facility accessibility evaluation and participation analysis

Running head: ACCESSIBLITY EVALUATION AND PARTICIPATION ANALYSIS 1

Community Practice and Occupational Therapy Facility Accessibility Evaluation and Participation

Analysis: Wells Fargo

Megan McCarthy and Gretchen Kempf

The University of Scranton

ACCESSIBLITY EVALUATION AND PARTICIPATION ANALYSIS 2

Introduction

This paper provides an in-depth description of the accessibility and accommodations that

can be found at a Wells Fargo Bank branch office in Scranton, Pennsylvania, through the eyes of

an occupational therapist specializing in Americans with Disabilities Act (ADA) consultation. An

accessibility and participation analysis is utilized to evaluate the banking facility’s ability to

provide services to individuals with disabilities. The paper also examines the physical, sensory,

cognitive-perceptual and psychosocial aspects of participating in customary banking services.

Description of Facility and Services

As one of the nation’s largest financial institutions, Wells Fargo Bank serves one in three

households (Stumpf, 2012). The company aims to provide a full range of banking services and

products to enable all its customers to achieve financial success. The company’s publicly

disseminated vision and values statement emphasizes that the building of a lifelong relationship

with each customer takes priority over any individual transaction or financial product. The

importance of the bank’s relationship with its customers is reflected in the company motto of

“We’ll never put the stagecoach ahead of the horses” (Stumpf).

In articulating the company’s core values, Wells Fargo highlights its commitment to

diversity and inclusion, both in its hiring practices and policies and in its outreach to a diverse

customer base. The corporate culture of Wells Fargo aims to be inclusive and to accept

differences. The company strives to make each employee and customer feel valued and respected

for who they are (Stumpf, 2012). This value is exemplified, in part, by the bank’s efforts to better

accommodate customers with disabilities by providing features such as a wheelchair-accessible

buildings, talking ATMs, and written material available in large print, braille and audio formats.


Wells Fargo also provides customers with online access to accounts, which may be especially

helpful in cases where an individual's disability hinders their ability to engage in tasks on site.

Wells Fargo Bank maintains three separate branch offices in Scranton, Pennsylvania. The

branch office located at 330 Meadow Avenue provides retail-banking services in a one-story

building adjacent to a dedicated parking lot. This facility is open for business Monday through

Thursday, 9 a.m. to 5 p.m., Friday, 9 a.m. to 8 p.m., Saturday, 8 a.m. to 1 p.m., and has no hours

on Sunday. The bank has one front entrance accessible from the parking lot from the sidewalk

running in front of the building. The bank also has a drive-up teller window in the back of the

building and provides 24-hour access to an ATM located in the front of the building.

Accessibility Evaluation and Participation Analysis

In an effort to test the proclaims of Wells Fargo Bank’s corporate statements regarding its

commitment to inclusion and to accommodating customers with disabilities, a community

accessibility evaluation and participation analysis was conducted on the Meadow Avenue branch

office. As detailed below, the evaluation uncovered several accessibility issues with the facility.

Sensorimotor/Physical Evaluation

Located on a steep hill, the parking lot had an uneven surface. There were twenty-five

available parking spaces, with one space designated as a accessible parking spot. This ratio falls

well within the ADA criteria. The designated accessible spot was well marked, van accessible, and

appropriately labeled with the international symbol of accessibility, but had a width of less than

eight feet. An additional sign indicated that violators would be subject to towing and a fine of

$250. In summary, although the designated handicap parking space met most of the criteria for

ADA, the steep incline and uneven surface of the parking lot create potential safety and

accessibility challenges for individuals with disabilities, especially for individuals needing to

perform car-wheelchair transfers and for other individuals who use adaptive equipment.


Located adjacent to the accessible parking spot, a curb cut enabled individuals with

disabilities to independently access a ramp to the building and ATM. Alternative entrances

outfitted with accessibility devices such as elevators or lifts were nonexistent. The ramp appeared

to be quite steep and fell outside of the ADA requirement of a 1:12 ratio. Other possible

challenges to accessibility presented by this entrance route were that the ramp was relatively

narrow (approximately 30 inches), it was not cane detectable, and had a railing on only one

side. Despite these negative features, ADA requirements were met in regard to having a five foot

long landing at the top and the bottom of the ramp. In theory, individuals with physical disabilities

would be able to utilize the ramp accommodations independently, but the ease and safety of

utilization would be dependent on individual strength, endurance, and type of mobility device.

