Short answer: if your dental practice takes Medicaid, CHIP or other HHS funding, your website, patient portal, online forms and payment pages need to meet WCAG 2.1 Level AA. HHS moved the deadline by one year: May 11, 2027 for practices with 15 or more employees and May 10, 2028 for smaller ones. The extra year is time to fix things properly, not a reason to wait.
This guide explains what changed in May 2026, who is covered, what the standard means on a real dental website, and a quick check you can run on your own site in about 20 minutes. It is written for practice owners and office managers in the United States. It is not legal advice: ask your healthcare attorney whether your practice counts as a recipient.
What changed in May 2026
In 2024, HHS updated its rule under Section 504 of the Rehabilitation Act. For the first time it set a technical standard for the websites and mobile apps of organizations that receive HHS funding: WCAG 2.1 Level AA. Larger recipients had until May 11, 2026.
On May 7, 2026, the HHS Office for Civil Rights filed an interim final rule that pushed both dates back by a year. It took effect the same day and was published in the Federal Register on May 11, 2026.
| Practice size | Original deadline | New deadline |
|---|---|---|
| 15 or more employees | May 11, 2026 | May 11, 2027 |
| Fewer than 15 employees | May 10, 2027 | May 10, 2028 |
Two things did not change. The standard is still WCAG 2.1 Level AA, and HHS says the delay "does not relieve recipients of their other obligations under Section 504," including reasonable accommodations. The same notice also says HHS plans future rulemaking on the substance of the 2024 rule, so the requirements could still be revised. Until a new rule is published, plan against the dates above.
Who is covered
The rule applies to any entity that receives federal financial assistance from HHS, directly or indirectly. ADA News lists these among the dental organizations covered:
- Medicaid and CHIP dental providers
- Community health centers with dental services
- Dental practices and clinics affiliated with hospitals or health systems
- Dental schools and academic dental programs
- Dental specialists and researchers who receive federal funding
The employee count decides which deadline applies to you. If you are close to 15 staff, check the number with whoever runs your payroll and plan for the earlier date.
What it covers on a dental website
The rule is about web content and mobile apps, not only the homepage. ADA News names the patient-facing tools practices should check:
- The practice website, including service pages, team pages and blog posts
- Online booking and appointment request forms
- New patient intake, consent and medical history forms
- The patient portal and any practice app
- Online bill pay
One point catches many practices out. ADA News says it is not acceptable to rely on phone calls or staff help as a substitute for accessible digital tools. "Call us if the form does not work" is not a fix.
Many of these tools come from outside vendors: the booking widget, the intake form, the payment page. They still show up on your site and in your patients' journey, so ask each vendor in writing whether their tool meets WCAG 2.1 AA and when they last tested it.
What WCAG 2.1 AA means in plain terms
WCAG 2.1 is a long technical document. On a typical dental website, these are the requirements that matter most:
| Requirement | What it means on your site |
|---|---|
| Text alternatives | Photos of the team, the office and before and after cases have alt text that says what they show. Decorative images are marked as decorative. |
| Contrast | Normal text has a contrast ratio of at least 4.5 to 1 with its background. Light grey text on white and white text on pale photos often fail. |
| Keyboard access | Every menu, button, form field and booking step works with the Tab key alone, and you can see where the focus is. |
| Form labels and errors | Every field on the booking and intake forms has a visible label. Errors say what went wrong in words, not only with a red border. |
| Zoom and reflow | The page still works when text is enlarged to 200%, and content fits a narrow screen without scrolling sideways. |
| Video captions | Recorded videos, such as a welcome video or a procedure explainer, have captions. |
| Page structure | Each page has a clear title and headings in order, so screen reader users can jump to "Insurance" or "Book". |
| Time limits | Long intake forms do not time out without a warning and a way to ask for more time. |
A 20-minute check you can run today
You do not need special software to find the most common problems. Set aside 20 minutes and try this on your own site:
- Put the mouse away. On a desktop, press Tab from the top of the homepage. Can you reach the menu, the Book button and the phone number, and can you see which item is selected each time?
- Try to book with the keyboard only. Open your booking or appointment request form and complete it without the mouse. Note where you get stuck.
- Zoom to 200%. In the browser, zoom in until text is twice the size. Does anything overlap, disappear or need sideways scrolling?
- Read the light text. Look for grey text, text over photos and buttons with pale colors. If it is hard for you to read in daylight, it probably fails the contrast rule.
- Submit a form with a mistake. Leave a required field empty. Does the error message say which field and what to do?
- Play your videos. Do they have captions you can turn on?
- Turn on the phone's screen reader. VoiceOver on iPhone or TalkBack on Android. Listen to the homepage for one minute. Do images and buttons make sense when read aloud?
Write down each problem with the page address. That list is the brief for your web developer, and the same list helps you ask your booking, forms and payment vendors the right questions.
Common mistakes
- Waiting for 2027. A full fix often means changes to templates, forms and third-party tools. Each step can take weeks once vendors are involved.
- Fixing only the homepage. Patients use the booking, intake and payment pages as much as the homepage, and those are usually where the hardest problems are.
- Relying on a plug-in alone. A toolbar that changes font sizes does not repair missing form labels, keyboard traps or uncaptioned video. Fix the page itself.
- Leaving PDFs behind. Intake forms that are only available as scanned PDFs are hard or impossible to use with a screen reader. An accessible online form is usually the better route.
How this fits with the rest of your website
An accessible site is also a clearer site for everyone. Visible labels, readable text, a booking flow that works on any device and pages with a clear structure help every patient book. They also help search engines and AI assistants understand your pages. In our teardown of three of the best dental websites, the strongest sites already put booking and the phone number on the first screen and answer insurance and money questions on the page. Accessibility work is a good moment to do the same.
If your practice also has locations outside the US, the rules differ by country. For Australian practices, see our guide to dental clinics not showing on Google Maps. For practices in Alberta, see what the CDSA allows on a dental website.
Want a second pair of eyes?
If you are not sure how your booking flow, intake forms or templates would hold up, we can go through a few live pages with you. See how we work with practices on our dental websites page. Every project is planned and quoted after a short call. Book a free 15-minute call when it suits you.