HHS's section 504 regulations at 45 CFR part 84 apply to programs and activities conducted by recipients of Federal financial assistance, and an interim final rule published May 11, 2026 extended the web content and mobile app compliance dates to May 11, 2027 for recipients with 15 or more employees and May 10, 2028 for those with fewer than 15. This page is for compliance officers, executives and boards at hospitals, clinics, social service providers and other organizations that may be recipients. Integral Healthcare Solutions (IHS) drafts the accessibility policy set, self-assessment, vendor contract language and training plan for your compliance officer and counsel to review and approve, and your organization adopts and runs the program.
Last reviewed: October 2026.
What is the HHS Section 504 rule for recipients of HHS funds?
It is the Department of Health and Human Services' revision of its section 504 regulations at 45 CFR part 84, in the final rule of May 9, 2024 (89 FR 40066). The interim final rule that followed says recipients include "health care providers of all sizes, ranging from large hospital systems to small local clinics" (Federal Register document 2026-09266, page opened October 6, 2026).
Subpart I, Web, Mobile, and Kiosk Accessibility, adopted WCAG 2.1 Level AA success criteria as the technical standard for web content and mobile apps. Under 45 CFR 84.84(a), a recipient "shall ensure that" web content and mobile apps it provides or makes available "directly or through contractual, licensing, or other arrangements" are "readily accessible to and usable by individuals with disabilities" (Cornell LII copy, page opened October 6, 2026).
What are the web content and mobile app compliance dates?
The interim final rule, effective May 7, 2026, says "The compliance date for recipients with fifteen (15) or more employees is extended from May 11, 2026, to May 11, 2027." It also says "The compliance date for recipients with fewer than fifteen (15) employees is extended from May 10, 2027, to May 10, 2028." (Federal Register document 2026-09266, and the public inspection PDF, pages opened October 6, 2026).
Both dates are in the future as of October 6, 2026. The interim final rule asked for comments through July 6, 2026, and a Federal Register search on October 6, 2026 found no later HHS final rule on this subject. IHS has not read any follow-on action, so your counsel watches for changes.
What else does part 84 require besides web content?
Under 45 CFR 84.7, a recipient that employs 15 or more persons "shall designate at least one person to coordinate its efforts to comply with this part" and "shall adopt grievance procedures that incorporate appropriate due process standards and that provide for the prompt and equitable resolution of complaints". Under 45 CFR 84.8, a recipient must make information about the part and its applicability to its programs available to employees, applicants, participants, beneficiaries and other interested persons.
Subpart J, Accessible Medical Equipment, covers medical diagnostic equipment (MDE). Under 45 CFR 84.92(a), MDE that recipients purchase, lease or otherwise acquire after the date stated in that paragraph must meet the Standards for Accessible MDE until the scoping requirement in paragraph (b) is satisfied. Under paragraph (b)(1), where a program uses MDE, at least 10 percent of the total units, "but no fewer than one unit, of each type of equipment in use", must meet them. Under 45 CFR 84.94, recipients "must ensure their staff are able to successfully operate accessible MDE, assist with transfers and positioning of individuals with disabilities, and carry out the program access obligation regarding existing MDE". The medical equipment sections carry their own dates, which are not the web content dates above. For example, 45 CFR 84.92(c), as published in the May 9, 2024 final rule (89 FR 40066, page opened October 6, 2026), says "Within 2 years after July 8, 2024" for examination tables and weight scales. IHS has not read whether any later action changed those dates, and your counsel confirms them.
Who needs a Section 504 compliance program, and what triggers it?
Organizations that may be recipients are the buyers, and your counsel decides whether the regulation applies to you. Points that prompt a review with your counsel, in IHS's reading as of October 2026:
- You provide or make available web content or a mobile app, directly or through a vendor, and your counsel is placing you under one of the two dates.
- You employ 15 or more persons and are building the coordinator role and grievance procedures that 45 CFR 84.7 describes.
- Your programs use medical diagnostic equipment and you are reading 45 CFR 84.92 through 84.94 with your counsel, including the dates those sections carry.
How IHS helps with a Section 504 compliance program
IHS offers process expertise. IHS drafts the program, policies and clinical content for your compliance officer, clinicians and counsel to review and approve, and your organization adopts and runs it.
- Read the text with you, meaning 45 CFR 84.7, 84.8, 84.84 and 84.92 through 84.94, with your counsel's scoping decisions.
- Assess the gaps between that text and your current accessibility, grievance, notice, vendor and equipment documents.
- Map each section to the policy, record or vendor term that supports it, including a self-assessment your staff complete.
- Draft the accessibility policy set, the coordinator role and grievance procedure, the notice, vendor contract language and the training plan.
- Run a mock review of the draft set against the text.
- Support readiness while your counsel and leadership revise and adopt the documents.
What you supply: your counsel's scoping decisions, your current policies, your list of web content, apps, vendors and equipment.
The limit: technical website and mobile app remediation is outside the offer. IHS does not test, repair or rebuild websites or apps, and your web developer or accessibility vendor does that work. IHS does not decide whether the rule applies to you, how your employees are counted, or whether an undue burden position holds. IHS does not contact HHS Office for Civil Rights or any agency, and your organization submits anything it chooses to submit. See also compliance services and compliance program development.
