Background image with text "Another Delay"

HHS Delays the Section 504 Web Accessibility Deadline

Three weeks ago, I warned that HHS was preparing to postpone the Section 504 web and mobile accessibility deadline.

Well, it happened. On May 7, HHS published an Interim Final Rule that extends the compliance deadline by one year. Recipients with 15 or more employees now have until May 11, 2027, while smaller recipients have until May 10, 2028.

What the Rule Does — and Doesn’t Do

The IFR covers recipients of HHS financial assistance, including hospitals, community health centers, clinics, and any other organization that accepts Medicare or Medicaid funding. It extends the deadline for conforming web content and mobile applications to WCAG 2.1 AA. HHS says it acted, in part, to align its timeline with DOJ’s parallel delay of the ADA Title II web accessibility rule.

That is the full scope of the rule. The broader Section 504 protections I discussed in April (e.g., prohibitions on denying medical treatment based on disability, requirements for accessible diagnostic equipment, and the mandate to serve people in integrated community settings rather than institutions) are untouched. Those provisions remain in force. Delaying them would have cost lives.

Justice Delayed is Still Justice Denied

This delay is frustrating, but it shouldn’t surprise anyone. Accessibility is already the lowest priority for most organizations, and digital accessibility is the lowest priority within accessibility. It’s the lowest of the low. It gets pushed aside first because most people — including most policymakers — don’t consider it essential. Instead, they view it as a convenience, something a person can work around by picking up the phone.

Web and mobile technology have eliminated many of the human touchpoints that people with disabilities used to rely on, leaving those who remain stretched thin. When a person with a disability asks a harried worker to compensate for an inaccessible system, the outcome is predictable: they receive worse service, become frustrated, and stop asking for service except when absolutely necessary.

In most cases, the telephone is the only viable alternative. When a website or app is inaccessible, calling is better than nothing. But it is a band-aid fix, and everyone knows it. The expectation is that vendors will make their technology accessible — or be replaced by competitors who do. Every extension of the compliance deadline lengthens the time the band-aid stays on and the underlying wound doesn’t heal.

What You Can Do

HHS has opened a 60-day comment period. Comments are due by July 6, 2026. If you want to be on record — whether as a patient, a provider, a person with a disability, or an organization that believes digital accessibility is not optional — now is the time.

Submit your comment at regulations.gov. Search for docket HHS-OCR-2026-0004 or RIN 0945-AA17. Be specific. Tell HHS what inaccessible web content and mobile apps actually cost people with disabilities in the healthcare system. Personal accounts carry weight. So do organizational ones.

Regardless of the new deadline, keep working. The obligation to make your web content and mobile apps accessible hasn’t changed. The date moved. The law didn’t.

Disclaimer: Nothing in this post should be interpreted as legal advice or as forming an attorney-client relationship. It is offered for educational purposes only. You should always contact a qualified attorney in your area to discuss your legal rights and responsibilities.

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