Section 504 now requires any organization that takes HHS money to make its website and apps accessible. HHS moved the date back one year. It did not change the rule.
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Section 504 Facts
HHS digital accessibility rule, 45 CFR part 84
Both dates were extended one year in May 2026. A lawsuit asking a court to restore the original 2026 dates is pending.
Size does not decide coverage. Federal funding does. If any of your revenue comes from an HHS program, you are a recipient under Section 504, whether you are a hospital or a two-chair dental office.
Share covered by the rule. HHS estimate, 2024.
Outside Section 504 is not outside the law. Every business open to the public is covered by ADA Title III, which has no deadline and is where the lawsuits come from.
The rule names WCAG 2.1 Level AA. We fix to WCAG 2.2 AA, which includes every 2.1 AA requirement and adds a few more, so your site clears the rule with room to spare.
Anyone can file a complaint with the HHS Office for Civil Rights. OCR investigates, and it can also open a compliance review without any complaint at all.
Most cases end with a required plan to fix the problem on a schedule. The end of that road, if an organization does not fix it, is the loss of federal program funding.
A patient can sue under Section 504 directly. ADA Title III suits apply on top, and those have no deadline at all.
The original deadline was May 11, 2026. HHS pushed it back days before it arrived, without the usual public comment period.
On May 21, 2026 the National Federation of the Blind sued HHS and the Department of Justice in federal court in Maryland, asking the court to throw out the extension and restore the original dates. No ruling had been reported as of mid-September 2026.
If the court sides with them, the original date, which has already passed, would apply again. Organizations that waited would be out of compliance the day the ruling lands.
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.
A free grade does not replace testing by people. Our software finds problems it can detect, while manual testing checks how people use the site.
We fix barriers in the website code. AI-powered fixes, tested by our team. We also offer ongoing care for changes that can bring barriers back.
We grade your site against the standard, fix the code, and hand you dated documentation of every change: the record a 504 review asks for.
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Facts checked October 14, 2026. This is a plain summary, not legal advice. Grade is an accessibility services firm, not a law firm.