When the Department of Health and Human Services (HHS) finalized its long-awaited Section 504 rule in 2024, healthcare marketers and digital leaders got the clarity they had been waiting for: websites, mobile apps, and patient portals must meet WCAG 2.1 AA standards by May 2026 (or 2027 for very small organizations). 

This shift, covered in Part 1 of our series, makes accessibility not just a best practice, but a regulatory requirement. In Part 2, we explored how accessibility improvements deliver ROI through better user experience, SEO, and equity. 

Now, in Part 3, we turn to a question we hear in nearly every conversation: “Can I just buy a tool to become accessible?” The short answer: No. Accessibility isn’t something you can fully automate. It requires a combination of technology, manual testing, and human expertise. 

A quick refresher on why accessibility matters 

Accessibility is a civil rights issue, a patient experience imperative, and yes, the law. Patients with disabilities are more likely to need healthcare, and inaccessible digital experiences create real barriers to care. Improving code quality for accessibility often improves SEO and overall UX, too. 

Just as important: outsourcing a portal, bill pay, or scheduling tool to a vendor doesn’t move your obligation. If patients experience it as part of your digital front door, it must meet WCAG 2.1 AA—full stop. 

Watch the webinar: Web Accessibility 101 for Healthcare Marketers | Meeting HHS Section 504 Compliance

What automated accessibility tools can and can’t do

Automated scanners, such as platform‑ or browser‑based tools, are indispensable for scale and speed. They’re excellent at finding repeatable, code‑level issues such as missing alt text, low color contrast, and empty links. Tools like WAVE, Axe, and Siteimprove provide valuable diagnostics that help teams spot trends and prioritize fixes. 

But tools have limits. Automation can’t reliably evaluate:  

• Keyboard operability and tab order: Many failures—like a “hamburger” menu that’s unreachable via keyboard—are invisible to scanners but completely block access. 
• Screen reader and voice control flows: Whether labels are meaningful, focus moves predictably, and announcements happen at the right moments requires hands‑on testing with assistive technology. 
• Content intent and context: An auto‑generated alt text of “doctor” might be technically true, but it misses that the image promotes a women’s health event—context a patient needs. 
• Contrast over images/video: A drop shadow on text over a variable photo isn’t a guaranteed pass; you need to confirm the text/background boundary remains readable. 
• Heading hierarchy and semantics: Styling a line to “look like” a heading without semantic <h> tags breaks how screen reader users navigate. 
• PDFs and “conventional” documents: Tagging, reading order, and form fields require document‑specific checks and remediation—not just web scans. 

Only human reviewers can judge the quality and usability of accessibility features.  

Related reading: What the New HHS Rule Means for Healthcare Websites 

“Compliance is not intended to be a last-minute fix. There is no magic tool that’s just going to make your website compliant.”

—Amanda Gansemer, certified web accessibility expert 

The pitfalls of overlays and quick fixes

The rise of “accessibility overlay” products has added confusion. These tools promise instant compliance by injecting scripts that adjust color contrast, add text-to-speech features, or offer keyboard shortcuts. 

While they may improve surface-level accessibility, overlays are not a substitute for accessible design. In fact, the Department of Justice has noted that overlays do not guarantee compliance and, in some cases, introduce new barriers. 

Healthcare organizations relying solely on overlays or automated checkers risk:

• False confidence: Believing they are compliant when they are not 
• Legal exposure: Lawsuits continue to target sites using overlays 
• Poor patient experience: Patients may still be locked out of scheduling, billing, or accessing records 

What counts, what doesn’t: Section 504 exceptions

The HHS rule allows limited exceptions, so you’re not forced to retrofit everything in your archives. Five notable categories:

• Archived web content created before your compliance date, retained solely for reference/record‑keeping, stored in a clearly labeled archive, and unchanged since archiving 
• Pre‑existing conventional electronic documents, such as a past event flyer PDF posted before your compliance date that isn’t needed to access a current service 
• Content posted by a true third party, not under agreement with your organization 
• Individualized, password‑protected documents, such as an exported PDF bill inside a secure portal 
• Pre‑existing social posts —moving forward, new posts must be accessible 

Even with exceptions, most patient‑facing content (finding care, forms, portals, education) must be accessible. And don’t forget that third‑party tools presented as part of your experience are also in scope! 

Related reading: HMPS 2025 Recap: Storytelling & Connections Lift the Patient Experience 

Why a combination strategy works 

Think of accessibility as a diagnostic process. Automated tools act like lab tests—they flag potential issues quickly and at scale. But just like a physician interprets test results and examines the patient, accessibility requires expert review and manual checks. This combination approach ensures your digital properties meet both the letter and spirit of WCAG. 

At Stamats, our audits combine: 

• Automated scanning for baseline issues 
• Manual and assistive technology testing using screen readers and keyboard navigation. 
• Human evaluation of alt text, forms, headings, and error messages 

This layered approach catches what automation misses and ensures your fixes are meaningful, not just technical. 

Related reading: The ROI of Web Accessibility: A Business Case for Intentional, Inclusive Healthcare Websites 

Getting started the right way

So what should healthcare marketers and digital leaders do now? Start where patient impact and traffic are highest. For most systems, that means fixing global header/navigation, primary forms (find a doctor, request an appointment, bill pay), and key patient tasks first. 

Here’s a pragmatic 90-day game plan:

1. Inventory your digital assets: Include websites, microsites, portals, kiosks, PDFs, and mobile apps. 
2. Run automated scans: Use trusted tools to flag common issues. 
3. Perform manual testing: Test tab order, keyboard navigation, and screen reader performance. 
4. Engage experts: Accessibility professionals provide context, prioritize fixes, and guide remediation. 
5. Train your teams: Ensure writers, designers, and developers know how to create accessible content from the start. 

Download the white paper: Make Your Healthcare Website Accessible by 2026 

One last myth to retire

There is no “magic switch,” overlay, or single platform purchase that will instantly make a complex healthcare ecosystem accessible. The most successful teams blend smart automation, hands‑on testing, and operational discipline to deliver inclusive, compliant experiences—and keep them that way. 

By investing in accessibility now, your organization can strengthen trust, equity, and your brand reputation. And by rejecting “quick fixes” in favor of a thoughtful, combined approach, you position your team for sustainable compliance—and better digital care experiences. 

Stay ahead of the HHS Section 504 accessibility deadline with help from the experts at Stamats. We can help you make your website open to everyone so patients (and federal regulators) can access the important information they need.