Summary
- The deadline for a new Department of Health and Human Services (HHS) web and mobile accessibility compliance rule has been extended, but is still approaching. Any practice with 15 or more employees must comply by May 2027, and any with fewer than 15 employees has until May 2028.
- If you’re a healthcare organization that receives federal funding through HHS, such as Medicare or Medicaid, your digital communication must be accessible to individuals with disabilities.
- The regulation includes websites, patient portals, telehealth platforms, mobile applications, and any other digital tools patients rely on to access care.
- The risk of noncompliance is a loss of funding or even a lawsuit.
Whether you’re a healthcare startup or a small practice owner, there are endless competing demands for your time and resources. A recently extended deadline for website accessibility compliance needs to be pushed up the priority list.
“The final rule extension makes clear that, even though there’s been a one-year extension on these deadlines from HHS, the legal obligation isn’t changing –– there’s still a requirement that websites are accessible to people with disabilities,” says Libby Addington, president of Gecko Agency, a marketing agency that designs websites following ADA best practices.
What Is the HHS Section 504 Final Rule for Healthcare Websites?
The Rehabilitation Act prohibits discrimination against individuals with disabilities by any organization that receives federal funds, such as Medicaid. The HHS Section 504 Final Rule under the Rehabilitation Act of 1973 clarifies that accessibility obligations extend to digital spaces, such as your website.
The benchmark for most organizations’ websites is the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standard, says Addington.
Why ADA Website Accessibility Matters for Healthcare Practices
Patients rely on healthcare websites to find providers, make an appointment, complete forms, access patient portals, download instructions, prepare for procedures and more. “Patients are interacting with their healthcare website at high volume, so it makes total sense that this is an area under scrutiny,” says Addington.
When those digital tools are inaccessible, patients with disabilities may encounter barriers to care or to obtaining critical information.
For Gecko, building sites that people with disabilities can navigate is a basic standard for every website –– even when there’s no issue of equitable patient access. “As people who live and breathe all things websites, we feel like it’s the right thing to do. The provision of information is essential to any website that we create, and if people can’t access it, then there’s no point,” says Addington.
How to Check Your Healthcare Website for ADA Accessibility Issues
Here’s a basic litmus test for whether your website is accessible:
- If you close your eyes, can you navigate your site using just the keyboard? Tab moves you between links and buttons, Enter activates them, and arrow keys let you move through menus and form options.
- Can you fill out forms using your keyboard?
- Is there a description of images that helps you visualize it, even with your eyes closed?
To help you fix your site, Andrew Rhyand, senior developer at Gecko, recommends starting with a free accessibility tool such as:
- Lighthouse
- WAVE
- axe
Automated scans provide a useful starting point, but they don’t identify every accessibility barrier. Rhyand estimates they catch about a third of a website’s accessibility issues.
How to Manually Test Your Healthcare Website for ADA Compliance
To catch other issues, you need a website developer to manually test how real users experience your site, including:
- Keyboard-only navigation
- Screen-reader usability
- Form accessibility
- Interactive elements
- Navigation menus
One simple test is to try to navigate the website using only your keyboard. “If you turned your mouse off, can you navigate with the keyboard and tab system from top to bottom on a page?” says Andrew Rhyand, senior developer at Gecko Agency.
For most sites, the answer is no.
6 Common ADA Accessibility Issues on Healthcare Websites
After designing dozens of healthcare websites, Addington and Rhyand have identified common issues that make sites inaccessible to people with vision impairments.
- Missing or ineffective image alt text
Alternative text allows screen readers to describe an image. Many organizations skip this crucial step by uploading an image without adding anything to the alt text box, or by providing only a basic, context-free description.
For example, an image labeled “doctor treating patient” describes what appears in the photo, but it doesn’t convey what the image is meant to communicate. Strong alt text describes the image in the context of the page it’s on, for instance, “pediatrician examining a child during a wellness visit” on a pediatric services page.
- Generic button labels
Buttons labeled “Click Here” or “Read More” make sense visually, but they often create confusion for screen-reader users.
More descriptive alternatives include:
- Schedule an appointment
- Download patient forms
- Contact our clinic
- View treatment options
- Improper heading structure
Screen readers rely on heading hierarchy, such as H1, H2 and H3, to understand how your pages are organized. Skipping headings or using them inconsistently causes users who rely on screen readers to struggle to navigate.
- Poor color contrast
Low contrast between text and background colors makes content difficult to read for users with low vision. For example:
- Light text on light backgrounds, such as light gray text on a white background
- Dark text on dark backgrounds, such as dark blue text on a black background
- Forms that rely only on color
Many forms indicate errors or missed fields by highlighting fields in red. Meanwhile, people who are colorblind can’t distinguish certain color differences. Instead, forms should include clear labels, written instructions and text error messages that identify issues without relying solely on color.
- Lack of ongoing accessibility monitoring
One of the biggest challenges is keeping websites compliant once they’re built. New images, pages, forms and content updates can unintentionally introduce accessibility barriers. “Any website built with a content management system by definition, gives control of our clients to be able to manage and change it. Any changes risk bringing the site out of compliance if they aren’t well-versed enough in website accessibility,” says Addington.
ADA Website Compliance Is an Ongoing Requirement, Not a One-Time Fix
It’s not uncommon for busy practice owners to treat their website like a final, published document. However, a website is dynamic and launching it is only the beginning (despite the work and funds that go into creating it).
Maintaining website accessibility requires following ADA compliance rules on every newly published page. Each update can potentially introduce new accessibility issues.
Addington recommends regularly auditing your website for accessibility by testing and remediating any issues.
H3: ADA healthcare website compliance checklist:
- Audit your website for ADA user experience with a free online platform
- Manually test keyboard navigation
- Review your website forms
- Add descriptive alt text to photos that convey information
- Indicate which are decorative images so screen readers skip them
- Fix the heading structure, such as H1, H2, H3
- Use best practices for ADA color contrast
- Consider doing quarterly accessibility reviews with a web developer familiar with the compliance requirements
- Consult legal or compliance experts if you’re unsure
Gecko Agency performs website accessibility audits to help identify issues that could negatively affect the patient experience. This article is intended for general informational purposes only and does not constitute legal advice. For guidance on your specific obligations and a fuller understanding of accessibility requirements, be sure to consult legal counsel or a qualified compliance professional.
Explore CM&F Group’s professional liability coverage options to help protect your practice as regulations and enforcement evolve.
Frequently Asked Questions
- What is the HHS Section 504 Final Rule for healthcare websites? The HHS Section 504 Final Rule clarifies that healthcare organizations receiving federal funding — such as Medicare or Medicaid — must make their digital tools accessible to individuals with disabilities. This includes websites, patient portals, telehealth platforms, and mobile applications. The compliance standard for most organizations is WCAG 2.1 Level AA.
- What is the deadline for ADA website accessibility compliance for healthcare practices? The HHS compliance deadline has been extended but remains firm: healthcare organizations with 15 or more employees must comply by May 2027, and those with fewer than 15 employees have until May 2028. The extension does not eliminate the legal obligation to make websites accessible.
- What are the most common ADA accessibility issues on healthcare websites? The most common issues include missing or ineffective image alt text, generic button labels like “Click Here,” improper heading structure (H1, H2, H3), poor color contrast between text and backgrounds, and forms that rely solely on color to indicate errors. Automated tools like WAVE or Lighthouse can identify some issues, but manual testing by a developer is also recommended.
