accessibility

# What Healthcare Organizations Need to Know Before the 2026 Deadline

The HHS Section 504 deadline is real: patient portals, scheduling systems, and telehealth platforms must meet WCAG 2.1 AA by May 2026—or risk losing federal funding. Most healthcare sites aren't ready. Here's what's actually required and where to start.

By Axibly Team

HHS Section 504: What Healthcare Organizations Need to Know Before the 2026 Deadline

If your organization accepts Medicare, Medicaid, or any other federal healthcare funding, your patient-facing websites and mobile apps must comply with WCAG 2.1 Level AA accessibility standards by May 2026—or May 2027 for smaller organizations.

This isn't optional. The HHS Office for Civil Rights can investigate complaints, conduct compliance reviews without a complaint, and suspend federal funding for violations.

Here's what you need to know.

The Deadlines

The updated Section 504 rule took effect July 8, 2024. Compliance deadlines are based on organization size:

  • May 11, 2026: Organizations with 15 or more employees
  • May 10, 2027: Organizations with fewer than 15 employees

These dates apply to web content, mobile apps, patient portals, telehealth platforms, online scheduling systems, and self-service kiosks.

Who's Covered

Section 504 applies to any program or activity receiving federal financial assistance from HHS. In practice, this includes:

  • Hospitals and health systems
  • Clinics and physician practices
  • Mental health providers
  • Health insurers
  • Telehealth services
  • Any organization participating in Medicare, Medicaid, or CHIP

If you're unsure whether you're covered: if you accept federal healthcare funding in any form, assume you are.

What's Required

Your digital properties must conform to WCAG 2.1 Level A and Level AA success criteria. This technical standard—developed by the World Wide Web Consortium—covers four principles:

Perceivable: Information must be presentable in ways users can perceive. Images need alt text. Videos need captions. Color alone can't convey meaning.

Operable: Users must be able to navigate and use your interface. Everything accessible by mouse must work with a keyboard. Users need enough time to read and interact with content.

Understandable: Content and navigation must be predictable and readable. Error messages should explain what went wrong and how to fix it.

Robust: Content must work reliably across different browsers, devices, and assistive technologies like screen readers.

For healthcare specifically, this affects patient portals, appointment scheduling, bill pay, test results, intake forms, prescription refills, and telehealth interfaces. If a patient can't complete these tasks because your interface doesn't work with a screen reader or keyboard navigation, that's a compliance failure.

What's Exempt

The rule includes narrow exceptions:

  • Archived web content: Material retained only for reference that's clearly marked as archived and isn't updated
  • Pre-existing documents: PDFs, Word docs, and spreadsheets published before your compliance deadline—unless they're used to apply for, access, or participate in services
  • Third-party content: User-generated content like public comments (though your own interface must still be accessible)
  • Pre-existing social media posts: Content posted before your deadline

These exemptions are limited. If archived content gets used in an active workflow, it needs to be accessible. And critically, any document a patient needs to access care—forms, instructions, consent documents—must be accessible regardless of when it was created.

The Enforcement Reality

HHS isn't just setting requirements—they're creating enforcement mechanisms:

  • OCR can investigate complaints filed by individuals
  • OCR can conduct compliance reviews proactively, without a complaint
  • Violations can result in suspended or terminated federal funding
  • Cases can be referred to the Department of Justice

Meanwhile, private lawsuits under the ADA continue to rise. Healthcare organizations have faced class actions over inaccessible patient portals and hospital websites. In 2024, over 4,000 web accessibility lawsuits were filed in federal courts, with healthcare among the most-targeted industries outside of e-commerce.

The combination of federal enforcement authority and private litigation creates significant risk.

Why Most Healthcare Sites Aren't Ready

Research consistently shows the majority of healthcare websites have significant accessibility problems. Common issues include:

  • Missing or inadequate alt text for images
  • Forms that don't work with keyboard navigation
  • Poor color contrast making text unreadable
  • Missing labels on form fields
  • Videos without captions
  • PDFs that screen readers can't interpret
  • Error messages that don't explain what's wrong

Many of these issues exist because accessibility wasn't considered during initial development. Fixing them requires systematic auditing and remediation—not a quick overlay solution.

A Practical Approach

Healthcare organizations typically have 6-12 month procurement and development cycles. With May 2026 approaching, the time to act is now.

1. Inventory your digital assets

Map everything patient-facing: main website, patient portal, mobile apps, telehealth platform, appointment scheduling, bill pay, intake forms, and any PDFs or documents patients need. Include third-party tools—you're responsible for accessibility of services provided through vendors.

2. Run an initial audit

Start with automated scanning to identify the scope of issues. Tools can detect many WCAG violations—missing alt text, color contrast failures, missing form labels, keyboard traps. This gives you a baseline.

Automated tools catch real problems, but they can't catch everything. They won't tell you if alt text is actually descriptive, if a form makes sense to a screen reader user, or if the tab order is logical. Plan for manual testing with actual assistive technologies.

3. Prioritize by patient impact

Focus first on workflows that affect access to care:

  • Appointment scheduling
  • Patient portal login and navigation
  • Test results and medical records
  • Prescription refills
  • Bill pay and financial assistance applications
  • Telehealth session access

An inaccessible appointment scheduler can directly prevent someone from receiving care. Fix those paths first.

4. Address your vendor relationships

Review contracts with third-party providers. Your patient portal vendor, telehealth platform, and scheduling software all need to meet WCAG 2.1 AA. Include accessibility requirements in RFPs and contract renewals. Request conformance documentation.

5. Build ongoing processes

Accessibility isn't a one-time project. New content gets published, features get updated, vendors release new versions. Build accessibility checks into your design, development, and content workflows. Train the teams who publish content.

How to Start Testing Today

You can run a WCAG compliance scan on any page in under a minute using browser-based tools. This won't catch everything, but it identifies concrete issues you can start fixing immediately.

Axibly is a free Chrome extension that scans for WCAG 2.1 AA violations and shows you exactly where problems occur on the page. No account required, no data leaves your browser. Install it, navigate to your patient portal, and run a scan.

Look at what comes back. Missing alt text, color contrast failures, form labeling issues—these are things your team can start addressing now while you plan the broader compliance effort.

The Bigger Picture

Accessibility requirements exist because 61 million Americans live with disabilities. For healthcare organizations, this isn't an abstract population—these are your patients. A visually impaired patient who can't access their test results online. A patient with motor impairments who can't navigate your appointment scheduler. A deaf patient who can't use your telehealth platform because there's no captioning.

The 2026 deadline creates urgency, but the underlying obligation is simpler: patients with disabilities deserve equal access to healthcare services. The organizations that treat accessibility as a core part of patient experience—not just a compliance checkbox—will be better positioned for whatever comes next.

Have questions about healthcare accessibility compliance? Contact us or try Axibly free to scan your patient-facing pages today.