HHS Extended the Section 504 Web Deadlines: A Healthcare Action Plan

The current HHS compliance dates

HHS extended the specific WCAG 2.1 Level AA deadlines for covered web content and mobile apps by one year. Under 45 CFR 84.84, the dates are May 11, 2027 for recipients with 15 or more employees and May 10, 2028 for recipients with fewer than 15 employees.

Correction, September 11, 2026: This article previously said HHS had not extended the deadlines. That was incorrect. HHS announced its separate extension on May 7, 2026. The underlying duty to make web content and mobile apps accessible remains in effect.

The DOJ's Title II extension and the HHS extension are separate rules. Title II uses the public entity's population and special-district status; HHS uses the recipient's employee count. A public hospital or university may need to assess both. Use the deadline comparison and HHS rule guide to keep those tests separate.

Start with your patient journeys

Build an inventory around what patients need to accomplish, then identify the systems that deliver each task. For example, an appointment journey may begin on a public information page, continue in a third-party scheduler, and end in a confirmation email. Reviewing only the first page misses most of the journey.

Include appointment scheduling, intake, patient portal sign-in, test results, bill payment, prescription requests, telehealth entry, and the documents people need to use those services. Record who controls each component and how changes reach production. This is a suggested planning inventory, not a claim that every listed feature appears on your site.

Define the audit before asking for quotes

Ask each provider to identify the target WCAG version and level, included templates, complete processes, mobile apps, document types, authenticated areas, and third-party services. Have them state which assistive technologies and browsers they will use, how findings will be reproduced, and whether retesting is included.

W3C's conformance evaluation guidance explains how evaluation scope and representative sampling support a structured review. Our audit process guide translates that into questions for a supplier. A preliminary scan can find some detectable issues, but it cannot establish that all patient journeys are accessible.

Turn findings into assigned work

For each finding, record the affected journey, reproduction steps, user impact, responsible team, proposed fix, and retest status. Group shared component defects so one change can be checked across all affected templates. Keep content issues, application changes, and vendor escalation in the same inventory so none disappears between teams.

Prioritize barriers that block a person from completing an essential task. An inaccessible booking control can prevent access to care even if a scanner reports fewer errors on that page than elsewhere. Use the keyboard accessibility guide and PDF accessibility guide when scoping those parts of the work.

Make the remaining time useful

Set milestones for inventory, audit, remediation, vendor follow-up, and independent retesting. Keep evidence of the tested version and date. Add checks to content publishing and software releases so a corrected component is not replaced by an inaccessible version later.

The extension is a planning window, not an accessibility exemption. If you need a starting point, request a preliminary accessibility review, then agree on the scope of any fuller manual evaluation. This article is educational and does not constitute legal advice.