What is HHS Section 504? — US Healthcare Accessibility Standard Explained for UK 2026

„What is HHS Section 504 and why does it matter for UK healthcare organisations?" That's a question many NHS leaders and healthcare managers ask when they hear about US healthcare accessibility standards.

In this guide, we'll explain what HHS Section 504 is, how it relates to UK healthcare, and what it means for NHS organisations with US partnerships, research funding, or American patients.

What is HHS Section 504?

HHS Section 504 is a regulation from the U.S. Department of Health and Human Services (HHS) based on Section 504 of the Rehabilitation Act of 1973. It prohibits discrimination against people with disabilities in programs and activities that receive federal funding from HHS.

In 2024, the regulation was updated with a Final Rule that sets clear requirements for digital accessibility in healthcare. The rule requires all digital offerings of healthcare organisations to meet WCAG 2.1 Level AA standards.

The HHS regulation applies to:

• Websites — hospitals, clinics, GP practices
• Patient portals — appointment booking, test results, billing
• Telehealth platforms — video consultations with captions
• Mobile apps — health apps for patients
• Digital documents — clinical letters, results, patient information

Why does HHS Section 504 matter for UK healthcare?

UK healthcare organisations may need to comply with HHS Section 504 in several situations:

1. You treat American patients

If your NHS Trust or private hospital treats American patients who are reimbursed through federal programs like Medicaid or Medicare, you may be covered by HHS Section 504.

2. You collaborate with US organisations

If you collaborate with US healthcare organisations or receive federal funding for research or partnerships, the HHS regulation may apply.

3. You receive US grants or research funding

Many UK research institutions receive federal grants for medical research. These organisations must comply with HHS Section 504.

4. You want to be a global leader

Even if not legally required, following HHS Section 504 shows your organisation is committed to international accessibility standards.

What are the requirements?

HHS Section 504 requires healthcare organisations to make all digital offerings accessible. Key requirements include:

1. Patient portals

Patient portals are critical functionality and must be fully accessible:

• Login and registration — screen reader and keyboard compatible
• Appointment booking — accessible date selection, provider choice
• Test results — accessible PDFs with proper tagging
• Billing and payments — accessible payment processes
• Messaging — accessible chat and notifications

2. Telehealth platforms

Telehealth services must be accessible:

• Captions — for all video consultations (WCAG 1.2.2)
• Keyboard operation — all functions with keyboard (WCAG 2.1.1)
• Screen sharing — understandable for screen reader users
• Chat function — accessible with ARIA, keyboard, focus

3. Websites

Hospital and clinic websites must be accessible:

• Alternative text — for all clinical images (WCAG 1.1.1)
• Colour contrast — minimum 4.5:1 for normal text (WCAG 1.4.3)
• Keyboard accessibility — all functions with Tab key (WCAG 2.1.1)
• Form labels — all input fields must have labels (WCAG 3.3.2)
• Heading structure — logical H1-H6 hierarchy (WCAG 1.3.1)

What are the deadlines?

HHS Section 504 has two important deadlines based on the size of your organisation:

⚠️ Important: These deadlines are realistic and achievable, but you must start now with testing and improving your healthcare website.

What are the exemptions?

The HHS regulation has five exemptions for certain types of content:

• 📦 Archived content — content no longer current and not used for live services
• 📄 Existing documents — documents created before the deadline (if not essential)
• 🔗 Third-party content — content managed by third parties not under your control
• 🔐 Password-protected documents — documents only accessible to specific users
• 📱 Existing social media posts — posts published before the deadline

⚠️ Note: These exemptions are limited. The core functionality of your healthcare website must always be accessible.

What are the penalties for non-compliance?

Healthcare organisations that fail to comply with HHS Section 504 risk significant consequences:

1. Loss of federal funding

The most severe consequence is the loss of federal funding from HHS. This can cost millions of pounds in grants, reimbursements, and research funding.

2. HHS Office for Civil Rights (OCR) enforcement

The HHS OCR can investigate complaints and take enforcement action, including fines, corrective action plans, and public disclosure.

3. Lawsuits

Patients can bring lawsuits against healthcare organisations that are not accessible, leading to settlements and reputational damage.

4. Reputational damage

An inaccessible healthcare organisation faces negative publicity and loss of patient trust.

How to test your healthcare website for HHS compliance

Step 1: Use a free HHS checker

Use the free UK HHS checker to scan your healthcare website against WCAG 2.2 Level AA (which exceeds HHS requirements).

Step 2: Manual testing

Conduct manual tests:

• Keyboard test — can everything be operated with the Tab key?
• Screen reader test — is the content logical with a screen reader?
• Contrast test — is the text readable?

Step 3: Patient portal testing

Test your patient portal specifically — this is often the most critical functionality for patients.

Step 4: Document everything

Document all tests and improvements. This serves as evidence of your compliance efforts.

Frequently Asked Questions — HHS Section 504

Internal links — UK Healthcare Accessibility Resources