Healthcare providers must comply with a host of accessibility rules for medical diagnostic equipment (MDE) by the Department of Health and Human Services’ (HHS’s) deadline of July 8, 2026. While many of the rule’s requirements are already in effect, healthcare providers should be checking to ensure they are meeting the new requirements governing accessible MDE, including examination tables and weight scales used in patient care (45 CFR § 84.91).
In 2024, for the first time in decades, HHS comprehensively updated its regulations implementing Section 504 of the Rehabilitation Act, the federal law prohibiting disability discrimination by programs or activities that receive federal financial assistance from HHS (45 CFR Part 84). The sweeping 2024 final rule modernizes disability-access requirements across the healthcare sector and reflects HHS’s broader effort to address barriers that individuals with disabilities continue to encounter when seeking healthcare services.
The deadline marks the end of the two-year implementation period that HHS provided when it finalized its updated Section 504 regulations in 2024.
Below are 15 questions healthcare organizations should be asking before the July 8 deadline arrives.
1. Does this apply to my organization?
Section 504 applies to recipients of federal financial assistance from HHS. Many healthcare providers, including physicians, dentists, hospitals, clinics, emergency rooms, ambulatory surgery centers, imaging providers, laboratories, community health centers, urgent care facilities and specialty clinics, receive HHS financial assistance through participation in federal healthcare programs, grants or other funding arrangements.
2. What counts as “medical diagnostic equipment”?
MDE includes equipment used to perform examinations, assess health status, obtain diagnostic information or monitor patients. Examples include examination tables, chairs used for ocular or dental examinations and procedures, weight scales, mammography equipment, and x-ray machines.
3. What does the rule require?
The most pressing component of the rule is the requirement that covered organizations that use exam tables and scales as part of their operations ensure they are accessible to individuals with disabilities.
For most recipients, at least 10% of MDE, and no fewer than one unit of each covered type, must be accessible. For recipients that specialize in treating conditions affecting mobility, such as rehabilitation centers and physical therapy providers, at least 20% must be accessible.
4. Why is HHS imposing these requirements?
HHS concluded that individuals with disabilities continue to experience significant barriers when accessing healthcare services. Patients with mobility disabilities reported being examined in wheelchairs rather than on examination tables, being unable to obtain accurate weights or being referred elsewhere because providers lacked appropriate equipment.
HHS views accessible MDE as a necessary component of equal access to healthcare services rather than simply a convenience or accommodation. In HHS’s view, the availability and usability of MDE directly affect whether a patient with a disability can receive the same clinical evaluation offered to other patients.
5. How should practices evaluate services that do not require examination tables?
The rule is tied to MDE actually used by the provider. If examination tables are outside the provider’s clinical model, the equipment-specific requirements should be evaluated accordingly rather than treated as a universal purchase mandate. Organizations should distinguish equipment that is genuinely outside the scope of their services from equipment that is used occasionally, inconsistently or only in particular locations.
6. What if obtaining patient weights is not part of our standard of care?
HHS structured the requirements around the categories of equipment a provider uses as part of its practice, rather than a universal obligation to acquire every type of accessible equipment. A provider that ordinarily omits patient weights from its clinical services may have a different compliance analysis than a primary care practice or specialty provider that routinely records patient weight during encounters. This same analysis applies to other categories of MDE: If the provider uses the equipment to deliver covered services, the equipment should be part of the accessibility assessment.
7. Is one accessible examination table and one accessible scale enough?
One accessible examination table and one accessible scale may satisfy the specific July 2026 requirement for a recipient that uses those categories of equipment. However, organizations should treat the requirement as an accessibility standard that depends on availability, usability, and integration into patient care, rather than a simple procurement exercise.
HHS requires MDE to be placed in a facility so that it can be readily used by patients with disabilities. An accessible examination table that is difficult to schedule, located in an impractical part of the facility or unsupported by trained personnel may create the same access problem the regulation is designed to address.
