PDF and document remediation
Tagging, reading order, alt text, tables and fillable forms to PDF/UA and WCAG — from one file to 100,000+ pages.
Healthcare · Updated October 2026
HHS Section 504 rule: digital accessibility for healthcare
Hospitals, health systems, clinics, insurers and other recipients of HHS funding must make their websites, mobile apps, patient portals and documents meet WCAG 2.1 AA.
What the rule requires
On May 9, 2024, the Department of Health and Human Services published a final rule updating its regulations under Section 504 of the Rehabilitation Act of 1973 (45 CFR part 84). Subpart I adopts WCAG 2.1 Level AA as the technical standard for web content and mobile applications of any program or activity that receives HHS funding. The structure closely mirrors the DOJ’s ADA Title II rule, including similar exceptions.
Deadlines
| Recipient size | Original | Current (HHS interim final rule, May 7, 2026) |
|---|---|---|
| 15 or more employees | May 11, 2026 | May 11, 2027 |
| Fewer than 15 employees | May 10, 2027 | May 10, 2028 |
As with Title II, the National Federation of the Blind has challenged the extension in federal court (filed May 21, 2026). Until a court rules, the 2027 and 2028 dates apply.
Who is a “recipient”
Any entity that receives federal financial assistance from HHS — not just hospitals. Depending on how they are funded, that commonly includes:
- hospitals and health systems,
- federally qualified health centers and community clinics,
- state Medicaid and public health agencies,
- health plans and insurers participating in HHS-funded programs,
- nursing homes, home health agencies and behavioral health providers,
- medical schools and research institutions with HHS grants (such as NIH).
If you’re not sure whether your organization is covered, ask counsel; the answer depends on the specific funding you receive.
High-risk content in healthcare
- Patient portals: login, appointment booking, test results, secure messaging.
- Forms: intake, consent, financial assistance, records requests — often PDFs that can’t be filled with a screen reader.
- Billing: statements, price transparency files and payment pages.
- Notices: nondiscrimination notices, privacy practices, language access taglines.
- Telehealth: video platforms, waiting rooms and chat.
- Health education: patient handouts, videos without captions, infographics without text alternatives.
Working with protected health information
Remediating patient documents means handling PHI. We sign Business Associate Agreements, can work inside your environment, and prioritize fixing templates so every future statement or letter is accessible automatically — instead of remediating documents one patient at a time.
Getting ready
- Inventory your public site, portal, apps and every vendor platform you offer to patients.
- Audit against WCAG 2.1 AA, starting with scheduling, portal login, payments and forms.
- Fix your PDF form library or replace forms with accessible web forms.
- Add accessibility requirements to vendor contracts and renewals.
- Train communications and patient-education staff to produce accessible documents.
Frequently asked questions
When do HHS-funded organizations need to comply?
May 11, 2027 for recipients with 15 or more employees, and May 10, 2028 for recipients with fewer than 15 employees. HHS set these dates in an interim final rule on May 7, 2026, extending the original 2026 and 2027 deadlines by one year.
Does the rule cover patient portals and third-party apps?
Yes. It covers web content and mobile apps that a recipient provides or makes available, directly or through contractual, licensing or other arrangements. If you offer a vendor’s patient portal, scheduling tool or telehealth app, it must conform.
Are patient bills and statements covered?
Documents posted on your website or apps are covered. Individualized, password-protected documents (like one patient’s statement) have a limited exception, but they must be made accessible promptly on request — and many organizations find it simpler to make the templates accessible.
Find out where you stand, in writing.
Send us a few URLs or sample PDFs. Within two business days you get a free, plain-English snapshot of your biggest accessibility risks and what it takes to fix them.