HHS Section 504 website accessibility rule: dates and first steps for small health practices

If your practice receives funding from the U.S. Department of Health and Human Services (HHS), a federal rule now sets a specific technical standard for your website and any mobile app. The deadline was pushed back in May 2026, so most small practices have time to do this calmly. Here's what the rule says, in plain English, with links to the source text.

What the rule says

The rule is 45 CFR 84.84, part of HHS's Section 504 regulations. It says a recipient of HHS funding must make its web content and mobile apps "readily accessible to and usable by individuals with disabilities", and that they must meet the Level A and AA success criteria of WCAG 2.1.

The dates (extended in May 2026)

On May 7, 2026, HHS announced a one-year extension. The current dates are:

• May 11, 2027 for recipients with 15 or more employees.
• May 10, 2028 for recipients with fewer than 15 employees.

The rule allows an exception where a recipient can show that meeting it would fundamentally alter a program or cause undue financial and administrative burdens. That's a legal question for your own adviser, not something to assume.

Who it covers

It applies to recipients of HHS federal financial assistance. HHS's examples include hospitals and community health centres; its Section 1557 fact sheet mentions doctors who receive Medicaid payments as an example of HHS funding. Whether your own practice counts depends on how you're paid and funded, so check with your attorney, your professional association or the HHS Office for Civil Rights. We can't tell you that, and this page isn't legal advice.

Your vendors' tools count too

The rule covers web content and apps you provide "directly or through contractual, licensing, or other arrangements". In practice that means your online booking widget, patient portal, intake forms and telehealth links are part of the picture, not just the pages you edit yourself. Ask each vendor for their accessibility conformance report (often called a VPAT; see our VPAT guide) and note the answer.

A calm plan for a small practice

1. List what you provide online: website pages, PDFs (intake forms, notices), booking, portal, payment and any app.
2. Fix the common website issues first: missing alt text, low colour contrast, unlabelled form fields and icon-only buttons. Our 25-point checklist covers them.
3. Replace or tag key PDFs. New-patient forms work best as accessible web forms; see accessible PDFs.
4. Test the booking flow with only a keyboard using our 5-minute keyboard test.
5. Ask vendors for conformance reports and their plans for WCAG 2.1 AA.
6. Add an accessibility statement with a phone number and email, so patients can reach you if something doesn't work. Use our template.

What automated scans can and can't do

An automated scan, including ours, finds a useful share of WCAG issues quickly, but it can't confirm full WCAG 2.1 AA conformance on its own. Some criteria need a person to check, such as whether alt text is accurate or whether a form makes sense with a screen reader. Treat a scan as a fast first pass, and plan a manual review for complex flows like portals.

Related: medical and chiropractic clinic websites, dental practice websites.

Want the fixes written for you?

Start with a free homepage snapshot. The $149 Fix-Pack scans up to 10 pages and gives copy-paste fixes for your platform within 48 hours, with a 14-day refund promise. See a sample report first.

This is general technical guidance, not legal advice, and it does not certify compliance with the ADA or any law.

Related guides

• Online booking and appointment widget accessibility: a 10-minute test for small businesses
• WCAG 2.2 explained for small-business websites
• Squarespace accessibility fixes: alt text, contrast, forms and more
• Wix accessibility fixes: a practical checklist

All guides

This guide is general technical information, not legal advice. Following it does not certify ADA or any legal compliance. Automated checks find only part of accessibility barriers.