8. What accessibility features should providers be looking for?
The regulations incorporate existing technical accessibility standards developed by the U.S. Access Board addressing transfer surfaces, wheelchair access, adjustability, support features and lift compatibility. Providers should not assume that manufacturer references to “ADA-compliant” equipment necessarily satisfy the applicable technical standards for use in healthcare settings.
Notably, recipients are not required to alter diagnostically required structural or operational characteristics of MDE if doing so would prevent the equipment from serving its intended diagnostic purpose.
9. We recently purchased new equipment. Are we already supposed to be compliant?
Possibly.
One frequently overlooked aspect of the rule is the acquisition obligation that began on July 8, 2024. Since then, recipients that buy, lease, rent or otherwise acquire MDE generally must acquire equipment that meets the accessibility standards until they have obtained the required number of accessible pieces of equipment.
Organizations that purchased MDE during the last two years should review those acquisitions and determine whether they meet the applicable standards.
10. What if we do not own our equipment?
The acquisition requirements apply to all MDE, including equipment that is leased, rented or otherwise acquired. Providers that rely on third-party vendors, management companies, equipment leasing arrangements or shared-service models should evaluate who controls equipment acquisition decisions and whether accessibility requirements have been incorporated into procurement processes.
11. Do we need specially trained employees?
The regulations do not describe specific training requirements. However, HHS expects providers to maintain processes that allow accessible equipment to be used effectively, including procedures for patient transfers and positioning. Many organizations will need targeted training for clinical and support personnel, along with periodic refreshers as equipment, staffing or workflows change.
12. Can we refer patients elsewhere if they require accessible equipment?
Potentially, but the analysis should be documented and patient-centered.
The final rule recognizes that program accessibility may sometimes be achieved through methods such as alternative accessible locations, home visits, purchasing or leasing MDE, or other effective approaches. In a multi-facility practice, transferring a patient to another location may be appropriate in some circumstances.
However, providers should be cautious about routing patients elsewhere simply because accessible equipment is unavailable. The key question is whether the patient receives timely, dignified and clinically equivalent access to the same service without unnecessary delay, burden or segregation.
13. What happens if we rarely treat patients with mobility disabilities?
HHS made clear that recipients using MDE may not exclude individuals with disabilities from, deny them benefits of, or otherwise discriminate against them in the relevant program or activity. Historical encounter volume should therefore inform planning, but it does not define the legal obligation.
That said, recipients generally are not required to take actions that would result in a fundamental alteration in the nature of a program or activity or impose undue financial and administrative burdens. Cost, space constraints, staffing limitations and operational disruption may inform a covered entity’s analysis, but they should not be automatic exceptions. Organizations should take reasonable, effective steps to avoid a meaningful difference in access for patients with disabilities, regardless of how often the need arises.
14. What are the enforcement risks?
The most immediate enforcement risk is an investigation by the HHS Office for Civil Rights following a patient complaint. Accessibility issues may also surface during broader compliance reviews, accreditation activities, litigation, payer audits or government investigations.
15. What should healthcare providers do right now?
Organizations that are still working through their assessments should consider taking the following steps before July 8:
- Inventory existing examination tables, examination chairs, scales, imaging equipment and other diagnostic equipment;
- Determine which requirements apply to the organization’s services and equipment;
- Review equipment purchased, leased, rented or otherwise acquired since July 2024 and the procurement analysis supporting these acquisitions;
- Assess patient transfer, positioning, scheduling and accommodation policies and train qualified clinical and operational personnel; and
- Document compliance decisions, implementation steps, and any remediation plans.
The Bottom Line
The July 8, 2026, deadline is best understood as an operational deadline supported by the procurement department. For many organizations, compliance will depend on equipment, placement, staffing, training, policies and operational readiness.
McGuireWoods continues to follow developments at HHS regarding patient accessibility. If you have any questions or concerns in this area, contact the author or a member of the Healthcare Compliance, Regulatory & Policy Practice Group.