy also requires facilities to conduct an ADA Compliance Audit using the ADAcomplianceHELP app and, if not fully ADA compliant, to develop a corrective action plan using the results of the audit. This physical access plan shall be prioritized and budgeted to correct any ADA deficiencies.
Action Items: Facility is to conduct an ADA Compliance Audit using the ADAcompliainceHELPapp and any deficiencies are to be corrected with ongoing construction and routine maintenance projects.
7 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
E&C ADA.002• PROCEDURE:1. Facility-managed ADA Removal of Physical Barriers Compliance Process
i. Facilities must conduct an ADA Compliance Audit.
ii. Any deficiencies shall be coordinated for correction with ongoing construction and routine maintenance projects. The audit will generate a list of ADA compliance deficiencies and when an area of the facility is modified (e.g., a sleep lab) the facility must consult the deficiency list and correct those items in the modified area as part of the project.
iii. If the barrier removal effort requires funding, the facility will plan accordingly. Some deficiency work may not require additional funding, just attention to detail and basic maintenance, such as adjusting door closure pressures or cleaning loose gravel off disabled parking spaces.
8 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
E&C ADA.0022. Corporate-funded and -managed ADA Compliance Process for Ambulatory Surgery Centers (ASCs) and Acquisitions. Projects that are funded and managed by the Corporate office, including remedial efforts at ASCs and for newly acquired facilities require the following actions by the facility:
i. Coordination with Corporate Design and Construction.
ii. Budgeting and cash flow management by the Corporate ADA Compliance Director.
iii. Undertaken in an ADA compliant manner.
9 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
HCA ADA Resources
• This app will be used by the Architect to aid in determining design and construction compliance to the ADA.
• Registration is required
• Must be trained
• Training is available at HealthStream
App located at:HealthStream
10 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
HCA ADA ResourcesADA compliance HELP app• You don’t need to know the ADA to
conduct an audit.• An ADA deficiency report will be your
guide on what to fix and what ADA standard applies.
• Design remedial issues should be corrected before permits.
• Construction remedial issues should be corrected during the punch list process.
App located at:HealthStream
11 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
HCA ADA ResourcesDesign Standards
HCA ADA Requires compliance with:
• 2010 ADA Federal Standards• State and Local codes and standards• HCA ADA Design Standards
ADA Design Guidelines:HCACaptialDeployment.com
12 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
HCA ADA ResourcesDesign Standards
ADA Design Standards:HCACapitalDeployment.com
Two Standards 2010 ADA Federal & the HCA Standard
Topic area
Add’l Info/ Codes: references to CA, FL, TX &
ANSI
hyper-link
13 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
HCA ADA Resources
2010 ADA Quick Reference Guide• Register for updates
• Works on any computer or device
ADA Quick Reference Guide:HCACapitalDeployment.com
14 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
HCA ADA Resources
ADA Templates:HCACapitalDeployment.com
Full size templates for restrooms
15 | HCA Capital DeploymentCONFIDENTIAL – Contains proprietary information.
Not intended for external distribution.
ADA Physical Access: Architects
HCACapitalDeployment.com
Questions? Contact: Jon FaillADA Program Director [email protected] O: 615-344-2339C: 615-944-4722
