Understanding Section 504 and What It Means for Healthcare Website Accessibility

Section 504 of the Rehabilitation Act is a federal civil rights law that prohibits discrimination based on disability in programs or activities that receive federal funding. For healthcare organizations, this includes ensuring patients and users can access digital experiences such as websites, applications, patient portals, and other online tools. 

Recent 2026 industry data shows that 90% of healthcare organizations reviewed had no visible accessibility solution in place, despite already being subject to Section 504 requirements. This gap highlights why clearer guidance and practical planning are becoming increasingly important.  

In May 2024, the U.S. Department of Health and Human Services finalized updates to Section 504 that clearly define digital accessibility expectations for healthcare organizations. These requirements take effect May 11, 2026, meaning healthcare and HME organizations that receive federal funding are now expected to ensure their websites and digital tools are accessible. OCR is already accepting complaints, and enforcement does not wait for intent or awareness. Most organizations won’t realize there’s an issue until a complaint arrives. The ones who get through enforcement are the ones with a documented accessibility plan, not a perfect website. 

Healthcare organizations looking to build a stronger foundation around this topic may also find it helpful to explore VGM Forbin’s broader resources on website accessibility and how accessibility fits into modern digital experiences. 

What Is Section 504? 

Section 504 was established to ensure individuals with disabilities are not excluded from or denied benefits of programs or services that receive federal financial assistance. While this has long applied to physical spaces, the recent updates formally extend these protections to digital environments. 

This means healthcare organizations must consider accessibility not only in their facilities, but also in how patients, caregivers, and referral partners access information and services online. 

Who Does Section 504 Apply To? 

Section 504 applies to healthcare organizations that receive federal funding, directly or indirectly. This includes many hospitals, clinics, private practices, long‑term care organizations, and HME providers that participate in Medicare, Medicaid, or other federally funded programs. 

If your organization receives federal financial assistance, Section 504 digital accessibility requirements likely apply to your website and online tools. 

What Digital Accessibility Means for Healthcare Websites 

Under the updated Section 504 rule, covered digital content is expected to align with Web Content Accessibility Guidelines (WCAG) 2.1 Level A and AA. These standards help ensure websites and applications are usable by individuals who rely on assistive technologies such as screen readers, keyboard navigation, or voice commands. 

For healthcare websites, accessibility considerations commonly include: 

• Page structure and navigation 

• Online forms and patient intake tools 

• Images, videos, and downloadable content 

• Appointment scheduling and patient portals 

The goal is to create digital healthcare experiences that are perceivable, operable, understandable, and robust for all users. 

Why Section 504 Matters to Healthcare Organizations 

Healthcare delivery continues to rely heavily on digital tools to communicate, educate, and serve patients. When those tools are not accessible, individuals with disabilities may encounter barriers to care, information, or services. 

The updated Section 504 regulations reinforce that digital accessibility is part of equitable healthcare delivery, not an optional enhancement. Addressing accessibility also supports better user experiences, trust, and long‑term digital sustainability across healthcare organizations. 

Learn More in Our Free Healthcare Accessibility Webinar 

With updated Section 504 digital accessibility requirements taking effect May 11, 2026, many healthcare and HMEs are seeking clarity on what these changes mean and how to prepare in a practical, realistic way. 

To support this need, VGM Forbin is partnering with accessiBe for a live, healthcare‑focused webinar on May 6. This session is designed specifically for healthcare and HMEs audiences who want a better understanding of digital accessibility requirements and how they apply to real‑world websites, patient portals, and online tools. 

Join Cassi Price of VGM Forbin and Josh Basile, Esq. of accessiBe as they discuss: 

• What Section 504 requires from healthcare organizations 

• How digital accessibility fits into compliance and patient access 

• Common website accessibility challenges healthcare organizations face 

• What organizations should be thinking about now ahead of the 2026 deadline 

This webinar is an educational insight to help healthcare organizations move forward with greater confidence. 

Looking for Next Steps for Your Website? 

Recent data shows many healthcare organizations still have accessibility gaps under the new Section 504 WCAG 2.1 Level AA standards. For organizations that want a clearer picture of where their website currently stands, an accessibility audit can be a practical first step. 

VGM Forbin’s Accessibility Audit helps identify potential accessibility issues and outlines plan options tailored to your business, so you can take informed, realistic steps toward compliance without needing a perfect website on day one. 
Secure Your Free Accessibility Audit 

Section 504 Digital Accessibility FAQs 

Q: What is Section 504 of the Rehabilitation Act? 

Section 504 is a federal law that prohibits disability‑based discrimination in programs or activities that receive federal financial assistance, including digital services such as websites and online tools. 

Q: When do Section 504 digital accessibility requirements take effect? 

The updated digital accessibility requirements take effect May 11, 2026 for most healthcare organizations. 

Q: Does Section 504 apply to healthcare websites? 

Yes. The updated regulations clarify that websites, mobile apps, and other digital tools used by healthcare organizations must meet accessibility standards. 

Q: What accessibility standard is required under Section 504? 

The regulations reference WCAG 2.1 Level A and AA, which outline technical accessibility standards for digital content. 

Q: Do HME providers need to comply with Section 504? 

If an HME provider receives federal funding, including Medicare or Medicaid reimbursement, Section 504 requirements may apply to their digital experiences. 

Q: Is this legal advice? 

No. This content is provided for educational purposes only. Healthcare organizations should consult qualified legal or compliance professionals for guidance specific to their situation. 
 
VGM Forbin is partnering with accessiBe to continue the conversation during a free, live healthcare‑focused webinar on May 6. Recent 2026 data shows that 84.3% of healthcare websites reviewed still had measurable accessibility failures under the new Section 504 WCAG 2.1 Level AA standards, highlighting why clarity and planning are so important right now.  
 
Save your spot today by registering for the webinar.