What to have ready
This is IHS's planning list, built from the government texts named above.
- Your counsel's written decision on whether your organization is a recipient and how its employees are counted for 45 CFR 84.7 and 84.84(b).
- Which date, May 11, 2027 or May 10, 2028, your counsel places you under for web content and mobile apps.
- Your designated coordinator's name and your current grievance procedure, if 45 CFR 84.7 applies to you.
- Any notice you already make available about part 84, for 45 CFR 84.8.
- A list of the web content and mobile apps you provide or make available, including those a vendor runs for you.
- The vendor and license agreements behind those platforms, for the "contractual, licensing, or other arrangements" language in 45 CFR 84.84(a).
- Accessibility testing reports from your technical vendor.
- A list of your medical diagnostic equipment by type, count and facility, for 45 CFR 84.92 and 84.93.
- Staff training records on operating accessible equipment, transfers and positioning, for 45 CFR 84.94.
Printable version of this checklist (PDF)
Bring what you have to the free introductory call.
How it compares
| Job | What it covers | Who does it |
|---|---|---|
| Policy and governance work | Accessibility policies, coordinator and grievance procedures, notice, vendor contract language, equipment and training plans | IHS drafts, and your organization adopts and runs |
| Technical website and app remediation | Testing and fixing web content and mobile apps against WCAG 2.1 Level AA | A web developer or accessibility vendor, outside the IHS offer |
| Legal counsel | Whether the rule applies, how employees are counted, fundamental alteration and undue burden positions | Your counsel |
IHS has a separate page on Section 1557 nondiscrimination compliance, which is a different program with its own governing text.
What it costs
The Federal Register rule and the regulation text IHS opened state no fee payable to HHS. Verify current requirements with HHS Office for Civil Rights. IHS scopes each engagement after a free introductory call.
What this is not
- IHS is a consulting firm, not a law firm, and this page is not legal advice. IHS gives no opinion on whether the rule applies to your organization, how employees are counted, or whether an undue burden claim holds. Those questions belong to your counsel.
- It is not website or mobile app remediation. IHS does not test, fix or rebuild digital content.
- IHS does not contact or speak for your organization to HHS or any agency.
Frequently asked questions
What is the HHS Section 504 rule for recipients and who is covered?
It is HHS's revision of its section 504 regulations at 45 CFR part 84, which apply to programs and activities conducted by recipients of Federal financial assistance. The interim final rule lists State and local governments, social service providers, post-secondary institutions and health care providers of all sizes among recipients. Whether your organization is a recipient is a question for your counsel.
What is the new web content and mobile app compliance date?
It is May 11, 2027 for recipients with 15 or more employees and May 10, 2028 for recipients with fewer than 15, according to the interim final rule effective May 7, 2026. These two dates address web content and mobile apps.
Did the deadline pass?
No. As of October 6, 2026 both dates, May 11, 2027 and May 10, 2028, are in the future. The interim final rule asked for comments, and a Federal Register search on October 6, 2026 found no later HHS final rule on this subject. Your counsel watches for changes.
What does a recipient have to do besides web content?
The regulation text IHS opened includes a coordinator and grievance procedures (45 CFR 84.7), information about the part (45 CFR 84.8), and medical diagnostic equipment obligations (45 CFR 84.92 through 84.94). Your counsel confirms which apply to you and when.
What does fifteen or more employees turn on?
Both 45 CFR 84.84(b) and 45 CFR 84.7 set requirements by employee count, 15 or more versus fewer than 15. How employees are counted is a question for your counsel, and IHS gives no opinion on it.
What about vendors and third party platforms?
Section 84.84(a) covers web content and mobile apps a recipient provides or makes available "directly or through contractual, licensing, or other arrangements". IHS's reading, October 2026: that places vendor and license terms inside the program, and your counsel confirms how it reaches your vendors. IHS drafts vendor contract language for your counsel and compliance officer to review and approve.
What is the fundamental alteration or undue burden exception?
Section 84.84(b) applies its requirements "unless the recipient can demonstrate that compliance with this section would result in a fundamental alteration in the nature of a program or activity or in undue financial and administrative burdens". IHS gives no opinion on whether any such position holds, and that belongs to your counsel.
What goes into a Section 504 compliance program?
IHS's planning list, which is not a government requirement list, includes an accessibility policy set, a coordinator role and grievance procedure, a notice, a self-assessment, vendor contract language, a medical equipment access policy and a training plan. IHS drafts these for your counsel to review and approve.
How is this different from Section 1557 compliance?
They are separate programs with their own governing text. This page covers the section 504 regulations at 45 CFR part 84, and IHS has a separate page on Section 1557 nondiscrimination compliance. Your counsel decides which rules apply to your organization.
Does IHS fix websites?
No. Technical website and mobile app remediation is outside the IHS offer. IHS drafts the policies, self-assessment, vendor contract language and training plan, and your web developer or accessibility vendor tests and fixes the sites and apps.