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.
For years HHS treated Medicare Part B as insurance, not federal funding, which left many physician practices outside Section 504. In 2024 HHS reversed that position. A practice whose only federal money is Part B is now covered, and so are practices taking Medicaid, CHIP or Medicare Advantage.
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.
Title III applies separately and has no deadline. A patient who cannot book, pay or fill in a form on your site can bring a private suit today.
This covers primary care, urgent care and every specialty: cardiology, orthopedics, OB-GYN, pediatrics, allergy, ENT, gastroenterology and the rest.
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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