HHS Section 504 / WCAG 2.1AA Deadline 9 Days Away — Final Sprint Week for Every CA FQHC With 15+ Employees

Today is May 2, 2026 — exactly 9 days from the May 11 HHS Section 504 enforcement date for digital accessibility (WCAG 2.1 Level AA). All FQHCs with 15+ employees must have remediated patient portals, public websites, mobile apps, online scheduling, telehealth platforms, intake forms, and self-service kiosks. The April 22 AHA News confirmation reiterated: the DOJ Title II web accessibility extension does NOT apply to HHS Section 504 — Section 504 enforcement window stays open. The April 22 Converge Accessibility 'Red Alert' speculated about regulatory contest, but no official rescission has occurred — assume the deadline holds. Final-sprint focus: confirm contrast ratios, alt text, keyboard navigation, ARIA roles, screen-reader compatibility, and accessibility statement publishing. Section 504 also provides a private right of action — even without OCR enforcement, lawsuits can begin May 12. Document remediation work and good-faith compliance posture even if 100% conformance is not yet complete.