DOJ Just Extended ADA Title II by 1 Year. HHS Section 504 Did NOT — Why FQHCs Still Have to Comply by May 11

Two Rules. One Got Extended. One Did Not.

There are two federal web-accessibility rules in play right now, and both reference the same WCAG 2.1 Level AA technical standard. They sound interchangeable. They are not.

• ADA Title II (DOJ-administered): Covers state and local governments — counties, public hospital districts, city public health departments. Original deadlines were April 24, 2026 (50K+ population) and April 24, 2027 (under 50K). DOJ extended these on April 20 to April 26, 2027 and April 26, 2028 respectively.
• HHS Section 504 (HHS-OCR-administered): Covers any entity that receives HHS funding — which is every FQHC. The compliance date is May 11, 2026 for entities with 15 or more employees, and May 10, 2027 for those with fewer than 15. HHS did not match DOJ's extension.

AHA News confirmed this on April 22. Jackson Lewis, Duane Morris, and Holland & Knight all published guidance reaching the same conclusion: the DOJ extension is for state and local governments under Title II. Section 504 deadlines remain unchanged. If your FQHC takes any HHS dollars — Section 330 grant, Medicaid PPS, Medicare, BHCIP, ARP, NHSC — you are governed by the rule that did not get extended.

Why the Confusion Risk Is So Dangerous Right Now

Mainstream coverage of the April 20 DOJ rule led with 'web accessibility deadline extended.' That framing is true for cities and counties. It is false for FQHCs. The risk is that an executive director or compliance officer reads the news, exhales, and shifts the May 11 remediation work down the priority list. That decision would create real exposure.

There is also a separate signal worth flagging. On April 22, Converge Accessibility published what it called a 'Red Alert' suggesting the HHS Section 504 rule itself may be subject to administration review. Nothing has been formally proposed. No rulemaking notice. Legal advisors uniformly recommend assuming the rule holds. Translation: you cannot plan around a rumor of relief that may never arrive. You can plan around a deadline that has been on the calendar for over a year.

What Section 504 Actually Requires

The May 11 deadline applies to web content and mobile applications used to deliver programs, activities, and services. For FQHCs, that scope is broad. The compliance bar is WCAG 2.1 Level AA.

• Public website (homepage, location finder, services, hours, contact, ADA notice).
• Patient portal — including any portion patients log into for appointments, messaging, prescription refills, or visit records.
• Online appointment scheduling, intake forms, and registration flows.
• Pre-visit forms, post-visit summaries, and any patient-facing PDF documents (sliding-fee scale forms, financial assistance applications, consent forms).
• Mobile apps tied to patient access, telehealth, or care coordination — including third-party apps you direct patients to use.
• Marketing pages, blog posts, and educational content if they are part of how patients access services.
• Job application portals and careers pages — these are 'programs' offered by your organization, even when handled through a third-party ATS.

Holland & Knight's April 2026 guidance specifically called out the 'digital front door' — virtual visits, online intake, e-prescribing, telehealth platforms — as the highest-risk surface area for Section 504 review. If a patient with a disability cannot complete an online appointment booking with a screen reader, that is the kind of fact pattern that becomes an OCR complaint.

What an OCR Complaint Actually Looks Like

OCR enforcement of Section 504 historically follows a standard pattern: complaint filed, OCR opens investigation, voluntary resolution agreement (VRA) negotiated. The VRA typically requires the FQHC to remediate within a defined timeline, train staff, designate an ADA coordinator, post grievance procedures, and submit periodic compliance reports for 1–3 years.

Resolution agreements are public. Recent OCR healthcare actions have included six-figure remediation costs, third-party accessibility audits, mandatory annual reporting, and — in HIPAA cases — eight-figure settlements (PIH Health: $600K phishing settlement in 2025; Metropolitan Community Health Services: $25K for a 1,263-patient breach). Section 504 will follow the same enforcement architecture: deficiency letter, VRA, public docket entry. Any FQHC facing a VRA loses the ability to claim 'we didn't know' going forward — which makes any subsequent complaint more expensive.

The 15-Day Triage Plan

If your FQHC is not yet in compliance, you do not have time to run a clean perfect-state remediation. You have time for triage. Below is a defensible 15-day plan that focuses energy on the surfaces that get patients through the door and the documentation OCR will look for first.

• Days 1–3: Run an automated WAVE or axe DevTools scan on your homepage, location finder, services, contact, and patient-portal entry page. Collect the issue list. Tag each item: keyboard navigation, color contrast, alt text, form labels, focus indicators.
• Days 4–7: Fix the top three categories of issues sitewide. Missing alt text and form labels are usually 80% of the volume and the lowest-effort fix. Color-contrast failures often require design-token updates. Keyboard traps and missing focus indicators are higher impact, lower volume.
• Days 8–10: Test the patient portal login + scheduling flow with a screen reader (NVDA on Windows is free; VoiceOver on macOS is built in). Document every blocker. Even if you cannot fix all of them by May 11, having the documentation shows good-faith remediation effort.
• Days 11–13: Publish your accessibility statement. Designate an ADA/Section 504 coordinator and post their contact info. Establish a documented grievance procedure. These are programmatic compliance items independent of the technical fixes.
• Days 14–15: Add a remediation roadmap with quarterly milestones for items you cannot fix by deadline. OCR distinguishes between 'no effort' and 'imperfect but documented effort.' Plant the flag publicly.

If you outsource your website to an EHR vendor (OCHIN, NextGen, eClinicalWorks portals): demand their Section 504 conformance documentation in writing this week. You are accountable for content delivered through your domain even if a vendor renders it.

Why This Hits FQHCs Disproportionately

FQHC patient panels are weighted toward people with disabilities, older adults, and limited-English-proficiency populations — exactly the groups Section 504 was designed to protect. According to UDS data, roughly 1 in 4 FQHC patients has at least one disability that affects daily function. Many use assistive technology to access health information online. A patient who cannot read your appointment portal with a screen reader cannot get care.

There is also a workforce dimension. A patient-portal screen-reader failure is a patient-care failure, but a careers-page accessibility failure is a workforce equity failure. FQHCs that cannot make their job application portals accessible are systematically excluding candidates with disabilities from the safety-net workforce — including the candidates most likely to share lived experience with the patient panel.

What This Connects To: Section 1557 Is Coming Right Behind

May 11 is not the only HHS civil rights deadline on FQHC executives' calendars. The HHS Section 1557 Annual Notice of Availability (free language assistance services in English plus the 15 most common LEP languages in your state) has been in effect since July 5, 2025 — meaning the Year 1 compliance review window approaches July 5, 2026.

California's 15 LEP languages include Spanish, Chinese, Vietnamese, Tagalog, Korean, Armenian, Russian, Persian, Arabic, Punjabi, Khmer, Hmong, Hindi, Japanese, and Mon-Khmer. The Notice has to be posted, distributed, and translated. Two HHS OCR rules with overlapping enforcement risk land in the same eight-week window. The same compliance officer who is sprinting toward May 11 is going to be doing language-access readiness in June. Plan for both.

The Bottom Line

DOJ extended Title II by a year. HHS did not extend Section 504. Fifteen days remain. The single most useful action you can take today is to email your IT lead, your communications lead, your patient experience lead, and your compliance officer with the question: 'Do we have a Section 504 readiness plan for May 11, and have we confirmed the DOJ extension does not apply to us?' If the answer is hesitant, you have your priority for the next two weeks.