A Section 504 website checklist for practice managers

Who this is for

Practice managers, administrators and compliance leads at providers that take Medicare or Medicaid, who have been asked to get the website ready for the Section 504 deadline. The current dates are 11 May 2027 for providers with 15 or more employees and 10 May 2028 for smaller ones¹.

1. Confirm you're covered, and count your employees

Write down which HHS programs pay you and how many people you employ. Medicaid, CHIP and Medicare Part A bring you in, and HHS treats Medicare Part B as federal financial assistance too². Our guide does Section 504 apply to my practice? goes through it.

2. List everything patients use

The rule covers what you provide through vendors as well as your own pages¹. List the website, online booking, intake and registration forms, bill pay, the portal and any telehealth or chat tool, with the vendor for each.

3. Check each one against WCAG 2.1 AA

Run an automated check on every page, then have a person try the important journeys with only a keyboard and with a screen reader: finding a location, booking, and filling in the intake form. Automated tools find only about 57% of accessibility issues³. Meeting WCAG 2.2 AA covers 2.1 AA⁴.

4. Ask your vendors

For each vendor, ask whether their product meets WCAG 2.1 AA, for their accessibility conformance report, and how fast they fix reported problems. Keep the answers.

5. Fix or rebuild

If the problems are in a few pages, fix them. If they're in the templates, the page builder or the forms, a rebuild is usually faster and lasts longer. Replace PDF intake forms with accessible web forms where you can. Don't rely on an overlay widget: the FTC has acted against one vendor for claiming its tool could make any site comply with WCAG⁵.

6. Publish an accessibility statement

One page that says which standard you aim for, how patients can report a problem, and how quickly you'll respond.

7. Keep a dated record

What was tested, when, how, what was found and what was fixed, plus each vendor's answers. It's what you'll show your administrator, and anyone who asks.

A timeline back from May 2027

• Now to January: steps 1 to 4.
• February: choose who does the work, and agree a launch date with time to spare.
• March and April: build, test and fix.
• Early May: publish the statement and file the record.

Smaller practices have until 10 May 2028, and can follow the same steps at a calmer pace¹. The dates have moved once already⁶, so check them again before you rely on them. Our free check is a quick way to start step 3.

This guide is general information, not legal advice.