As part of our ongoing commitment to supporting rural healthcare compliance efforts, we want to make all clinics aware of important federal accessibility requirements under Section 504 that may impact healthcare organizations over the next several years. In addition to the requirements, it’s important to know that initial deadline dates have been extended as of May 7, 2026.
What is Section 504?
Section 504 is a federal civil rights law requiring healthcare organizations to ensure equal access to programs and services for individuals with disabilities and to avoid discrimination. This applies to all provider types.
Healthcare organizations should be aware of important updates related to Section 504 accessibility requirements and website compliance deadlines.
The U.S. Department of Health and Human Services (HHS) recently issued an Interim Final Rule extending the compliance deadlines for website and mobile application accessibility requirements under Section 504 of the Rehabilitation Act. These requirements apply to healthcare organizations receiving federal financial assistance and are intended to improve access for individuals with disabilities.
Updated Website Accessibility Deadlines:
Previously larger clinics were given a deadline of May 11, 2026 to complete their website review.
Under the updated rule:
• Organizations with 15 or more employees now have until May 11, 2027 to comply with WCAG 2.1 website accessibility standards.
• Organizations with fewer than 15 employees now have until May 10, 2028 to comply.
• July 8, 2026 – Accessible exam table and weight scale
The extension was issued in response to concerns from healthcare providers, local governments, and other organizations regarding implementation timelines, staffing limitations, vendor availability, and remediation costs.
What Clinics Should Be Doing Now
Although the deadlines have been extended, healthcare organizations should continue preparing for compliance and evaluating accessibility across their operations.
Focus on the following areas to demonstrate compliance:
- Website & Digital Access:
Review your website, patient portal, and telehealth platforms to ensure they meet WCAG 2.1 standards. - Kiosks (if applicable)
Ensure kiosks are accessible or have a staff-assisted alternative available. - Medical Equipment
Ensure access to an accessible exam table and weight scale
Larger facilities should ensure a percentage of equipment is accessible
If this presents an undue financial or administrative burden, we recommend consulting with legal counsel to determine documentation requirements needed to support and prove this position. - Policies & Procedures
We recommend reviewing and updating your civil rights policies to confirm compliance with section 504. If you would like support, we would be happy to provide a quote. - Staff readiness and accommodation procedures
- Documentation of accessibility efforts and mitigation strategies
- Enforcement
Enforced by the Office for Civil Rights (OCR)
Typically initiated by a patient complaint
Importantly, the extension does not eliminate existing obligations under Section 504. Organizations are still expected to provide reasonable accommodations and ensure meaningful access for individuals with disabilities.
How HSA Is Supporting Clinics:
For clinics enrolled in HSA’s Policy Subscription service, updated Section 504-related policies have already been added within Glacier™. Policy Subscription clinics also have access to additional compliance support resources, including website accessibility readiness tools and ongoing policy guidance.
If your organization is not currently supported by HSA and would like assistance with Section 504 readiness, policy support, or compliance planning, please contact our team at info@hsagroup.net or call 231.924.0244.
Resources:
Extension of Compliance Dates for Nondiscrimination on the Basis of Disability;
Accessibility of Web Content and Mobile Applications of Recipients of Departmental
Financial Assistance Helpful Resource
NARHC Free Webinar:
https://vimeo.com/1178597642/c18011d859?share=copy&fl=sv&fe=ci