Complying with 2024 ADA/HHS Requirements for Web and Mobile Content Accessibility

In 2024, the U.S. Department of Justice (DOJ) and Department of Health and Human Services (HHS) finalized rules to strengthen requirements for web and mobile content to be accessible to individuals with disabilities. The DOJ rule under Title II of the Americans with Disabilities Act (ADA) applies to public entities’ websites and mobile applications (apps), while HHS also updated Section 504 of the Rehabilitation Act to extend the requirements to clinicians and other healthcare entities that receive federal funding from HHS. Together, these rules clarify expectations and timelines for making web and mobile content accessible.

Overview of the 2024 ADA/HHS Rules for Web and Mobile Content

Who the Rules Apply to
Although the DOJ’s final rule applies to public entities, HHS also finalized these requirements so that they apply to any organization that receives HHS funding. As a result, pediatric practices participating in Medicaid, Children’s Health Insurance Program (CHIP), Medicare, or other government funding programs are subject to these requirements for web and mobile content accessibility.

Key Requirements
The following are some of the key requirements applicable to pediatric practices:

Web content, including websites and mobile applications, that is made available to individuals with disabilities must conform to Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standards. See the FAQ[TS1.1] below for more information on the standards.
Digital content must be perceivable, operable, understandable, and robust for users with a wide range of disabilities, including those who rely on assistive technologies such as screen readers or keyboard navigation. See the FAQ[TS2.1] below for more information.
Organizations are expected to identify and remediate accessibility barriers in existing available content, with all new or updated content to be accessible from the outset.

Key Compliance Dates
The timeline for compliance is based on the size and type of entity:

By May 11, 2027, practices with 15 or more employees that receive HHS funding must comply with accessibility requirements for web content and mobile applications.
By May 10, 2028, practices with fewer than 15 employees that receive HHS funding must be in compliance.

(For reference, public entities with a total population ≥ 50,000 must begin complying by April 26, 2027, and public entities with a total population < 50,000 must begin complying by April 26, 2028, per the interim final rule which extended compliance dates.)

Accessibility compliance is an ongoing process rather than a one-time certification. Website updates, content changes, third-party integrations, forms, videos, PDFs, and design modifications can all affect accessibility over time. Practices should work with their website and technology vendors to periodically review and improve digital accessibility.

Frequently Asked Questions

Does this rule apply to my medical practice?[

Are there any exemptions to who must comply with the web and mobile content accessibility requirements?

The 2024 DOJ and HHS rules apply broadly, with limited exemptions based on who must comply. While the DOJ rule covers state and local government entities, the HHS rule extends these requirements to clinicians and other organizations that receive federal funding.

There is no general exemption for smaller practices or individual clinicians. Most pediatric practices receiving federal funding are expected to comply with these accessibility requirements.

The DOJ and HHS allow an exemption only if accessibility changes would result in undue burden, although this is a high standard that must be carefully documented; further, these do not exempt an entity from the overall obligation to provide accessible services. Consult an attorney if considering claiming undue burden.

What type of accessibility requirements are included in the WCAG 2.1 Level AA standards?

WCAG 2.1 outlines a wide range of technical requirements designed to make digital content accessible to individuals with disabilities. These standards are organized around four core principles: content must be perceivable, operable, understandable, and robust.

Following are examples of requirements for each principle:

Perceivable content: Providing text alternatives (descriptive text that conveys the meaning of an image in digital content) for images, captions for videos, and sufficient color contrast.
Operable functionality: Making websites and mobile applications to be fully navigable using a keyboard, without relying on a mouse or touch gestures.
Understandable information and navigation: Using clear language, consistent layouts, and predictable navigation.
Robust compatibility with assistive technology: Designing content so it works with screen readers, voice recognition software, and other assistive technologies.

These requirements facilitate accessibility for individuals with disabilities.

Does this apply only to websites?

Are there any exceptions to the type of content that must be in compliance?

Limited exceptions exist. These include archived web content, some preexisting conventional electronic documents, content posted by a third party that is not in control of the recipient of funding, individualized password-protected conventional electronic documents, and pre-existing social media posts. Refer to the DOJ and HHS rules for more information on these exceptions.

What if my web or mobile content is managed by a vendor?

How will compliance with the ADA/HHS requirements be enforced?

Agencies often emphasize voluntary compliance and corrective action plans before pursuing formal enforcement, particularly for first-time violations. Enforcement often begins with a complaint from an individual. Allegations of non-compliance may be investigated by the DOJ for ADA requirements or the HHS Office of Civil Rights for HHS requirements. Both public and private entities can face enforcement actions, including potential financial and legal exposure, if their web and mobile content does not meet accessibility requirements.

Additional Resources

See the ADA fact sheet for more information on the 2024 rule on accessibility of web content.
The HHS fact sheet, New Requirements on the Accessibility of Web Content, Mobile Apps, and Kiosks, provides an overview of the new requirements for accessible web and mobile content.
For more information, refer to the final rules published by the Federal Register, Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities and Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance.
Refer to the WCAG 2 webpage for more information on the standards.

Disclaimer: This information is general in scope and educational in nature. It is not intended as legal advice. If you require legal advice, contact an attorney.

Last Updated

05/19/2026

Source

American Academy of Pediatrics