The potential challenges posed to an individual in a wheelchair were readily apparent upon

an examination of the building’s entrance. Entry is gained through two heavy doors, outfitted with

14-inch long handles, which have to be manually opened. Although the doorway had no threshold

and had low-pile carpeting (both of which simplified horizontal accessibility), the large door

handles could be burdensome for an individual to grasp, reach, or pull towards them. Opening the

door required moderate force and the door closing occurred within 4-5 seconds upon releasing the

door. With over 32 inches of clear space for the door to open and 18 inches of wall space on the

pull side of the door, there was adequate room, as per ADA criteria, to open the doors.

Upon entering the bank, a few more potential challenges were noticeable. Only one station

for tasks such as writing deposit slips and signing checks was available to customers. This station

consisted of a high counter with no chairs, which was not accessible by an individual seated in a

wheelchair. Standard-print deposit slips were the only deposit slips available at the station. In

response to our inquiry, an employee stated that large print format slips were no longer obtainable

at branch facilities. The standard-print deposit slip had a very small font and only provided


miniscule blank spaces in which to write required information. Individuals with physical

disabilities may have difficulty writing in such a confined space, and those with visual deficits

may be unable to read the small print.

Another obstacle became apparent when examining the teller’s desk designated for use by

individuals with disabilities. It was the furthest teller’s desk from the bank entrance and did not

appear to differ in any fashion from other tellers’ desks. It presented the impression that the bank

had placed an accessible sign on a random desk in order to create the appearance that they catered

to customers with disabilities. The aisle to approach the designated desk was approximately 2½

feet wide, which may be too narrow to permit someone with physical impairments to easily

navigate through it. This narrow aisle width also could inhibit a wheelchair-user’s horizontal

access and ability to reverse when waiting in line.

In the roped-off area where customers line up to wait for an available teller, there were two

throw rugs covering the floor. In spite of the fact that the rugs were low-pile, had a non-slip

backing and did not appear to present a physical obstacle to a person maneuvering a wheelchair, it

is important for the bank staff to recognize them as a potential risk factor. If there is not enough

visual contrast between the rugs and the uncarpeted surfaces, the rugs may present a tripping

hazard, especially to those who have compromised vision. This risk would be heightened if

windows or artificial lighting created glare. In this case, however, the uncarpeted area had flooring

with a smoothly waxed, non-reflective surface. The bank had also installed adjustable shades on

every window to help reduce glare. There was sufficient visual contrast between the waxed floor

surface and non-slip mats, which helped to minimize safety hazards.

Emergency systems such as a fire alarm and sprinklers were readily visible inside the

building. The fire alarm was equipped with a blinking red light and a warning sticker indicated

that it would sound an audible alarm and flash a bright light if activated. The sprinkler heads lined


the ceiling and appeared to cover the entirety of the lobby. It is essential for the bank to have the

ability to immediately alert all customers of an emergency situation and to have staff members

who are ready, willing and able to assist those with disabilities in such a situation.

Signage for goods and services could be seen throughout the building. The majority of

signs were equipped with written words and braille text. The signs were written in high-contrast

ink colors and had a non-glare finish, both of which assist customers with low vision in reading

the signs. Directional and informational signage at Wells Fargo Bank also was presented in this

visual format. All signage was of an appropriate dimensional size and had an adequate font size

for easy reading from a distance and all signage was placed at a height so as to be readable by both

individuals standing or seated in a wheelchair.

When we inquired about opening a new account, it appeared many of the employees were

reluctant to work with us. We were told to wait for a consultant in the center of the lobby since

there was no wall space for wheelchair seating. When we were summoned to a table in an alcove,

the employee had to move a chair aside so that our wheelchair could fit under the table. All the

chairs had arms, which would inhibit an individual who wished to transfer from their wheelchair.

