The U.S. Department of Health and Human Services (HHS) has issued an important update regarding federal digital accessibility requirements that apply to all community health centers receiving funding from the HHS. Federal guidance has recently increased expectations for digital accessibility: under the HHS final rule updating Section 504 of the Rehabilitation Act, organizations receiving HHS federal funding must ensure that their websites, web‑based content, and mobile applications conform to the Web Content Accessibility Guidelines (WCAG) 2.1 Level A and AA by the following deadlines:
- Health centers with 15 or more employees must comply by May 11, 2026
- Health centers with fewer than 15 employees must comply by May 10, 2027
These requirements apply broadly to all covered digital content, whether developed internally or provided by third‑party vendors, including public‑facing websites, patient portals, online forms, PDFs, scheduling tools, and mobile applications.
Beginning this work now allows time to engage vendors, identify gaps, and address issues in a thoughtful, manageable way ahead of the deadline.
Support Available: CHCANYS Solution Partner
In light of these new requirements CHCANYS Solutions Partner, rayogram, has developed a focused program to help community health centers identify and remediate accessibility gaps. This tiered offering is designed as a practical way to assess risk, prioritize improvements, and take meaningful steps toward compliance. Please email questions@chcanys.org if you are interested in learning more about this offer.
The CHCANYS Communications Team is developing social media guidance related to the updated regulations and will share it directly with health center communications contacts. Please note that the regulations for social media only apply to posts made after the May 11th deadline.
What to Ask of Your Third-Party Vendors
Because these requirements also apply to third-party tools, an important early step is engaging your vendors. We recommend requesting both:
- An Accessibility Conformance Report (ACR), often provided in the form of a VPAT®, that documents how the product supports WCAG 2.1 Level A and AA.
- A public‑facing Accessibility Statement describing the vendor’s commitment to accessibility, known limitations, and how accessibility issues can be reported.
These documents help support due diligence and provide greater clarity about whether a product is likely to meet federal accessibility expectations.
Additional Resources
We have assembled some practical resources to support you in planning next steps, including plain‑language explanations of the requirements and vendor and internal review checklists. These resources are available here:
- Accessibility checklists and guidance:
- HHS Final Rule: Web & Mobile Accessibility:
Next Steps
- Inventory all patient‑facing digital tools — assume websites, patient portals, online forms (intake, scheduling, bill pay), telehealth entry points, mobile apps, and vendor‑hosted tools are in scope.
- Assess accessibility against WCAG 2.1 Level AA — use a combination of automated tools and real user experience testing to identify gaps (or work with vendors to complete this where applicable).
- Request and collect vendor documentation — obtain an Accessibility Conformance Report (VPAT/ACR) and accessibility statement for all third‑party products and services.
- Document results and remediation plans — maintain records of testing, identified issues, remediation steps, retesting, and timelines leading up to the compliance deadline.
Given the upcoming deadlines, we strongly encourage health centers to begin conversations with vendors and internal teams now, particularly around obtaining Accessibility Conformance Reports (VPATs) and accessibility statements.
Accessibility is both a regulatory requirement and fundamental to equitable access to care and information. Digital barriers can limit patients’ ability to schedule appointments, complete forms, access educational materials, and use online services—creating real obstacles to care and increasing compliance risk as deadlines approach.