This is the single most misunderstood point in healthcare web accessibility, and getting it wrong goes in both directions: practices that think they are exempt and are not, and practices being sold a deadline that does not apply to them.
The answer
Yes. Medicare Part B, on its own, is now enough to make a practice a recipient of federal financial assistance, and therefore subject to Section 504.
That was not true before. For decades HHS took the position that Part B was a payment for services rendered rather than federal financial assistance, which kept a great many ordinary physician practices outside these civil rights statutes entirely.
Where the change actually lives
Here is why competent people still get this wrong.
The change is not in the Section 504 web accessibility rule. Sit down with 45 CFR Part 84, the obvious document, the one titled to be about exactly this, and you will not find it.
It is in the Section 1557 final rule, Nondiscrimination in Health Programs and Activities, published May 6 2024 at 89 FR 37522. And the reversal there is not confined to Section 1557. It applies for purposes of Section 504, Title VI, Title IX, and the Age Discrimination Act as well.
So the trigger for one rule is defined inside a different rule. Anyone citing Part 84 to tell you Part B does not count is reading a real document and drawing the wrong conclusion from it.
Two other ways this goes stale:
- Anything written before May 2024 states the old position, correctly for its time.
- Summaries of the 1557 rule often focus on its gender-identity provisions, which drew most of the coverage and most of the litigation, and skip the federal-financial-assistance reversal entirely.
What it means in practice
If your practice bills Medicare Part B and nothing else federal, you are in scope. That means:
- The standard is WCAG 2.1 Level AA.
- The deadline is May 11 2027 with 15 or more employees, May 10 2028 with fewer.
- The documentation matters as much as the build: a published accessibility statement, a working feedback channel, and a remediation log.
The main Section 504 page covers what conformance involves in more detail.
Where it does not reach
A practice that takes no Medicare and no Medicaid is not a recipient, and Section 504 creates no obligation. Cash-pay-only practices, direct primary care without Medicare participation, and some concierge models fall here.
Two cautions on that. First, check at the NPI level rather than assuming. Practices are often participating in something a partner signed up for years ago. Cash-only chiropractic and non-Medicaid dentistry are the most common places we see people assume wrong in both directions. Second, being outside Section 504 does not mean being outside all risk: the duty to communicate effectively with patients who have disabilities arises elsewhere and is actionable now.
How much of this is settled
Less than anyone would like.
Parts of the 2024 rule have been stayed or enjoined in particular jurisdictions through separate litigation, so the picture is not uniform nationally. Separately, the one-year deadline extensions issued in spring 2026 are being challenged by the National Federation of the Blind, which sued DOJ and HHS in May 2026 asking a court to vacate them.
What is not in motion is the underlying obligation. Effective communication with patients who have disabilities has been required for years, entirely independent of any of this, and practices receive demand letters over inaccessible websites today without any reference to a 2027 date.
That is the honest case for building to the standard now: it is the only position that does not depend on predicting how the litigation lands.
This page is general information about federal rules and is not legal advice. Whether any particular practice is a recipient of federal financial assistance is a legal question about your facts. Ask your own counsel.
Related
- Section 504 web accessibility: the requirement in full
- Section 504 vs ADA Title II: two rules, two different deadlines