Complying with 2024 ADA/HHS Requirements for Accessible Medical Diagnostic Equipment

To be compliant, exam tables must meet all the Standards for Accessible Medical Diagnostic Equipment including M301 of the standards which provides details on MDE for patients in supine, prone, or side-lying position. Standards include the following: 

• Height adjustable
  • Transfer surfaces must include a low transfer position at a height of 17 inches maximum
  • Transfer surfaces must include a high transfer position at a height of 25 inches minimum 
  • There must be at least 4 additional transfer positions between the low and high transfer positions which are separated by a minimum of 1 inch
• Compatible with patient lifts, as well as wheelchairs
• Transfer surfaces must be 21 inches wide minimum by 17 inches deep minimum 
• Transfer surfaces must provide two unobstructed sides for patient transfer
  • Obstructions no more than 3 inches deep are permitted to extend beyond transfer sides of transfer surfaces provided that such obstructions do not protrude above the tops of transfer surfaces.
  • Temporary obstructions are permitted provided that they can be repositioned during transfer to comply with the requirements.
• Where stirrups are provided, leg supports must be provided
• Where MDE is used in a reclined position, head and back support must be provided
• Adequate clearance in and around base to accommodate transfer from a wheelchair or lift
  • Clearance in base of diagnostic equipment of 29 inches wide minimum, 6 inches high minimum from the floor, and 36 inches deep minimum from the edge of the examination surface (if width of examination surface is less than 36 inches, clearance depth shall extend full width of equipment)
  • Clearance around base of 6 inches high minimum from floor and 36 inches deep minimum measured from edge of examination surface. The width of the base within the clearance is permitted to be 26 inches wide maximum at the edge of the examination surface and is permitted to increase at 1 inch in width for every 3 inches in depth.
• Edge protection
  • For platforms more than 1.5 inches in height, edge protection must be 2 inches high minimum from the surface of the platform on every side that does not provide entry to or exit from the equipment 

Not all standards are listed above. See Standards for Accessible Medical Diagnostic Equipment for the full standards. 

To be compliant, weight scales must meet all the Standards for Accessible Medical Diagnostic Equipment, including M303 of the standards which provides details on MDE for patients seated in a wheelchair. Standards include the following:

• A base with width 32–36 inches minimum (depending on height from the ground) to accommodate a wheelchair
  • Wheelchair spaces must be 36 inches wide
  • Wheelchair spaces on raised platforms are permitted to be 32 inches wide to a height of 4 inches from the platform surface
• A base with depth of 40 inches minimum where wheelchair space entry and exit allows pass through from one end to the other
  • Wheelchair spaces must be 48 inches deep if entry/exit is provided only at one end
  • Wheelchair spaces must be 60 inches deep minimum if entry/ is only from the side
• Knee and toe clearances for wheelchair spaces between diagnostic equipment
  • Depth of 17 inches minimum and 25 inches maximum
  • For toe clearance, height of 9 inches minimum above the floor to a depth of 6 inches maximum measured from the toe end of the wheelchair space
  • For knee clearance-
    • depth of 11 inches minimum and 25 inches maximum at 9 inches above the floor and at a depth of 8 inches minimum at 27 inches above the floor measured from the leading edge of the equipment
    • Between 9 inches and 27 inches above the floor, the knee clearance shall be permitted to reduce at a rate of 1 inch in depth for every 6 inches in height
  • Edge protection
    • If platform is more than 1.5 inches in height, edge protection must be 2 inches high minimum from the surface of the platform on every side that does not provide entry to or exit from the equipment
  • Ramp with a gentle slope and edge protection for changes in level greater than 1/2 inch high at the entry to the wheelchair space (refer to standards for requirements for changes in level under 1/2 inch)
    • Running slope must not be steeper than 1:12
    • Running slope not steeper than 1:8 is permitted for ramp runs with a maximum height of 2.5 inches
    • Cross slope of ramp must not be steeper than 1:48
    • Width of ramp must be 36 inches minimum
    • Edge protection must be 2 inches high minimum on each side with a drop off 

Not all standards are listed above. See Standards for Accessible Medical Diagnostic Equipment for the full standards. 

No. Practices are not required to make all MDE accessible. Private practices that use exam tables and weight scales must have at least one of each that meets the accessibility standards by July 8, 2026, for those that receive funding from HHS, or August 9, 2026, for public entities. As a practice procures new MDE, the new MDE must meet the accessibility requirements until 10% of MDE meets the standards, or 20% for those specializing in treating mobility-related conditions. 

