Healthcare website accessibility
Additional Requirements for Medical Providers and HHS-Funded Organizations
Healthcare websites and digital services connect patients with appointments, forms, telehealth visits, test results, billing information, and other important services. Medical providers may also face accessibility requirements beyond those that apply to a typical private business.
Private hospitals and medical offices are generally covered by ADA Title III. Public hospitals and clinics operated by state or local governments fall under ADA Title II. Healthcare organizations that receive federal financial assistance may also be covered by Section 504 of the Rehabilitation Act. Coverage may include organizations receiving Medicaid funds, HHS grants, or other qualifying federal financial assistance.
Section 504 and WCAG 2.1 AA
This is an important distinction from the general ADA requirements affecting many private businesses: qualifying healthcare organizations have a defined WCAG standard and compliance timetable.
Current Section 504 deadlines
| Organization size | Compliance date |
|---|---|
| 15 or more employees | May 11, 2027 |
| Fewer than 15 employees | May 10, 2028 |
These dates apply to the technical WCAG conformance requirement. The updated HHS rule took effect July 8, 2024. The 2027 and 2028 dates apply to the specific WCAG 2.1 AA technical requirements for web content and mobile apps. Existing Section 504 obligations—including effective communication, reasonable modifications, and equal access—continue to apply before those deadlines. HHS can investigate complaints right now, regardless of whether your deadline has passed.
What's covered
The rule applies to web content and mobile apps that your organization provides or makes available — directly or through vendors, contractors, or licensing arrangements. In practice, this means:
- Your organization's website and all its pages
- Patient portals and online scheduling
- Telehealth platforms
- Digital intake forms and bill pay systems
- Mobile applications
- PDFs and documents posted online (patient education materials, consent forms, billing statements)
- Digital check-in systems and the accessibility of services provided through kiosks
- Third-party portals, scheduling systems, payment tools, telehealth platforms, and other services provided through contractual or licensing arrangements
Using a vendor or licensed platform generally does not remove the recipient organization’s responsibility to provide accessible digital services.
Why the Deadlines Matter
The deadline extension applies only to the specific WCAG 2.1 Level AA requirements for web content and mobile apps. It does not suspend a recipient’s broader obligation to provide people with disabilities equal access to its programs and services.
The HHS Office for Civil Rights accepts disability-discrimination complaints, conducts compliance reviews, and may require corrective action. Healthcare organizations should use the additional time to identify covered websites, apps, documents, portals, and vendor systems rather than waiting until the applicable deadline.
Digital Patient Services to Review
Healthcare accessibility involves more than the public-facing homepage. A review may also need to include:
- Appointment scheduling and intake forms
- Patient portals and secure messages
- Telehealth platforms
- Test results and downloadable documents
- Billing and payment systems
- Mobile applications
- Educational videos and patient instructions
- Digital check-in systems and kiosks
Telehealth providers must give patients with disabilities an equal opportunity to participate. Depending on a patient’s needs, this may involve screen-reader compatibility, real-time captions, qualified interpreters, accessible video content, or allowing a support person to join a virtual appointment. Providers generally may not charge the patient for required communication aids or services.
How we can help
We provide accessibility audits and remediation for healthcare websites, combining automated scanning with manual expert testing against WCAG 2.1 Level AA. We won't simply hand you a report and leave you to implement necessary changes on your own. We identify the barriers, prioritize what to fix first, and do the remediation work ourselves.
Learn about our ADA audit & remediation services →
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