What does the Section 504 website rule require?
In May 2024, the U.S. Department of Health and Human Services (HHS) updated its rules under Section 504 of the Rehabilitation Act. The update says that organizations getting HHS funding must make their websites and mobile apps accessible to people with disabilities.
The rule uses a specific technical standard: the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. WCAG is written by the World Wide Web Consortium (W3C). Level AA is the middle of three levels and the one most laws use. The rule names version 2.1, not the newer 2.2.
In everyday terms, someone who is blind, has low vision, is deaf or hard of hearing, or can't use a mouse should be able to learn about your building, read your PDFs, watch your videos and fill out your forms.
Does the rule apply to our nursing home?
Almost certainly. The rule covers "recipients" of HHS federal financial assistance. Medicaid and Medicare count, so nearly every skilled nursing facility is covered.
Employees, not beds. Which deadline you have depends on how many employees your organization has. The rule doesn't explain how to count across a group of buildings that each hold their own license, so ask your counsel if you're close to 15. Almost every nursing home is well over it.
Your vendor doesn't take it off your plate. The rule covers content you provide directly "or through contractual, licensing, or other arrangements." If your website company, tour scheduler or chat tool isn't accessible, that is still your building's problem.
Public buildings may have a second rule. County- or state-owned nursing homes may also fall under the Department of Justice's ADA Title II web rule, which has its own dates: April 26, 2027 for governments serving 50,000 people or more, and April 26, 2028 for smaller ones.
When is the Section 504 website deadline?
| Your organization | Original date | Current date |
|---|---|---|
| 15 or more employees | May 11, 2027 | |
| Fewer than 15 employees | May 10, 2028 |
HHS moved both dates back one year in an interim final rule published May 11, 2026. It changed only the dates. HHS said it may propose other changes later; if it does, we'll update this page. Be careful with older articles, and even HHS's own 2024 fact sheet: many still show the 2026 date.
A 2026 court judgment in Texas v. Kennedy threw out some other parts of the Section 504 rule. It did not touch the website requirements.
What WCAG 2.1 AA means on a nursing home website
WCAG 2.1 AA has 50 success criteria. These are the ones that trip up nursing home websites most, in plain language. The printable checklist adds a quick test for each one and questions to ask your vendor.
Photos, video and audio
- Every meaningful photo has a text description (alt text). Decorative images are marked so screen readers skip them.
- Videos have accurate captions, not auto-captions no one checked.
- If a video shows something important that no one says out loud, like on-screen text, there's an audio description or a text version.
- Nothing flashes more than three times a second.
Color and text
- Body text has a contrast ratio of at least 4.5 to 1 against its background; large text needs 3 to 1. Light gray text and words over photos often fail.
- Color isn't the only signal. Required fields, errors and links also use words or symbols.
- Text can be enlarged to 200%, and pages work on a 320-pixel-wide screen without sideways scrolling.
Keyboard and navigation
- Menus, buttons, forms and pop-ups all work with a keyboard alone, and no one gets stuck.
- A visible outline shows where the keyboard is on the page.
- Keyboard users can skip past the menu, usually with a "skip to content" link.
- Sliders, scrolling news and auto-playing video that run longer than five seconds can be paused.
Structure and wording
- Each page has a clear title and headings that follow an outline.
- Links say where they go: "Schedule a tour," not "Click here."
- The page language is set, and Spanish pages are marked Spanish.
- Menus and repeated buttons stay in the same place with the same names.
Forms
- Every field has a visible label, not just gray placeholder text.
- Errors are explained in words, with how to fix them.
- Forms don't time out on people, or they warn and allow more time.
Documents and outside tools
- PDFs work with screen readers, or the same content is on a web page. Activity calendars, menus and admission packets are often scanned images that fail.
- Tour schedulers, chat widgets, review feeds and maps on your site work with a keyboard and screen reader.
Good practice, not required by the rule: post an accessibility statement with your standard and a phone number and email for reporting problems. It shows good faith and gets problems fixed faster.
The Section 504 website checklist for nursing homes
Under the HHS Section 504 rule, providers that receive federal funds, including most nursing homes, need websites that meet WCAG 2.1 AA. With 15 or more employees, the deadline is May 11, 2027. This checklist shows what to check, in plain language.
What content isn't covered?
The rule has five narrow exceptions. Each has conditions, so read them closely before you rely on one.
- Archived content made before your compliance date, kept only for reference or records, never changed, and stored in an area clearly labeled as an archive.
- Older documents such as PDFs posted before your compliance date, unless people still use them to apply for, get or take part in your services. An admission packet doesn't qualify.
- Content posted by others, like a family's comment, unless they post it for you under a contract or other arrangement.
- Private documents about one person, such as a resident's bill, when they're password-protected or otherwise secured.
- Social media posts made before your compliance date. New posts after that date are covered, so add alt text and captions going forward.
The rule also allows other approaches that give equal or better access, and it excuses changes that would be an undue burden or fundamentally change a program. The organization has to prove that, in writing, and still do as much as it can.
What happens if our website isn't compliant?
The HHS Office for Civil Rights (OCR) takes complaints and can open compliance reviews. OCR first tries to settle problems informally, usually with an agreement to fix them. If an organization won't, the final step is losing federal funding, which for a nursing home means Medicare and Medicaid.
People can also sue under Section 504 to make you fix the site, and courts can award attorney's fees.
A common myth: Section 504 doesn't set HHS fines. Anyone selling a fix by quoting a fine amount is mixing up laws.
Do accessibility overlay widgets make a site compliant?
No. Overlays and accessibility toolbars sit on top of a website without fixing the code underneath. In April 2025 the Federal Trade Commission finalized an order requiring overlay company accessiBe to pay $1 million over claims that its tool could make websites compliant. Plan on fixing the site itself.
What to do before May 11, 2027
- List what you have. Every website, app, PDF, video, tour scheduler and chat tool your building uses.
- Run a quick check. Test your home, admissions, careers and contact pages with the free WAVE tool (opens in a new tab) and a keyboard-only test.
- Get a written audit. Ask your vendor, or an outside firm, for a list of problems and where they are.
- Fix the templates first. Menus, colors and forms repeat on every page, so one fix covers dozens of pages.
- Replace image-only PDFs. Start with what families and job seekers use: calendars, menus, admission packets and applications.
- Caption your videos. Tour, welcome and recruiting videos first.
- Keep it up. Post an accessibility statement and teach whoever posts new photos, PDFs and posts how to keep them accessible.
A separate rule: Section 1557 notices
The 2024 Section 1557 rule (45 CFR 92.10 and 92.11) separately calls for a notice of nondiscrimination and a notice about language help to be posted on health providers' websites. Parts of the Section 1557 rule have been challenged in court, so confirm the current requirements with your counsel.