HHS Section 504 / WCAG 2.1AA Deadline 7 Days Away — DOJ Title II Extension Confirmed Not Mirrored by HHS

Today is May 4, 2026 — exactly 7 days from the May 11 HHS Section 504 enforcement date. Key clarification: legal advisories from Duane Morris (April 26) and Alston & Bird (March) confirm that the DOJ's April 20 Interim Final Rule extending Title II ADA web accessibility deadlines for state/local government agencies does NOT apply to HHS Section 504.

Many FQHC executives have wrongly assumed the extension applied to them — it does not. The May 11 deadline holds. OCR enforcement focus: documented good-faith progress (not perfect WCAG 2.1 AA conformance).

But Section 504 has been enforceable since July 8, 2024 — May 11 simply makes WCAG 2.1 AA the technical benchmark. Critical: private right of action begins May 12. ADA-related litigation against healthcare providers grew 11% year-over-year in 2025, much of it Section 504-based.

Final-week priorities: confirm exam table + scale ≥10% of MDE accessibility (HRSA OSV will check this), publish accessibility statement, document remediation timeline, train front-desk staff on accessibility complaint intake.