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Elizabeth Samples

Elizabeth is a trusted advisor to her educational institution clients, bringing nearly 20 years of experience to her work providing day-to-day counsel, conducting investigations and reviews, training, and advising on policy and system development.

A Final Rule updating Section 504 of the Rehabilitation Act of 1973 recently published by the Department of Health and Human Services (HHS) issued new mandates stipulating that every facility, program, or activity with 15 or more employees that receives HHS funding will need to comply with new digital accessibility guidelines.

To align its requirements

UPDATE (May 2026): To align its requirements with what DOJ has mandated, HHS extended the Rules compliance deadline to May 11, 2027 for entities with 15 or more employees and May 10, 2028 for those with fewer than 15 employees.

On May 9, 2024, the Department of Health and Human Services (“HHS”) published a Final Rule (“the Rule”) updating Section 504 of the Rehabilitation Act of 1973 (“Section 504”) regulations. As part of the Rule, every facility, program, or activity with 15 or more employees and receiving HHS funding will need to comply with new digital accessibility guidelines by May 11, 2026. Those with fewer than 15 employees will need to comply by May 10, 2027.