Section 1557: Understanding Document Accessibility Requirements

The rules governing accessible healthcare communication can be difficult to track. Section 1557 of the Affordable Care Act, Section 504 of the Rehabilitation Act, and the Americans with Disabilities Act (ADA) often apply to the same organization. Here’s the catch: they do not all impose the same requirements or follow the same compliance schedule.

The differences became especially significant in May 2026, when the U.S. Department of Health and Human Services (HHS) extended the deadline for certain web and mobile accessibility requirements under Section 504. The extension provides covered recipients with more time to meet the technical standard. However, it does not delay their obligation to provide effective communication and equal access upon request. 

If you are confused about why Section 508 is not the governing law that implemented change, let me clear that up for you. Section 508 is federal guidance for internal federal programs, whereas Section 504 requires agencies to provide equal access to people with disabilities. 

What is Section 1557?

Section 1557 is the nondiscrimination provision of the Affordable Care Act. Enacted in 2010, it prohibits discrimination in covered health programs and activities on the basis of race, color, national origin, sex, age, or disability.

The law draws on four long-standing federal civil rights laws:

• Title VI of the Civil Rights Act of 1964
• Title IX of the Education Amendments of 1972
• Section 504 of the Rehabilitation Act of 1973
• The Age Discrimination Act of 1975

Section 1557 does not replace these laws. It applies their nondiscrimination protections to covered healthcare programs and activities and provides HHS with a framework for enforcement. This may seem overwhelming, but the intent is to protect those who need it most. Many of these laws overlap, but each addresses different areas of concern and civil rights.

Who must comply?

Section 1557 generally applies to health programs or activities receiving HHS financial assistance, to programs administered by HHS, and to entities established under Title I of the Affordable Care Act. Depending on an organization’s funding and structure, covered entities may include:

• Hospitals, clinics, and physician practices
• Community health centers
• Nursing facilities, home health agencies, and hospice providers
• Dental and vision care providers
• State Medicaid and Children’s Health Insurance Program agencies
• Health Insurance Marketplaces and issuers participating in them
• Health insurance carriers and third-party administrators when their covered activities fall within the rule

Coverage can be fact-specific and may seem like a moving target. To determine whether your organization is responsible, review the source and purpose of its federal funding, the health programs or activities it operates, and any responsibilities it has assumed through contracts or other arrangements. This is the best practice for understanding which laws apply and why.

What does document accessibility require?

Section 1557 requires covered entities to take appropriate steps to ensure that communications with people with disabilities are as effective as those with others. This includes providing appropriate auxiliary aids and services, free of charge and in a timely manner, when necessary for effective communication.

For a person who is blind or has low vision, an appropriate format may include:

• Braille
• Large print
• Accessible electronic text that works with assistive technology
• Tagged and accessible PDF documents
• Audio
• Another format or service that provides equally effective access

The right format depends on the person and the communication. A person who is blind may not read braille. Someone with low vision may need large print with sufficient contrast, while another person may rely on a screen reader. Providing a single format to everyone is not an effective communication strategy. Likewise, some people may need more than one format depending on the situation.

Just an FYI, these responsibilities can also extend to a companion, such as a parent, spouse, caregiver, or other person involved in communicating about the patient’s care. It’s important to remember that it’s not just the patient who has rights your organization must follow.

The individual’s communication needs matter

The appropriate aid or service depends on the communication’s complexity and context, as well as the person’s usual method of communication. An appointment reminder may require a different solution than a consent form, treatment plan, explanation of benefits, or a notice affecting healthcare coverage.

State and local government entities covered by Title II and Title III of the ADA must give primary consideration to the aid or service requested by a person with a communication disability. A different method may be used when the entity demonstrates that it is equally effective or that the requested method would cause a fundamental alteration or undue financial and administrative burdens. Even then, the entity must take another action that provides effective communication to the greatest extent possible.

The following is very important: staff should neither assume nor request that a family member or companion serve as the person’s communication method. This not only deprives the person of their right to independence and privacy but also violates HIPAA. Properly training all staff members is key to remaining compliant and protecting the rights of others.

What information needs to be accessible?

If information is provided to patients, members, applicants, or the public, accessibility should be considered from the beginning. Examples include:

• Insurance plans, explanations of benefits, and marketing materials
• Consent forms and treatment information
• Patient rights and grievance information
• Notices of nondiscrimination and notices about language assistance and auxiliary aids
• Billing statements, appointment information, and prescription instructions
• Emails, websites, mobile applications, patient portals, and digital forms
• Emergency, discharge, and follow-up instructions

Accessibility also extends beyond documents. Buildings, facilities, signage, kiosks, telehealth services, digital workflows, and policies can all affect whether a person has meaningful access to a healthcare program or service.

