The new HHS Section 504 web rule requires recipients of federal financial assistance from the Department of Health and Human Services to make their web content and mobile apps accessible. The standard is WCAG 2.1 Level AA. Large recipients had to comply by May 11, 2026. Small recipients have until May 10, 2027. The rule covers hospitals, clinics, state health agencies, nonprofits receiving HHS funding, and any entity operating a program funded in whole or in part by HHS.
This pocket guide to the HHS Section 504 web rule covers the essentials: who is covered, the technical standard, the deadlines, the exceptions, and the practical steps to take now.
| Item | Detail |
|---|---|
| Who it covers | Recipients of HHS federal financial assistance, including hospitals, health systems, clinics, state and local health agencies, and HHS-funded nonprofits |
| Technical standard | WCAG 2.1 Level AA |
| Scope | Web content and mobile apps provided by, or made available by, the recipient |
| Large recipient deadline | May 11, 2026 |
| Small recipient deadline | May 10, 2027 (fewer than 15 employees) |
| Enforcement | HHS Office for Civil Rights |
Who Does the Rule Cover?
The rule applies to entities receiving federal financial assistance from HHS. That reach is wide. It includes hospitals and health systems receiving Medicare or Medicaid reimbursement, clinics, federally qualified health centers, state and local health departments, universities running HHS-funded research, and nonprofits operating HHS-funded programs.
If your organization accepts HHS funding in any form, the rule likely applies to your public-facing web content and any mobile apps you offer.
What Standard Must Be Met?
Web content and mobile apps must conform to WCAG 2.1 Level AA. This is the same standard adopted in the ADA Title II web rule for state and local governments, which creates consistency across federal accessibility requirements.
WCAG 2.1 AA covers the criteria most relevant to issues people with disabilities encounter on websites and apps: text alternatives, keyboard operability, color contrast, form labels, focus visibility, and accessible names for interactive components, among others.
When Do You Need to Comply?
Two compliance dates apply based on recipient size:
Large recipients (15 or more employees): May 11, 2026
Small recipients (fewer than 15 employees): May 10, 2027
The large recipient date has already passed. If your organization had not reached conformance by that date, the priority is to begin the audit and remediation process now and document active progress.
What Content Is Covered?
The rule covers web content and mobile apps provided, used, or made available by the recipient. That includes patient portals, appointment scheduling, billing systems, public health information, program enrollment forms, and educational materials.
Third-party content used to conduct the recipient’s programs is also covered. If a hospital uses a vendor scheduling tool on its website, that tool falls under the rule.
Are There Exceptions?
The rule includes limited exceptions for archived web content meeting specific criteria, preexisting electronic documents (unless currently used for an active program), individualized password-protected documents (such as a specific patient’s chart), and preexisting social media posts. Each exception has narrow conditions and should not be assumed without review.
How Do You Know If Your Site Conforms?
The only way to determine WCAG conformance is a manual accessibility audit. Automated scans flag approximately 25% of issues, which means a clean scan does not indicate conformance. An auditor evaluates each page against the WCAG 2.1 AA success criteria and identifies every issue with location, description, and remediation guidance.
Accessible.org conducts fully manual audits aligned to the WCAG 2.1 AA standard required by the HHS rule. The audit report becomes the working document for remediation.
What Should You Do Now?
Practical steps for HHS recipients working toward Section 504 conformance:
Take inventory of every web property and mobile app your organization operates or makes available. Conduct a manual audit against WCAG 2.1 AA on representative pages and templates. Prioritize issues using Risk Factor or User Impact prioritization formulas. Remediate issues with developer support and validate fixes. Document the audit, remediation, and ongoing monitoring efforts. Review vendor contracts for accessibility obligations on third-party tools embedded in your sites.
Documentation matters. If HHS Office for Civil Rights opens an investigation, evidence of a structured accessibility program carries weight.
What is the difference between the HHS Section 504 rule and ADA Title II?
Both rules adopt WCAG 2.1 AA. ADA Title II applies to state and local government entities. The HHS Section 504 rule applies to recipients of HHS federal financial assistance. An organization can be covered by both, such as a county hospital receiving Medicare reimbursement.
Does the HHS rule require an accessibility statement?
The rule does not mandate a public accessibility statement, but publishing one is a recognized best practice. A statement communicates conformance status, lists the standard followed, and gives users a way to report issues.
What happens if a recipient does not comply by the deadline?
HHS Office for Civil Rights enforces the rule. Noncompliance can lead to investigations, corrective action requirements, and in serious cases, loss of federal financial assistance. Complaints filed by the public can also trigger review.
Are mobile apps treated the same as websites?
Yes. Native mobile apps must conform to WCAG 2.1 AA in the same way as web content. Mobile audits evaluate the app against the same success criteria, adapted for the iOS or Android environment.
The HHS Section 504 web rule does not introduce a new standard. It applies an established one to a large group of healthcare and HHS-funded entities. The work is identifying issues against WCAG 2.1 AA, fixing them, and keeping documentation current as web content changes.
Contact Accessible.org for an audit aligned to the HHS Section 504 web rule.
