Patients with low vision, hearing loss, tremors or memory problems use practice websites like everyone else. If they cannot read your hours, use your booking form or find your phone number, they call someone else, or they cannot get care as easily as other patients.
There is also a legal side. The rules for practice websites come from two places: the Americans with Disabilities Act, enforced by the Department of Justice, and Section 504 of the Rehabilitation Act, which HHS updated in 2024 with specific website requirements and dates. This guide explains both in plain terms, with links to the sources at the end. If your practice has received a demand letter or a complaint about its website, see our guide to ADA website demand letters and lawsuits. Pop-ups and dialogs bring their own keyboard and focus problems, which we cover in pop-ups on a medical practice website. Captions, alt text and motion in social posts and video ads are covered in our guide to accessible social media posts and video ads. For PDFs and other downloadable files, including the document exceptions in the Section 504 rule, see our guide to accessible PDFs and patient documents.
This is general information, not legal advice. Which rules apply to your practice, and from when, depends on facts such as how the practice is funded and how many people it employs. Dates in this area have already changed once, so confirm the current version with your adviser.
The ADA and practice websites
Title III of the ADA covers businesses open to the public, which the law calls public accommodations. The statute’s list of public accommodations includes the “professional office of a health care provider” and hospitals. So a private practice is covered by Title III for the services it offers.
The Department of Justice published guidance on web accessibility and the ADA in March 2022. It says the Department has consistently taken the position that the ADA’s requirements apply to goods and services that public accommodations offer on the web. It also says businesses currently have flexibility in how they make their websites accessible, and points to existing technical standards, the Web Content Accessibility Guidelines (WCAG) and the federal Section 508 Standards, as helpful guidance. There is no separate federal regulation that sets a WCAG version for private businesses under Title III. That flexibility is about how, not whether: DOJ is clear that websites still have to be accessible.
Section 504: a specific standard and dates
Section 504 of the Rehabilitation Act applies to programs and activities that receive federal financial assistance. In May 2024, HHS published a final rule updating its Section 504 regulations (45 CFR part 84) for recipients of HHS financial assistance. Section 84.84 of that rule requires recipients to make their web content and mobile apps conform to WCAG 2.1 Level A and AA, unless they can show a fundamental alteration or undue financial and administrative burdens. It covers content provided directly or through contracts and other arrangements, which includes sites built and run by vendors.
The original compliance dates were May 11, 2026, for recipients with 15 or more employees and May 10, 2027, for recipients with fewer than 15. On May 7, 2026, HHS made an interim final rule effective that extends both by one year:
- 15 or more employees: May 11, 2027
- Fewer than 15 employees: May 10, 2028
HHS says the extension does not change the substantive requirements of the 2024 rule, including its scope. Whether your practice is a recipient of HHS financial assistance depends on your programs and payers, so that is a question for your adviser. The 2024 rule also says compliance is ongoing: content you add after the deadline has to meet the standard too.
Which WCAG version to aim for
WCAG is published by the W3C. The Section 504 rule names WCAG 2.1 Level AA. WCAG 2.2 became a W3C Recommendation on October 5, 2023. It adds nine success criteria, several of them directly relevant to patients using a practice site: larger click and tap targets, keyboard focus that is not hidden behind sticky headers, consistent placement of help such as your phone number, not asking people to re-enter information they already gave, and login steps that do not depend on memorizing or solving puzzles. It also removes one older criterion (4.1.1 Parsing).
A practical target for a new site is WCAG 2.2 AA, while checking against 2.1 AA as well wherever a rule names 2.1. The two are very close, and building to the newer version covers the barriers patients run into most.
Common barriers on practice websites
DOJ’s guidance lists barriers it sees across the web. On practice sites, these are the ones that come up most:
- Low color contrast: light gray text on a pale background, often in footers with hours and addresses. People with low vision cannot read it.
- Color as the only signal: “fields in red are required” or open and closed hours shown only by color.
- Images without text alternatives: provider photos, office photos and images of text (such as a flyer with your hours) that a screen reader cannot read.
- Videos without captions: procedure explainers and welcome videos.
- Forms that are hard to complete: fields without visible labels, no clear error messages, and booking widgets that cannot be used with a keyboard or screen reader.
- Mouse-only navigation: menus, sliders and pop-ups that cannot be reached or closed with a keyboard.
