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ACAA Disability Complaint Management

Every airline disability complaint under the ACAA answered within 30 days, from what actually happened

Every disability complaint answered within 30 days, with the facts rebuilt and cited.

See one case, screen by screen ↓
demo7sourcesread to rebuild one passenger's journey, stop by stop, with the moment assistance broke
demo9 of 9factsin the drafted reply cited to their source, with 4 of 4 required elements
demo6daysfrom receipt to a signed, sent dispositive reply on the sample complaint — due on day 30
target100%of disability complaints answered within 30 days with all four required elements
In short

What is ACAA Disability Complaint Management?

ACAA Disability Complaint Management runs every airline disability complaint under the ACAA — the Air Carrier Access Act and its rule, 14 CFR Part 382 — from intake to the 30-day dispositive reply and the DOT annual report. Seven agents start the clock, rebuild the passenger's journey from the airline's own systems, decide each Part 382 section and draft a reply with every fact cited; the Complaints Resolution Official decides and signs.

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Updated

The problem

Why an airline disability complaint under the ACAA runs out of its 30 days

Every written airline disability complaint under the ACAA needs a dispositive reply within 30 days of receipt: it must admit or deny a Part 382 violation, summarize the facts, state the steps the airline will take and tell the passenger of the right to pursue DOT enforcement. The facts sit in the reservation and its SSR codes, departure control, the gate history, the wheelchair contractor's dispatch log, the cabin report and the station's call log. So the Complaints Resolution Official chases stations by email, waits days for a log, and too often answers from the passenger's letter.

Complaints arrive by web form, email, letter, social, the call center, the airport CRO and DOT referrals through ACERS, and not every one says the word "disability". A clock missed on one channel or a reply missing one element is a violation DOT can count. A station failing the same way for months often shows up only in the year-end DOT report, and the carrier answers for its contractors' failures under 382.15.

typical49,082complaintsdisability-related complaints airlines reported to DOT in 2023
typical51%of them about failure to provide adequate wheelchair assistance
typical$50millioncivil penalty in one DOT consent order on wheelchair assistance, October 2024
Where a disability complaint's 30 days goestimated
By hand18 days
With the solution2.7 days
  • Recognizing it as a disability complaint and starting the clock1 → 0.1 d
  • Getting the reservation, scans, gate history and contractor log from stations8 → 0.5 d
  • Deciding each Part 382 section2 → 0.5 d
  • Drafting a reply with all four required elements3 → 0.5 d
  • Review, remedy approval and signature3 → 1 d
  • Coding the case for the DOT annual report1 → 0.1 d

Estimated split for a typical written wheelchair assistance complaint at a network carrier, by hand and with the solution.

How it works

How a complaint moves

Seven specialist agents rebuild each journey, decide each Part 382 section and draft the cited reply; the CRO decides and signs.

What comes in
Complaints in7 channels · web, email, letters, social, airports, call center, DOT
Agents at work
Intake agentclassify, start the clock
Then
Journey builder7 systems, stop by stop
Then
Determination agentsection by section
Reply draftercited reply
Then
Second readerelements and facts
Report and contractor agentsDOT code, notice, alert
A person decides
Complaints Resolution Officialdecides, edits, signs
What comes out
Signed reply
DOT report coded
Station alert
One case, step by step

One airline disability complaint under the ACAA, from web form to signed reply

Joanna Whitcombe, 71, flew Corvane Airways flight CV 1422 from Chicago O'Hare to Phoenix on October 6, with a wheelchair request (SSR WCHR) on her reservation since she booked. Three days later she wrote that in Phoenix nobody came. Here is what happens next, screen by screen, in the working solution.

  1. 01Thursday morning

    Six things need her, the agents' work first

    Nadia Brennan · Complaints Resolution Official

    Nadia owns about 70 open disability complaints. Her Today screen shows 6 that need her, 5 due in 7 days and 99.8% answered on time in 2026. In the last 24 hours the agents read 24 messages, opened 17 complaints and drafted the reply to Joanna Whitcombe; a station alert for PHX and a case where two agents disagree wait beside it.

    “Journey builder rebuilt the journey for DC-2026-1187 from 7 sources: attendant dispatched to B22 after the 12:51 gate change to B26; 48-minute wait.”

