Deaf passengers and medical transportation: booking by relay or text, arrival, and talking in the van

The rules that apply to the van

A transportation company has to communicate with a deaf or hard of hearing rider as well as it does with everyone else, and it pays for whatever that takes. Three sets of federal rules say so.

• DOT’s ADA rule. Under 49 CFR 37.5(f), a private company whose main business is transporting people must follow the Justice Department’s rules on auxiliary aids and services, 28 CFR 36.301 to 36.306. Section 37.5(d) bars charging riders with disabilities for the services that accommodate them. Section 37.167(f) requires enough communications capacity, through accessible formats and technology, for riders to get information and schedule service.
• DOJ’s auxiliary aids rule. Under 28 CFR 36.303, the right aid depends on how the person communicates and on the nature, length, complexity, and context of the conversation. The business should consult the person, and the aid has to be timely and protect the rider’s privacy and independence. Companions with disabilities are covered too.
• Section 1557. For health programs that receive federal health money, HHS’s rule at 45 CFR 92.202 applies the standard written for state and local governments in 28 CFR 35.160. That standard gives primary consideration to the aid the person asks for. Medicaid rides fall here; our guide to language access in NEMT explains why.

Training is part of the duty. Under 49 CFR 37.173, drivers and other staff must be trained to proficiency to treat riders with disabilities respectfully, with attention to the differences among them. The vehicle and lift side of the ADA is covered in ADA requirements for NEMT.

Who you are serving

Hearing loss rises steeply with age. NIDCD, part of NIH, estimates that about 15 percent of American adults, or 37.5 million people, report some trouble hearing. Its staff analysis of 2015 to 2020 national survey data found disabling hearing loss in 22 percent of adults aged 65 to 74 and 55 percent of those 75 and older.

These riders do not all communicate the same way. The DOJ rule lists aids ranging from written notes and captions to video remote interpreting, and DOJ’s guidance names sign language, oral, cued-speech, and tactile interpreters. For example, one rider signs in American Sign Language, another reads lips and speaks, and a third hears well enough with hearing aids in a quiet room but not over road noise.

So ask, once, at booking. Record how the rider wants to be reached (text, relay, or voice), how they communicate in person, and whether anyone rides along. Put it on the rider profile and the driver’s trip notes so nobody has to ask again.

Bookings by relay, video relay, and text

A deaf rider may call through a relay service, and your dispatchers need to recognize those calls. The FCC defines several kinds at 47 CFR 64.601:

• TTY relay. The rider types; an operator, called a communications assistant, voices the words to you and types your answers back. Dialing 711 reaches relay anywhere in the United States.
• Video relay service. A rider who signs talks to an operator by video, and the operator interprets the call with you by voice. Video relay users have their own ten-digit phone numbers, mapped to their device in a national directory, so dialing the rider’s number reaches them through their provider.
• IP Relay. The rider sends text over the internet instead of using a TTY.
• Captioned telephone (IP CTS). For a rider who can speak but has trouble hearing on the phone. They talk to you directly and read captions of your side.
• Speech-to-speech. A specially trained operator repeats the words of a caller with a speech disability.

The rules for handling these calls are short. Under 28 CFR 36.303(d)(4), a relay call gets the same response as any other call, and DOJ’s guidance tells phone staff not to handle it differently. An automated phone menu must work with TTYs and relay services under 36.303(d)(1). Relay operators may not disclose what was said or keep records of the conversation beyond the call, under 47 CFR 64.604, and relay users pay no more than voice callers.

Habits that make relay calls go smoothly:

1. Stay on the line through the introduction. The operator explains the call first, and there is a short lag after each turn.
2. Talk to the rider, not the operator. Say “What time is your appointment?” rather than “Ask her what time.”
3. Read back the trip. Pickup address, time, return plan, and your callback method.

Text is often simpler than any call. If your company books or confirms by text or email, tell deaf riders and note it in their profile. Brokers offer similar channels: MTM Health’s Virginia member handbook lists real-time web chat and a member app alongside TTY at 711, and offers large print and Braille free of charge.

Confirmations, will-calls, and delays

Every phone call in a normal trip needs a text version for a deaf rider. Set it up at booking so it is not improvised at the clinic door.

• Day-before confirmation. Send the pickup time and window by text. Riders hear nothing from a voicemail.
• Will-call returns. A will-call usually starts when the rider phones in. Virginia’s member handbook, for example, tells members to call the broker when the visit ends. Agree whether the rider will text your dispatch number, call through relay, or book a timed return instead.
• Running late. A late van with no message looks like a no-show from the rider’s side. Text the new time as soon as dispatch knows it.
• Changes on the day. If the trip moves to a different vehicle or driver, text the new description.

