Digital accessibility is no longer just “nice-to-have” for healthcare providers.
With new federal requirements, increasing legal scrutiny, and growing patient expectations, accessibility has become an essential part of delivering care online. For any organization operating in the healthcare space, an inaccessible website can now create real operational, legal, and financial risk.
Below, we break down why accessibility matters, what WCAG (Web Content Accessibility Guidelines) 2.1 AA requires, and how healthcare organizations can prepare ahead of the coming compliance deadlines.
The New Reality: WCAG 2.1 AA Compliance Is Now Required
In April 2024, the U.S. Department of Justice published a final rule to establish specific technical accessibility standards for web and mobile apps offered by state and local governments. While WCAG AA standards have been previously referenced in ADA cases, the final rule explicitly names WCAG 2.1 AA as the standard. Shortly after that, in May, the U.S. Department of Health and Human Services (HHS) implemented this guidance in a major update to Section 504, expanding these requirements to any healthcare organizations receiving federal funding. In that update, HHS states that “web content and mobile apps that recipients make available must be made accessible … by ensuring conformance with WCAG 2.1 Level AA standards.” Reference here.
This applies to hospitals, clinics, mental health providers, insurers, telehealth services, and any organization that participates in Medicaid, Medicare, or CHIP.
The compliance deadlines are:
- May 11, 2026 for organizations with 15 or more employees
- May 10, 2027 for smaller organizations with less than 15 employees
State- or county-run healthcare organizations that are considered “public entities” under Title II, such as public health programs, are required to comply even sooner: by the end of April 2026 (the dates vary depending on the size of your state or district population). For more info, ADA.gov provides a guide for public entities.
Failure to comply can result in investigations, corrective action plans, and possible loss of federal funding. Reference here.
This shift signals something important: accessibility is now a central part of healthcare compliance. It is not just a best practice. It is a requirement.
What WCAG 2.1 AA Means for Healthcare Websites
WCAG 2.1 AA is the globally recognized accessibility standard created by the World Wide Web Consortium (W3C). Reference here.
WCAG is built around four principles: content must be perceivable, operable, understandable, and robust. For healthcare organizations, this typically includes:
- Adequate color contrast for text
- Meaningful page structure with clear headings
- Descriptive link text
- Accurate alt text for images
- Captions and transcripts for multimedia content
- Full keyboard access for all navigation
- Accessible forms with clear labels and error feedback
- Screen reader compatibility
- Accessible PDFs and downloadable patient materials
These requirements are especially critical in healthcare, as healthcare websites are increasingly serving as gateways to essential health-related services. Patients go online to schedule appointments, access test results, complete intake forms, find providers, and join telehealth visits.
If someone cannot navigate a website or interact with a form, they may be unable to access care. For many patients, especially those who are older, visually impaired, or managing chronic conditions, the website is the front door to their healthcare experience. An inaccessible appointment form can mean missing time-sensitive follow-ups; a screen-reader-incompatible test results page can prevent someone from understanding critical health information; and a poorly structured telehealth portal can make it impossible for a patient to join a virtual visit they rely on. Accessibility issues don’t just create frustration; they can create real barriers to receiving timely, essential care.
Why Healthcare Organizations Are Especially Impacted
An inaccessible healthcare website does more than harm the user experience. It can create serious barriers for patients.
Patients may experience:
- Difficulty scheduling appointments
- Inability to complete intake or insurance forms
- Challenges accessing telehealth instructions
- Trouble using patient portals
- Disrupted communication with providers
Organizations may face legal and business consequences:
- Legal exposure under Section 504 or the ADA
- Loss of federal funding for repeated non-compliance
- Increased administrative workload when patients cannot self-serve online
- Reputational harm and loss of patient trust
Healthcare already serves many people who are older, disabled, or managing chronic conditions. Accessibility is a core part of equitable care.
What “Time In and Time Out” of Forms Means in Accessibility
Healthcare websites rely heavily on forms, and accessibility experts often talk about whether forms remain usable over time. “Time in and time out” refers to a user’s ability to:
- Navigate into and out of fields without losing data
- Move through the form with a keyboard
- Return to earlier steps in multi-step forms
- Understand and fix errors
- Complete forms without time limits that expire unexpectedly
- Use assistive technology such as screen readers
If any step of a form is inaccessible, a patient may be unable to schedule an appointment or complete a required document. This inaccessibility t can have direct consequences on the patient’s ability to receive care.
A Strategic Approach: Turning Accessibility Into a Healthcare Advantage
With WCAG 2.1 AA now required, healthcare organizations benefit by taking a proactive approach:
- Audit the entire digital ecosystem including websites, mobile apps, scheduling systems, patient portals, PDFs, and telehealth tools.
- Prioritize fixes that impact patient access first, such as forms, navigation, images, and color contrast.
- Remediate inaccessible legacy content including older PDFs and long-form patient documentation.
- Ensure third-party tools are accessible because organizations remain responsible even when using external platforms.
- Adopt accessibility as an ongoing practice rather than an annual or one-time update.
Accessibility is not just about avoiding penalties. It is about improving patient care, expanding access, and creating a more inclusive digital experience. WCAG 2.1 AA compliance is now an essential part of healthcare operations. It protects organizations from legal and financial risk, but more importantly, it ensures that every patient has equal access to the information and care they need.
For healthcare providers, accessibility supports a core mission: delivering high-quality, equitable care to all.
If you are a healthcare organization looking for assistance in ensuring your website is accessible, our team takes a thoughtful, comprehensive approach to accessibility auditing. We combine automated testing with manual, human-centered reviews—including screen reader testing, keyboard navigation checks, content structure evaluation, and usability assessments—to identify not just technical issues but real-world barriers that affect patient access. We also provide clear, prioritized recommendations and collaborate closely with internal teams to support remediation and long-term accessibility improvements.
Learn more about our accessibility consulting service.
Disclaimer: This post is provided for general informational purposes only and does not constitute legal advice. Regulatory requirements, including those related to WCAG 2.1 AA and healthcare accessibility compliance, may vary based on an organization’s specific circumstances. For guidance tailored to your situation, consult legal counsel or a qualified accessibility compliance professional.
