The HHS Section 504 web rule applies to any entity that receives federal financial assistance from the Department of Health and Human Services. That includes hospitals, state and local health agencies, Medicaid and Medicare providers, public health programs, human services organizations, and many universities and research institutions. Covered entities must make their websites and mobile apps conform to WCAG 2.1 Level AA. Large recipients had a May 11, 2026 deadline. Small recipients (under 15 employees) had until May 10, 2027. The rule covers web content and mobile apps used to provide programs, services, or activities funded by HHS.
| Item | Detail |
|---|---|
| Who it applies to | Recipients of HHS federal financial assistance |
| Common covered entities | Hospitals, health systems, Medicaid/Medicare providers, state health agencies, human services agencies, federally funded universities and research programs |
| Standard required | WCAG 2.1 Level AA |
| Assets covered | Websites and mobile apps used to deliver HHS-funded programs, services, or activities |
| Large recipient deadline | May 11, 2026 |
| Small recipient deadline (under 15 employees) | May 10, 2027 |
What the rule covers
HHS finalized the rule under Section 504 of the Rehabilitation Act in May 2024. It sets WCAG 2.1 Level AA as the technical standard for web content and mobile apps operated by recipients of HHS funding.
The rule mirrors the structure of the Department of Justice’s ADA Title II web rule. Both reference the same WCAG version and level. Many entities are covered by both.
Who is a recipient of HHS funding?
A recipient is any public or private entity that gets federal financial assistance from HHS. The funding can flow directly from HHS or pass through a state or local agency.
Typical recipients include hospitals and health systems that bill Medicare or Medicaid, state and local public health departments, community health centers and FQHCs, nursing homes, home health agencies, and hospice providers, behavioral health and substance use treatment programs, human services agencies (child welfare, refugee services, aging services), universities and research institutions receiving NIH or HRSA grants, and health insurance issuers participating in HHS programs.
If your organization receives a check, grant, contract, or reimbursement from HHS, or from a program funded by HHS, Section 504 obligations attach. Web accessibility is now part of those obligations.
What digital assets are covered?
The rule reaches the websites and mobile apps a recipient uses to offer its programs, services, or activities. That includes the public-facing site, patient portals, appointment scheduling, billing systems, member portals, and any mobile app used by the public or program participants.
Internal-only tools used exclusively by staff are treated under separate Section 504 obligations related to employment. The web rule’s main focus is the digital content the public interacts with.
Are there exceptions?
Yes. The rule includes limited exceptions modeled on the DOJ’s ADA Title II rule. These include archived web content that is not used or referenced for current programs, preexisting conventional electronic documents (PDFs, Word files) unless used for current services, content posted by third parties not under the recipient’s contract or control, linked third-party content not used for current programs, and course content for individual password-protected accounts of specific students or members (with conditions).
Exceptions are narrow. If content is used to deliver a current program or service, it must conform.
How do recipients confirm conformance?
A manual accessibility evaluation against WCAG 2.1 AA is the only way to determine conformance. Automated checkers detect approximately 25% of issues and cannot assess criteria that require human judgment, such as meaningful alt text, logical reading order, or correct name and role on custom components.
The evaluation identifies issues. Remediation addresses them. Validation confirms the fixes hold. That sequence is the basis of any credible conformance claim under the HHS rule.
How does this overlap with ADA Title II?
State and local government health agencies are often covered by both rules. The DOJ’s ADA Title II web rule reaches state and local government entities directly. The HHS Section 504 rule reaches them as federal funding recipients.
The technical standard is the same: WCAG 2.1 Level AA. A single evaluation and remediation effort can satisfy both, provided the scope covers all relevant digital assets.
FAQs
Does the HHS Section 504 web rule apply to private hospitals?
Yes, if the hospital receives Medicare or Medicaid reimbursement, accepts HHS grants, or otherwise receives federal financial assistance from HHS. Almost every hospital in the United States meets this definition.
Does the rule apply to private medical practices?
A small private practice that participates in Medicare or Medicaid is a recipient of HHS federal financial assistance and falls under Section 504. The small recipient deadline (under 15 employees) applied later than the large recipient deadline.
What standard does the HHS rule require?
WCAG 2.1 Level AA. The rule adopts this version and level explicitly, matching the ADA Title II web rule.
What about mobile apps?
Mobile apps used to deliver HHS-funded programs or services are covered. The same WCAG 2.1 AA standard applies, evaluated in mobile contexts (iOS, Android, screen readers like VoiceOver and TalkBack).
What is the penalty for non-conformance?
Section 504 enforcement can include loss of federal financial assistance, complaints filed with HHS’s Office for Civil Rights, and private lawsuits. Individuals can file complaints with OCR alleging disability discrimination.
How long does an evaluation take?
For most healthcare websites, an Accessible.org evaluation completes in two to four weeks depending on scope. Remediation timelines vary based on the volume of issues and developer availability.
Recipients of HHS funding now operate under a defined technical standard with defined deadlines. The path to conformance starts with knowing exactly what you have and where the issues are.
Contact Accessible.org for an evaluation quote: Contact our team.
