Healthcare organizations in the U.S. just got more time to meet the federal digital accessibility deadline under Section 504 of the Rehabilitation Act. The Department of Health and Human Services (HHS) pushed the web and mobile compliance dates to May 11, 2027, for larger organizations with 15 or more employees and May 10, 2028, for smaller ones.
It’s tempting to take this as an opportunity to put off working towards Section 504 compliance in favor of anything more urgent. But the teams that do that will regret it when the deadline comes around again. After all, your legal obligations have not changed. You just have more time to meet them now.
And there is more to do than most teams expect, especially once you account for accessibility in every language your members read.
The good news is that the year ahead is enough time to get accessibility right for your members, patients, and customers, as long as you start now. Here’s how to make that extra year count.
Making ALL Digital Content Accessible
Accessibility means members with disabilities can use your digital content on their own. That includes members who are blind or have low vision, who are deaf or hard of hearing, who have cognitive or learning disabilities, or who have motor disabilities that affect how they navigate a screen.
And it applies to far more than your public website. Member and patient portals, mobile apps, online enrollment and intake forms, telehealth platforms, and self-service kiosks are included in the regulation. So are the documents you post online: benefit notices, formularies, and the forms members receive as PDFs. Documents are particularly easy to underestimate, because you have to make each posted PDF accessible on its own.
By 2027 and 2028, all of that content has to meet the Web Content Accessibility Guidelines (WCAG) 2.1, Levels A and AA, built in from the start so a member with a disability can use it without asking. Otherwise, that member may file a complaint.
If you buy a portal or app from a vendor, you are still responsible for whether it is accessible. When a third-party tool falls short, the HHS Office for Civil Rights (OCR) can investigate you, and your federal funding is at risk.
One exception covers documents tied to a single member’s account, like a coverage notice behind a login: those don’t have to conform up front, though you still have to make them accessible for the member who needs them. That duty is separate from the deadline and already in effect: when a member asks for an accessible version of a notice or form, you have to provide it, and a member who is denied can file a complaint today.
Not only do health plans have to make digital content accessible to people with disabilities, but they also have to give members with limited English proficiency meaningful access in their language to comply with language access regulations. For a member who is both, that means content that is translated and accessible at once.
Why Compliance Is Complicated for Healthcare Organizations
Meeting that standard across all of it is harder than it looks, for two reasons.
1. Your Content Is Likely Already Fragmented
A typical healthcare org has a load of legacy PDFs and forms, runs member communications through several systems, and relies on vendor platforms it does not fully control. Translation and accessibility usually sit with separate teams who rarely coordinate. Pulling all of that up to one accessible standard takes time, which is the real reason to start now rather than in 2027.
2. Accessibility Planning Often Stops at English
Most teams plan accessibility for English and stop there. They audit the English website and the English portal. The translation, to make content accessible for non-native English speakers, is a separate workflow and is left for later.
But even a document that was made to be accessible to people with disabilities before translation will likely require additional accessibility work to remain accessible after it’s translated. Picture a member who reads Spanish and uses a screen reader. When your vendor translates your enrollment form into Spanish, the accessibility tagging from the English file doesn’t transfer to the new version. With nothing to label the fields, their screen reader can’t tell them which field is which, and they can’t enroll on their own unless you make the Spanish document accessible, too
Since some non-native-English speaking people need digital content that’s both accessible and translated into their preferred language, it’s more useful and effective to think of accessibility and language access as part of the same problem, included in a growing body of language access requirements for healthcare programs.
For Medicaid and Medicare Advantage plans, this is front and center. On the accessibility side, California’s APL 25-016 already requires Medi-Cal plans to track each member’s chosen format and deliver written communications in it. These plans also serve some of the largest populations of members with limited English proficiency, people who depend on translated notices, formularies, and appeals instructions to use their coverage at all.
Five Steps to Take Now
The smart move is to treat the extra year as one coordinated push. This is your chance to build accessibility into your translation process from the start, so every language comes out accessible the first time.
Take the planning opportunity you’ve been given, then spend the rest of the year fixing what you find.
Here are the steps we recommend:
- Audit accessibility and language together. Inventory your digital content in every language, and flag what is member-facing and in active use.
- Prioritize high-volume, high-stakes content. Start with what members use most: notices, forms, Explanations of Benefits, and portal content. Fixing those first protects the most people and closes the biggest gaps early.
- Pressure-test your vendors. Review each vendor workflow for translation and accessibility gaps. Where separate vendors handle translation and accessibility, this is the moment to consolidate, since that split is where most gaps open. Ask for an accessibility conformance report, and write WCAG requirements, remediation timelines, and audit rights into your contracts.
- Build governance across content types and languages. Get your compliance, UX, and language access teams working from one plan, with clear ownership so new content ships accessible in every language and format. Handling that at creation costs far less than fixing it later under deadline pressure.
- Start remediation now, not later. A backlog of untagged PDFs and translated documents takes months to clear, and the closer 2027 gets, the harder it becomes to find the specialists you need. Our guide to planning for alternate format communications is a good place to start.
Spread across the year, all of this is doable. Crammed into early 2027, it will overload your people, process, and budget.
How BIG Helps
This is the kind of cross-functional problem BIG Language Solutions handles every day. We build accessibility into the translation process itself, so your translated content meets the same compliance standard as your English content the first time through, reducing your risk and providing better outcomes for all. For health plans, that means one team handling translation and accessibility together, rather than a separate vendor you have to coordinate.
In practice, that includes:
- Multilingual content production aligned with your compliance requirements
- Accessible alternate formats for regulated member and patient communications, including notices, Explanations of Benefits, and forms
- Production and delivery at healthcare scale
- Advisory support to bring your language access and accessibility strategies under one plan
The result is member material your team can stand behind: accurate in every language and usable by everyone, including members who use assistive technology.
Start This Quarter
The organizations that start this quarter will reach 2027 ready. The ones that wait will do a year of work in a few months, under pressure and at a higher price.
Whatever you build, make it work in every language your members speak. Members notice when their language is an afterthought, and so do regulators.
You don’t have to build this plan alone. BIG Language Solutions can review your accessibility and language access together, find the gaps, and turn what we find into a plan you can execute well before 2027. Let’s talk.
