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On May 9, 2024, the U.S. Department of Health and Human Services Office for Civil Rights published a final rule updating Section 504 of the Rehabilitation Act of 1973. The rule requires every recipient of HHS federal financial assistance to make its websites, mobile applications, and self-service kiosks accessible — and bakes WCAG 2.1 Level AA in as the technical standard.
Recipients with 15 or more employees
Compliance required by May 11, 2026 — three years after the final rule's effective date.
Recipients with fewer than 15 employees
Compliance required by May 10, 2027 — four years after the final rule's effective date.
Section 504 reaches anyone receiving federal financial assistance from HHS. In practice that means most of the U.S. healthcare system, including:
The rule incorporates the W3C's Web Content Accessibility Guidelines version 2.1, Level AA, by reference. There are limited exceptions for archived content, pre-existing electronic documents, third-party content not posted by the recipient, and password-protected content not used by people with disabilities — but the exceptions are narrow and most provider-published content does not qualify.
The matching DOJ Title II rule uses the same standard, so a single accessibility program can typically satisfy both — see our Title II deadline coverage.
Healthcare websites are already being targeted in private litigation under Title III of the ADA — well before the Section 504 deadline. Hospitals, pharmacies, and insurers have settled multi-million-dollar class actions in the past 24 months. See our healthcare accessibility lawsuit hub.
A complaint filed under Section 504 can also lead to a loss of federal funding — a far steeper consequence than statutory damages.
Run a baseline scan of your patient portal, then walk it with a screen reader. Most providers find their first 50 critical issues in under a day.