The rule sets forth general provisions that apply to all recipients of federal funding from HHS. Therefore, it is interpreted that each and every recipient of federal funding from HHS must comply with these requirements.  

Per DOJ and HHS, this depends on various factors, such as whether MDE is a significant distance from where the patient is seeking care, the impact that change in location has on wait times, and whether the patient requires additional assistance in seeking care at a different location. Therefore, practices with multiple locations should evaluate whether their specific situation would meet the criteria outlined by the DOJ/HHS for the equipment to be readily accessible to and usable by patients with disabilities. 

In “New Requirements for Accessible Medical Diagnostic Equipment,” HHS states, “Methods for achieving program accessibility include doctors seeing patients at an accessible hospital where they have staff privileges or serving a patient with a disability at another, accessible location of a recipient’s multiple facility practice.” Again, though, it must be determined whether the MDE at the alternative location is readily accessible to and usable by patients.  

In the response to public comments, HHS states, “If a recipient requires a patient with a disability who requires accessible MDE to use the MDE of another department, the recipient must ensure that the accessible MDE is readily accessible to and usable by the patient. Factors to consider in determining whether this standard has been met may include, among other things, whether the MDE is readily available and not a significant distance from where the patient is seeking care; whether changing locations during the patient visit significantly increases wait times; whether the patient is required to be undressed or partially dressed to use the MDE (if, for example, the patient has to go to a different part of the same building to use the accessible MDE); and whether the recipient provides assistance moving between locations. This means that some of the situations commenters described, including going to a separate campus or building to use a recipient's accessible MDE, could result in the recipient's program or activity not being readily accessible to and usable by patients with disabilities as required by § 84.93(a). Recipients must ensure that the dispersal of their accessible MDE does not discriminate against people with disabilities.” 

Later, HHS states, “Situations where a recipient has multiple campuses and requires a patient who requires accessible MDE to go to different campuses for services from the same department due to the distribution of accessible MDE may constitute violations of § 84.92(b)(3) if the recipient's MDE is not readily accessible to or usable by persons with disabilities. In such situations, however, the recipient may be able to take other measures to ensure that its programs and activities are readily accessible to and usable by the patient. For example, it could offer home visits that provide equal access to care or accessible transportation to the patient with a disability at no cost to them within a reasonable time frame.” 

See aligned response from the DOJ here.  

MDE must be readily accessible to and usable by patients with disabilities. This means that equipment must be available whenever it is needed during care and not just present somewhere in the facility that is not readily accessible and/or available only upon request.  

If the multi-purpose piece of equipment meets accessibility standards, then yes, that fulfills the requirement for the weight scale. If it is an exam table and it meets all accessibility standards, then that will also meet the requirements for the exam table.  

Just like buying vaccines through a vaccine buying group can help reduce costs, buying MDE through a group purchasing organization may help with finding the best price. The Standards for Accessible Medical Diagnostic Equipment are very detailed, and some of this detail may not be included on equipment websites. Make sure to fully research equipment to make sure it meets all required standards.  

No. HHS has clarified that it applies to all recipients of HHS funding, regardless of size.  

The DOJ/HHS allows an exemption only if accessibility changes would create undue financial or administrative burdens. However, this may be difficult to prove and is interpreted narrowly. Even then, practices must find alternative solutions to facilitate access. Consult an attorney if considering claiming undue burden. 

Practices should maintain documentation to demonstrate compliance with the ADA/HHS MDE standards. Examples include, but are not limited to, the following:

• an updated inventory of all MDE, including accessible and non-accessible MDE, to demonstrate compliance with the applicable threshold (10% or 20%) of all MDE needing to be accessible
• acquisition records and/or manufacturer specifications of accessible MDE to demonstrate that it meets the applicable standards
• written policies and procedures describing how MDE is readily accessible to and usable by patients with disabilities
• documentation of staff training on operating accessible MDE and assisting patients when needed. 

Many times, enforcement is triggered by a complaint from an individual. The Department of Justice or the Office of Civil Rights may investigate complaints of non-compliance with ADA or HHS requirements, respectively. Both non-publicly owned and publicly owned entities can face significant fines and legal risk if they are non-compliant with the requirements for accessible MDE.