Section 504 Battle Card  •  Print or save as PDF to share with your compliance team

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⚡ Quick Reference  •  Healthcare IT

Section 504 Compliance
Battle Card

29 U.S.C. § 794  •  45 C.F.R. Part 84  •  2024 HHS Final Rule (89 Fed. Reg. 40066)  •  Applies to all HHS financial assistance recipients — including Medicare & Medicaid billers

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May 11, 2026
🚧 Larger Orgs — 39 Days Remaining Organizations with 15 or more employees must have compliant web content, mobile apps, digital communications & telecom systems. Procurement timelines are 60–120 days — act now.
May 10, 2027
🕑 Smaller Orgs — 403 Days Organizations with fewer than 15 employees have until May 2027 — but same full scope applies. Early action avoids last-minute vendor scrambles.
What § 504 Requires

Section 504 prohibits discrimination against individuals with disabilities by any organization receiving HHS federal financial assistance — including every Medicare and Medicaid biller.

The 2024 HHS Final Rule (effective July 8, 2024) expanded requirements to cover digital and telecom accessibility, requiring web content and communications systems to meet WCAG 2.1 Level AA and telecom accessibility standards including TTY/RTT support.

Communications with persons with disabilities must be "as effective as communications with others." (45 C.F.R. § 84.77)

Who Is Covered
  • Medicare or Medicaid billers — any clinic, practice, or hospital that bills either program
  • HHS grant recipients — HRSA, SAMHSA, NIH, CDC-funded organizations
  • FQHCs & community health centers — explicitly covered
  • Behavioral health & safety-net providers
  • Small practices are NOT exempt — they have until May 2027, not 2026
  • Consequences: Loss of Medicare/Medicaid funding + HHS OCR complaints + private lawsuits
VoIP & Telecom Compliance Essentials (§ 84.77)
TTY / RTT Support
Must support Real-Time Text (RTT) as TTY replacement on VoIP. "We support TTY" without documentation is not sufficient — demand proof.
Hearing Aid Compatibility
Hardware and softphones must minimize RF interference. FCC HAC ratings required. VoIP codecs can degrade hearing aid performance — verify explicitly.
Video Relay Service (VRS)
Platform must support VRS calls so deaf patients can communicate via sign language interpreter through a relay service.
Auto-Captioning
Real-time captioning for calls, video conferences, and telehealth encounters. Required for patients who are deaf or hard of hearing.
VPAT Documentation
Demand a current Voluntary Product Accessibility Template (VPAT) — within 2 years. No VPAT = compliance risk. Non-negotiable for procurement.
Digital Channels
Patient portals, scheduling platforms, telehealth apps, and mobile apps must meet WCAG 2.1 Level AA. Covers color contrast, screen readers, keyboard nav, captions.
⚠️
VoIP TTY Incompatibility — The Hidden Gap
VoIP compresses audio as digital packets, disrupting the audio-tone encoding that TTY devices use. This is a documented, widespread problem acknowledged by both the FCC and HHS. Any organization on VoIP must confirm their vendor supports RTT natively or has certified TTY passthrough — or they have a §504 compliance gap even if everything else is in order.
6-Step Action Checklist
1

Confirm Your Deadline

Count FTEs. 15+ = May 11, 2026. Under 15 = May 10, 2027. Confirm you receive HHS assistance (Medicare/Medicaid = yes).

2

Audit All Systems

Catalog every patient-facing system: phone, portal, scheduling, telehealth, mobile app. Request current VPAT from each vendor.

3

Interrogate Your Telecom Vendor

Ask: RTT support? HAC rating? VRS support? TTY passthrough method on VoIP? If no confident answer — flag as a compliance gap.

4

Prioritize Gaps

Determine remediation path: upgrade plan, enable feature, or replace vendor. Patient-facing communications gaps = highest priority.

5

Find Compliant Alternatives

Use Clearony's free Needs Analysis to find vendors that match your clinical environment, volume, budget, and §504 requirements.

6

Document Everything

Retain VPATs, certifications, audit records, and remediation actions. Documentation is your first defense against HHS OCR complaints.

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Section 504 Battle Card  •  April 2026  •  29 U.S.C. § 794  |  45 C.F.R. Part 84  |  89 Fed. Reg. 40066