How Section 1557 and Section 504 work together

The 2024 Section 1557 rule requires covered health programs and activities delivered via information and communication technology to be accessible to people with disabilities. It also reinforces requirements for effective communication, reasonable modifications, and nondiscrimination for healthcare services delivered in person, digitally, and through telehealth.

A separate HHS rule issued in 2024 under Section 504 established a technical standard for web content and mobile applications. Covered recipients of HHS funding must conform that content to the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, subject to the rule’s exceptions and limitations. Because many healthcare organizations are covered by both Section 1557 and Section 504, the requirements work together in practice.

HHS extended the Section 504 digital accessibility deadlines

On May 7, 2026, HHS announced an Interim Final Rule that gives recipients of HHS financial assistance an additional year to meet the Section 504 WCAG 2.1 AA requirements for web content and mobile applications.

The revised deadlines are:

• May 11, 2027, for recipients with 15 or more employees
• May 10, 2028, for recipients with fewer than 15 employees

The extension applies to the technical compliance dates under the HHS Section 504 rule. It does not eliminate or delay the broader obligation to ensure that programs and activities are accessible. HHS specifically reminded recipients that web content and mobile applications must remain readily accessible and usable by people with disabilities.

In practical terms, an organization should not deny a person access while awaiting the WCAG deadline. If an inaccessible portal, PDF, mobile application, or online form prevents someone from receiving information or using a service, the organization still needs to provide an effective and timely means for that person to participate.

Third-party vendors do not remove responsibility

Healthcare organizations often rely on outside vendors for websites, patient portals, billing platforms, mobile applications, document production, and communications. Accessibility responsibilities do not disappear when a service is outsourced. Section 504’s web and mobile requirements expressly apply to content made available directly or through contractual, licensing, or other arrangements, and Section 1557-covered entities remain responsible for operating their health programs without disability discrimination.

Accessibility expectations should be addressed during procurement, incorporated into contracts, tested before launch, and monitored after implementation. A vendor’s general statement that a product is accessible is not a substitute for meaningful review.

Policies and procurement practices that proactively support accessibility for all people will save your organization time, headaches, violations, and reputational damage.

Notices, policies, and internal responsibility

The 2024 Section 1557 rule includes requirements for notices, written policies and procedures, employee training, and—when the applicable employee threshold is met—a designated Section 1557 Coordinator. These internal systems help ensure that requests for accessible communication are recognized and handled consistently.

Organizations should make it easy for patients and members to find out:

• How to request an auxiliary aid, accessible document, or reasonable modification
• Who is responsible for coordinating the request
• How to file an internal grievance
• How to contact HHS’s Office for Civil Rights

Enforcement and complaints

HHS’s Office for Civil Rights investigates complaints and conducts compliance reviews under Section 1557 and Section 504. OCR may require corrective or remedial action when it finds noncompliance. Depending on the law and the circumstances, additional legal remedies may also be available.

Good documentation matters. Covered entities should retain records of accessibility requests, the interactive steps taken to understand the person’s needs, the aid or format provided, the response timing, and the basis for any decision that a requested method could not be provided.

What healthcare organizations should do now?

The additional time should be used to strengthen accessibility, not to postpone it. Healthcare organizations can begin by:

• Inventorying public-facing and patient-facing documents, websites, portals, forms, and mobile applications
• Prioritizing communications that affect health, safety, consent, coverage, benefits, billing, and legal rights
• Establishing a reliable process for producing braille, large print, accessible electronic documents, and audio materials
• Reviewing vendor contracts and procurement requirements
• Training employees to recognize and respond to requests for effective communication.
• Testing digital content with both automated tools and people who use assistive technologies
• Tracking progress toward the applicable Section 504 deadline in May 2027 or May 2028.

Final thoughts

The 2026 deadline extension provides additional time to meet the Section 504 technical standard for web content and mobile applications. It is not a pause on accessibility. Section 1557, Section 504, and the ADA continue to require covered organizations to communicate effectively and provide equal access to healthcare programs and services. Use the extra time to implement your compliance plan and train your staff. Do not wait until the deadline to comply. Compliance requires a skilled, methodical approach. 

Accessible communication is a right, not a privilege.

Braille Works now offers consulting services to entities seeking to explore how to bring their entity into regulatory compliance in an efficient and streamlined way. We also provide training on identifying needs and addressing them in the most legal and professional way possible. Reach out to us for more information.

This article is for general informational purposes and is not legal advice.