Understand healthcare digital accessibility requirements

Distinguish HHS Section 504 web requirements, ADA context, and other applicable obligations.

Starter draft for review. Use as a conversation or planning aid.

HHS Section 504 web and mobile requirements

For covered recipients of HHS financial assistance, the web and mobile rule uses WCAG 2.1 Level AA. The May 2026 extension sets these compliance dates:

15 or more employees: May 11, 2027.
Fewer than 15 employees: May 10, 2028.

These dates concern the specified web and mobile standard. Existing obligations to provide access continue. Confirm recipient status, employee-count rules, scope, and any exception with the organization's authorized civil rights, accessibility, and legal leads.

Keep overlapping obligations distinct

Public providers may also be subject to ADA Title II, which uses different classification and population rules. Private providers and other covered health programs may have additional duties under the ADA, Section 1557, contracts, or other laws. Do not treat one date as the deadline for every healthcare organization or every access obligation.

Connect the rule to the service

Include portals, scheduling, digital forms, messages, and vendor-delivered web or mobile services in the scope discussion. Review telehealth communication support and applicable privacy and security requirements through the organization's approved processes.

Primary sources

Sources checked November 2, 2026. Use live official guidance for updates. Institute tools support planning; they do not establish conformance or determine legal applicability.

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