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

Recipients of HHS funding must make their web content and mobile apps accessible. HHS extended the specific WCAG 2.1 Level AA compliance dates to May 11, 2027 for recipients with 15 or more employees and May 10, 2028 for smaller recipients. 45 CFR 84.84 sets these requirements.

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	Status
Recipients with 15+ employees	May 11, 2027	Upcoming — extended by HHS
Recipients with under 15 employees	May 10, 2028	Upcoming — extended by HHS

Official source: 45 CFR 84.84 — current requirements · full plain-English breakdown

FAQ

Did HHS extend its Section 504 web/mobile deadlines like DOJ did for Title II?: Yes. HHS issued its own May 2026 interim final rule. The WCAG 2.1 AA compliance dates are May 11, 2027 for recipients with 15 or more employees and May 10, 2028 for recipients with fewer than 15. The underlying accessibility obligations remain in effect. See 45 CFR 84.84.
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.