accessiBe - Section 504 Readiness A strategic checklist for healthcare organizations

Preparing for the Sec 504 deadline: May '26

For most HHS-funded healthcare organizations, the 2024 Section 504 Final Rule means that digital accessibility is no longer just a best practice — it's a legal requirement. Starting May 11, 2026, your websites, patient portals, scheduling tools, and other digital services need to be accessible to every patient. This checklist is designed to help you see where your organization stands today and what you'll need to focus on next.

How to use this checklist

Review your departments Look across compliance, IT, digital, operations, and procurement teams

Mark your progress Check off what’s done, what’s in the works, and what still needs a plan

Set your priorities Use these results to decide which documents to tackle first

01. Confirm your coverage

Confirm Section 504 applies to your organizationVerify that your organization receives federal financial assistance from HHS — including Medicare or Medicaid reimbursements — which brings you within Section 504’s scope

Identify your compliance deadlineOrganizations with 15 or more employees must meet WCAG 2.1 Level AA by May 11, 2026. Fewer than 15 employees: May 11, 2027.

Map every patient-facing digital propertyInclude your website, patient portal, scheduling tool, telehealth platform, bill pay system, mobile apps, kiosks, and any documents provided digitally

Include third-party vendor platformsDocument every platform provided to patients through a contractual or licensing arrangement. Under Section 504, you are responsible for these systems even if you don’t control the underlying code

Audit institutional noticesGather digital versions of official policies, handbooks, and campus announcements.

Categorize by usageSeparate active documents used daily from older files that are just kept for archives.

02. Assign responsibility

Name a designated responsible employeeDocument the individual responsible for overseeing Section 504 compliance. Required for organizations with 15 or more employees.

Establish grievance proceduresCreate a clear, documented process through which patients and staff can report digital accessibility barriers and receive a timely response. Required for organizations with 15 or more employees.

Assign cross-functional ownershipEnsure compliance, IT, digital, and procurement teams each understand their role — and that there is a single point of coordination across all of them

03. Prioritize by patient impact

Start with required workflowsIdentify the digital pathways patients must complete to access care — scheduling, portal login, intake forms, bill payment, telehealth access

Prioritize your patient portalIf patients rely on a portal to access records, communicate with providers, or manage their care, it is your highest concentration of Section 504 risk

Rank vendor platforms by patient impactPlatforms patients must use to receive care should be addressed before lower-traffic or optional tools

Flag inaccessible patient-facing documentsIdentify PDFs and digital documents patients receive as part of their care — discharge instructions, consent forms, financial statements — and prioritize those that are not properly tagged or text-based

04. Audit, document, and remediate

Conduct a WCAG 2.1 AA baseline auditCombine automated scanning with manual testing using assistive technologies — including screen readers and keyboard-only navigation — to get a complete picture of where your organization stands

Request a current VPAT/ACR from each vendorAsk every vendor providing a patient-facing platform for a current Accessibility Conformance Report

Build a remediation plan with owners and timelinesAssign a named owner to each identified issue and set realistic resolution timelines.

Review and update vendor contractsAdd explicit WCAG 2.1 AA conformance requirements, vendor-paid remediation clauses, and regression protection to all new agreements and renewals

05. Maintain your progress

Build accessibility review into your publishing processAny document, form, or page published to a patient-facing digital environment should be reviewed for accessibility before it goes live

Include accessibility in all future procurementEvery new vendor relationship should begin with WCAG 2.1 AA as a non-negotiable requirement — not an afterthought at renewal

Establish ongoing monitoring and re-testingNew content, new features, and vendor updates can introduce new barriers. Regular monitoring ensures your compliance posture doesn’t erode over time.

Train your teamEnsure that everyone responsible for creating content, managing vendors, and procuring technology understands their role in maintaining Section 504 compliance

A note on your path to compliance

Under Section 504, demonstrating a proactive and organized approach is key to managing legal risk. The HHS Office for Civil Rights (OCR) does not expect perfection — it expects evidence that your organization has identified existing barriers, prioritized the most impactful patient-facing systems, and established repeatable processes to address them. This checklist is a foundation for that strategy — helping you document your good-faith efforts as you work toward the May 2026 deadline.