Does the Section 504 website rule apply to my practice?
If your practice is paid by Medicaid, CHIP or Medicare, including Part B, HHS treats you as receiving federal financial assistance, so the Section 504 website rule applies. Practices with 15 or more employees have until 11 May 2027, and smaller ones until 10 May 2028.
Written by the nextwebsite.co team, and last checked on November 9, 2026.
The short test
Section 504 of the Rehabilitation Act applies to programs and activities that receive federal financial assistance. For a healthcare provider, the question is whether any of your income comes from HHS programs. If it does, the rule's website requirements apply to you, and your deadline depends on how many people you employ1.
Which payments count
- Medicaid and CHIP. Providers who take part in Medicaid and the Children's Health Insurance Program are named as recipients in HHS's own summary of the rule2.
- Medicare Part A. Hospitals, nursing homes, home health agencies and hospices paid under Part A are recipients2.
- Medicare Part B. In 2024 HHS gave notice that it treats Part B payments as federal financial assistance for Section 504 and the other civil rights laws it enforces. That brings in most physician practices, therapists, chiropractors and other clinicians who bill Medicare3.
- Grants and other HHS funding, such as community health center grants, count too2.
HHS's reading of Part B changed in 2024 and could be revisited. If Part B is your only federal income, check the current position with your counsel before you rely on it either way.
What about dentists?
Medicare covers very little routine dental care, so most dental practices come under the rule through Medicaid or CHIP. If your practice sees Medicaid or CHIP patients, treat the rule as applying to you2.
Counting employees
The deadline depends on the number of employees, and the rule draws the line at fifteen1. Count everyone the practice employs: clinicians, front desk, billing and management, full-time and part-time. Contractors you don't employ aren't counted, but any website, booking or form they provide for you is still covered.
- 15 or more employees: from 11 May 2027.
- Fewer than 15 employees: from 10 May 2028.
Both dates were pushed back a year in May 20264.
If you're not sure
Write down which programs pay you and how many people you employ, and ask a healthcare compliance lawyer. If you're covered, the next step is to check your site, booking and forms against WCAG 2.1 AA. Our free check shows where you stand in about a minute.
This guide is general information, not legal advice.
Checklist
- List every HHS program that pays you: Medicaid, CHIP, Medicare Part A or Part B, and any grants.
- Count everyone the practice employs, full-time and part-time.
- Note your date: 11 May 2027 for 15 or more employees, 10 May 2028 for fewer.
- If Part B is your only federal income, check the current position with counsel.
Check your own site
The free scan checks your pages for the accessibility problems a machine can find, and marks the checks that need a person. It takes under a minute.
Or run just this check: the accessibility checker.
Read next
- Healthcare websites and the HHS Section 504 rule: the deadlines
Providers that take Medicare or Medicaid must make their websites meet WCAG 2.1 AA. The deadlines are May 2027 and May 2028.
- What Section 504 covers on a practice website: booking, forms, portals
The rule covers what patients use, including vendor booking, intake forms and portals. What's in scope, the five exceptions, and what to ask vendors.
- A Section 504 website checklist for practice managers
Seven steps to get a practice website, booking and forms ready for the Section 504 deadline, with a timeline back from 11 May 2027.
More on section 504 for healthcare, and what we build for medical practices, dental clinics and home health and hospice.