After discussing available account options, we undertook an evaluation of the accessibility

of the on-site ATM. The screen and card reader were at an appropriate height, but since there was

no cut-out under the ATM, the extended reach required to use the features of the ATM presented a

challenge. The screen was slanted away from the user to increase privacy, decrease glare, and

make it easier to see from an upright position. Touch screen features and buttons were all

accessible and could be utilized by an individual with a closed fist. Though these features are

beneficial accommodations, they may not work as well as intended for individuals in a mobility

device if the proper cut-out below the machine is not installed. When assessing the headphones

feature for individuals with visual impairments, we learned that the earphones were locked inside


the ATM and could only be accessed by asking a staff member to retrieve them. The ability to use

an ATM when the bank is closed is an essential banking service for most customers. Considering

the bank’s established business hours, individuals needing to use headphones would be severely

restricted as to when they could independently utilize the ATM at this branch office.

When requesting to use the lavatory facility, we learned that Wells Fargo Bank has a

policy of not allowing customers to use the single bathroom on site due to security reasons. The

employee suggested that we use the bathroom at Gerrity’s Supermarket next door. That restroom

was clearly labeled, displayed the international symbol of accessibility, and contained braille text

on signage. Although the bathroom doorway met the ADA criteria of being at least 32 inches

wide, the door handle could be problematic for individuals with physical disabilities. Operation of

the door handle required it first to be pushed down and then to be pulled. The door also required

approximately 8 lbs of maximum force to open, which exceeds the recommended range set forth

in the ADA criteria. The bathroom was equipped with automatic lights and had adequate space in

which to maneuver a wheelchair.

The bathroom was configured into a square, approximately 3½ feet long and 3½ feet wide,

with no stall, which optimized accessibility. The open space allowed for proper positioning of the

wheelchair to complete a safe transfer to the toilet. The toilet met the ADA criteria of being no

higher than 34 inches from the ground and was positioned in the right corner of the room to allow

for the proper installation of grab bars. Horizontal grab bars were placed at an adequate height on

the back and side walls of the bathroom. Additional vertical and diagonal grab bars had been

appropriately installed to assist individuals when completing transfers or toilet hygiene tasks.

The sink was placed at an appropriate height and consisted of a standard push/pull knob.

Other features that were examined in the lavatory were the push-in soap dispenser and automatic

hand dryer, both of which presented at appropriate heights and proved unchallenging to use to


complete self-care tasks. The mirror, however, had been mounted too high for seated individuals

to view themselves.

Cognitive/Psychosocial/Participation Evaluation

Financial management can be a complex system for an individual with cognitive or

psychosocial disabilities. When a financial issue presents itself, an individual must first decide

what banking task(s) they need to undertake, such as depositing money, withdrawing money, or

opening a new account. Additionally, an individual must be able to plan or sequence the necessary

actions to complete the financial task at hand. For example, it is crucial to stay abreast of the dates

when bills are due in order to avoid late penalties and interest charges and to ensure that there are

adequate funds in the account that will be used for payment of those bills.

Comprehension is one of the many key elements involved in completing financial tasks.

Maintaining attention is another essential factor that correlates with and enhances one’s ability to

comprehend and complete tasks. The efforts by Wells Fargo Bank to ease the cognitive burden on

customers is exemplified, in part, by their posting of clear and direct signs that display beneficial

information, such as business hours. Directional information, which indicated where services were

located in the bank, was clearly displayed both inside and outside the bank and this signage

provided visual cues to guide customers in the completion of their desired banking task. Basic

cognitive skills (reading, writing, and performing simple math functions) are essential when

performing financial tasks such as writing checks or filling out deposit/withdrawal forms. These

skills also are required for the utilization of the ATM. Some features incorporated into the ATM to

assist customers with common banking tasks are a screen text which offers to display how much

money an individual has left in an account and an audio setting, available in several languages, to

assist customers who have difficulty with reading comprehension or visual processing.


Some customers with disabilities may have a low or fixed income and would be more

likely to patronize a bank that provides banking options to meet their unique financial needs.

When we inquired about account options at Wells Fargo, a consultant provided a complicated

explanation regarding the standards for opening and maintaining an account. His rapid-fire verbal

delivery of information quickly became overwhelming to us; this issue would be compounded for

an individual with cognitive disabilities.

