Section 504 and Your Practice Website

What the rule requires, when it lands, and how to tell whether it reaches you.

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If your practice bills Medicare or Medicaid, your website has a federal accessibility standard attached to it and a date by which to meet it. This page lays out what that actually means, without the urgency theatre.

The short version

The rule. Section 504 of the Rehabilitation Act prohibits disability discrimination by recipients of federal financial assistance. In 2024 HHS issued a rule (45 CFR Part 84) applying that to web content and mobile apps, and naming a specific technical standard.

The standard. WCAG 2.1 Level AA. Not “accessible-ish”, but a published, testable specification.

The dates. May 11 2027 if you have 15 or more employees. May 10 2028 if you have fewer.

Who it reaches. Recipients of federal financial assistance. For most private practices that means Medicare or Medicaid billing. If you take neither, this rule is not about you.

How to tell whether it applies to you

Two questions, in this order.

1. Do you receive federal financial assistance? Medicaid participation has counted for decades. Medicare Part B now counts as well, following a reversal of HHS’s longstanding position. That change has its own page, because it is the one most often missed and most often explained wrongly.

If the answer is no, genuinely cash-pay only with no Medicare and no Medicaid, you can stop. This rule imposes nothing on you.

2. How many employees do you have? Fifteen or more puts you on the May 11 2027 date. Fewer puts you on May 10 2028. It counts employees, not providers, not locations, not patient volume.

What conformance actually involves

WCAG 2.1 AA is a long specification, but for a practice website the work concentrates in a few places:

  • Keyboard access. Everything reachable and operable without a mouse, with a visible focus indicator.
  • Contrast. Text at 4.5:1 against its background, and 3:1 for interface components. This is measurable, and it is where most sites fail.
  • Structure. Correct heading order, real labels on form fields, landmarks a screen reader can navigate.
  • Alternatives. Meaningful alt text on images that carry information, empty alt on images that are decoration.
  • Content that changes. Anything that moves, auto-plays, or updates needs to be controllable.

An accessibility overlay widget does not accomplish this. Overlays sit on top of the underlying markup and cannot repair a heading structure or a missing label. Several have been the subject of litigation themselves.

The part vendors skip: documentation

Conformance is the technical half. The other half is being able to show your work:

  • A published accessibility statement naming your conformance target and any known issues.
  • A feedback channel that reaches a real person, so someone who hits a barrier can report it.
  • A remediation log recording what was reported, what was done, and when.

That paper trail is what a regulator or a plaintiff’s attorney asks for, and it is what most website vendors do not provide. An accessible template is not the same as a documented practice.

About the deadline holding

In May 2026 the National Federation of the Blind sued DOJ and HHS in the District of Maryland, arguing the one-year extensions were issued without the required notice and comment and should be vacated. If the court agrees, earlier dates could come back.

Separately, some provisions of the 2024 HHS rule have been stayed or enjoined in particular jurisdictions through other litigation, so the picture is not uniform across every state.

None of that changes the practical advice. The underlying duty to communicate effectively with patients who have disabilities has been in force for years and never paused. Practices receive demand letters over inaccessible websites today, with no reference to any 2027 date. Building to the standard now is the position that holds regardless of how the litigation lands.

What we would tell you if you called

That the first question is whether the rule reaches you at all, and that we would rather answer that honestly than sell you a deadline you do not have. If it does reach you, that the work is a website built to WCAG 2.1 AA plus the documentation package, and that any vendor promising you “compliance” as a deliverable is describing something they cannot actually give you.

This page is general information about a federal rule. It is not legal advice, and it does not create a relationship of any kind. For a determination about your organisation, ask your own counsel.