Under a recent update to HHS rules, health care professionals, groups, hospitals, and facilities that receive federal funding from HHS must ensure that all their patient-facing technology is compliant with the Americans with Disabilities Act. ¹

The compliance deadline is May 11, 2026, for health care organizations with more than 15 employees. Organizations with less than 15 employees have until May 10, 2027, to comply. ²

The updated rule specifically requires that recommendations found in Web Content Accessibility Guidelines (WCAG) 2.1 become standard practice. ³ These compliance measures can include:

• providing alt text or descriptions for website images and graphics;
• adding captions to videos for individuals who are deaf or hard of hearing;
• offering non-visual digital maps for blind patients using screen readers; and
• using a telehealth platform that can offer a sign-language interpreter on a video call. ²

The rule's accessibility requirements extend beyond a provider's main website and mobile applications to include apps operated by third parties on a provider's behalf (such as an EHR vendor), as well as third-party tools like patient portals, appointment schedulers, bill pay portals, and telehealth platforms. ⁴

Self-service kiosks — used by patients to check in to appointments, record vital signs, or access other services — must also be fully accessible. Where kiosk accessibility cannot be achieved, providers must offer an alternative service that affords patients with disabilities the same level of access, confidentiality, and convenience. ⁴

Certain types of content are exempt from these requirements, including

• archived web content;
• preexisting conventional electronic documents;
• content posted independently by a third party (unless posted on behalf of the provider under a contractual or licensing arrangement);
• linked third-party web content;
• individualized password-protected documents; and
• preexisting social media posts. ⁴

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Notably, these rules may be waived for entities that can demonstrate the changes would fundamentally alter their operations or impose significant hardship. Failure to comply may result in investigation by the Office for Civil Rights (OCR), potential loss of federal funding, and increased legal risk. ⁴

Sources

1. U.S. Department of Health and Human Services. Civil Rights. Section 504 of the Rehabilitation Act of 1973. Last content reviewed January 7, 2025. Available at https://www.hhs.gov/civil-rights/for-individuals/disability/section-504-rehabilitation-act-of-1973/index.html. Accessed February 18, 2026.
2. Pierce A. HHS imposes first-time digital accessibility standards for patients with disabilities. Texas Medical Association. February 10, 2026. Available at https://www.texmed.org/Template.aspx?id=67217&utm_campaign=TMT&utm_medium=email&_hsenc=p2ANqtz--2WLkCe7WFYgWoXygpYoVvPLK8GG9XhnKjDBqrqOlMKtJDIFHiGIStK_0vR56jw7CqkHWrJFtnLydg6c36isUEcE4UEQ&_hsmi=403048415&utm_content=403048415&utm_source=hs_email. Accessed February 18, 2026.
3. Rivenburgh K. New HHS rule summary: Web and Mobile App Accessibility (WCAG 2.1 AA) required. Accessible.org. May 20, 2024. Available at https://accessible.org/hhs-web-accessibility-wcag-21-aa/#who-is-covered-by-the-new-hhs-rule. Accessed February 18, 2026.
4. White J. DiVarco SM. Kelley A. May 2026 deadline: HHS imposes accessibility standards for healthcare company websites, mobile apps, kiosks. McDermott Will & Schulte. January 8, 2026. Available at https://www.mwe.com/insights/may-2026-deadline-hhs-imposes-accessibility-standards-for-healthcare-company-websites-mobile-apps-kiosks/. Accessed February 18, 2026.

Additional resources

• Section 504 Fact Sheet, U.S. Department of Health and Human Services
• Web Content Accessibility Guidelines (WCAG) 2.1, World Wide Web Consortium
• The must-have WCAG checklist, Level access