Another key element involved in managing personal finance issues is emotional regulation

ability. Financial issues and tasks often place an immense informational burden on an individual.

It is critical for an individual to have the ability to control his or her emotions so that they can

engage in appropriate conversations about the issue at hand or otherwise process the information

required to successfully complete a financial task. Social aspects also come into play when

completing banking tasks since psychosocial skills are required to engage with others

appropriately. For instance, having the social capacity to be able to ask an employee for help is

one of the many skills that can assist individuals in completing their financial management. Since

customers may need to wait in line before speaking to an employee, an individual must have the

ability to be patient and to engage in appropriate behavior in a public setting. In view of the

foregoing, the perceived reluctance of employees at this Wells Fargo office to help customers, and

their tendency to send a customer to another station instead of helping them directly, might cause

an individual with compromised or undeveloped psychosocial skills to act out inappropriately and,

perhaps, to be ultimately prevented from successfully participating in a desired banking activity.

Occupational Therapy Practice Framework, 2nd Edition

As future occupational therapists, it is essential to incorporate the Occupational Therapy

Practice Framework, 2nd Edition (OTPF-II) when evaluating and analyzing facility

accommodations. In this instance, incorporating the theoretical framework promotes a greater


understanding of the specific demands that are placed on individuals during their engagement in

financial management occupations at the Meadow Avenue Wells Fargo Bank office. The OTPF-II

unifies professionals within the field and directs client treatment to encompass the overarching

mission statement of “supporting health and participation in life through engagement in

occupation” (AOTA, 2008, pp. 626). The centennial vision of the American Occupational Therapy

Association (AOTA) requires occupational therapists, in all aspects of their practice, to be

cognizant of their “power to influence others” and to act as “societal means for health and well-

being” (AOTA, 2007). This can be interpreted as a directive to occupational therapists to seek to

influence community businesses, such as Wells Fargo Bank, to provide all their customers with

appropriate accommodations to meet their societal needs and activity demands.

Activity Demands

The OTPF-II (2008) defines “activity demands” as the objects, properties, space, social

demands, sequencing, timing, required actions, required skills, and required underlying body

functions and body structure needed to carry out a desired activity. To properly complete common

financial management tasks, individuals must choose a bank that provides the appropriate

accommodations to them for the activity demands of the desired financial task. In addition to

accommodations offered at the physical site, individuals also should explore accommodations

made available by the bank in any online services offered by the bank.

Some general tools and objects that can assist in meeting the demands of completing

financial tasks include calculators, pens, paper, a flat surface for filling out documents, budgeting

journals, deposit/withdrawal slips, and/or a debit card. It is critical that the physical environment is

designed to enhance an individual’s ability to perform the task at hand. Some examples of key

environmental factors to be considered include noise levels, organization of space, and lighting.


The Wells Fargo Bank office is located in a very small building, which presents numerous

physical challenges. Due to a steep ramp leading to the entrance of the bank, an individual who

uses a wheelchair for mobility may not have the necessary strength to propel themselves up the

ramp and/or to open the heavy doors to enter the bank. Inside the bank, areas designated as

handicap-accessible lacked the necessary additional space to allow clients with disabilities

(especially those using a wheelchair for mobility) to properly maneuver to complete tasks.

The height of the teller’s desk also may serve to disrupt the social demands that are

required during banking transactions. Customers seated in a wheelchair would be unable to easily

make eye contact or read the teller’s facial cues when completing banking transactions. Also, as

discussed above, the tellers appeared reluctant to readily provide us with services or information.

Sensorimotor/Physical Recommendations

In light of the required activity demands and performance skills involved in financial

management occupations, various recommendations can be made to Wells Fargo Bank, under the

auspices of the OTPF-II, to assist and accommodate customers with disabilities.

To make accommodations more accessible to individuals with physical and sensorimotor

disabilities, the ramp leading to the entrance of the bank should be elongated to decrease the angle

of the slope and beveled to allow for a non-slip surface. Widening of the ramp also would be

beneficial and this, in turn, would require the railing to be relocated. In reconstructing the ramp,

the curb cut must remain in a location that is easily accessed from the designated handicap parking

spot. The accessible spot should be reconfigured to increase the width to meet ADA standards.

