Captions, alt text and accessible social posts and video ads for medical practices

A practice posts a short video of its new hygienist explaining what to expect at a first cleaning. Another runs a paid video ad for a new weight management program with music, quick cuts and the phone number shown only on screen. A third posts a flyer image for a flu shot clinic, with the dates and address written in the picture. Each one works for a viewer who can see and hear it. A patient who is deaf gets nothing from the hygienist video without captions, and a patient who uses a screen reader gets nothing from the flyer without a text alternative.

This guide covers social media posts and paid video and image ads: which federal accessibility rules reach them, what the rules say about posts on platforms you do not control, and what captions, alt text and motion settings to use. The practice website itself is covered in our guide to website accessibility for medical practices, the Section 1557 notices in our guide to Section 1557 website notices, what to do if a letter arrives in our guide to ADA website demand letters, and what to film and the patient consent rules in our guide to healthcare video marketing.

The short version

• If your practice receives federal financial assistance from HHS, the HHS Section 504 rule requires your web content to meet WCAG 2.1 Level A and AA, beginning May 11, 2027, with 15 or more employees and May 10, 2028, with fewer than 15 (45 CFR 84.84(b)).
• HHS says the posts a recipient puts on social media platforms are provided by the recipient and must conform to WCAG 2.1 Level AA, and that it is the recipient’s responsibility to use the platform’s caption and alt text features (89 Fed. Reg. 40134 to 40135).
• Posts made before your compliance date are excepted, and so is content posted by third parties, unless they post under an arrangement with you (45 CFR 84.85(c), (e)).
• A private practice is a public accommodation under ADA Title III, and open and closed captioning are on the regulation’s list of auxiliary aids (28 CFR 36.104, 36.303(b)(1)). DOJ has no detailed Title III web standard but says businesses must make what they offer online accessible.
• For video, WCAG 2.1 asks for captions on prerecorded video (1.2.2), captions on live video (1.2.4) and audio description of prerecorded video (1.2.5). For images, it asks for a text alternative (1.1.1).
• The rule text does not single out paid ads. We found no HHS or DOJ statement that excludes them, so we recommend treating each ad like any other post.

Which rule reaches your posts and ads

Four federal rules can apply to a practice’s online content, and which ones apply depends on who funds and runs the practice.

• HHS Section 504 rule (45 CFR part 84). Applies to recipients of HHS federal financial assistance. A recipient must make the web content and mobile apps it provides or makes available, directly or through contractual, licensing or other arrangements, conform to WCAG 2.1 Level A and AA, unless it can show a fundamental alteration or undue financial and administrative burdens (45 CFR 84.84(a), (b)). The compliance dates, as extended in May 2026, are May 11, 2027, for recipients with 15 or more employees and May 10, 2028, for recipients with fewer than 15 (45 CFR 84.84(b)(1), (2); 91 Fed. Reg. 25496).
• Section 1557 rule (45 CFR part 92). A covered entity must make health programs and activities provided through information and communication technology accessible to individuals with disabilities, unless that would be an undue burden or a fundamental alteration (45 CFR 92.204(a)). A recipient must make health programs and activities provided through websites and mobile apps comply with Section 504 as interpreted consistent with ADA Title II (45 CFR 92.204(b)). Section 92.204 is not on the later-date schedule in 45 CFR 92.1(b), so it took effect with the rule on July 5, 2024.
• DOJ Title II rule (28 CFR 35.200). Applies to public entities, such as a county clinic, a public hospital district or a state university practice. Web content and mobile apps must conform to WCAG 2.1 Level A and AA beginning April 26, 2027, for public entities with a total population of 50,000 or more, and April 26, 2028, for smaller public entities and special district governments (28 CFR 35.200(b); 91 Fed. Reg. 20902). An independent practice is not a public entity.
• ADA Title III. The professional office of a health care provider is a place of public accommodation (28 CFR 36.104). Title III treats as discrimination a failure to take the steps necessary to ensure that no individual with a disability is excluded or treated differently because of the absence of auxiliary aids and services, unless that would fundamentally alter what is offered or be an undue burden (42 USC 12182(b)(2)(A)(iii)). The regulation lists open and closed captioning, including real-time captioning, as auxiliary aids (28 CFR 36.303(b)(1)).

