Back in 2024, the Department of Health and Human Services (HHS) updated Section 504, and it changed the game for how community clinics handle their digital presence. For the first time, there is a strict technical standard for any organization receiving federal funding which includes your health center.
Meeting WCAG 2.1 Level AA is no longer just a “nice to have” or a design best practice; it’s now a federal requirement. The reality is that most FQHCs haven’t had the chance to audit their sites against these new rules yet, and many aren’t aware that the clock on these deadlines has already started ticking.
Before 2024, Section 504 required federally funded organizations to not discriminate against people with disabilities. How that applied to websites was left to interpretation, and largely ignored.
The 2024 HHS rule ended that ambiguity.
It now requires WCAG 2.1 Level AA compliance across your website, patient-facing tools, and downloadable documents. Deadlines are based on organization size. Most FQHCs, as large entities with 15 or more employees, face the shorter compliance window.
This is separate from the DOJ’s Title II rule, which covers government entities and does not apply to FQHCs. The HHS Section 504 rule does, but many web agencies do not know the difference, we do.
Section 504 covers more than your homepage. It covers every digital touchpoint a patient interacts with through your website:
| Approach | Works? | Reality |
|---|---|---|
| Overlay tools | No | Does not meet WCAG |
| Patch fixes | Limited | Breaks over time |
| Partial remediation | Weak | Misses structural issues |
| Full rebuild | Yes | Fixes root problems |
ADA website lawsuits against healthcare organizations cost between $25,000 and $150,000 to resolve. Most begin with an automated scan of your public website, not a patient complaint.
For FQHCs, non-compliance now runs on two tracks: ADA litigation exposure and Section 504 federal funding compliance. A non-compliant website is no longer just a lawsuit risk. It is a risk to your federal designation.
A professional audit costs a fraction of a demand letter response.
We work exclusively with FQHCs and community health clinics. We don’t spend out time on restaurants, or tech start ups.
That means we already know what a sliding fee scale disclosure looks like, why your intake process works the way it does, and what HRSA expects from a federally funded health center’s digital presence. You do not spend the first three meetings educating us.
We’ve built and audited FQHC websites for providers all over the country from our home base here in Charlotte, bringing nationwide experience to the health centers that need it most.
WCAG 2.1 AA requires your website to be usable by people with disabilities, including:
For FQHCs, this applies to all patient-facing content, including appointment forms, service pages, and navigation.
No. Websites fall out of compliance over time due to:
This is why many FQHCs fix issues once but still remain exposed later.
The only reliable way is through a combination of:
A checklist or tool alone is not enough.
We consistently see:
These issues often affect both compliance and patient access.
It depends on the structure of your website.
If issues are isolated, internal teams may be able to address them.
However, when problems are systemic (navigation, templates, content structure), fixing them properly usually requires deeper changes.
Many FQHCs start with remediation, but move to a rebuild when issues are widespread or recurring.
It depends on the scope:
Risk includes:
In many cases, the bigger issue is operational , patients cannot easily access care through your website.
No. Overlay tools do not meet WCAG 2.1 AA requirements and do not fix underlying accessibility or usability issues.
At minimum:
Many issues are introduced gradually over time.
You receive:
Your team can act on it, or we can scope the work if needed.
Rebuild is typically the better option when:
In these cases, fixing individual issues becomes inefficient and unreliable.
