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This page focuses on recipients of HHS financial assistance, including dental practices when covered. Section 504 also addresses matters beyond websites. This is general information, not legal advice or a determination that your practice is covered or in violation.
1. An OCR investigation or compliance review
HHS’s Office for Civil Rights (OCR) can investigate disability-discrimination complaints and review covered recipients’ compliance. A review can also begin without a patient filing a complaint. The incorporated enforcement procedures describe both routes (PDF).
An investigation can involve document requests, witness interviews and site visits. For a practice, that means gathering relevant records and explaining its policies and actions. A complaint starts an assessment; it is not itself a finding of a violation. HHS explains its complaint process.
2. Corrective action and a documented response
If OCR finds a violation, HHS says the recipient is given a specific period to correct it or provide a correction plan. Depending on the issue, action can include changing procedures, providing an accessible service or notifying people of steps taken to comply. See HHS’s corrective-action explanation.
For website and intake work, a practical repair record should identify the affected patient task, responsible vendor, change made and retest result. Administrative work and remediation can take staff time even when a matter is resolved cooperatively.
3. Proceedings that can affect federal financial assistance
HHS’s Section 504 rule incorporates the Title VI enforcement procedures. Where informal resolution fails, they permit suspension, termination, or refusal of federal financial assistance, as well as referral to the Department of Justice or other lawful enforcement.
A funding order requires notice, unsuccessful voluntary-resolution efforts, a recorded finding after an opportunity for a hearing, and congressional reporting and waiting steps. Its reach is limited to the recipient and program covered by the finding. Funding loss is not automatic after a website scan.
Sources: 45 CFR 84.98, incorporating the enforcement procedures (PDF), and 45 CFR 80.8, funding action and safeguards (PDF).
4. Private lawsuits and legal costs
Private individuals can bring Section 504 claims against funding recipients. Litigation creates a separate process from OCR’s administrative investigation. A court may award reasonable attorney’s fees to a qualifying prevailing party under 29 USC 794a (PDF).
Available remedies depend on the claim and governing law. In Cummings v. Premier Rehab Keller, the Supreme Court held that emotional-distress damages are unavailable in the private Rehabilitation Act action at issue and explained the precedent excluding punitive damages. Those limits do not eliminate the possibility of a lawsuit or other available relief. Read the Supreme Court opinion (PDF).
Is there a fixed Section 504 fine for a website error?
The HHS enforcement provisions cited above do not establish a flat fine for each WCAG error. A practice’s potential exposure depends on its coverage, the alleged violation, available remedies and the process involved.
The 2027 and 2028 deadlines do not remove existing obligations
HHS extended the dates for covered recipients to meet the specific WCAG 2.1 AA web and mobile requirements:
| Recipient size | Compliance date |
|---|---|
| 15 or more employees | May 11, 2027 |
| Fewer than 15 employees | May 10, 2028 |
The extension changes those specific dates. HHS also reminds recipients of their ongoing obligation to make programs and activities accessible. Coverage, exceptions and other applicable laws still need assessment. Read the HHS announcement and the 2026 rule amendment (PDF).
Common questions from practices
Does using an outside website or portal vendor remove our responsibility?
The HHS web rule includes content and apps a covered recipient makes available through contractual or licensing arrangements. Hiring a vendor does not, by itself, remove the recipient’s obligations. The scope of the work and each party’s responsibilities need to be clear. See 45 CFR 84.84 (PDF; read its original dates together with the 2026 amendment above).
Does a failed accessibility scan prove a Section 504 violation?
A scan can identify some technical issues. It cannot decide a practice’s legal coverage, applicable exceptions or whether all accessibility requirements are met. Human evaluation is also necessary to assess accessibility. W3C explains the limits of automated evaluation.
What should a practice do next?
If you receive a complaint or enforcement notice, preserve it and the relevant records, involve qualified counsel, and address the stated response deadlines. For the accessibility work, create an inventory of affected pages, booking paths, portals and forms. Record which vendor controls each system, what needs changing, and how the changes will be checked.
Our dental website accessibility checklist and vendor handoff template can help organize that work. Intake Compliance handles agreed website accessibility fixes and vendor coordination and intake-form accessibility work.