Posted in: Announcements

AAAHC urges health care organizations to take immediate action to comply with updated Section 504 regulations under 45 CFR Part 84. The updated Section 504 reinforces nondiscrimination requirements for individuals with disabilities. These updates apply to all providers and facilities receiving federal financial assistance, including those participating in Medicare and Medicaid programs.

Accessibility is now a core operational responsibility. Providers must ensure that patients with disabilities can access services, communicate effectively, and use digital tools without barriers.

Key Compliance Deadline

By July 8, 2026, covered entities are generally required to:

  • Maintain at least one accessible examination table (if exam tables are used)
  • Maintain at least one accessible weight scale (if weight scales are used)
  • Meet medical diagnostic equipment (MDE) scoping requirements, typically ensuring at least 10% (or a minimum of one unit) of each type is accessible (or 20% for mobility-focused specialties)

Additionally, all new MDE acquired after July 8, 2024 must meet accessibility standards until the organization achieves full compliance with scoping requirements.

What This Means for Organizations

The updated rule expands expectations beyond physical access, requiring a comprehensive approach to accessibility across all aspects of care delivery. Key focus areas include:

  • Accessible medical equipment
    Examples include exam tables, scales, diagnostic tools
  • Effective communication
    This includes qualified interpreters and auxiliary aids
  • Digital accessibility
    Websites, portals, mobile apps, and AI-supported tools must be navigable and usable by all patients
  • Policies and procedures
    These must prioritize equitable access at every stage of care
  • Staff training
    Employees must be able to identify and address patient access needs
  • Documentation
    Record compliance efforts and corrective actions when they are necessary

Surveyors and regulators will expect evidence that organizations are proactively identifying gaps, implementing remediation plans, and integrating accessibility into daily operations.

Act Now

AAAHC recommends that organizations begin preparing immediately by taking the following steps:

  • Inventory and assess accessibility of current medical equipment
  • Evaluate facilities and physical environments for barriers
  • Review communication practices and availability of accommodations
  • Audit digital platforms for accessibility and equity
  • Update policies, procedures, and workflows
  • Train leadership and frontline staff
  • Maintain documentation of assessments, actions, and outcomes

Use the crosswalk tool developed by AAAHC to align your organization’s Section 504 requirements with AAAHC Standards. While this resource can guide gap assessments and corrective action planning, organizations must ensure compliance with the actual regulatory requirements, not solely accreditation standards.

The Bottom Line

Patient accessibility is no longer an optional or low-priority initiative. Organizations that act now can reduce regulatory risk, improve patient experience, and advance equitable access to care. Those that delay may face enforcement actions, increased costs, and reputational harm.

For additional resources and guidance, AAAHC encourages organizations to review the full Section 504 regulation and incorporate accessibility into ongoing quality and compliance initiatives. To help guide your alignment efforts, access our crosswalk tool here.