Center on Disability strongly supports disability organizations’ statement opposing the delay of Section 504 compliance deadlines

May 19, 2026

On May 18, the American Association of People with Disabilities (AAPD) and other leading disability and civil rights organizations signed a statement (see below) expressing their opposition to the US Department of Health and Human Services delaying the Section 504 web and mobile accessibility compliance deadlines. The Center on Disability strongly concurs with the statement and its conclusion that this action reduces access to health care for people with disabilities.

Leading Disability Organizations: Delaying Section 504 Compliance is Unacceptable

AAPD Press Release, May 18, 2026

WASHINGTON, DC — AAPD and the undersigned disability and civil rights organizations are profoundly disappointed in the Department of Health and Human Services’ (HHS) Interim Final Rule (IFR) that makes changes to the 2024 Section 504 Rehabilitation Act regulations preventing disability discrimination in healthcare and human services. 

The IFR extends the compliance deadlines for accessibility requirements related to web content, mobile applications, and certain electronic systems used by health and human service providers receiving federal funding. Delaying these timelines is unacceptable and will reduce access to health care for people with disabilities. 

In 1973, Congress passed Section 504 of the Rehabilitation Act, prohibiting discrimination against people with disabilities by entities or programs that receive federal funding. In 2024, HHS updated its regulations under Section 504 for the first time in fifty years to require accessibility and prohibit discrimination in healthcare and human services.

This regulation did not establish a new obligation to make digital health content accessible. Rather, it clarified and detailed how covered entities should act in order to comply with this existing obligation. In doing so, it created clarity and transparency for all parties, increasing accessibility while simultaneously reducing liability risk. 

The initial compliance deadline was May 11, 2026 for entities with 15 or more employees. Such entities may include hospitals, Medicaid providers, nursing homes, state and local government departments, or childcare centers. For smaller entities like vaccination centers, small clinics, or family health centers with fewer than 15 employees, the initial compliance deadline was May 10, 2027. 

On May 7, 2026, HHS issued an IFR extending this deadline to May 11, 2027 for entities with 15 or more employees and May 10, 2028 for entities with fewer than 15 employees. This follows a similar use of the interim final rule process by DOJ to bypass standard rulemaking procedures. On April 20th, 2026, the Department of Justice similarly issued a last-minute delay to the compliance deadline for the Title II web accessibility rule. 

To justify issuing the IFR, HHS primarily relied on comments from various healthcare entities — including some anonymous commenters — arguing that compliance with accessibility standards would require additional time, impose significant costs, and involve the use of external vendors. However, these entities have had decades to make their services accessible, as digital accessibility obligations, whether for state and local government or in healthcare, are not new under either the Rehabilitation Act or the Americans with Disabilities Act.

HHS also claimed it has not recently received input from the disability community or advocacy organizations regarding the 2024 regulation’s accessibility requirements. This assertion is incorrect and does not reflect the record. The rulemaking process for the 2024 regulation received hundreds of comments from people with disabilities, advocacy organizations, and service providers. Many of these comments directly addressed barriers in websites, patient portals, mobile applications, telehealth platforms, electronic communications, and physical kiosks — systems that people with disabilities use every day to access healthcare and human services.

HHS’s claim also ignores the extensive input submitted in connection with the Title II web accessibility regulation, which informs and closely parallels the approach taken by HHS. In addition, the Web Content Accessibility Guidelines (WCAG) — the standard adopted in the rule — was developed through years of input from people with disabilities, advocacy organizations, and technical experts. It reflects well-established, widely accepted practices for making digital content accessible. Taken together, this record makes clear that HHS has in fact received substantial and meaningful input from the disability community.

The delay also creates confusion for entities actively working to meet the original deadline and increases the costs associated with accessibility remediation. Most importantly, the delay prolongs the barriers that people with disabilities face in accessing healthcare and human services that are federally funded through programs like Medicaid and Medicare. It will exclude people with disabilities from accessing a wide range of essential digital tools and platforms. For example, many individuals with disabilities will be unable to use healthcare provider websites to locate services, review treatment options, schedule appointments, complete intake forms, or access medical records. It will also undermine their ability to independently and privately use online mental health platforms that provide therapy, counseling, and crisis support.

Beyond web-based services, the delay affects physical kiosks and electronic systems commonly used in healthcare settings. As a result of the extended deadline, many people with disabilities will continue to face barriers when using check-in kiosks at hospitals and clinics. Yet, while HHS acknowledged that extending the compliance timelines may adversely affect people with disabilities, it nonetheless suggests that concerns about potential litigation outweigh the urgent access needs and civil rights of individuals with disabilities.  

The IFR further signals HHS’s intent to make substantial revisions to the Section 504 regulation in the future. Such efforts could take us backward when it comes to advancing and protecting the rights of people with disabilities to obtain equal and accessible healthcare. 

The 2024 regulation was developed through extensive input from organizations and advocates. By contrast, HHS is using the IFR process to implement these changes immediately upon publication before meaningful notice-and-comment engagement with impacted communities can occur. Many of our organizations requested meetings with the Office of Management and Budget (OMB) about this rule, but were declined because OMB had already concluded review. 

When taking these events together, we do not agree that the administration has good cause for issuing the IFR. This approach undermines the integrity of the rulemaking process and deprives disabled constituents of the opportunity to meaningfully raise concerns and objections. It also creates instability within the regulatory environment, which causes hesitation and delay by those to whom these rules apply, blocking further progress.

We strongly oppose these changes and urge that HHS withdraw the IFR and restore the original compliance deadlines. If the Administration wants to make changes to rules, it should use the notice-and-comment process, in order to hear from impacted communities.

To see the full list of organizations that signed the statement, see the AAPD press release.