Here are three things worth doing this week if you run a hospital, clinic, nonprofit, or agency that touches federal health or human services money. First, confirm whether your organization receives HHS funding in any form, grants, Medicaid, CHIP, Head Start, anything. Second, open your website, put your mouse away, and try to book an appointment or find your phone number using only the Tab and Enter keys. Third, put May 11, 2027 on your compliance calendar.
Those three steps are the heart of the Section 504 web accessibility rule. If the keyboard test went badly, you got stuck, could not see where you were, or gave up, keep reading, because that is exactly what the rule was written to fix.
What Section 504 is, in plain English
Section 504 of the Rehabilitation Act is a 1973 civil rights law with a simple deal at its core: if you take federal money, you cannot discriminate against people with disabilities. It has applied to buildings, programs, and paperwork for fifty years.
In May 2024, the U.S. Department of Health and Human Services finalized a rule that spells out what that deal means online: if you receive HHS funding, your websites and mobile apps must meet WCAG 2.1 Level AA, the same widely used accessibility standard that applies to state and local governments under the ADA. WCAG is best understood as a building code for the web: specific, testable requirements covering things like keyboard access, color contrast, captions, and forms that screen readers can actually fill out. Our web accessibility workspace walks through what meeting that standard looks like in practice.
Who counts as “HHS-funded”
More organizations than you might think. You are likely covered if you are:
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- A hospital, clinic, or physician practice that participates in Medicaid or CHIP
- A nursing home or long-term care facility
- A community health center, mental health provider, or substance use program receiving federal grants
- A state or county health or human services agency, including Medicaid and child welfare agencies
- A nonprofit or university running programs funded by HHS grants, Head Start, HRSA, SAMHSA, NIH, and similar
The trigger is receiving federal financial assistance from HHS, not your size or your tax status. Small providers are covered too, they just get an extra year, as you will see below.
The deadlines and what changed in 2026
The original rule set the first compliance date for May 2026. Days before that deadline arrived, HHS issued an interim rule pushing both dates back by exactly one year. The current deadlines are:
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- May 11, 2027 for recipients with 15 or more employees
- May 10, 2028 for recipients with fewer than 15 employees
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Two things about that extension are easy to misread. It was not a repeal, the WCAG 2.1 AA requirement is unchanged and remains on the books. And it did not pause your existing obligations. HHS itself was clear that recipients still have to provide effective communication and reasonable modifications today, and pointed to things like inaccessible Medicaid enrollment websites as problems that cannot wait for the deadline.
“Could the rule still change?” An honest answer
Maybe at the edges, but waiting is still the wrong bet. Here is the honest picture as of mid-2026. The 2024 rule has been challenged in court, but the litigation has centered on other parts of the rule; no court has blocked the web accessibility requirements. HHS has said it may consider future rulemaking that could affect these requirements, and also said that if nothing changes, it fully expects to enforce the new deadlines.
And there is a piece many providers miss: Section 504 gives individuals a private right of action. People can sue over an inaccessible website directly, regardless of what federal enforcement is doing. That risk exists right now, deadline or no deadline, the same dynamic we describe in our website accessibility remediation guide.
What to do between now and the deadline
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- Confirm your funding status. Ask your finance office one question: do we receive any federal financial assistance from HHS? If yes, the rule applies.
- Inventory what you own. Main website, patient portal, appointment scheduling, mobile app, intake forms. Everything a member of the public uses counts.
- Get a real audit. An automated scan is a starting point, but most serious barriers need human testing to find. Our guide to website accessibility audit costs explains what to expect.
- Fix in priority order. Start with the paths patients and clients actually use, scheduling, enrollment, contact, billing, then work outward.
- Build it into your process. Train whoever publishes content, and make accessibility part of every redesign and procurement so you do not drift out of compliance the month after you reach it.
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Eighteen months sounds like a long time. For a site with years of accumulated pages, PDFs, and third-party widgets, it is not, especially since most organizations need budget cycles to line up first. Starting with an audit this year puts the deadline comfortably within reach; starting next spring does not.
Frequently asked questions
We are a small clinic. Does the HHS Section 504 rule really apply to us?
If you receive HHS federal financial assistance, including participating in Medicaid or CHIP, yes. Providers with fewer than 15 employees have until May 10, 2028 to meet WCAG 2.1 AA, but the basic duty not to discriminate applies now.
Is this the same as the ADA Title II rule?
They are siblings, not twins. Title II covers state and local governments; Section 504 covers anyone receiving federal funds, including private hospitals and nonprofits. Both point to the same WCAG 2.1 AA standard, so the actual work on your website is the same, and many public agencies are covered by both.
What does WCAG 2.1 AA compliance for a healthcare website involve?
In practical terms: every function works by keyboard alone, text has sufficient color contrast, images have meaningful alt text, videos have captions, forms have clear labels and error messages, and the site works with screen readers. An audit tells you how far your site currently is from that bar.
Where to start
You do not have to figure out the whole path today — you just need to know where you stand. Request a free audit and we will test your site by hand and show you exactly what the rule requires you to fix, or explore our web accessibility workspace and manual audit and remediation service to see how we take healthcare and nonprofit sites from where they are to WCAG 2.1 AA. Current rates are on our pricing page.
