The HHS Section 504 rule requires WCAG 2.1 AA by May 11, 2027 for organizations with 15 or more employees, and by May 10, 2028 for smaller ones. HHS pushed both dates back one year in May 2026. The requirement itself did not change, and the National Federation of the Blind has sued to bring the original dates back.
Many of these organizations have under 15 employees and so have until May 10, 2028. That is the date for the web rule only. The general duty not to exclude people with disabilities already applies.
Eligibility screeners, program applications and multilingual pages are the usual problem areas, and they are the pages the people you serve need most.
Yes, if your practice takes Medicare, Medicaid, CHIP or other HHS money. Medicare Part B payments alone count. A practice that takes only commercial insurance or cash is outside Section 504 but still covered by ADA Title III. Source: HHS final rule.
May 11, 2027 for organizations with 15 or more employees, and May 10, 2028 for those with fewer than 15. HHS moved both dates back one year in May 2026. The rule itself did not change. Source: HHS extension summary, Healthcare Law Insights.
The rule covers tools you provide through contracts as well as your own website. Include booking, patient portals, payment and intake tools when you plan the work. Source: HHS final rule.
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