HHS Section 504 video accessibility requirements for healthcare: kiosks, websites, mobile apps, and the revised 2027–2028 deadlines

Update: HHS extended the compliance dates (May 2026)

On May 7, 2026, HHS announced that the Office for Civil Rights issued an interim final rule extending Section 504 web, mobile app, and kiosk accessibility compliance dates by one year. Recipients with 15 or more employees must now conform by May 11, 2027 (previously May 11, 2026). Smaller recipients have until May 10, 2028 (previously May 10, 2027). See the official HHS announcement.

The sections below explain what the underlying 2024 rule requires for video and kiosks; deadline references in this article reflect the revised 2027 and 2028 dates above unless clearly marked as historical.

On May 9, 2024, the U.S. Department of Health and Human Services published a final rule updating Section 504 of the Rehabilitation Act. The rule requires recipients of HHS federal funding to make their web content, mobile applications, and kiosks accessible to people with disabilities by conforming to WCAG 2.1 Level AA. After the May 2026 extension, larger recipients (15 or more employees) must comply by May 11, 2027, and smaller recipients by May 10, 2028.

The DOJ also extended ADA Title II web accessibility compliance dates by a year. Many organizations must plan for both schedules: a public entity may get extra time under Title II for some digital properties while HHS-funded programs still follow the Section 504 dates in the Update section above.

Who is covered

The HHS rule applies broadly to any entity receiving federal financial assistance from HHS. That includes:

• Hospitals and health systems (Medicare Parts A, C, and D; Medicaid)
• Clinics, dental offices, and mental health providers receiving Medicaid or CHIP reimbursement
• Long-term care and assisted living facilities
• Medical and nursing schools and health-related colleges and universities
• Child welfare agencies and service providers
• Research institutions receiving NIH or other HHS grants
• Health insurers participating in Medicaid, CHIP, or marketplace programs
• Social service organizations receiving TANF, Head Start, SNAP, or other HHS program funding

If your organization bills Medicare or Medicaid, accepts HHS research grants, or participates in any HHS-funded program, this rule applies to you.

What the rule requires for video

HHS adopted WCAG 2.1 Level AA as the technical standard. For video content specifically, that means:

Captions (WCAG 1.2.2, Level A)

All prerecorded video with audio must have synchronized captions. HHS specifically called out uncaptioned video as a barrier to access: "Other barriers include information delivered by videos that are not captioned for persons who are deaf or hard of hearing."

This applies to patient education videos, telehealth recordings, training content, public-facing marketing videos, and any other video delivered through a covered digital property.

Live captions (WCAG 1.2.4, Level AA)

Live or synchronous video, such as telehealth appointments and livestreamed events, requires real-time captions. When a patient requests captions during a telehealth visit, the provider must be able to deliver them.

Audio descriptions (WCAG 1.2.5, Level AA)

When prerecorded video conveys visual information essential to understanding, audio descriptions are required. In healthcare, this frequently applies to:

• Instructional videos showing physical therapy exercises or medical procedures
• Patient education content with diagrams, charts, or anatomical illustrations
• Orientation and wayfinding videos for facilities
• Training videos for staff and students at medical schools

Extended audio descriptions (WCAG 1.2.7, Level AAA, referenced at AA)

When pauses in dialogue are too short for standard audio descriptions, extended audio descriptions (which pause the video to insert narration) may be necessary. While WCAG classifies this as Level AAA, the rule's adoption of Level AA still requires organizations to provide audio descriptions sufficient for equivalent access, and extended audio descriptions may be the only way to achieve that for content-dense video.

Transcripts (WCAG 1.2.3 and 1.2.8)

Audio-only content requires text transcripts. Video content benefits from descriptive transcripts that capture both dialogue and visual information, and WCAG 1.2.8 (Level AA) requires a text alternative for all prerecorded synchronized media.

The kiosk provision: what organizations are missing

The kiosk accessibility requirement is the part of the rule catching many organizations off guard. While healthcare providers have been remediating websites, kiosk fleets have gone largely unaudited.

What the rule says

Section 84.90 of the final rule states that recipients must make their programs accessible when using kiosks. The rule does not mandate a specific hardware standard for kiosks, but it does require that programs delivered through kiosks be equally accessible to people with disabilities.

Recipients may comply by either:

1. Making the kiosks themselves accessible, or
2. Providing alternative procedures that afford the same access, convenience, and confidentiality as the kiosk

That second point is critical. Telling a patient to "ask someone at the front desk" is not equivalent access if it sacrifices privacy (for example, when the kiosk handles insurance information, medical history intake, or check-in for sensitive services).

