On May 7, 2026, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) issued an Interim Final Rule (IFR) extending, for one year, the compliance deadlines for recipients of HHS funding (such as community health centers and Head Start agencies) to meet certain accessibility requirements for web content, mobile applications and related technologies under Section 504 of the Rehabilitation Act of 1973 (Section 504).

Under the revised timeline:

• Recipients with 15 or more employees will now have until May 11, 2027
• Recipients with fewer than 15 employees will now have until May 10, 2028

The rule applies to web content, websites, mobile applications, and certain medical kiosks and self-service technologies used by individuals accessing health care or social services.

OCR stated that the extension was issued in response to concerns that many covered entities would not be able to meet the original deadlines for compliance with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standards. HHS also noted that the extension is intended to make Section 504 requirements more consistent with the Department of Justice’s parallel rulemaking under Title II of the Americans with Disabilities Act for entities subject to both laws.

The Interim Final Rule is open for comments through July 6, 2026.

For additional background on WCAG 2.1 Level AA compliance and what your organization may want to consider before the new deadlines, please refer to our prior client alert.

Possible Steps to Take

Organizations subject to Section 504 may wish to consider the following:

• Assess your organization’s compliance deadline based on employee headcount.
• Conduct an inventory of covered web content, including content or services provided through contracts or arrangements with third parties. Consider whether your organization’s:
  • Website include images, maps, or visual information inaccessible to screen readers
  • Videos include captions for individuals who are deaf or hard of hearing
  • Social media content is accessible
  • Patient-facing technologies, such as kiosks or insurance card scanners, provide accessible alternatives
• Determine if WCAG 2.1 Level AA-compliance will be addressed internally or through third parties, and whether existing agreements may need to be updated
• Identify who within the organization will be responsible for monitoring accessibility compliance and testing results
• Assess whether any exceptions under the Final Rule may apply and document those

Organizations should also keep in mind that, although these specific accessibility standards are new, Section 504 of the Rehabilitation Act and Section 1557 of the Affordable Care Act continue to require covered entities to provide effective communication, auxiliary aids and services, reasonable modifications where necessary to avoid discrimination, and equal access to programs and activities for individuals with disabilities.

Additional resources may be found at: Provider Obligations for Providers of Health Care and Social Services and Section 504 of the Rehabilitation Act of 1973.

If you have questions about how your organization can prepare for this rule, please contact Kathy Ghiladi.