Two sets of rules to know about
First, Title III of the ADA covers the professional office of a health care provider as a place of public accommodation. The Department of Justice has not set a technical website standard for private businesses, but its guidance says the ADA applies to web content.
Second, the HHS rule implementing Section 504 sets a technical standard for recipients of HHS federal financial assistance. It requires web content and mobile apps to meet WCAG 2.1 Level AA. Under the extended compliance dates, recipients with 15 or more employees must comply by May 11, 2027. Recipients with fewer than 15 employees have until May 10, 2028. Whether your clinic is a recipient depends on its funding, such as Medicaid, so confirm with your attorney.
What clinics publish and where it breaks
- Patient portals. Often supplied by an electronic health record vendor. You cannot rewrite the code, but you can ask for the vendor's accessibility conformance report and hold them to it.
- Telehealth links. A video visit that cannot be joined with a keyboard or screen reader blocks care.
- Intake and consent forms. Scanned or non fillable PDFs force a patient to ask for help.
- Provider directories and maps. Cards that rely on photos or color alone to convey location and specialty.
- Billing pages. Payment forms with unclear errors and short time outs.
- Health information pages. Long, dense text with no headings and poor contrast.
Beyond the technical checks
Accessibility in healthcare also includes language. Plain language helps patients with cognitive disabilities and limited health literacy. A clinic should offer another way to do anything on the site, such as a phone number that is easy to find and a staff member who can help with a form. Good alternatives matter, but they do not replace an accessible site. The HHS rule has limited exceptions and defenses, which have conditions. Rely on counsel for how they apply.
A sensible first month
- Scan the home page and your key landing pages.
- Test appointment booking, the portal login, and a telehealth join by keyboard.
- Ask each vendor for a written accessibility statement or conformance report.
- Convert the most used forms to accessible, fillable versions.
- Plan fixes with our remediation service or a rebuild with accessible redesign if the site cannot be repaired.
Dental offices have a related guide: dental practices.
General information, not legal advice. Automated testing cannot establish full ADA compliance or guarantee protection from lawsuits. It finds some kinds of barriers quickly. A person still has to test the rest. Ask a qualified attorney how the law applies to you.
Frequently asked questions
Does the HHS Section 504 rule apply to a small clinic?
If the clinic is a recipient of HHS federal financial assistance, yes, with a later date for those with fewer than 15 employees: May 10, 2028. Ask your attorney.
Are patient portals our responsibility?
Web content you make available through a vendor can still be your responsibility. Ask the vendor for testing evidence and write accessibility into contracts.
What is the standard in the HHS rule?
WCAG 2.1 Level AA, which is the same level named in the DOJ local government rule.
Is a phone number enough?
An alternative way to get service is helpful, but an accessible website is the goal. Rely on counsel to judge how the rule applies to you.