Whether your practice is a recipient of HHS financial assistance is a legal question. Our Section 1557 guide explains why HHS now treats Medicare Part B payments to providers as federal financial assistance, which can bring an independent practice into the 504 and 1557 rules.

What the rules say about social media posts

The rule text of 45 CFR 84.84 does not use the words social media. The definition does the work: web content means the information and sensory experience communicated to the user by means of a user agent, and the examples include text, images, sounds, videos, animations and conventional electronic documents (45 CFR 84.10). HHS explained in the preamble to the 2024 rule how that applies to platforms you do not control.

• The platform is not your responsibility. HHS says the rule does not require recipients to make social media platforms themselves conform to WCAG 2.1 Level AA, because the platforms are available to the public apart from any arrangement with a recipient (89 Fed. Reg. 40134 to 40135).
• Your posts are. HHS says that because the posts recipients put on those platforms are provided or made available by the recipients, they must conform to WCAG 2.1 Level AA (89 Fed. Reg. 40134 to 40135).
• Use the features the platform gives you. HHS says it is the recipient’s responsibility to use features such as captions and alt text when it puts web content on a social media platform, and gives the example of an image posted to a platform that allows alt text: the recipient needs to make sure appropriate alt text accompanies the image (89 Fed. Reg. 40135).

DOJ said the same about public entities in the preamble to the Title II rule, and added that social media posts posted after the compliance date are treated the same as all other web content (89 Fed. Reg. 31357, 31382).

Both rules list exceptions that matter for social accounts (45 CFR 84.85; 28 CFR 35.201):

• Preexisting social media posts. Posts made before the date you are required to comply are excepted (45 CFR 84.85(e)). Posts made on or after that date are not.
• Content posted by a third party. Content posted by someone else is excepted, unless the third party is posting due to contractual, licensing or other arrangements with you (45 CFR 84.85(c)). A patient’s comment under your post is third-party content. A video an agency or a paid creator posts for you under a contract is not.
• Archived web content. Content created before the compliance date, kept only for reference, research or recordkeeping, not altered or updated after it was archived, and stored in an area clearly identified as archived is excepted (45 CFR 84.10, 84.85(a)). A social feed that is still live and public is not an archive area in the sense of that definition.

These exceptions apply only where the 504 or Title II rule applies. A practice outside both rules is under ADA Title III, which has no social media exception because it has no detailed web rule at all.

Paid ads: the same rules, read carefully

Neither rule mentions paid advertising. The rules cover web content a recipient provides or makes available, directly or through contractual, licensing or other arrangements (45 CFR 84.84(a)), and the definition of web content includes images and videos (45 CFR 84.10). We found no statement by HHS or DOJ that excludes paid ads from that, and no statement that includes them by name. We recommend treating each ad your practice runs, including ones made and placed by an agency, as covered content: captions on each video with speech, a text alternative for each image ad where the platform allows one, and the key facts in text, not only inside the picture.

Ad formats add a practical issue: an image ad can carry the whole offer inside the picture, such as the price, the date and the phone number. A screen reader user gets none of it unless the same facts are in the ad text or the alt text. Our guide to Facebook and Instagram ads for medical practices covers the platform health policies that apply on top of accessibility.

Captions for video posts and video ads

WCAG 2.1 has a set of success criteria for time-based media. The ones that matter for practice video are these.

• 1.2.2 Captions (Prerecorded), Level A. Captions are provided for all prerecorded audio content in synchronized media. WCAG defines captions as a visual or text alternative for both speech and the non-speech audio needed to understand the content, including sound effects, music, speaker identification and location.
• 1.2.4 Captions (Live), Level AA. Captions are provided for all live audio content in synchronized media. This reaches a live question-and-answer session or a livestreamed open house. Our guide to livestreaming procedures on social media covers the consent side of live video.
• 1.2.3 Audio Description or Media Alternative (Prerecorded), Level A, and 1.2.5 Audio Description (Prerecorded), Level AA. At Level AA, audio description is provided for all prerecorded video content. If the important information is spoken in the main audio, such as a provider saying where the entrance is, there is less to describe.
• 1.2.1 Audio-only and Video-only (Prerecorded), Level A. A video with no audio track, such as a silent slideshow ad with music removed, needs either a text alternative or an audio track that presents the same information.