  2. 02Every channel

    Every complaint recognized, every clock started

    Intake agent

    The intake agent reads 24 items from 7 channels and decides which are disability complaints, even when the word is never used. A DOT referral through ACERS is flagged “reply required, copy DOT”; a letter sent 51 days after the flight is marked late under 382.155(c), with a reply sent anyway by policy; a cabin-bag complaint read as a baggage issue keeps a “Treat as a disability complaint” button. Joanna's web form came in Oct 9 at 21:40 CT, three days after the flight: day 0 of 30, due Sun, Nov 8.

    The intake agent never closes a complaint: every routing decision is logged and a person can override it.

  3. 03One click

    What actually happened, stop by stop

    Journey builder

    The case opens on her journey, rebuilt from 7 systems: curb at ORD 10:22, check-in, TSA, gate C17, preboarded 11:18 — all assisted. At 12:51 MST, while she was in the air, PHX moved the arrival from B22 to B26. Meridel Ground Services' job still said B22. On block at 13:46; she walked to the jet bridge with the purser at 13:58 and waited 48 minutes, until 14:46.

    The journey builder never fills a gap with an assumption: where a system has no record, it says so.

  4. 04Every value

    Each source a click away, the words highlighted

    Journey builder

    Every number in the strip and the letter opens its source with the words it came from. The Meridel PHX dispatch log reads: job created 12:10 from the schedule feed, gate B22; 14:05 closed “passenger no show”; 14:31 re-dispatched to B26; 14:46 attendant at the B26 jet bridge. Nine sources sit in one viewer, and one click asks PHX for the jet bridge camera log.

  5. 05Section by section

    A violation of 14 CFR 382.95(a) — and one question it will not decide

    Part 382 determination agent

    Five findings, each with reasons and confidence: a violation of 382.95(a), prompt deplaning assistance (94%); no separate 382.91(a) violation (88%); Corvane answers for Meridel under 382.15 (97%); a reply due Nov 8 (99%). On 382.11(b), safe and dignified assistance, Joanna says she stood “for a long time”; the purser says a chair came at 14:09, 11 minutes in. Nadia decides: no separate violation, acknowledged in the reply, and approves the other four with reason code A1.

    “Both can be true; the records cannot settle how long she stood. I will not decide this — it changes what the reply admits.”

  6. 06Under the letter

    She edits a sentence, an agent rechecks it

    Nadia Brennan, with the reply drafter and second reader

    The reply drafter wrote 11 sentences with the four elements 382.155(d) requires and a $250 travel credit inside her authority. The second reader checked every fact against its source, then suggested one change: sentence 4 blamed the contractor, but under 382.15 the failure is Corvane's. Nadia softens it — “That was our failure, not only our contractor's, and I am sorry” — and the second reader rechecks it against the gate change and the dispatch log.

    “Rechecked sentence 4: it still matches the gate change and the dispatch log, and the facts element stays complete.”

  7. 07Signed on day 6

    Nothing goes out until she signs

    Nadia Brennan · Complaints Resolution Official

    Sign-off shows every finding decided, the second reader's check of all four elements, and the $250 credit inside her $300 authority under remedy policy CR-POL-12 — $400 would go to Gregory Hale, Director of Consumer Affairs. She signs with its meaning and sends it by email, as Joanna asked, on day 6 of 30.

    “I have reviewed the facts, the findings and the reply, and I sign it as Corvane's dispositive response under 14 CFR 382.155(d).”

  8. 08The contractor

    A cited notice to Meridel, for the station to send

    Contractor and pattern agent

    Corrective action notice CAN-PHX-26-019 is drafted with the evidence: the attendant reached the aircraft door 60 minutes after on-block against the 5-minute standard in contract §7.1, a $350 service credit under §7.3, and a root cause and fix due in 10 business days. It waits for Teresa Quan, the PHX airport customer service manager, to approve and send it.

    The agent never sends to a contractor: the station manager approves.

  9. 09Not at year end

    PHX: 11 complaints in 30 days, 7 after a gate change

    Contractor and pattern agent

    Four a month is normal at PHX. The agent traced 7 of the 11 to gate changes the wheelchair dispatch never saw — Meridel reads gates from an hourly schedule feed — and ranks stations per 10,000 assisted passengers: PHX 6.1, ORD 1.6. It recommends sending gate changes to dispatch as they happen, owned by Teresa Quan by Nov 30, and one click opens a station review with her.

