In May 2024, the U.S. Department of Health and Human Services (HHS) issued a significant update to Section 504 of the Rehabilitation Act of 1973. This final rule modernizes civil rights protections for individuals with disabilities across all HHS funded programs.
The rule applies broadly to healthcare organizations that receive federal financial assistance, including hospitals, physician groups, skilled nursing facilities, and senior living providers that accept Medicare or Medicaid reimbursements, grants, or other HHS funding.
A central component of this update is digital accessibility. Covered entities are now required to ensure that their websites, mobile applications, and digital tools meet specific accessibility standards under the Web Content Accessibility Guidelines (WCAG).
These changes represent a meaningful shift in how accessibility is defined, enforced, and operationalized across healthcare.
Overview of the HHS Section 504 Final Rule
The updated Section 504 rule strengthens protections for individuals with disabilities and expands expectations for healthcare providers.
Key provisions include:
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Ensuring medical treatment decisions are not influenced by bias or assumptions related to disability
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Prohibiting discrimination through value assessment methods
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Reinforcing nondiscrimination in child welfare and related services
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Requiring digital accessibility for websites and mobile applications under WCAG standards
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Mandating accessibility of medical equipment, including exam tables and diagnostic devices
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Requiring services to be delivered in the most integrated setting appropriate
Additional context can be found in the full rule summary.
Digital Accessibility and WCAG Requirements
One of the most impactful aspects of the final rule is the requirement for digital accessibility.
Healthcare providers must ensure that all public facing and patient facing digital platforms comply with WCAG 2.1 Level AA standards.
Compliance Deadlines
- Organizations with 15 or more employees must comply by May 11, 2026
- Organizations with fewer than 15 employees must comply by May 10, 2027
Key Requirements
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All websites and mobile applications must conform to WCAG 2.1 AA
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Alternative standards such as WCAG 2.2 may be used if they provide equal or greater accessibility
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Third party platforms, including patient portals and vendor systems, must meet accessibility requirements
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Kiosk based systems must be accessible or provide equivalent alternatives
Core Accessibility Considerations
To meet WCAG requirements, healthcare organizations should ensure that digital experiences are accessible to individuals with a wide range of abilities.
Key considerations include:
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Videos must include accurate captions
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Images should include descriptive alternative text
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All functionality must be accessible using a keyboard alone
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Forms must include properly labeled fields for assistive technologies
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Color cannot be the only method used to communicate important information
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Each page must define its primary language in the code
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Error messages should be clear and actionable
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Text must meet contrast requirements for readability
These elements are foundational to creating inclusive digital environments and meeting compliance standards.
Implications for Skilled Nursing Facilities
Skilled nursing facilities rely heavily on digital systems for admissions, care coordination, communication, and telehealth services.
Because most SNFs receive Medicare or Medicaid funding, they are considered covered entities and must ensure compliance across:
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Public facing websites
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Telehealth platforms
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Resident and family communication systems
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Kiosk and intake systems
Failure to address accessibility gaps may introduce compliance risk and disrupt access to care.
Implications for Assisted Living Providers
Assisted living providers are subject to Section 504 requirements if they receive federal financial assistance, such as Medicaid waivers.
This impacts:
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Resident portals and communication platforms
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Public websites and marketing materials
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Third party tools used for operations and engagement
Organizations should evaluate both internal systems and vendor supported platforms to ensure compliance.
Implications for Independent Living Communities
Independent living communities are only subject to Section 504 if they receive federal funding. When applicable, accessibility requirements extend to:
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Resident portals
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Transportation scheduling systems
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Maintenance request platforms
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Community apps and websites
Understanding whether your organization qualifies as a covered entity is a critical first step.
Practical Steps Healthcare Providers Should Take
With compliance deadlines approaching, organizations should begin preparing now.
Recommended actions include:
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Conducting a comprehensive digital accessibility audit
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Updating vendor contracts to include accessibility requirements
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Prioritizing remediation of high traffic and high impact user journeys
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Training staff on accessible communication practices
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Ensuring kiosk systems are accessible or provide alternative access
Taking a proactive approach can reduce risk and support a smoother path to compliance.
Frequently Asked Questions About Section 504 and WCAG Compliance
What is the HHS Section 504 Final Rule
The HHS Section 504 Final Rule is an update to the Rehabilitation Act that strengthens protections for individuals with disabilities and expands accessibility requirements for healthcare providers receiving federal funding.
What is WCAG 2.1 AA and why does it matter
WCAG 2.1 AA is a set of technical standards that define how to make digital content accessible to people with disabilities. Under the Section 504 Final Rule, healthcare organizations must meet these standards to ensure equitable access to digital services.
Who must comply with Section 504
Any healthcare organization that receives federal financial assistance, including Medicare or Medicaid reimbursements, grants, or funding, must comply with Section 504 requirements.
What happens if a healthcare provider is not compliant
Noncompliance may result in regulatory action, loss of funding, or legal risk. It may also limit access to care for individuals with disabilities.
Do third party platforms need to be WCAG compliant
Yes. Patient portals, scheduling tools, and other third-party systems used by healthcare providers must also meet accessibility standards under the rule.
When are the compliance deadlines
Organizations with 15 or more employees must comply by May 11, 2026. Smaller organizations have until May 10, 2027.
Preparing for Section 504 and WCAG Compliance in Healthcare
As digital tools continue to play a central role in healthcare delivery, accessibility is no longer optional. The HHS Section 504 Final Rule makes it clear that equitable access must extend beyond physical spaces into every digital interaction, from websites and portals to telehealth and communication platforms.
For covered entities, compliance with WCAG standards is not just a regulatory requirement. It is a critical component of delivering inclusive, high quality care. Proactively addressing accessibility gaps now can help organizations reduce risk, improve user experience, and ensure all individuals can fully engage with services.
With approaching compliance deadlines, organizations should begin evaluating their current digital environments, identifying gaps, and building a roadmap to meet accessibility standards. Early action will be key to ensuring a smooth transition and sustained compliance.
