Healthcare systems serve a wide variety of patients and families with a diverse array of health conditions and concerns. About 1 in 4 adults in the U.S. live with a disability that impacts major life activities, such as hearing, thinking, or mobility.  

Navigating websites should be easy for everyone, including those who use a mouseless display, screen reader, or other assistive technologies. That’s the spirit of Web Content Accessibility Guidelines (WCAG): making sure everyone can access care with dignity. 

Digital accessibility requirements based on WCAG are newly enforceable. After decades of delay, in 2024 the U.S. Department of Health and Human Services (HHS) updated Section 504 of the Rehabilitation Act. This update requires healthcare organizations that receive federal funding to meet WCAG 2.1 Level AA across all digital properties.    

The rule compels covered healthcare organizations to make sure all public-facing web content and mobile apps to meet the standards. This includes websites, patient portals, online forms, and third-party integrations, even if those tools are designed or hosted by vendors. 

Healthcare organizations must achieve compliance by: 

• May 11, 2026 for those with 15 or more employees 

• May 10, 2027 for those with fewer than 15 employees 

Noncompliance can result in formal investigations from the HHS Office of Civil Rights. Enforcement can include requiring corrective plans or referral to the Department of Justice. In extreme cases, HHS may suspend or terminate federal funding to noncompliant organizations.  

There can be other consequences, too. One organization tracking web accessibility noted that plaintiffs filed more than 4,500 related lawsuits in 2023, or about 80-100 per week. Healthcare organizations were among the most likely to be sued.  

Accessibility is more than meeting the letter of the law. Going beyond compliance can have real benefits for patient recruitment and retention. Highly accessible websites, such as those that meet and exceed the latest WCAG, strengthen the patient experience, support equitable care, and reinforce the health system’s mission. 

Stamats experts can help your organization understand and implement differences in the latest guidelines, but that’s just the beginning. Building an ongoing culture of accessibility can help everyone get the information and care they need, while improving patients access and satisfaction now and in the future. 

WCAG 2.1 vs 2.2: Updated Criteria for Accessibility Success 

WCAG 2.1 Level AA is the most widely recognized standard for digital accessibility. The guidelines, published by the World Wide Web Consortium (W3C), are the basis for government regulations. They’re built on a foundation of four key principles: 

• Perceivable: Information must be presented in ways users can perceive, for example text alternatives for images or captions for video 

• Operable: Navigation and user interfaces must be clear and predictable, such as keyboard or voice control 

• Understandable: Content and interactions must be clear and predictable to avoid confusion and cognitive overload 

• Robust: Digital content must be compatible with current and evolving technologies, such as screen readers and other tools 

The latest version is WCAG 2.2, published in October of 2023. It provides updated criteria for accessibility success, building upon versions 2.0 and 2.1. WCAG 2.2 includes nine additional criteria.  

Navigable 

These guidelines enable users to find content, navigate the site, and understand where they are. 

Updated guidelines include: 

• 2.4.11 Focus Not Obscured (Minimum): Ensure that when an element gets keyboard focus (such as an outline or highlight that indicates an interactive element on the page) it is not obscured. For instance, a pop-up banner could block important buttons or information and users without a mouse could have difficulty dismissing the banner. 

• 2.4.12 Focus Not Obscured (Enhanced): When an item gets keyboard focus, it is fully visible. In other words, no part of the component is hidden by other content, so keyboard-only users aren’t blocked. 

• 2.4.13 Focus Appearance: Focus indicators should be of sufficient size and contrast, so people who can’t see small changes in appearance can use them. 

Input Modalities 

Updated guidelines make it easier for users to operate with different methods of input. 

These new guidelines include: 

• 2.5.7 Dragging Movements: Provide a simple pointer alternative for any action that involves dragging. Some people have difficulty using a mouse or otherwise dragging items across a screen.  

• 2.5.8 Target Size (Minimum): Buttons and other targets should meet a minimum size and have enough space around them. Small and close buttons can be difficult to click, especially for people with a physical impairment.  

Predictable 

Webpages should appear and operate in ways users can anticipate. WCAG 2.2 updates include: 

• 3.2.6 Consistent Help: Users should be able to find help in the same place on multiple pages, which makes it easier to locate. 

Input Assistance 

These new guidelines help users avoid mistakes, and correct them when necessary: 

• 3.3.7 Redundant Entry: The same information should not be requested more than once in the same session to reduce challenges for users. 

• 3.3.8 Accessible Authentication (Minimum): Users should not need to solve, recall, or transcribe to log in. Users may be challenged when asked to complete puzzles, memorize information, or re-type passcodes. 

• 3.3.9 Accessible Authentication (Enhanced): Users should not need to recognize objects or images and media to log in. Completing puzzles or identifying objects and non-text information can be challenging.  

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

Beyond Compliance: The Case for Accessibility 

Web accessibility isn’t just about mitigating legal risk and avoiding enforcement. It’s an opportunity for your organization to carve out a competitive advantage.  

More than 61 million people in the U.S. and 1.3 billion worldwide live with a disability. When their friends and family are included, it adds up to $13 trillion in purchasing power.  

Organizations that make inclusive digital design a priority report stronger brand perception, more customer loyalty, and broader market reach. Reputation, retention, and engagement can be especially critical in healthcare, where accessibility can improve efficiency and expand access to underserved patients.  

Accessibility reduces support call volume. It assists aging patients, mobile-first users, and patients with temporary impairments. It’s critical for organizations seeking to reinforce (or establish) brand perceptions such as equity, modernity, and patient-centeredness.  

Moreover, digital accessibility is good ethics, helping health systems meet their mission of providing care for all citizens. After all, accessible websites are useful for everyone, not just patients and families with disabilities.  

Compliance with WCAG is the floor for your organization’s efforts, not the ceiling. Forward-thinking healthcare organizations are embedding accessibility into innovation strategies, not just checklists. 

Evaluating your patient-facing tech stack through an inclusive lens reduces legal risk and helps build a healthcare system that offers all patients the care and access they deserve. 

Stamats experts can help you lead your organization through this transformation.  

Want to secure your compliance and serve all your patients effectively? Download the Section 504 Compliance Guide today.