  10. 10The DOT report

    Coded once, counted from the case

    DOT report coder

    When the reply goes, the case's Appendix A code locks: mobility, failure to provide adequate or timely assistance — wheelchair. The 2026 report already counts 2,231 complaints by nature and type of disability; 4 codes below 85% confidence wait for Darnell Brooks, and Gregory Hale files through ACERS by Mon, Jan 25, 2027.

    The report coder never files: low-confidence codes go to the analyst, and the Director files.

Who it’s for

Built for everyone who answers for a disability complaint.

The same complaint, seen by the four people who carry it, from the CRO to the analyst who owns Part 382 compliance reporting — what it looked like before, and what it looks like now.

NB
Nadia BrennanComplaints Resolution Official · Customer Relations, Chicago
Complaints Resolution Official
Before
“Tell me what happened at the gate, not what the letter says happened.” She chased stations by email for logs while about 70 clocks ran.
Now
Opens each case with the journey already rebuilt and every fact cited, decides the findings, edits the wording and signs.
GH
Gregory HaleDirector of Consumer Affairs · approves above CRO authority, files the DOT report
Director of Consumer Affairs
Before
“If we admit a violation, I want the facts and the fix in the same letter.”
Now
Sees each admission with its evidence, the corrective step and the credit; approves credits above $300 and any injury case.
TQ
Teresa QuanAirport Customer Service Manager, PHX · runs the station and its wheelchair contractor
Airport Customer Service Manager, PHX
Before
“Show me the pattern before the passenger writes to DOT.”
Now
Gets a station alert when gate-change failures repeat at PHX, a cited notice to approve for her contractor, and a station review to own.
DB
Darnell BrooksDisability Compliance Analyst · codes cases, checks evidence, prepares the annual report
Disability Compliance Analyst
Before
“Every count in the DOT report has to open a case.”
Now
Reviews only the codes the agent is less than 85% sure of; every other count is already traced to its case.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven specialist agents rebuild each journey, decide each Part 382 section and draft the cited reply; the CRO decides and signs.

Intake agent

Reads every channel — web form, mailboxes, scanned letters, social, call center notes, airport CROs and DOT referrals through ACERS — decides whether a message is a disability complaint, de-duplicates, starts the 30-day clock and applies the 45-day rule.

  • Never closes a complaint — routing is logged and can be overridden
  • Every clock cites its rule
Journey builder

Rebuilds the passenger's trip stop by stop from the reservation and SSR history, check-in and boarding scans, gate changes and on-block times, the contractor's dispatch log, cabin reports and station logs, and marks where assistance broke.

  • Every stop carries its source
  • Gaps are shown, never filled
Part 382 determination agent

Tests the rebuilt journey against each relevant section of Part 382 and gives a finding, its reasons with sources and a confidence.

  • Never admits a violation — the CRO approves
  • Never decides on conflicting evidence; it asks the CRO
Reply drafter

Drafts the dispositive reply in plain language with the four 382.155(d) elements, every factual sentence footnoted, in the passenger's chosen format, with a remedy from the airline's policy.

  • Never sends
  • Never offers outside policy
Second reader

Reads every reply against 382.155(d) and against the evidence, and challenges the drafter and the determination agent where they are wrong — including rechecking every sentence the CRO edits.

  • Cannot approve or sign
  • Flags go to the CRO
DOT report coder

Codes each case by type of disability and nature of complaint under Appendix A to Part 382 and builds the annual DOT report for filing through ACERS.

  • Never files
  • Below 85% confidence goes to the analyst
Contractor and pattern agent

Drafts cited corrective-action notices to contractors with the contract standard and service credit, and watches complaints by station, gate, contractor and cause, raising an alert when one repeats.

  • Never sends to a contractor — the station manager approves
  • Every alert shows its cases
CRO and Director

Decide every finding, sign every reply. The agents propose; a named person decides.

Ask in plain words

Ask about any complaint, station or Part 382 rule

Ask about any complaint, station, contractor or rule, in plain words — the agents answer with sources and can act for you.

Which complaints are closest to day 30?

5 complaints are at day 23 or later. Closest: DC-2026-1158, Grace Holloway, day 27 — waiting for MIA's seat map change log (Philip Ward); and DC-2026-1163, Henry Lam, day 24 — reply ready, no violation (Ana Ruiz). None is past day 30.

Why is PHX getting more wheelchair complaints?

PHX had 11 disability complaints in 30 days, against 4 a month normally; 7 came within 60 minutes of a gate change. Meridel's dispatch reads gates from the hourly schedule feed, so late changes never reach it — as on CV 1422, sent to B22 after the move to B26.

