ADA And Web Accessibility: Is Your Healthcare Website Ready?

For healthcare marketers, the shift to WCAG 2.1 isn’t just a technical update; it’s a move toward better patient equity and access.

In the U.S., the Department of Health and Human Services (HHS) has mandated that healthcare organizations receiving federal funding under Section 504 of the Rehabilitation Act conform to WCAG 2.1 Level AA standards by May 2026. These accessibility standards are organized around four principles: content must be perceivable, operable, understandable and robust.

I spoke with Aimee Morgan, President & CEO of Good Aim Communications, a digital agency focused on helping healthcare and government entities achieve compliance, about the impact of the federal guidelines for health organizations.

What are the key elements of the WCAG guidelines required by May 2026?

The May 2026 deadline applies to healthcare organizations receiving federal funding under Section 504 of the Rehabilitation Act, requiring conformance with WCAG 2.1 Level AA standards.

“A common misconception is that this only affects public hospitals,” Morgan said. “While the April 2026 ADA Title II deadline specifically targets government entities, the HHS Section 504 rule captures virtually any healthcare organization receiving federal funding through Medicare or Medicaid, which includes most hospitals and many private practices.”

What can be achieved on the content side, and which may need the help of a developer?

“The key distinction is that content accessibility is about what you publish, while technical accessibility is about how the underlying code supports assistive technologies,” Morgan said.

Content teams can handle several key areas without developer intervention:

• Writing meaningful alt text for images that conveys the purpose and content
• Ensuring sufficient color contrast (4.5:1 for normal text, 3:1 for large text)
• Structuring documents with proper heading hierarchy
• Creating descriptive link text rather than “click here”
• Adding captions and transcripts for video and audio content
• Writing in plain language that’s accessible to users with cognitive disabilities.

Developer support is typically needed for:

• Ensuring keyboard navigation works throughout the site
• Implementing proper ARIA labels and roles
• Making forms accessible with associated labels and error handling
• Ensuring screen reader compatibility
• Managing focus states for interactive elements
• Making dynamic content updates accessible.

Does installing an overlay make your site compliant?

“No. In fact, overlays can increase your legal risk,” Morgan said. “In 2024, roughly 25% of all ADA lawsuits explicitly cited accessibility widgets or overlays as barriers rather than solutions. In the first half of 2025, that number held steady at around 23%, representing over 450 lawsuits.

“More than 700 accessibility professionals have signed an open letter opposing overlay widgets. The fundamental problem is that overlays attempt to modify how content is displayed rather than fixing the underlying code. When plaintiff attorneys scan websites for violations, they’re looking at the source HTML–not the overlay-modified version. Courts have consistently held that actual accessibility is required, not the appearance of effort.”

The FTC recently reinforced this, reaching a $1 million settlement in January 2025 with a leading overlay provider for misleading businesses about what their widget could actually do.

“When you install an overlay, you’re signaling awareness of accessibility obligations,” Morgan said. “If your site remains non-compliant, plaintiffs can argue you knew about the problem and chose a cheap fix over real remediation.”

How can creative teams maintain a high-end brand aesthetic while meeting digital accessibility requirements?

“Accessibility and beautiful design aren’t mutually exclusive–in fact, many accessibility principles lead to better design,” Morgan said. “The key is building accessibility into the creative process from the start rather than treating it as an afterthought.”

For visuals:

• Choose color palettes with sufficient contrast. Tools like Stark or WebAIM’s contrast checker can validate choices during the design phase.
• Use color to enhance meaning, not convey it exclusively. Pair color coding with icons, patterns or text labels.
• Hero images can remain dramatic while still being paired with clear, accessible text.

For video:

• High-quality captions aren’t just legally necessary; they’re increasingly expected. Studies show most people watch mobile video with the sound off. Thoughtful caption styling that matches your brand actually enhances the viewing experience.
• Audio descriptions for complex medical procedures or facility tours can be crafted as polished brand content rather than afterthoughts.

“The real shift is treating accessibility as a design constraint that sparks creativity, the way responsive design or mobile-first thinking reshaped how we approach web design,” Morgan said. “The most sophisticated brands now view accessibility as a signal of quality, not a limitation.”

What misconceptions have you seen about this new requirement?

Many of the misconceptions center on the scope of the requirements. Morgan says the WCAG 2.1 AA requirements extend well beyond traditional websites.

“I see organizations underestimating the scope,” Morgan said. “This isn’t just about your main website. Patient portals, mobile apps, online scheduling tools, telehealth platforms, and intake forms must all be accessible. You need to verify that, not just trust vendor claims. If any step of an appointment booking or intake process is inaccessible, a patient may be unable to access care.

“The business case is compelling: research consistently shows that accessible user experiences reduce friction, improve conversion rates and increase customer satisfaction across the board. When you design for the edges, you improve the center.”