WCAG defines open captions as captions that cannot be turned off, such as captions burned into the video image, and closed captions as captions the viewer can turn on and off. Both are captions under the definition, and the ADA regulation lists both as auxiliary aids (28 CFR 36.303(b)(1)). No federal rule picks one over the other for social video. We recommend closed captions uploaded as a caption file where the platform accepts one, because the text stays readable at the viewer’s chosen size, and burned-in captions for formats where a caption file is not supported. Where you burn captions in, keep them clear of the platform’s own buttons and text overlays.

Platforms offer automatic captions. No federal rule says whether automatic captions alone are enough. We recommend reviewing and correcting them before a post goes live, with attention to drug names, procedure names, provider names and numbers, since an error in a dose, a date or a price changes the meaning.

Alt text for images and graphics

WCAG 2.1 Success Criterion 1.1.1 Non-text Content (Level A) says all non-text content presented to the user has a text alternative that serves the equivalent purpose, with listed exceptions such as pure decoration. On a practice account, that covers photos of the office, graphics announcing hours or a closure, infographics and image ads.

• Describe the purpose, not each detail. For a photo of the front desk in a post about new hours, the alt text can say who and what is shown in a sentence; the hours belong in the post text.
• Put text from the image into text. Success Criterion 1.4.5 Images of Text (Level AA) says text, not images of text, is used to convey information where the technology can do it, with exceptions for logos and essential presentation. If a flyer image carries a date, an address or a phone number, repeat it in the post text or the alt text.
• Charts and infographics need the numbers. A text alternative for a chart has to serve the equivalent purpose, so give the key figures and the source in the post text or a linked page.
• Check contrast. Success Criterion 1.4.3 Contrast (Minimum) (Level AA) asks for a contrast ratio of at least 4.5:1 for text and images of text, or 3:1 for large text. Text that is part of a logo has no contrast requirement.
• Do not rely on color. Success Criterion 1.4.1 Use of Color (Level A) says color is not the only visual means of conveying information. A graphic that marks open days in green and closed days in red needs words too.

Motion, flashing and sound

Short-form video and animated ads bring motion rules into play. Success Criterion 2.3.1 Three Flashes or Below Threshold (Level A) says web pages do not contain anything that flashes more than three times in any one-second period, unless the flash is below the general flash and red flash thresholds. WCAG notes that content failing this criterion can interfere with use of the whole page. We recommend removing strobe effects and fast flashing transitions from practice videos and ads altogether, since the platform cannot stop them once they play.

Two more criteria apply where you control the player, such as a video embedded on your own website or landing page. Success Criterion 2.2.2 Pause, Stop, Hide (Level A) asks for a way to pause, stop or hide moving content that starts automatically, lasts more than five seconds and runs alongside other content. Success Criterion 1.4.2 Audio Control (Level A) asks that audio playing automatically for more than 3 seconds can be paused or stopped, or its volume controlled separately.

When a post brings in a patient

Accessibility does not end at the post. Under the Section 1557 rule, a covered entity must make communications with individuals with disabilities as effective as communications with others, and provide appropriate auxiliary aids and services free of charge, in accessible formats, in a timely manner and in a way that protects the individual’s privacy and independence (45 CFR 92.202(a), (b)). Title III has a parallel duty for public accommodations (28 CFR 36.303(c)(1)).

No federal rule says what an ad’s call to action has to offer. We recommend that any ad or post that asks people to call also gives a way to book or ask a question without a voice call, such as an online form or a text line, and that the landing page it sends people to meets the same standard as the rest of your site.