- PDF forms: scanned intake forms that a screen reader cannot read and that cannot be filled in on a phone.
Third-party tools count. The 504 rule covers content provided through contracts and other arrangements, and under the ADA patients experience your scheduling widget, chat tool or patient portal link as part of your site. Ask vendors for their own accessibility documentation and test the parts patients actually use.
Why an overlay widget is not the fix
Some products promise to make any website accessible or compliant by adding one line of code, usually a widget with a toolbar icon. In January 2025, the FTC announced an order requiring accessiBe, the maker of one such tool, to pay $1 million over claims that its AI-powered product could make any website compliant with WCAG; the FTC said those claims were false, misleading or unsubstantiated. The FTC approved the final order in April 2025. It bars the company from claiming its automated products can make any website WCAG-compliant unless it has evidence to support that.
The lesson for a practice is broader than one vendor. Accessibility comes from how the site is designed, written and built, and from testing by people. A widget cannot add missing labels to your booking form or captions to your videos.
A practical plan
- Test the patient paths firstFinding a location and hours, calling, booking or requesting an appointment, filling in forms, and reaching the portal. Try each with only a keyboard, and with a phone screen reader (VoiceOver or TalkBack).
- Run an automated check, then look by handFree checkers catch contrast, missing alt text and missing labels. They cannot judge whether alt text makes sense or whether a form is usable, so a person has to review too.
- Fix the templates, not just pagesOn WordPress, most barriers live in the theme, menus and form plugin. Fixing them once fixes every page that uses them.
- Replace PDFs with web forms or accessible documentsStart with the forms new patients need before the first visit.
- Check your vendorsAsk scheduling, chat, payment and portal vendors what WCAG level they meet and for documentation, and keep the answers on file.
- Publish a way to report barriersAn accessibility statement with a phone number and email, and a promise to help by phone in the meantime. Then keep checking as content changes.
How we approach it
We build practice websites to WCAG 2.2 AA as our working standard, test with tools and by hand, fix what we find, and do not rely on overlay widgets. We will not tell you a site is “ADA compliant”, because accessibility is ongoing work and no one can promise that. You can see how we handle it on our own site in our accessibility statement. Specialty sites have their own patterns, for example booking-heavy dental and med spa sites, and we test those flows in particular.
Frequently asked questions
Does the ADA apply to a medical practice website?
The ADA lists the professional office of a health care provider as a public accommodation, and the Department of Justice has said the ADA’s requirements apply to what public accommodations offer on the web. DOJ’s guidance gives businesses flexibility in how they make websites accessible and points to WCAG as helpful guidance.
What is the Section 504 website deadline for healthcare providers?
For recipients of HHS financial assistance, the 2024 Section 504 rule requires WCAG 2.1 Level AA for web content and mobile apps. After HHS’s interim final rule of May 7, 2026, the dates are May 11, 2027, for recipients with 15 or more employees and May 10, 2028, for those with fewer than 15. Check the Federal Register for any later changes.
Should we use WCAG 2.1 or WCAG 2.2?
The Section 504 rule names WCAG 2.1 AA. WCAG 2.2, published by the W3C in October 2023, adds nine criteria and removes one. Building to 2.2 AA while also checking 2.1 AA is a sensible target for a new practice site.
Will an accessibility widget make our site compliant?
No tool can promise that. The FTC ordered one overlay maker to pay $1 million in 2025 over claims that its AI product could make any website WCAG-compliant. Accessible design, content and testing are what make a site usable.
Are our scheduling and chat tools our responsibility?
The Section 504 rule covers web content a recipient provides directly or through contracts and other arrangements, and patients experience those tools as part of your site. Ask vendors for accessibility documentation and test the steps patients use.
Sources
- 42 U.S.C. 12181: ADA definitions, including public accommodations
- U.S. Department of Justice: Guidance on Web Accessibility and the ADA (March 18, 2022)
- HHS final rule: Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance (Federal Register, May 9, 2024), 45 CFR 84.84
- HHS interim final rule: Extension of Compliance Dates for web content and mobile app accessibility (effective May 7, 2026)
- W3C: What’s New in WCAG 2.2
- FTC: Order requires online marketer to pay $1 million for deceptive claims about its AI accessibility product (January 2025)
- FTC: Final order approved (April 2025)