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ADA requires accessible reservation systems
March 14 2012

Understanding your guests’ needs for accessible rooms and features at your hotel is becoming increasingly important for managing reservations systems.

  • Under the new ADA guidelines, one in four hotel rooms must have a communication feature.
  • There is safe harbor under the new ADA guidelines, which is an important concept as hoteliers go forward into the reservation process.
  • “However you have a reservation system, be sure that everyone can use it,” Carolyn Doppelt Gray of Proskauer Rose LLP, said.
By Alissa Ponchione
HNN contributor

REPORT FROM THE U.S.—Being cautious of guests’ needs is becoming increasingly important in managing reservations for accessible rooms.

The Department of Justice has a specific process and elements that need to be included that give guests with accessibility issues the “opportunity to participate,” said Carolyn Doppelt Gray, co-chair of Accessibility and Accommodations Practice Group at Washington, D.C.-based Proskauer Rose LLP, during a webinar titled “Managing Reservations for Accessible Rooms.”

Exclusionary practices also need to be eliminated. These include staff members asking guests for driver’s licenses, excluding people that only hold state IDs, or having the accessible front door closed after a certain time. If that’s the case, “you need to change your practice,” she said.

Adopting ADA requirements
Compliance for the 2010 standards is effective Thursday, but Gray reminded that hoteliers don’t have to do new construction or make alterations, as long as they are in compliance with 1991 standards. “That has been the basis of how the (Department of Justice) has operated. Once you’ve undertaken new construction, then you must look to the current standard.”

Under the new guidelines, one in four hotel rooms must have accessible communication features, Gray said.

The problem comes when a hotel staff makes assumptions about what their handicapped guests need, as well as what separates the Department of Justice 1991 standards from the 2010 standards. Gray explained hoteliers should use “those as a bar for what is readily available.”

Gray also warned about state and local requirements that can be more stringent but still have to be filed. In Illinois, for example, she said it is required to have a separate access aisle in the parking spaces for handicapped or disabled people.

“That’s not part of the federal requirements” but hoteliers should be aware of all these changes, and they should all be placed in the reservation system.

Safe harbor for 2010 regulations
“You are probably well aware when the 1991 standards came out there was no grandfathering in,” she said. Those standards, Gray said, were readily achievable.

Under the 2010 standards, there also is no blanket grandfathering but there is safe harbor, which is an important concept as hoteliers go forward in revising their reservation process, she said.

“What the government has done is they will include a safe harbor when it’s done on an element-by-element basis,” she said. “If the element was built or altered in compliance with 1991 standards and you don’t touch it, it’s good to go into the future until that time when you do alter it.”

Safe harbor allows hoteliers to leave things as they are as long as they don’t change the room or the construction of the wall. However, once the configuration changes, hoteliers will have to follow 2010 guidelines.

“That is so important—the concept of safe harbor. Those are the kinds of issues someone might ask you at the front desk or reservation system,” Gray said.

Modifying your reservation system
Gray advised hotels to modify their policies and practice procedures. She said reservation systems for accessible guestrooms must have the same hours and same manners as nonaccessible rooms.

“If you close at 11 p.m. for everyone, then you can shut it down, but if you operate 24/7, then you have to take accessible rooms,” too. Hoteliers also must hold unoccupied accessible guestrooms until all other guestrooms have been rented.

“You have to guarantee that specific accessible guestroom is held for the reserving customer,” Gray said.

Gray pointed out some of the problems with the reservation process come from ignorance. “The government believes individuals with disabilities can’t access architectural access because of shortcomings of the hotel reservation system,” she said, meaning a guest arrives to discover the room isn’t available or accessible for his or her needs.

“Very often I hear it’s hard to design a front desk that is welcoming, services a lot of people and still meets the ADA requirements” even if it has a lowered counter, knee space for a wheelchair and a ledge for those who are standing. But where that information is usually incorrect, Gray said, is from wrong measurements.

Additionally, websites also should be accessible. If not, the Department of Justice takes the position that an alternative avenue must be available, and made available 24/7, she added.

“However you have a reservation system, be sure that everyone can use it,” Gray said.

When it comes to third-party service, Gray said the hotelier should provide the correct information regarding accessible rooms. “The government isn’t going to hold a third-party service to identify accessible features. Those come from the hotel,” she said.

Training the staff
It’s also key to have a well-trained staff who will identify and describe accessible features offered to guests.

As a hotel manager, you should provide a detailed description to your staff of how intense the whole process is, Gray said. “Train staff so they know specific layouts of rooms and bathrooms” while also providing them with information regarding accessible features and how to effectively communicate with individuals, especially with walk-in reservations, she said.

For example, if someone comes in with a hearing impairment, pass notes, have a dry erase board available and even use a computer, Gray said. “It needs to be effective and timely.”

Discussing service animals, Gray said, the 2010 standards indicate dogs and miniature horses are allowed in the hotel. Guests can be charged for damage caused by the service animal, yet there is no surcharge in the reservation process for the animal.

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