In May 2024, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) issued its long-awaited final rule updating Section 504 of the Rehabilitation Act its first major update in nearly 50 years. Section 504 has always prohibited discrimination based on disability in programs receiving federal financial assistance. Now, HHS has made something explicit that accessibility professionals have long emphasized: digital barriers are healthcare barriers.
If patients with disabilities cannot use a provider’s website, patient portal, mobile app, or telehealth tools, they cannot fully access care. This update clarifies that inaccessible digital experiences are a form of discrimination requiring organizations to make meaningful, measurable progress toward accessibility.
For healthcare leaders navigating regulatory compliance, this rule marks a significant shift. It demands structured digital accessibility programs not just one-time fixes.
Who Must Comply?
If your organization receives federal financial assistance through Medicare, Medicaid, CHIP, ACA Marketplaces, or HHS grants, you are very likely covered. This includes:
- Hospitals, clinics, and specialty care providers
- Health insurers and managed care organizations
- State Medicaid agencies
- Telehealth service providers and digital health platforms
- Long-term care and post-acute organizations
- Human and social service entities
Even if accessibility initiatives have already begun, the new rule raises expectations around consistency, testing methods, and documentation.
Compliance Timeline for Web and Mobile Accessibility
| Requirement | Deadline |
| Rule Effective Date | July 8, 2024 |
| WCAG 2.1 AA Conformance for Web and Mobile Apps — organizations with ≥15 employees | May 11, 2026 |
| WCAG 2.1 AA Conformance — organizations with <15 employees | May 10, 2027 |
Although these dates seem distant, most healthcare providers operate an ecosystem of websites, portals, EMR-connected apps, third-party tools, microsites, and legacy PDFs. Auditing, remediation, training, and vendor coordination all require long lead times.
What Section 504 Requires in Practice
The rule mandates that digital content conform to WCAG 2.1 Level A and AA with limited exceptions such as archived content, individualized documents, or undue burden cases.
Achieving and maintaining conformance requires these foundational elements:
1. Comprehensive Accessibility Audits
Organizations must evaluate all digital platforms, including:
- Public websites
- Patient portals and online scheduling systems
- Mobile apps
- Telehealth platforms
Testing must go beyond automated tools. Real-world usability requires:
- Keyboard-only interaction
- Screen reader and magnification testing
- Voice navigation workflows
- Cognitive accessibility considerations
Automated scans typically catch ~30% of WCAG issues; manual testing is essential for verifying access to care workflows.
2. Remediation of Barriers that Impact Meaningful Access
Common accessibility failures include:
- Inaccessible PDFs for consents and forms
- Missing alt text on clinical images
- Videos without captions or audio descriptions
- Screen reader–silent error messages
- Login flows requiring dragging, memory tests, or gestures
Telehealth must support captions, interoperable input methods, and accessible audio/video controls.
3. Ongoing Monitoring to Prevent Regressions
Digital accessibility is continuous work. Organizations must embed checks into:
- Design reviews and UX governance
- Code standards and development lifecycles
- QA testing and automated pipelines
High-impact flows portal login, scheduling, telehealth access, billing should be monitored continuously with both automation and manual testing.
4. Policies, Ownership, and Training
HHS expects accessibility to be operationalized, not siloed. That includes:
- A Section 504 digital accessibility policy referencing WCAG 2.1 AA
- Assigned governance across digital, IT, compliance, and patient experience teams
- Training for designers, developers, content authors, and clinical staff
5. Sustainable Long-Term Programs
Compliance is not the finish line. New features, apps, and vendors must align with accessibility requirements. Essential components include:
- Periodic audits and user testing
- Contract language mandating accessibility for third-party tools
- Clear reporting and documentation of improvements
A 5-Step Readiness Roadmap for Healthcare
Organizations
Healthcare providers making real progress are following a structured playbook:
- Inventory all digital assets — including third-party integrations
- Perform baseline audits — focusing first on care delivery workflows
- Develop a prioritized remediation plan — aligned to 2026/2027 deadlines
- Launch governance and internal training — building organization-wide capability
- Engage trusted Web Accessibility services partners — especially for remediation at scale
This approach allows measurable improvements without overwhelming lean digital teams.
Why Accessibility Matters Beyond Compliance
For patients with disabilities:
- An inaccessible portal may mean no access to test results
- An inaccessible telehealth tool may mean delayed care
- An inaccessible insurance form may mean lost coverage
Accessibility is patient safety, patient trust, and equitable care.
Healthcare organizations leading the way view accessibility as part of:
- Health equity and inclusion initiatives
- Better digital experience for all users
- Risk reduction and reduced OCR complaint exposure
How Web Accessibility Services Accelerate Outcomes
Many healthcare providers have purchased testing tools or received audit reports but remain stuck implementing changes. This is where Web Accessibility services bring tangible value:
- Expert remediation to reduce strain on internal developers
- Repeatable testing frameworks with WCAG 2.1 AA alignment
- Progress reporting to support compliance documentation
- Support for high-risk digital journeys first
With Section 504 enforcement now clearly covering web and mobile accessibility, results not reports matter most.
Final Takeaway
HHS’s updated Section 504 rule signals the future of healthcare: Digital access is a civil right.
Healthcare leaders should focus on:
- Risk — OCR can now act directly on digital accessibility complaints
- Integration — Accessibility must be built into DevOps and UX workflows
- Sustainability — Long-term governance ensures continued compliance
- Patient experience — Removing digital friction improves care outcomes
Meeting Section 504 requirements is more than a legal obligation; it’s a commitment to care for every patient who depends on your digital services.