Section 504 and Your WordPress Website
Section 504 is a different rule from ADA Title II, issued by a different agency, reaching organisations for a different reason, and sized by a different number. It also names exactly the same technical standard — which means the two rules disagree about almost everything except the work.
Two dates, decided by employee count
HHS Section 504
May 11, 2027
Recipients of HHS federal financial assistance with 15 or more employees
About 8 months from today.
HHS Section 504
May 10, 2028
Recipients of HHS federal financial assistance with fewer than 15 employees
About 20 months from today.
Counting employees is less obvious than it sounds
The threshold is a headcount, but which headcount is a legal question rather than a technical one: whether part-time and seasonal staff count, whether the number is taken across the whole recipient organisation or one program, and how affiliated entities are treated are all matters for current HHS guidance and qualified counsel.
Organisations close to the threshold are the ones that most need a written answer, and the ones least likely to have asked for one.
Where these dates come from. Verify current guidance before relying on any date for planning — both rules have already moved once.
- U.S. Department of Justice — ADA Title II web rule: ada.gov/resources/web-rule-first-steps
- U.S. Department of Health and Human Services — Section 504 deadline extension: hhs.gov press release
MakeWPCompliant provides technical accessibility services, not legal advice. How a rule applies to a specific organization is a question for current federal guidance and, where appropriate, qualified legal counsel.
How the two rules differ, and where they do not
Most confusion about Section 504 comes from reading it as a healthcare version of Title II. It is not. It is a separate rule that happens to point at the same standard.
| ADA Title II | HHS Section 504 | |
|---|---|---|
| Issued by | U.S. Department of Justice | U.S. Department of Health and Human Services |
| What brings you in scope | Being a state or local public entity | Receiving HHS federal financial assistance |
| What sets your date | The population the entity serves | The number of employees |
| Earlier date | April 26, 2027 — Population 50,000+ | May 11, 2027 — 15 or more employees |
| Later date | April 26, 2028 — Population under 50,000, and special districts | May 10, 2028 — Fewer than 15 employees |
| Technical standard | WCAG 2.1 Level AA | WCAG 2.1 Level AA |
| What it changes about the remediation work | Nothing | Nothing |
The rules differ about who and when. They agree about what.
That last row is the practically important one. Whichever rule reaches you — or if both do, or if neither does and a grant condition or a procurement clause gets you there instead — the technical target is the same, and so is the engineering.
Who receives HHS federal financial assistance
Coverage follows the money, not the sector, and it reaches further than most people expect. Organisations that commonly receive HHS assistance include:
- Hospitals and health systems
- Community health centres
- Clinics and physician practices
- Behavioural health providers
- Nursing and long-term care facilities
- Home health agencies
- State and local health departments
- Human services agencies
- Early childhood programs
- Aging services organisations
- Research institutions with HHS grants
- Nonprofits delivering HHS-funded programs
That list is a prompt to ask the question, not an answer to it. Whether a specific organisation is a recipient, and whether a particular program is covered, depends on the assistance received and how the organisation is structured. It is a question for current HHS guidance and your counsel — we are a technical service, not a legal one.
When both rules reach the same organisation
A public hospital, a county health department or a hospital district can be a public entity under Title II and a recipient of HHS assistance under Section 504. Both rules then apply, and the practical consequence is simple:
The earlier of the two dates is the one that governs planning.
For a large public health system that is usually the Title II date of April 26, 2027, which arrives before the Section 504 date of May 11, 2027. Planning to the later one and discovering the overlap afterwards is an expensive way to find out.
More on the ADA Title II rule, or the special district page if the hospital is its own district.
All four dates, in full
| Compliance date | Rule | Who it applies to |
|---|---|---|
| April 26, 2027 | ADA Title II | Public entities with a population of 50,000 or more |
| April 26, 2028 | ADA Title II | Public entities with a population under 50,000, and special district governments |
| May 11, 2027 | HHS Section 504 | Recipients of HHS federal financial assistance with 15 or more employees |
| May 10, 2028 | HHS Section 504 | Recipients of HHS federal financial assistance with fewer than 15 employees |
Do not wait for the coverage question to be answered
Working out whether Section 504 reaches you can take a while. It involves your counsel, your finance office and sometimes a grant administrator, and it is genuinely worth doing properly.
It is also not a reason to leave the site alone in the meantime. Because both rules name the same standard, none of the technical work depends on the answer:
- Theme, navigation, focus behaviour and colour contrast are the same fixes either way
- Appointment, contact and intake forms are the same fixes either way
- Provider and location directories are the same fixes either way
- Embedded scheduling and portal hand-offs need the same boundary analysis either way
- Documents need the same triage either way
Two things genuinely do depend on the answer: your date, and the paperwork you keep. The remediation does not.
The notices are part of the site too
Organisations covered by these rules typically already publish nondiscrimination and accessibility notices, along with language assistance information. Those pages are worth checking first, and they frequently fail — posted as a scanned image of a printed notice, or as a PDF that cannot be read aloud.
A notice about accessibility that is itself inaccessible is the finding nobody wants to explain later, and it is usually an afternoon's work to fix.
What healthcare WordPress remediation actually involves — the systems, the forms, the directories and the third-party dependencies.
Healthcare accessibility work is bigger than the homepage
Forms, patient information, documents, directories and third-party systems are all part of the picture. Start by finding out what is actually wrong.