Reconfiguring the roped-off waiting area inside the bank to widen the aisle would create

additional room for customers with disabilities to navigate through the line. The teller’s desk that

is designated as the accessible station should be moved to a station that is closer to the

entranceway of the bank. In addition, the height of the designated teller’s desk should be


decreased to allow customers easier access to services while seated in a wheelchair and to enhance

such an individual’s ability to make eye contact with the teller during the transaction of the

financial task.

The ATM was located at an accessible height, but without the proper cut-out underneath to

accommodate the legs and feet of a customer in a wheelchair. Installing such a cut-out would

allow individuals to more easily access and utilize the control features of the ATM and would not

require the ATM controls to be relocated or reconfigured. The cut-out also would allow a

customer in a wheelchair to benefit from the accommodation measures already in place at the

ATM, such as the tilted screen which provides a measure of privacy and reduces glare.

There are several recommendations for improving accessibility that can be made with

regard to the Gerrity’s Supermarket bathroom. Since the bathroom door required an excessive

amount of force to open, the door and handle should be replaced. Repositioning the mirror at a

lower height or installing a full-length mirror would provide access to individuals in wheelchairs.

To further accommodate customers, a feminine hygiene product dispenser should also be installed.

Cognitive/Psychosocial/Participation Recommendations

The evaluation of the Meadow Avenue branch office reveals that the bank has taken some

measures to accommodate customers who have cognitive or psychosocial disabilities, but further

steps are recommended. The bank may be able to broaden their customer base by establishing a

simplified financial package to better serve individuals with low or fixed incomes. According to

Framstad and Vallas (2013), the average monthly benefit for a disabled worker was about $1,129

and adults who receive Supplemental Security benefits receive approximately $552 per month. In

view of this, Wells Fargo should recognize that an individual with cognitive or physical

disabilities may not possess the financial qualifications for opening or maintaining a Wells Fargo’s

standard banking account since such a person’s disability benefits may constitute most or all of


their income. Also, breaking verbally-supplied information into smaller segments and/or providing

a visual handout would aid individuals with cognitive disabilities in their comprehension of the

bank’s account options.

Wells Fargo Bank also should be advised to hire employees who convey a welcoming

sentiment to customers with disabilities. It is essential to have employees who are friendly,

outgoing, and patient, and who exhibit eagerness to help all customers, regardless of disability.

The goal is to create a proactive environment in which both employees and customers will

flourish.

It should also be pointed out to Wells Fargo that the very narrow and winding roped-off

area designated for the formation of the line leading to the tellers’ desks might be confusing and

intimidating for a customer with a cognitive disability. The configuration of this area could create

unnecessary stress for such a customer while they attempt to engage in financial tasks.

Although the Gerrity’s bathroom appeared to be well adapted for patrons with

psychosocial and/or cognitive impairments, it is recommended that Gerrity’s label the hot and cold

handles on the faucet at the sink to reduce the risk of individuals burning themselves.

Conclusion

The Wells Fargo Bank branch office located on Meadow Avenue in Scranton,

Pennsylvania, presents with many areas that could be improved upon to make it a safer and more

productive environment for customers with disabilities to properly function as consumers of

community banking services. Although the undertaking of the recommended improvements would

require the bank to incur out-of-pocket expenses, the costs could be offset by the bank’s ability to

attract and better serve customers with disabilities.


References

American Occupational Therapy Association. (2008). Occupational therapy practice framework:

Domain & process. American Journal of Occupational Therapy, 62(6), 625-683.

American Occupational Therapy Association. (2007). AOTA’s centennial vision and executive

summary. American Journal of Occupational Therapy, 61(6), 613-614.

Fremstad, S., & Vallas, R. (2013, May 30). The facts on social security disability insurance and

supplemental security income for workers with disabilities . Retrieved from

http://www.americanprogress.org/wp-content/uploads/2013/05/FremstadDisabilityBrief.pdf

Stumpf, J. (2012). The vision & values of Wells Fargo. Retrieved from

https://www08.wellsfargomedia.com/pdf/invest_relations/VisionandValues04.pdf

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