Website Accessibility for Medical Practices: Section 504 and WCAG 2.1 AA

Why this matters to medical practices

Patients increasingly use digital services to find a location, request an appointment, complete forms, read instructions, review documents and interact with a practice. When a page, control or document cannot be used by a person with a disability, the barrier can prevent that patient from reaching the same information or service available to others.

Accessibility is therefore more than a visual-design preference. For organizations covered by HHS’s Section 504 rule, it is part of providing meaningful access to applicable health and human services programs and activities. For any practice, it can also improve the reliability and usability of patient-facing technology.

Who does Section 504 apply to?

The HHS Section 504 rule applies to health and human services programs or activities that receive federal financial assistance from HHS. HHS materials identify federally funded health programs and other forms of HHS assistance as examples, but a generic fact about a practice is not enough to make a definitive coverage determination.

A practice should identify the federal financial assistance it receives, the program or activity involved and the organizational entity that receives it. Where the answer is unclear, qualified legal or compliance advisers should confirm the practice’s regulatory status. This article addresses the HHS Section 504 requirement; it is not a general ADA analysis.

The current requirement and compliance dates

Covered recipients must make applicable web content and mobile applications conform to the Web Content Accessibility Guidelines (WCAG) 2.1, Levels A and AA—commonly referred to as WCAG 2.1 AA. HHS extended the original deadlines by one year on May 7, 2026.

The current regulatory deadlines are May 11, 2027 for recipients with 15 or more employees and May 10, 2028 for recipients with fewer than 15 employees. Practices should plan from these current dates while confirming how the rule’s definitions, scope and specific exceptions apply to their own content and services.

What WCAG 2.1 AA means in practice

WCAG organizes accessibility around four principles. Content should be perceivable so users can obtain the information; operable so users can navigate and use controls; understandable so information and interactions are clear; and robust so content works reliably with browsers and assistive technologies.

A practical technical review may include the following examples. This is not an exhaustive WCAG checklist or a determination that every item is handled the same way in every situation:

• Provide meaningful alternative text for important images and other non-text content.
• Make navigation, buttons, menus and other controls usable from a keyboard without requiring a mouse.
• Use adequate color contrast and avoid relying on color alone to communicate meaning.
• Label form fields and controls programmatically, and present validation or error messages in an understandable way.
• Use a logical heading structure and meaningful page titles so content is easier to navigate.
• Provide captions or transcripts where appropriate for patient-facing audio and video.
• Make covered downloadable documents accessible rather than assuming a PDF or office file is usable by assistive technology.

Your website is more than the home page

The review should follow the patient’s digital journey, not stop after checking a few marketing pages. Applicable scope may include public website pages, appointment or request forms, patient-facing online forms, mobile applications, downloadable instructions and documents, embedded third-party components and other patient-facing digital content.

HHS’s rule includes specific definitions and exceptions. A practice should not assume that every archived file, password-protected area or third-party component is automatically included or automatically excluded. The facts and the rule should be reviewed together, with technical findings separated from legal scope decisions.

Third-party software does not automatically solve the problem

A scheduling tool, patient form, map, chat feature or payment component may be supplied by another company, but patients still encounter it as part of the practice’s digital experience. Practices should evaluate important third-party components, understand available accessibility information and include accessibility in selection, configuration and vendor follow-up.

An accessibility widget or overlay is not a substitute for building and maintaining accessible content and functionality. A tool may assist with a narrow task, but it does not by itself correct every issue in page structure, keyboard interaction, forms, documents or third-party workflows.

Accessibility is an ongoing process

A website that passes a review can develop new barriers when a plugin changes, a form is replaced, a staff member uploads an inaccessible document or a redesign introduces a new control. Accessibility should be part of publishing, development, procurement and routine maintenance—not a one-time project completed just before a deadline.

A sustainable approach assigns ownership, trains the people who publish content, combines automated checks with human review, tests important interactions with keyboards and assistive technologies where appropriate, records remediation and rechecks the site after material changes.

How GO InfoTek can help

GO InfoTek can assist with evaluating the technical accessibility of websites under its management, identifying common technical deficiencies, coordinating remediation with developers and designers, and helping implement accessible forms, navigation, structure and content presentation. Accessibility considerations can also be incorporated into ongoing website maintenance.

That work supports the practice’s technical remediation process. GO InfoTek does not certify legal compliance or determine whether Section 504 applies to a particular organization; those decisions remain with the practice and its qualified legal or compliance advisers.