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.
Coverage follows the money, not the size of the practice. Medicaid, CHIP and Medicare payments, including Medicare Part B since 2024, all count as federal financial assistance. A practice that files with none of them is outside the rule, but still inside ADA Title III.
The rule covers web content and mobile apps you provide directly or through a contract or license. Your booking tool, patient portal and online forms count, even when a vendor built them.
Enforcement runs two ways. The HHS Office for Civil Rights investigates complaints and can open a compliance review on its own, and the end of that road is the loss of federal program funding. A patient can also sue under Section 504 directly.
Orthodontics, oral surgery and pediatric dentistry are covered the same way. If you file no federal insurance at all, scan anyway: Title III applies to every practice open to the public.
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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