Where video intersects with kiosks

Many healthcare kiosks now incorporate video content:

• Patient education kiosks in waiting rooms and exam rooms that play instructional videos about procedures, medications, or post-operative care
• Wayfinding kiosks with video walkthroughs of hospital campuses
• Check-in kiosks with video tutorials explaining the registration process
• Mental health and wellness kiosks with guided meditation or relaxation videos
• Lobby and common-area displays cycling through health information videos

If a kiosk displays video, that video must be captioned. If the video conveys visual information essential to understanding (such as demonstrating how to use a medical device or perform a physical therapy exercise), audio descriptions are required. The same WCAG 2.1 Level AA criteria that apply to your website apply to the software layer of your kiosks.

HHS suggests applying WCAG 2.1 to kiosk software

While HHS did not adopt a specific hardware accessibility standard, the agency's commentary suggests applying WCAG 2.1 to the kiosk software layer. The European EN 301 549 standard offers additional guidance on hardware accessibility and may be useful for procurement.

For video content specifically, this means:

• Kiosk video players should support closed captions that can be toggled on and off
• Caption display should meet WCAG contrast and sizing requirements
• Audio description tracks should be available when the content requires them
• Kiosk audio systems (speakers or headphone jacks) must support both the primary audio and the audio description track

The offline kiosk problem: why web-based solutions fall short

This is the part that trips up even well-prepared organizations. Most video accessibility vendors deliver audio descriptions through a web-based video player. The player loads the original video, fetches a separate audio description track, and synchronizes playback in the browser. That works well for websites and mobile apps.

Kiosks are a different story. Many healthcare kiosks operate in offline mode, on restricted internal networks, or with limited internet access. They are designed to be self-contained: a locked-down device running local software from an internal drive. In that environment, a web-based video player that depends on an external service to supply audio descriptions simply does not work. The kiosk cannot reach the vendor's servers, and the audio description track never loads.

The same challenge applies to captions in some cases. If the kiosk video player is a basic media player pulling files from local storage rather than a full web browser, it may not support sidecar caption files (WebVTT, SRT) at all, or may not render them correctly.

The solution: exported MP4s with burned-in accessibility

The practical answer for offline kiosks is to deliver video files that have accessibility built directly into the media itself, rather than relying on an external player or service to add it at playback time.

At Recap, audio-described videos can be exported as a new MP4 file with the description voiceovers and video pauses composed directly into the video. The exported file is a single, self-contained video that any media player can play, no internet connection, no special player, no sidecar tracks required. The facility transfers the file to the kiosk's internal drive via USB or network share, and the kiosk plays an audio-described version of the video natively.

For captions, the same approach applies: open (burned-in) captions can be rendered directly into the video frame, so they display regardless of whether the kiosk's media player supports caption file formats. This can even be done in multiple languages for translations and subtitles.

This means:

• No internet dependency. The kiosk does not need to reach an external service to play accessible video.
• No player compatibility issues. Any media player that can play an MP4 can play the audio-described and captioned version.
• Simple deployment. Copy the file to the kiosk. No software updates, no API integrations, no player plugins.
• Works with existing kiosk hardware. Organizations do not need to replace their kiosk fleet or upgrade kiosk software to support new caption or audio description formats.

For organizations with dozens or hundreds of kiosks across multiple facilities, this solution provided by Recap Innovations is the difference between a manageable rollout and a stalled project waiting on kiosk vendor software updates that may never arrive on time.

How the HHS deadline differs from ADA Title II

	HHS Section 504	ADA Title II
Compliance date (larger entities)	May 11, 2027 (extended from May 2026)	April 26, 2027 (extended from April 2026)
Compliance date (smaller entities)	May 10, 2028 (extended from May 2027)	April 26, 2028 (extended from April 2027)
Extended?	Yes; extended by 1 year (May 2026 OCR interim final rule)	Yes, extended by 1 year on April 20, 2026
Applies to	Any recipient of HHS federal funding (public or private)	State and local government entities
Covers kiosks explicitly?	Yes	No
Technical standard	WCAG 2.1 Level AA	WCAG 2.1 Level AA
Enforcement	HHS Office for Civil Rights; loss of federal funding	DOJ; fines, lawsuits, injunctive relief

The key takeaway: even when ADA Title II timelines overlap, the HHS Section 504 rule can still apply on its own schedule to HHS-funded programs and digital properties. A public university hospital, for example, may align some general campus obligations with Title II dates while patient-facing, HHS-funded web content, apps, and kiosks must still meet Section 504 by May 11, 2027 (larger recipients) or May 10, 2028 (smaller recipients), unless an exception applies.