Consent and opt-out rules for texting riders are in our guide to ride reminder texts.

Arrival: the horn does not work

A deaf rider will not hear a horn, a doorbell, or a driver calling their name across a lobby. Arrival needs a signal they can see or feel.

• Text on arrival. “I’m outside your front door in a white van” does more than any horn.
• Knock firmly and stay in view. Step back from the door so the rider can see who knocked through a window or peephole.
• At a clinic or facility, ask the front desk to point out the rider, then walk over so they see you coming. Avoid touching from behind to get attention.
• Show the trip. A phone screen or a printed card with the rider’s first name and your company name confirms you are their driver without a conversation.

Some riders bring an escort, and in Georgia that seat is free for deaf members under section 816.3 of the state’s NEMT manual. Bringing one is still the rider’s choice: 49 CFR 37.5(e) bars a provider from insisting on an attendant. How the extra seat is booked and billed is covered in the escort and attendant entry.

Talking in the van

Conversations on a ride are usually short and simple, and simple methods work for them. DOJ’s guidance gives writing notes back and forth as an example of effective communication for simple questions.

• Settle questions at the curb. Confirm the destination and any stop before the van moves. Virginia’s handbook limits drivers to a hands-free phone for talking with dispatch, so a driver cannot read or write notes while driving. If something comes up on the road, pull over somewhere safe first.
• Keep a pad and pen in every van, or use a speech-to-text app on a phone while parked.
• Face the rider when you speak, in good light, without covering your mouth, and speak clearly at a normal volume.
• Turn the radio off and close the windows before you talk.

Masks matter to lip readers. In a 2017 study in the Journal of the American Academy of Audiology, listeners with moderate or severe to profound hearing loss understood speech in background noise better when they could see the talker’s mouth through a transparent mask, with the largest gain in the severe to profound group. A 2023 study found clear speech helped offset the effect of masks, and in a 2025 study of 30 cochlear implant users, 82 percent preferred a transparent surgical mask to a standard one. A driver who must wear a mask should keep a clear one on hand.

Do not lean on a family member to interpret. Under 28 CFR 36.303(c)(3), a business may rely on an accompanying adult only in an emergency with no interpreter available, or when the rider asks and the adult agrees. A minor child may interpret only in an emergency.

When to bring in a sign language interpreter

A transportation company rarely needs an interpreter for the ride itself, but some conversations are too important for notes. Examples include investigating an incident or injury, a complaint or a dispute over a no-show, explaining a suspension, or an intake call long enough that relay or text would bury the details.

DOJ’s guidance defines a qualified interpreter as one who can interpret effectively, accurately, and impartially, both receptively and expressively, using any specialized vocabulary. Knowing some sign language is not the same as meeting that bar. Two ways to get one:

1. Video remote interpreting (VRI). Under 28 CFR 36.303(f), VRI must run on a connection fast enough to avoid lags and blurry images, show the interpreter’s and the rider’s faces, arms, hands, and fingers, carry clear audio, and come with training so staff can set it up quickly.
2. An in-person interpreter, booked ahead through a local agency, for a scheduled meeting.

The rider does not pay for either one. For a rider who is deafblind, ask what they use; DOJ’s list of interpreter types includes tactile interpreters. The medical visit is the clinic’s responsibility: DOJ notes that an interpreter is generally needed to take a medical history or discuss a serious diagnosis.

If something goes wrong on the road, Virginia’s handbook has the driver pull off to a safe place and call 911. Tell the dispatcher on the 911 call that the rider is deaf, then use notes or your phone screen to tell the rider what is happening.

Training dispatchers and drivers

Training to proficiency, as 49 CFR 37.173 puts it, means practice rather than a policy binder. A short session covers most of it:

1. Dispatchers place and take a relay call with a coworker, so the operator’s introduction does not surprise anyone.
2. Dispatchers learn the text routines: confirmations, will-call returns, and late notices for riders flagged as text-only.
3. Drivers rehearse arrival: text, knock, stay visible, and show the trip card.
4. Drivers keep a pad, a pen, and a clear mask in the van and know when to pull over to write.
5. Everyone learns the interpreter process, including who books VRI and how.

State programs point members to these services too. Georgia’s NEMT manual includes an appendix on Georgia Relay, a free state service that covers TTY, voice carry-over, hearing carry-over, speech-to-speech, video relay, and captioned telephone calls.

Keeping riders posted in HealthRide

A deaf rider gets the same reminder texts as every other HealthRide rider, before the ride and when the driver is on the way, so nothing depends on a voice call. The text also carries a link that shows when the driver will get there, and the rider can watch for the van instead of listening for a horn. See how it works on the live map.