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.
The updated Section 504 rule strengthens protections for individuals with disabilities and expands expectations for healthcare providers.
Key provisions include:
Ensuring medical treatment decisions are not influenced by bias or assumptions related to disability
Prohibiting discrimination through value assessment methods
Reinforcing nondiscrimination in child welfare and related services
Requiring digital accessibility for websites and mobile applications under WCAG standards
Mandating accessibility of medical equipment, including exam tables and diagnostic devices
Requiring services to be delivered in the most integrated setting appropriate
Additional context can be found in the full rule summary.
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.
All websites and mobile applications must conform to WCAG 2.1 AA
Alternative standards such as WCAG 2.2 may be used if they provide equal or greater accessibility
Third party platforms, including patient portals and vendor systems, must meet accessibility requirements
Kiosk based systems must be accessible or provide equivalent alternatives
To meet WCAG requirements, healthcare organizations should ensure that digital experiences are accessible to individuals with a wide range of abilities.
Key considerations include:
Videos must include accurate captions
Images should include descriptive alternative text
All functionality must be accessible using a keyboard alone
Forms must include properly labeled fields for assistive technologies
Color cannot be the only method used to communicate important information
Each page must define its primary language in the code
Error messages should be clear and actionable
Text must meet contrast requirements for readability
These elements are foundational to creating inclusive digital environments and meeting compliance standards.
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:
Public facing websites
Telehealth platforms
Resident and family communication systems
Kiosk and intake systems
Failure to address accessibility gaps may introduce compliance risk and disrupt access to care.
Assisted living providers are subject to Section 504 requirements if they receive federal financial assistance, such as Medicaid waivers.
This impacts:
Resident portals and communication platforms
Public websites and marketing materials
Third party tools used for operations and engagement
Organizations should evaluate both internal systems and vendor supported platforms to ensure compliance.
Independent living communities are only subject to Section 504 if they receive federal funding. When applicable, accessibility requirements extend to:
Resident portals
Transportation scheduling systems
Maintenance request platforms
Community apps and websites
Understanding whether your organization qualifies as a covered entity is a critical first step.
With compliance deadlines approaching, organizations should begin preparing now.
Recommended actions include:
Conducting a comprehensive digital accessibility audit
Updating vendor contracts to include accessibility requirements
Prioritizing remediation of high traffic and high impact user journeys
Training staff on accessible communication practices
Ensuring kiosk systems are accessible or provide alternative access
Taking a proactive approach can reduce risk and support a smoother path to compliance.
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.
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.
Any healthcare organization that receives federal financial assistance, including Medicare or Medicaid reimbursements, grants, or funding, must comply with Section 504 requirements.
Noncompliance may result in regulatory action, loss of funding, or legal risk. It may also limit access to care for individuals with disabilities.
Yes. Patient portals, scheduling tools, and other third-party systems used by healthcare providers must also meet accessibility standards under the rule.
Organizations with 15 or more employees must comply by May 11, 2026. Smaller organizations have until May 10, 2027.
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.