Third-party tools must comply too

The rule's requirements extend to web content and mobile apps "provided or made available by third parties on behalf of recipients through contractual, licensing, or other arrangements." This means:

• Electronic medical record (EMR) patient portals that display video content
• Telehealth platforms used to conduct appointments
• Appointment scheduling systems with embedded instructional video
• Patient education platforms licensed from third-party vendors
• Kiosk software vendors providing check-in, wayfinding, or education applications

If a third-party vendor's product is used to deliver your program and it includes video, you are responsible for ensuring that video meets WCAG 2.1 Level AA. Review your vendor contracts now and confirm that accessibility requirements are specified.

Exceptions

The rule includes five limited exceptions where WCAG 2.1 Level AA conformance is not required:

1. Archived web content (not updated since the rule's effective date and maintained only for reference)
2. Certain preexisting conventional electronic documents (PDFs, Word docs) not currently in use
3. Certain content posted by third parties (comments on a public forum, for example)
4. Individualized, password-protected conventional electronic documents
5. Preexisting social media posts

Even where exceptions apply, the rule still requires recipients to provide effective communication and reasonable modifications. If a patient with a hearing disability requests access to an archived video, the recipient must provide an alternative, such as adding captions to that specific video or providing a written transcript.

There is also a "minimal impact on access" provision: noncompliance is not a violation if the recipient can demonstrate that the issue has such a minimal impact that it does not affect the ability of an individual with a disability to use the content.

What to do before your compliance date

1. Audit all video content across your digital properties. That includes your website, patient portal, mobile app, telehealth platform, and every kiosk in your facilities. Know what exists, what has captions, and what needs audio descriptions.

2. Inventory your kiosk fleet. Document every kiosk model, the software it runs, whether it displays video, and the current state of its accessibility features. Many organizations have kiosks managed by different departments with no centralized tracking.

3. Prioritize by patient impact. Start with the video content patients encounter most frequently: check-in kiosk videos, patient education content shown before or after appointments, and telehealth recordings. High-traffic content first.

4. Contact your vendors. Ask EMR, telehealth, kiosk, and patient education platform vendors for a written statement of WCAG 2.1 Level AA conformance for their products, including any video features. If they cannot provide one, you need a remediation timeline or a plan to switch vendors.

5. Caption everything. Automated captions are a starting point but may not meet accuracy standards for medical terminology. Use a captioning service that supports medical vocabulary and custom dictionaries.

6. Add audio descriptions to visual content. Patient education videos that demonstrate exercises, explain anatomy through diagrams, or show how to use medical devices need audio descriptions. AI-assisted audio description tools can cover large catalogs quickly.

7. Document your compliance efforts. If you cannot fully conform by your applicable deadline, documented good-faith efforts, a clear remediation timeline, and demonstrated progress are your best position for any investigation.

How Recap helps healthcare organizations comply

Recap Innovations provides the video accessibility services healthcare organizations need to meet the HHS Section 504 deadline:

• Captions with medical vocabulary support. Custom dictionaries ensure that medical terms, drug names, and clinical terminology are transcribed accurately.
• Audio descriptions at scale. AI-assisted audio descriptions can process hundreds of patient education videos in days, with human review for accuracy.
• Live captions for telehealth. Real-time captioning for synchronous telehealth appointments and live events. Real-time automated translations and translated voice-overs (for select languages) available on-demand.
• Kiosk-ready exports. For online kiosks, we deliver captions and audio description tracks in standard formats (WebVTT, SRT, SCC). For offline or restricted kiosks, we export self-contained MP4 files with audio descriptions and open captions built directly into the video, ready for USB transfer to the kiosk drive.
• Bulk processing. Submit your entire video library and receive accessible versions back, rather than processing one video at a time.
• Platform integrations. Direct connections to video hosting platforms, so captions and audio descriptions are automatically deployed where your videos live.

If your organization is subject to the HHS Section 504 rule and you need to make video content accessible across your websites, apps, and kiosks, book a free consultation to scope the work.

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This article is provided for informational purposes and does not constitute legal advice. Organizations should consult with legal counsel regarding specific Section 504 compliance requirements.