Resources

The U.S. Department of Health and Human Services (HHS), through its Office for Civil Rights, has adopted updated accessibility requirements for medical diagnostic equipment under Section 504 of the Rehabilitation Act.[1] These requirements are intended to reduce barriers to care for individuals with disabilities and to ensure that covered providers offer services in a manner that is accessible and nondiscriminatory.

For health care providers that receive federal financial assistance, including providers participating in Medicare, Medicaid, CHIP, or other HHS-funded programs, the rule creates specific obligations regarding accessible medical diagnostic equipment (MDE), staff preparedness, and program accessibility. In practice, the rule is aimed at ensuring that patients with disabilities can receive routine examinations and diagnostic services using equipment that is accessible and usable.

Key takeaways from the updated rule include the following:

• The rule adopts accessibility standards for medical diagnostic equipment, including examination tables, examination chairs, weight scales, mammography equipment, and certain radiological equipment.
• Providers must ensure that their services are accessible in practice, even if a particular office or location does not yet have all required accessible equipment in place. If needed, the provider may need to arrange care at a hospital or another accessible practice location.
• Covered entities must have qualified staff who can operate accessible equipment and assist patients with transfers and positioning as needed.
• The rule also strengthens broader disability nondiscrimination protections affecting digital accessibility and other health and human services activities. 

Under the rule, each covered provider that uses examination tables and weight scales must have at least one accessible examination table and one accessible weight scale in place by July 8, 2026. Beyond that baseline requirement, covered providers generally must ensure that at least 10% of each type of medical diagnostic equipment is accessible, with a minimum of one accessible unit. For providers that specialize in treating conditions affecting mobility, such as rehabilitation centers and physical therapy practices, the threshold increases to 20%. 

With the July 8, 2026 compliance deadline now here for HHS-funded recipients, providers should assess current equipment inventories, identify whether accessible examination tables and weight scales are available at each relevant location, review purchasing practices, and train staff on equipment use and patient assistance protocols. Providers that fail to comply may face enforcement risk, including administrative action and potential litigation exposure. 

For many providers, this is not simply an equipment procurement issue. It is also an operational compliance issue that requires coordination across facilities, purchasing, clinical operations, and staff training. Covered entities should consider acting now to confirm that their accessibility practices align with the updated Section 504 requirements. 

For questions regarding the updated MDE accessibility requirements or assistance with compliance and implementation, please contact Vice President and Akron Managing Partner Amanda Waesch at alwaesch@bmdllc.com. 

[1] 29 U.S.C. §794.