Accessible PDFs for hospitals, clinics and health departments
If your organization receives federal financial assistance from HHS, the Section 504 web rule applies to the PDFs you post: WCAG 2.1 Level AA by May 11, 2027 with 15 or more employees, or May 10, 2028 with fewer. Here is what is covered, which documents to start with, and how Proof does the work and proves it.
The short answer
HHS’s Section 504 rule, 45 CFR part 84 subpart I, covers any organization that receives HHS funding, directly or through another recipient: hospitals, clinics, health departments, community health centers, and state Medicaid and human services agencies among them. It names PDFs as covered, and it often reaches the whole organization, not only the funded program. Archived files, older documents nobody uses to get care or services, and a patient’s secured documents can be exempt, but you will likely still need to provide them in an accessible format when someone asks.
Deadlines
Section 504 applies May 11, 2027. Public providers may have a Title II date too.
A county health department, public hospital or state Medicaid agency usually answers to both rules, each with its own date. Plan to whichever comes first: for a smaller government or a hospital district, the Section 504 date can come almost a year before Title II’s.
Recipients of HHS funding with 15 or more employees
Recipients with fewer than 15 employees
A public hospital or health department of a government serving 50,000 people or more
Smaller governments, and special districts such as a hospital district
Dates as of October 2026, set by interim final rules in April and May 2026 that moved the dates and left the WCAG 2.1 AA standard and the exceptions unchanged. A lawsuit filed in May 2026 (NFB v. DOJ and HHS) asks a federal court to set aside both extensions; we update these dates when the court rules. Not legal advice.
What Section 504 coversWhere to start
Fix what people use first. Sort the rest before you budget for it.
The rules ask whether anyone uses a document today to apply for, get or take part in something. If they do, it comes first. Older files nobody uses may be exempt.
Usually fix first
- Fillable intake and registration forms
- Consent forms for procedures and research studies
- Financial assistance policies, applications and summaries
- Price lists and notices of privacy practices, as each is updated
- Patient education handouts linked from clinic pages
- Benefit applications and eligibility rules
Sort before you fix
- Annual reports kept unchanged, for reference only, in an area clearly identified as archived
- Board minutes from before your date, moved to an archive (minutes created after it don’t qualify)
- Outdated handouts you can retire
- A patient’s own secured documents, such as lab results behind a portal login
These are working decisions to confirm with counsel, and exempt documents must still be provided in an accessible form when someone asks. Archive, keep or fix turns the exceptions into a checklist, and finding every PDF shows how to build the list to sort.
How Ockem Proof fits
Software does the fixing. Your team makes the calls.
Ockem Proof runs 42 automated fixers and re-checks each one after it runs. What is left for a person comes to your reviewer as a short decision, such as confirming reading order, approving a color change or approving AI-drafted alt text: one at the median, two at the 90th percentile (production documents, August 2026). Every certified document gets a certificate and a public verification page stating what software verified, what your organization attested, and what is not claimed.
Count the PDFs on your site
Enter your domain. We count every linked PDF, score a free sample against WCAG 2.1 AA (12 by default, up to 100 for requests we qualify) and price the job, usually within 3 business days.
FreeTry one PDF
No account: a verified email, one document per email, up to 10 pages and 50 MB. Get the remediated file and see which checks still need a person.
(opens the Ockem Proof app)PricingPrice the backlog
One document is a PDF of up to 50 pages: $59 on its own, and less in packs. Importing and the first check are free; you are charged when a document is certified.
For procurement. We accept purchase orders at any size and send a quote document and a W-9 (ask for a quote). Inference runs on hardware we operate; no customer document content goes to a third-party model. Your documents are never sold, never shared with other customers, and not used for model training unless your workspace turns that on. See Security and procurement.
Ockem Proof is not offered for documents that contain protected health information (PHI) or student education records protected by FERPA, and Ockem does not yet sign Business Associate Agreements. This does not apply to public documents that carry no such information, such as blank forms, notices and fact sheets. Health information and student records
Common questions
Is the whole hospital covered, or only the grant-funded program?
Often the whole organization. The rule’s definition of a program or activity reaches all the operations of an entire private organization principally engaged in providing health care, and all the operations of a government department or agency that receives the funding. A health system’s whole website is in scope, not only the grant-funded pages.
Does Medicare Part B count as HHS funding?
Medicare Part A has long been treated as federal financial assistance. In its May 2024 Section 1557 rule, HHS said it also treats Part B payments to providers as federal financial assistance, for Section 504 as well. A practice whose only federal funding is Part B should confirm with counsel, as should any recipient near the 15-employee line.
Do patient portal documents have to be accessible?
A PDF about one patient that sits behind a login, such as lab results or a bill, is exempt from the WCAG 2.1 AA requirement. You must still give that patient the information in an accessible format when they need it, and the portal itself generally must meet WCAG 2.1 AA.
Can we upload documents that contain patient information?
No. Ockem Proof is not offered for documents that contain protected health information (PHI) or student education records protected by FERPA, and Ockem does not yet sign Business Associate Agreements. Please do not upload such documents to Proof, including through the free trial. This does not apply to public documents that carry no such information, such as blank forms, notices and fact sheets. Security and procurement
What does it cost?
One document is a PDF of up to 50 pages: $59 on its own, and less in packs. A longer file counts as one document per 50 pages, so a 120-page PDF is three. Importing and the first check are free, and you are charged only when a document is certified. We accept purchase orders at any size. See prices and packs
We don’t have staff for the judgment calls. Can Ockem make them?
Yes. With Assured, Ockem experts complete the judgment calls, such as alt text, reading order, contrast and table decisions, and those attestations are made by our expert, not your team. It is quoted per document. Ask for an Assured quote
Read next
- The HHS Section 504 rule and your PDFsThe rule
- ADA Title II PDF requirementsPublic providers
- Accessible PDF formsForms
- Archive, keep or fix your PDFsExceptions
- Proof of accessibility for PDFsEvidence
Other sectors: State and local government · Higher education · K-12 school districts
Start with one PDF.
Free, no account: a verified email, one document per email, up to 10 pages and 50 MB. Get the remediated file and its verification record, and see which checks still need a person.
Longer document? Request an assessment.