Lexology January 8, 2026
McDermott Will & Schulte LLP

A US Department of Health and Human Services (HHS) Section 504 final rule imposes a May 2026 deadline on covered healthcare companies. Never before has a rule required all recipients of federal financial assistance – including private healthcare providers – to comply with digital accessibility standards for websites, mobile apps, and kiosks.

By creating a legal framework that was not previously available in the public accommodation context, this rule places heightened scrutiny on healthcare companies. As a result, noncompliance is likely to lead to greater litigation exposure and increased business risks.

In Depth

Background

To promote access to healthcare for individuals with disabilities, HHS, through its Office for Civil Rights (OCR), published a final rule on May 9, 2024, creating...

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