Questions to ask your agency or social media manager

• Do you add captions to each video with speech, and who reviews automatic captions before posting?
• Do you write alt text for each image post and image ad on platforms that allow it?
• Where does the text in our graphics also appear as text in the post?
• Do you check contrast on graphics and remove flashing effects from video?
• For live sessions, how will captions be provided?
• Does our contract say the content you post for us meets WCAG 2.1 Level A and AA, and who fixes it if it does not?
• Do you keep a dated record of posts, so we can tell which ones came before our compliance date?

Use and avoid

• Use: edited captions on each video post, reel, story and video ad with speech.
• Use: alt text that states the purpose of the image, and the key facts repeated in the post text.
• Use: a booking or question option that does not need a voice call.
• Use: a dated content log that shows when each post went live.
• Avoid: a flyer image as the only place a date, address, price or phone number appears.
• Avoid: unreviewed automatic captions on clinical content.
• Avoid: strobe effects and rapid flashing transitions.
• Avoid: treating an agency’s posts as third-party content; content posted under your contract is yours under the rules.

An illustration

This example is invented. [Practice name], a family practice with 22 employees that bills Medicare Part B, runs a social account and a small paid campaign for a new evening clinic. Its agency produces three short videos with music and on-screen text but no captions, and two image ads with the clinic hours written in the picture. The practice manager reads the HHS 504 rule and notes the May 11, 2027, compliance date for recipients with 15 or more employees.

Before the campaign runs, the practice asks the agency to add caption files to each video, correct the automatic captions where they misread a provider’s name, add alt text to both image ads and repeat the hours and the address in the ad text. One video uses a flashing transition; the agency replaces it. The ads link to a booking page with an online form as well as the phone number. The agency contract is amended to say the content it posts for the practice meets WCAG 2.1 Level A and AA, and the practice starts a dated log of posts. Older posts stay up; the practice decides with its attorney which ones are still used to promote current services and should be updated.

Checklist

• Ask your attorney whether your practice is an HHS recipient, a public entity or neither, and note your compliance date.
• Caption each prerecorded video with speech, and review automatic captions before posting.
• Plan captions for live video before you go live.
• Add alt text to each image post and image ad where the platform allows it.
• Repeat dates, addresses, prices and phone numbers from images in the post text.
• Check text contrast in graphics and do not use color as the only signal.
• Remove strobe and rapid flashing effects.
• Give a non-voice way to respond in each ad and post that asks people to call.
• Put accessibility in your agency and creator contracts.
• Keep a dated log of posts and ads.

How we help

We build websites, local and organic search, Google Ads and lead generation and an AI front desk for independent practices. For social posts and video ads, that means captions and alt text written into each piece of content before it runs, key facts in text as well as in the image, and landing pages built to the same WCAG 2.1 level as your site. Our tools are built with HIPAA in mind. We confirm in writing what a BAA covers before any patient information flows through a tool, and if it is not covered, we do not route patient information through it. We are not a healthcare provider and we do not give legal or medical advice. For the wider rules, see our healthcare marketing rules guide.

Sources

• 45 CFR 84.84: Requirements for web and mobile accessibility (HHS Section 504 rule)
• 45 CFR 84.85: Exceptions
• 45 CFR 84.10: Definitions
• HHS, Section 504 final rule, 89 Fed. Reg. 40066 (May 9, 2024)
• HHS, Extension of compliance dates, 91 Fed. Reg. 25496 (May 11, 2026)
• 45 CFR 92.1: Purpose and effective date (Section 1557 rule)
• 45 CFR 92.202: Effective communication for individuals with disabilities
• 45 CFR 92.204: Accessibility of information and communication technology
• 28 CFR 35.200: Requirements for web and mobile accessibility (ADA Title II)
• 28 CFR 35.201: Exceptions
• DOJ, Title II web and mobile accessibility final rule, 89 Fed. Reg. 31320 (April 24, 2024)
• DOJ, Extension of compliance dates, 91 Fed. Reg. 20902 (April 20, 2026)
• 42 USC 12182: Prohibition of discrimination by public accommodations (ADA Title III)
• 28 CFR 36.104: Definitions (place of public accommodation)
• 28 CFR 36.303: Auxiliary aids and services
• DOJ, Guidance on Web Accessibility and the ADA
• W3C, Web Content Accessibility Guidelines (WCAG) 2.1

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