Skip to main content
HealthLiteracyCopilot home

Section 504 and ADA Title II: the document backlog

Both rules use WCAG 2.1 AA for web content and posted documents. HealthLiteracyCopilot checks Word and HTML files. A trained reviewer decides on each finding. You keep a record of what was checked and fixed. Whether a rule applies to you depends on your entity, your funding and the content.

HHS §504 sets 2027-05-11 for recipients with 15 or more employees. ADA Title II sets 2027-04-26 for large public entities. Both use WCAG 2.1 AA.

Talk to our team

HealthcareGPS is SOC 2 Type II audited and HIPAA compliant. How we protect your documents

The problem

  • Posted documents are often the largest part of the backlog.
  • Whether a rule applies depends on the entity, its funding, the content and the exceptions. Existing duties still apply.
  • Teams need a plan, an owner and a date for each document.

What good looks like

  • A list of posted documents, ranked by how often people use them.
  • Each file checked against WCAG 2.1 AA, with findings a person reviews.
  • Reading level checked at the same time.
  • A record of what was checked, who fixed it and when.
Sketch of a document with tagged headings, an image with alt text and a table with a header row.H1H2AltHeadingsAlt textTable headers

Illustrative sketch of the document.

The dates

  1. Upcoming

    ADA Title II web and document accessibility

    State and local government entities serving a population of 50,000 or more

    DOJ interim final rule, 91 FR 20902 (Federal Register 2026-07663) · checked 2026-10-08

  2. Upcoming

    HHS Section 504 web and document accessibility

    Recipients of HHS funding with 15 or more employees

    HHS interim final rule, 45 CFR 84.84(b) (Federal Register 2026-09266) · checked 2026-10-08

  3. Upcoming

    ADA Title II web and document accessibility

    Smaller state and local government entities and special districts

    DOJ interim final rule, 91 FR 20902 (Federal Register 2026-07663) · checked 2026-10-08

  4. Upcoming

    HHS Section 504 web and document accessibility

    Recipients of HHS funding with fewer than 15 employees

    HHS interim final rule, 45 CFR 84.84(b) (Federal Register 2026-09266) · checked 2026-10-08

Questions

When is the HHS Section 504 deadline?

Under the May 2026 interim final rule, recipients with 15 or more employees must meet WCAG 2.1 AA by 2027-05-11. Smaller recipients have until 2028-05-10.

Does a review mean our documents meet the ADA?

No. A review finds issues for your team to fix and keeps a record of what was done. Whether you meet a rule is a question for your counsel.

Which files does it check?

Word and HTML files. Fixes to PDF files can go to a remediation partner.

Sources