Did she really stand?

Two accounts. Ms. Whitcombe: “I had to stand for a long time.” The purser: on the jet bridge 13:58, chair brought 14:09 — 11 minutes. Both can be true. I can't settle it from the records; the jet bridge camera log at PHX could. You decide whether it is a separate 382.11(b) violation.

How many complaints will we report to DOT for 2026?

So far 2,231, every one coded to Appendix A: 1,138 wheelchair assistance (51%), 241 devices, 176 seating and 676 others. 4 codes wait for review. Due Mon, Jan 25, 2027 through ACERS.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

TodayA Complaints Resolution Official's day: disability complaints that need her, replies due in 7 days, on-time rate, and what the agents did overnight.
Every disability complaint, with its clockOpen ACAA complaints from every channel with their 30-day clocks, status and CRO, filtered by due in 7 days, ready, DOT referrals and replied.
Intake from every channel24 messages from 7 channels triaged: disability complaints opened, DOT referrals flagged, late complaints under 382.155(c), duplicates merged, each with its reason.
The passenger's journey and the replyThe wheelchair passenger's trip rebuilt from 7 systems with the jet bridge break marked, the cited dispositive reply, and the 382.95(a) finding beside it.
Working with the agentsThe CRO asks, challenges and instructs the agents under the letter; the second reader rechecks her edit and lays out both accounts of the wait.
The evidence viewerNine sources for one disability complaint — reservation, boarding scans, gate history, contractor dispatch log, cabin report — with the cited words highlighted.
Part 382, section by sectionFindings on 382.95(a), 382.91(a), 382.11(b), 382.15 and 382.155 with reasons and confidence; the conflicting-evidence question left to the CRO.
Sign-offThe four 382.155(d) elements checked, the remedy within CRO authority, and the electronic signature on the dispositive response.
Wheelchair contractors and noticesContractors by station with assists, on-time rate and complaints, and a cited corrective-action notice with the contract standard and service credit.
Station patternsA repeat wheelchair assistance failure at one station, traced to late gate changes, with its cases, recommendations and stations ranked per 10,000 assisted passengers.
DOT annual disability reportAppendix A counts by nature of complaint and type of disability, low-confidence codes to review, and filing through ACERS by the last Monday in January.
Clocks and authorityThe 30-day reply clock, warnings, the 45-day rule, CRO credit authority, legal review and the locked rule that agents never send or admit.
Audit trailEvery action by people and agents on a disability complaint, with its source, kept three years, with an evidence pack per case.
Governance

Built for Part 382: every ACAA disability complaint cited, signed and on the record.

Every stop, finding and sentence citedEach journey stop, each Part 382 finding and each factual sentence of the reply opens the passage it came from — the reservation, the gate history, the dispatch log, the cabin report — with the words highlighted.
The CRO decides every findingA Complaints Resolution Official approves, edits or rejects every finding with a reason code (A1–A4 approve, J1–J4 reject), and settles any question the agents refuse to decide on conflicting evidence.
Agents never send, admit or fileOnly a CRO signs a reply, with the meaning of the signature recorded. The agents cannot send a reply or admit a violation — that setting is locked off — and a contractor notice waits for the station manager and the DOT report for the Director.
A second reader on every replyEvery reply is checked against the four 382.155(d) elements and against the evidence before it reaches the CRO, and every sentence the CRO edits is rechecked.
Authority limits on every remedyCredits stay inside the remedy policy band. Above the CRO's $300 authority the Director of Consumer Affairs approves, and any injury or legal risk goes to Legal before the CRO signs.
An audit trail kept three yearsEvery action by people and agents is recorded with its source and cannot be edited, kept 3 years as 382.157 requires for complaint records, with an evidence pack per case for DOT.
Configuration

Your clocks and authority, set once

The rules your airline disability complaint management runs on are settings; changes are on the audit trail, and the 30-day clock and the ones that keep a person in charge are locked.

