In May 2024, the U.S. Department of Health and Human Services (HHS) updated section 504 of the Rehabilitation Act. The rule, titled “Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance,”1 established, in part, enforceable standards requiring healthcare providers and organizations (collectively “healthcare providers”) to ensure individuals with disabilities had access to:
- Exam tables and weight scales, and
- Websites, mobile apps, and kiosks
The rule applies broadly to healthcare providers receiving federal financial assistance, including, but not limited to, hospitals, medical and dental offices, and individual healthcare providers.
HHS estimates that 92 percent of doctors, 43 percent of dentists, and all hospitals receive federal financial assistance and, therefore, are required to comply with the rule.2
Compliance Deadlines3
- Accessible exam table and weight scale requirements:
- July 8, 2026
- Accessible web, mobile app, and kiosk requirements:
- May 11, 2027: Healthcare providers with more than 15 employees
- May 10, 2028: Healthcare providers with less than 15 employees
NOTE: On May 11, 2026, HHS published an Interim Final Rule delaying the web and mobile app accessibility compliance deadlines for entities receiving federal financial assistance. The new deadlines were extended by one year to May 11, 2027, for entities with more than 15 employees and May 10, 2028, for those with fewer than 15 employees.
Accessible Medical Diagnostic Equipment Requirements 4
Medical diagnostic equipment (MDE) must meet the following requirements:
Scope: HHS has mandated that all healthcare providers' offices, clinics, emergency rooms, hospitals, outpatient facilities, and multi-use facilities that use exam tables and weight scales have at least one weight scale and one exam table that meet the standards for accessible MDE.5
- Weight Scales: To ensure equitable care, at least one wheelchair-accessible scale is required, with platforms large enough to weigh patients while seated. If a standard wheelchair scale is not available, integrated alternatives—such as scales built into patient lifts, hospital beds, or exam tables—may be used. See specific accessible weight scale requirements at Access to Medical Care for Individuals with Mobility Disabilities.6
- Exam Tables: Fixed-height exam tables and chairs are often inaccessible for people with mobility disabilities. Adjustable-height exam tables are needed so patients can transfer safely from wheelchairs, especially when the table can be lowered. Support features, such as side rails or handles, are important for stability during transfers and exams. At least one accessible exam table is required and should be able to lower to the height of a wheelchair seat (17 to 19 inches from the floor) and include elements to stabilize and support a person during transfer. See specific accessible exam table requirements at Access to Medical Care for Individuals with Mobility Disabilities.7
Exceptions: This rule provides exceptions when compliance is proven by the healthcare provider to result in a fundamental alteration in the nature of a program or activity, or in undue financial and administrative burdens. Where an exception does exist, the healthcare provider must nevertheless ensure that individuals with disabilities receive the benefits or services provided by the healthcare provider.
Qualified Staff: Healthcare providers must also ensure their staff can successfully operate accessible MDE, assist with the transfer and positioning of individuals with disabilities, and fulfill the access obligations for existing MDE.8
Deadline: The deadline for accessible MDE is July 8, 2026. By then, facilities must have at least one accessible examination table and one accessible weight scale in place.
Accessible Web, Mobile App, and Kiosk Requirements 9
Scope: Section 504 requires that any patient-facing website content, mobile apps, or kiosks provided by a healthcare provider through contract, licensing, or other arrangements must be readily accessible to and usable by individuals with disabilities. This requires the following:
- Websites and Portals: Items such as patient portals, mobile apps, online scheduling, bill-pay systems, telehealth platforms, EHRs, and prescription refill forms must be accessible to disabled users and meet the Web Content Accessibility Guidelines (WCAG) 2.1 level AA standard.10 Providers cannot delegate this responsibility and must verify that vendors meet these legal requirements to avoid significant penalties.
- Kiosk: Any programs or activities provided through self-service transaction machines, such as registration, check-in, or form completion, must be accessible.
Exceptions: This rule provides exceptions for archived web content, preexisting conventional electronic documents, content posted by a third party, password-protected individualized documents, and preexisting social media posts where compliance would result in a fundamental alteration in the nature of a program or activity or in undue financial and administrative burdens. Where an exception does exist, the healthcare provider must nevertheless ensure that individuals with disabilities receive the benefits or services provided by the healthcare provider to the maximum extent possible.
Notwithstanding the May 2026 compliance extension for web, portal, and mobile app accessibility, healthcare providers have an ongoing obligation to ensure that their programs and activities using web content and mobile applications are accessible to individuals with disabilities in accordance with their other obligations under section 504.
Deadlines: The digital accessibility compliance deadlines are:
- May 11, 2027, for healthcare providers with more than 15 employees
- May 10, 2028, for healthcare providers with less than 15 employees
Conclusion
Accessible healthcare provider offices and clinics are critical to ensuring people with disabilities can receive proper medical care. When accessibility barriers exist, individuals with disabilities are less likely to obtain routine preventive care, increasing the risk that minor health issues go undetected and become serious or life‑threatening. Ensuring accessibility is both a legal requirement and a medical necessity that supports early diagnosis, timely treatment, and better health outcomes.
References
- U.S. Department of Health and Human Services. Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance. Fed Register. 2024;89(91): 40066–40195. Published May 9, 2024. Accessed April 26, 2026. https://www.govinfo.gov/content/pkg/FR-2024-05-09/pdf/2024-09237.pdf
- U.S. Department of Health and Human Services, Office for Civil Rights. Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance: Final Rule Regulatory Impact Analysis. 45 CFR Pt 84. Published May 9, 2024. Accessed April 26, 2026. https://www.hhs.gov/sites/default/files/sec-504-ria-final-rule-2024.pdf
- U.S. Department of Health and Human Services. Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility of Web Content and Mobile Applications of Recipients of Departmental Financial Assistance. Fed Register. Published May 11, 2026. Accessed May 13, 2026. https://www.federalregister.gov/documents/2026/05/11/2026-09266/extension-of-compliance-dates-for-nondiscrimination-on-the-basis-of-disability-accessibility-of-web
- 45 CFR Part 84 Subpart J—Accessible Medical Equipment. Ecfr.gov. Published 2026. Accessed April 26, 2026. https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-A/part-84/subpart-J?toc=1
- U.S. Access Board—About MDE. Accessed April 26, 2026. https://www.access-board.gov/mde/
- Access to Medical Care for Individuals with Mobility Disabilities. ADA.gov. Published April 21, 2026. Accessed April 26, 2026. https://www.ada.gov/resources/medical-care-mobility
- Id.
- U.S. Department of Health and Human Services. New Requirements for Accessible Medical Diagnostic Equipment. Accessed April 26, 2026. https://www.hhs.gov/sites/default/files/new-requirements-accessible-medical-diagnostic-equipment.pdf
- 45 CFR Part 84 Subpart I—Web, Mobile, and Kiosk Accessibility. Ecfr.gov. Published 2026. Accessed April 26, 2026. https://www.ecfr.gov/current/title-45/part-84/subpart-I
- Web Content Accessibility Guidelines (WCAG) 2.1. W3.org. Published June 5, 2018. Accessed April 26, 2026. https://www.w3.org/TR/2018/REC-WCAG21-20180605/. Web Content Accessibility Guidelines (WCAG) 2.1. Perma.cc. Published 2022. Accessed April 26, 2026. https://perma.cc/UB8A-GG2F
The guidelines suggested here are not rules, do not constitute legal advice, and do not ensure a successful outcome. The ultimate decision regarding the appropriateness of any treatment must be made by each healthcare provider considering the circumstances of the individual situation and in accordance with the laws of the jurisdiction in which the care is rendered.
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