Did HHS extend its Section 504 web/mobile deadlines like DOJ did for Title II?

No. HHS has NOT issued an extension. The HHS Section 504 web/mobile accessibility rule (May 2024) still requires compliance by May 11, 2026 for recipients with 15+ employees and May 10, 2027 for those with fewer than 15. DOJ's April 2026 Interim Final Rule (91 Fed. Reg. 20902) only extended ADA Title II deadlines.

Who is covered by HHS Section 504?

Any program or activity that receives federal financial assistance from HHS — including most U.S. hospitals (Medicare/Medicaid recipients), federally qualified health centers, community health clinics, mental health and substance use programs, and many educational institutions that receive HHS grants. The web/mobile rule covers their public-facing websites and patient-portal apps.

What is the technical standard under HHS Section 504?

WCAG 2.1 Level AA — the same technical standard the DOJ codified for ADA Title II. HHS aligned its standard with DOJ's in the 2024 rules, even though the underlying statutes (Section 504 of the Rehabilitation Act vs. ADA Title II) and enforcement bodies differ.

How is Section 504 different from the ADA?

Section 504 of the Rehabilitation Act of 1973 prohibits disability discrimination by recipients of federal financial assistance — a contractual condition. The ADA is broader civil rights legislation, with Title II covering state/local government and Title III covering private public accommodations regardless of federal funding. Many healthcare providers are subject to both.

HHS Section 504 Web Accessibility Rule

HHS issued a parallel web/mobile accessibility rule in May 2024 under Section 504 of the Rehabilitation Act, requiring recipients of HHS funding to meet WCAG 2.1 Level AA. Compliance is due May 11, 2026 for entities with 15+ employees and May 10, 2027 for those with fewer than 15. HHS has NOT matched the DOJ Title II extension — these dates stand as of May 2026.

Who has to comply?

Any program or activity that receives federal financial assistance from HHS. In practice, that includes:

Most U.S. hospitals (Medicare and Medicaid are HHS programs)
Federally qualified health centers and community health clinics
Mental health, behavioral health, and substance use treatment programs
State Medicaid agencies
Public health departments
Educational institutions receiving HHS research or training grants
Long-term care facilities accepting federal reimbursement

Technical standard: WCAG 2.1 Level AA

The same WCAG 2.1 Level AA standard the DOJ codified for Title II — 50 success criteria across the POUR principles. See the WCAG 2.1 AA breakdown for what conformance actually requires.

HHS Section 504 deadlines

Entity size	Deadline	Extended?
Recipients with 15+ employees	May 11, 2026	No
Recipients with under 15 employees	May 10, 2027	No

Official source: hhs.gov — Section 504 · full plain-English breakdown

FAQ

Did HHS extend its Section 504 web/mobile deadlines like DOJ did for Title II?: No. HHS has NOT issued an extension. The HHS Section 504 web/mobile accessibility rule (May 2024) still requires compliance by May 11, 2026 for recipients with 15+ employees and May 10, 2027 for those with fewer than 15. DOJ's April 2026 Interim Final Rule (91 Fed. Reg. 20902) only extended ADA Title II deadlines.
Who is covered by HHS Section 504?: Any program or activity that receives federal financial assistance from HHS — including most U.S. hospitals (Medicare/Medicaid recipients), federally qualified health centers, community health clinics, mental health and substance use programs, and many educational institutions that receive HHS grants. The web/mobile rule covers their public-facing websites and patient-portal apps.
What is the technical standard under HHS Section 504?: WCAG 2.1 Level AA — the same technical standard the DOJ codified for ADA Title II. HHS aligned its standard with DOJ's in the 2024 rules, even though the underlying statutes (Section 504 of the Rehabilitation Act vs. ADA Title II) and enforcement bodies differ.
How is Section 504 different from the ADA?: Section 504 of the Rehabilitation Act of 1973 prohibits disability discrimination by recipients of federal financial assistance — a contractual condition. The ADA is broader civil rights legislation, with Title II covering state/local government and Title III covering private public accommodations regardless of federal funding. Many healthcare providers are subject to both.