Healthcare consistently ranks among the most active sectors for digital accessibility litigation. In 2025 alone, 5,114 digital accessibility lawsuits were filed across industries — and healthcare's share continues to grow as plaintiff attorneys gain access to an explicit technical standard under the 2024 Section 504 Final Rule.
Yet for many healthcare organizations, the actual state of their digital accessibility is unknown. Audits are expensive, internal expertise is scarce, and the daily demands of running a healthcare operation leave little bandwidth for systematic digital review.
To understand the gap between where healthcare organizations need to be — and where they actually are — we scanned 300 websites belonging to organizations subject to Section 504 requirements, evaluating them against WCAG 2.1 Level AA criteria.
What we found was consistent across the board: accessibility failures in this sector are not isolated or edge-case. They are structural, widespread, and concentrated in exactly the areas patients rely on most.
Why we conducted this scan
The 2024 HHS Section 504 Final Rule establishes WCAG 2.1 Level AA as the technical standard for digital accessibility across HHS-funded healthcare organizations.WCAG — the Web Content Accessibility Guidelines, developed by the World Wide Web Consortium (W3C) — defines measurable criteria across three conformance levels: Level A covers the most fundamental requirements, Level AA is the standard required by most accessibility regulations worldwide and what Section 504 now mandates, and Level AAA represents the highest level of conformance.
Most organizations understand the regulation in broad terms. Fewer have a clear picture of where their digital environment actually stands against it.
To provide that picture, we evaluated 300 websites belonging to healthcare organizations subject to Section 504 requirements against WCAG 2.1 Level AA criteria — examining the foundational accessibility components most directly tied to usability, workflow completion, and patient access.
What we found across 300 healthcare websites
The results point in one direction. Of the healthcare websites we scanned against WCAG 2.1 Level AA criteria:
- 84.3% showed measurable accessibility gaps
- Only 15.7% met baseline accessibility benchmarks
- 90% had no visible accessibility solution in place
That means 5 in 6 websites belonging to organizations now subject to Section 504's digital accessibility requirements have failures that would be detectable by a patient using assistive technology — and documentable by OCR in a compliance review.
The 90% figure is worth pausing on. It means that beyond having accessibility failures, the vast majority of these organizations have no structured accessibility program visible in their digital environment at all. Not a partial solution. Not a work in progress. Nothing.
For organizations preparing to demonstrate good-faith, documented progress to OCR — which is the standard the enforcement framework is built around — that absence is itself a significant risk.
Where the gaps are concentrated
The scan evaluated six foundational accessibility areas — the components most directly tied to whether patients can navigate, interact with, and complete tasks on a healthcare website. The failures were not evenly distributed. They clustered in the structural and interactive layers that patients depend on most.
Structural navigation
Only 14% of sites properly structured their pages for assistive technologies. Page landmarks — the structural signposts that allow screen reader users to move efficiently between sections of a page — were missing or incorrectly implemented on the vast majority of sites scanned.
For a patient using a screen reader to find a contact form, a service description, or a scheduling link, the absence of proper structure means navigating the entire page linearly — a slow, disorienting experience that often ends in abandonment.
Forms and transactions
Labeling and error clarity were inconsistent across the sites scanned. For healthcare organizations, this is a high-stakes category: equipment ordering, appointment scheduling, intake forms, and bill payment all depend on forms that assistive technology users can navigate and complete independently. When form fields lack proper labels, a screen reader user may not know what information a field is asking for — or whether they've made an error.
ARIA and dynamic content
Only 29% of sites properly implemented ARIA attributes for modern interactive elements. ARIA — Accessible Rich Internet Applications — is the technical framework that allows dynamic web components to communicate their state and purpose to screen readers. Without it, dropdowns, modals, and tabbed interfaces may be invisible or meaningless to assistive technology users.
Tables and data presentation
0% of scanned sites passed table accessibility checks. Pricing information, service comparisons, product listings, and billing details — content patients frequently need to review before taking action — may be entirely unreadable for users relying on assistive technologies.
Tabs and interactive components
Fewer than 1% of sites handled tab functionality correctly. Tabbed navigation is common in healthcare web environments, used to organize services, resources, and patient information. When tab functionality is inaccessible, the content behind those tabs may be unreachable for keyboard-only users and screen reader users alike.
Draggable elements
100% of scanned sites failed draggable element accessibility. Users who cannot operate a mouse — including many patients with mobility impairments — may be blocked entirely from features that rely on drag-and-drop interactions.
What these failures mean for patients
The failure categories above are technical in description. Their consequences for patients are immediate and concrete:
- A patient using a screen reader on a site without proper navigation structure cannot efficiently find what they need — a scheduling link, a contact form, a service description. They are forced to navigate the entire page linearly, repeatedly, until they either find it or give up.
- When form fields are unlabeled, a patient using assistive technology may not know what information is being asked for, whether they've made an error, or whether their submission went through. For someone trying to order medical equipment or complete an intake process, that is a blocked transaction — not a minor inconvenience.
- When tables fail accessibility standards — and none of the sites we scanned passed table accessibility checks — pricing, billing, and service information becomes unreadable for patients relying on screen readers.
Section 504 exists because access to healthcare services is not discretionary. When the digital pathway to those services is blocked, the impact falls on the patients least able to navigate around it.
Closing the gap: how accessiBe can help
The data is conclusive: most healthcare organizations subject to Section 504 have significant accessibility work ahead of them. Closing that gap requires a layered approach — structured auditing to understand where you stand, ongoing remediation to address what's found, and documentation to demonstrate that progress is real and continuous.
Combining the best in AI automation, human expertise, and developer tools, accessiBe's end-to-end accessibility platform helps healthcare organizations build a compliance program that holds up:
- AI-powered remediation — automated coverage across public-facing web environments addresses common accessibility barriers at scale, delivering screen reader compatibility and keyboard-only navigation - areas in which most sites fail
- Source code accessibility — developer-level tooling identifies and tracks WCAG issues at the code level, including ARIA implementation gaps, heading structure failures, and unlabeled form fields — the structural issues our scan found most consistently across healthcare websites
- Expert audits and VPAT documentation — manual accessibility testing against WCAG 2.1 AA gives you a clear, documented picture of where your organization stands today, and produces the Accessibility Conformance Reports that form the foundation of a defensible compliance record
