Many people have been confused lately about web accessibility deadlines. On April 20, 2026, the Department of Justice gave state and local governments an extra year to comply with Title II of the ADA. That update spread quickly, but it does not apply to healthcare organizations.
The HHS Section 504 rule is different and has its own deadline. If your organization gets federal funding from HHS - like Medicare, Medicaid, CHIP, or other programs - your websites, patient portals, and mobile apps must meet WCAG 2.1 Level AA standards by May 11, 2026. HHS has not given an extension.
If your team relaxed after hearing about the extension, it’s important to check which rule actually applies to your organization.
What the HHS Section 504 Rule Actually Requires
The rule was finalized in May 2024 and is the biggest update to Section 504 of the Rehabilitation Act in almost 50 years. For the first time, it sets clear, enforceable digital accessibility standards for private healthcare organizations that get federal funding.
WCAG 2.1 Level AA is the required standard. This means your digital tools must meet four main criteria:
- Perceivable: Content should be available in ways everyone can access. For example, use alt text for images, captions for videos, and layouts that adapt to different needs.
- Operable: Your site should work fully with just a keyboard. Avoid flashing content that could cause seizures.
- Understandable: Content needs to be clear and easy to follow. Forms should show helpful error messages, and navigation should work the same way throughout your site.
- Robust: Your site’s code should work with assistive technologies like screen readers, both now and as these tools change over time.
The rule applies to more than just your main website. It also covers patient portals, online appointment tools, mobile apps, telehealth platforms, and digital intake forms. Any third-party tools you offer to patients are included, too. For example, if you use a vendor’s scheduling system, it must also meet the standard.
Who Is Covered
Any organization with 15 or more employees that gets federal funding from HHS must comply by May 11, 2026. This includes hospitals, health systems, clinics, long-term care providers, health insurers, research institutions, and medical schools.
Organizations with fewer than 15 employees have until May 10, 2027, but the rule still applies to them. Even a small practice that accepts Medicaid is included. The size of your organization only affects the deadline, not whether you must comply.
The risks of not complying are serious. HHS's Office for Civil Rights can investigate complaints and start compliance reviews on its own. You could lose federal funding if you do not meet the requirements. The rule also makes it easier for private lawsuits under the ADA. Some attorneys already use automated tools to find accessibility problems on healthcare websites.
What Compliance Actually Looks Like
WCAG 2.1 AA compliance is not just a box to check. It involves a full accessibility audit, resolving any issues identified, and keeping up with ongoing maintenance.
During the audit, you review your site’s code, content, and features against WCAG standards. Automated tools can find some problems, but a real audit needs manual testing by someone who understands both the technical rules and how assistive technologies work in practice. Many organizations are surprised by what a thorough audit uncovers. Common issues include broken heading structures, missing form labels, poor color contrast, and inaccessible PDFs. These problems are usually invisible to most users.
After the audit, you move on to fixing the issues. Some fixes are simple, but others, especially for older or heavily customized WordPress or Drupal sites, take more time and effort. Timing is important. With the deadline approaching, organizations that have not started yet need to act fast and may need a partner to help.
Ongoing maintenance is often underestimated. A site that passes an audit in May could fail by July if new content, features, or third-party scripts are added without accessibility testing.
Inclind's Work in Healthcare Accessibility
Inclind has helped healthcare organizations like TidalHealth and Beebe Healthcare with web design, development, and ongoing support, including accessibility compliance. Our team runs accessibility audits, leads remediation on WordPress and Drupal sites, and helps marketing teams set up processes so accessibility does not become a constant emergency.
We know how healthcare marketing teams work. Most are small and handle a lot of content with limited technical resources. Our goal is to handle compliance, so your team can focus on what you do best.
If you are unsure about your organization’s status, an accessibility audit is the best place to start. We can check your current site against WCAG 2.1 Level AA, find any gaps, and show you what needs to be fixed before the deadline.
Where to Start
Begin by honestly reviewing your current site. If you have not had a recent accessibility audit, get one before assuming you are compliant. Automated scans are just a starting point, not the final answer.
Next, create a remediation plan that covers both your CMS and your content management. If your team often publishes new pages, blog posts, or documents, make accessibility part of your regular process, not something you fix once a year.
If you need help with any of this, we are here for you.