SettingDefaultChoose from
Reply due30 days from receipt, every channel (382.155(d))Locked
First warningDay 20, then day 25Any day from day 10 to day 25
Reply to complaints sent after 45 daysOn — reply anywayOn · Off (a reply is not required by 382.155(c))
CRO credit authority$300$100 to $500, in $50 steps
Injury or legal risk goes to LegalOn — reviewed before the CRO signsLocked on
Reason codesA1–A4 approve · J1–J4 reject · E1–E3 credit changeLocked on
Agents may send replies or admit a violationOff — a CRO signs every replyLocked off
Letter templatesAdmit · Deny · Partly admit · CRO airport statementEmail, letter, large print; braille for admit and deny; airport statement printed at the airport
Connections

Works with the systems a passenger's journey already runs through

Reservation systemPNRs and SSR codes — WCHR, WCHS, WCHC, BLND, DEAF, SVAN
Departure controlcheck-in, boarding scans and manifests sent to stations
Airport operational databasegate changes and on-block times at every station
Contractor dispatchwheelchair and assistance job logs from each contractor
Crew and station reportscabin reports, passenger service events, station call logs
Complaint channels and DOT ACERSweb form, mailboxes, letters, social, CRM, DOT referrals and annual report filing
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
100%
of disability complaints answered within 30 days with all four required elements
2025, by hand91.4% on time
Target100%
target
30%
fewer repeat wheelchair-assistance complaints at stations the agents flag
30% fewer
within two quarters
target
100%
of DOT annual report counts traced to the case behind them
Year-end tallycounts by hand
With the agentsevery count opens its case

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (U.S. DOT 2023 summary report of disability-related complaints received by airlines — 49,082 complaints, 51% wheelchair assistance; DOT Order 2024-10-15 — $50,000,000 civil penalty; 14 CFR 382.15, 382.151–.157 and Appendix A to Part 382). Corvane Airways, its contractors, stations' cases and the people named on this page are fictional — characters and sample data in the working solution.

Questions

What airlines ask about ACAA disability complaints.

What is ACAA Disability Complaint Management?

ACAA Disability Complaint Management runs every airline disability complaint under the ACAA — the Air Carrier Access Act and its rule, 14 CFR Part 382 — from intake to the 30-day dispositive reply and the DOT annual report. Seven agents start the clock, rebuild the passenger's journey from the airline's own systems, decide each Part 382 section and draft a reply with every fact cited; the Complaints Resolution Official decides and signs.

How long does an airline have to respond to a disability complaint?

Under 14 CFR 382.155(d), a dispositive written response is due within 30 days of receiving a written disability complaint under the Air Carrier Access Act. A reply is not required for a complaint sent more than 45 days after the incident unless DOT referred it (382.155(c)). The intake agent starts the clock at receipt on every channel and applies the 45-day rule; whether to reply to late complaints anyway is a setting.

What must a dispositive response under 14 CFR 382.155 include?

It must specifically admit or deny that a Part 382 violation occurred, summarize the facts, state the steps the airline will take if it admits a violation, and tell the passenger of the right to pursue DOT enforcement. The reply drafter writes all four, and the second reader checks every reply against them and against the evidence before the CRO signs.

How does it find out what actually happened to the passenger?

The journey builder rebuilds the trip stop by stop from the reservation and its SSR codes, check-in and boarding scans, the airport's gate history, the wheelchair contractor's dispatch log, cabin reports and station logs. Each stop carries its time and source, the stop where assistance broke is marked, and where a system has no record it says so rather than guess.

Is the airline responsible for its wheelchair contractor's failures?

Under 14 CFR 382.15 the carrier must make sure its contractors meet Part 382 as if it provided the service itself, so the finding is the airline's. The contractor and pattern agent drafts a cited corrective-action notice with the contract standard and service credit for the station manager to approve, and raises an alert when the same wheelchair assistance complaint repeats at a station.

How does it prepare the DOT annual disability report?

The DOT report coder codes each case by type of disability and nature of complaint under Appendix A to Part 382, and the code locks when the reply is sent, so every count traces to its case. Codes below 85% confidence go to the compliance analyst, and the Director files through ACERS by the last Monday in January; the agent never files.

Do people stay in control of what the airline says?

Yes. The agents never send a reply, admit a violation, send a contractor notice or file the DOT report. A CRO approves, edits or rejects every finding with a reason code and signs every reply; credits above the CRO's authority need the Director, and any injury or legal risk goes to Legal first.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your remedy policy, letter templates, contractor contracts and a sample of past disability complaints — and connects the systems the journey is rebuilt from. It goes live once every quality gate has passed; we walk you through it on your own complaints first.

See it on
your complaints.

We'll run ACAA Disability Complaint Management on a sample of your own past disability complaints and the systems behind them.