Section 504 & ADA Compliance: What Every Health Center Leader Needs to Do Before the Deadline

May 20, 2026

Episode Overview

Section 504 of the Rehabilitation Act has always required organizations receiving federal funding to provide equal access to people with disabilities. The May 2024 HHS final rule made it explicit: digital accessibility is part of that obligation, and FQHCs are squarely in scope. With the compliance deadline extended by one year to May 2026, health centers have a real window to act—but most leaders aren’t yet aware of what the rule requires, where the litigation risk is greatest, or what it actually takes to demonstrate good-faith effort. In this episode, Jill is joined by Steve Weinman and Jen Garces de Marcilla, both of FQHC Associates, to break down what the rule actually covers, what NOT to do, and why digital accessibility is one of the clearest patient experience opportunities health center leaders are going to get this year.

Disclaimer

Nothing in this episode constitutes legal advice. Accessibility compliance is an evolving area. The goal of this conversation is to help health center leaders understand the rule, reduce barriers for their patients, and demonstrate documented, good-faith effort toward compliance.

In This Episode, You’ll Learn

  • What Section 504 actually requires now that digital accessibility is explicitly in scope

  • The new compliance deadline (May 2026)—and why “I have a year” is the wrong mental model

  • The specific digital surfaces this rule covers: websites, patient portals, online scheduling, mobile apps, kiosks, PDFs, EHRs, and embedded third-party tools

  • How AI-powered “secret shoppers” are scanning websites for noncompliance—and why even small health centers are exposed

  • Why accessibility widgets and overlays are NOT a compliance solution (and may make things worse)

  • The most common, lowest-cost, highest-impact fixes: alt text, color contrast, captions, keyboard navigation, screen reader compatibility, and accessible PDFs

  • Why “we’ve never had a complaint” is not a defense

  • What “good-faith effort” actually looks like—especially when your EHR vendor isn’t compliant

  • How to handle vendor contracts and renewals going forward

  • The patient experience angle most leaders are missing—and how accessibility supports transformational, not transactional, care

  • Why accessibility benefits temporary disabilities and aging patients, not just permanent disabilities

  • Where the budget realistically comes from—and why a properly optimized website pays for itself

Key Takeaways

“It’s not just a compliance issue. It’s not even just a legal issue. It is a patient experience issue as well. Patients are looking for more of a transformational healthcare experience now rather than a transactional one.”

— Jill Steeley

“By making things accessible for people who might have disabilities, you’re actually making them more accessible for everyone. It’s not necessarily just for people that have permanent disabilities.”

— Jen Garces de Marcilla

“If you do it right, it pays for itself, because if you’re not running at peak efficiency, you are hemorrhaging visits and patients.”

— Steve Weinman

Free 504 Toolkit

To request a free 504 Toolkit, email [email protected] with “504 toolkit” in the subject line.

Mentioned in This Episode

Connect & Subscribe

If this episode was valuable to you, please:

  • Leave a rating and review

  • Subscribe so you never miss an episode

  • Share with a fellow health center leader who needs to hear this

Have a topic request or feedback? Jill would love to hear from you.

© 2026 Jill Steeley