HHS Puts Accessible Medical Equipment in Focus: What Providers Need to Know Before the July 8, 2026 Deadline

Healthcare providers that receive federal assistance from the U.S. Department of Health and Human Services (HHS) must comply with updated accessibility requirements for medical diagnostic equipment (MDE) by July 8, 2026. 

In 2024, as part of a broader effort to reduce barriers in healthcare for individuals with disabilities, HHS imposed new accessibility requirements for MDE, updating Section 504 of the Rehabilitation Act. The requirements apply broadly to healthcare providers and facilities that receive HHS funding, including entities participating in Medicare, Medicaid, CHIP, grants, or other HHS-funded programs. MDE includes equipment used for examinations, diagnosis, assessment, or monitoring, such as examination tables, examination chairs, weight scales, mammography equipment, and x-ray machines. 

HHS updated regulations after the U.S. Department of Justice (DOJ) issued essentially identical requirements for public entities, including state and local government entities under Title II of the Americans with Disabilities Act.

Key Requirements. 

Covered providers must ensure that individuals with disabilities are not denied healthcare services because MDE is inaccessible. Among other things, accessible equipment must support independent or assisted transfer, appropriate positioning, and use by individuals with mobility disabilities. 

1. MDE Acquired After July 8, 2024: Any MDE that a covered provider purchases, leases, rents, or otherwise acquires must meet the accessibility standards until the covered provider has enough accessible units to satisfy the applicable 10% or 20% scoping requirement. 

   1. General MDE: For most covered providers, at least 10% of each type of MDE, but no fewer than one unit, must meet the accessibility standards.

   2. MDE at Specialty Facilities: Recipients that specialize in treating conditions affecting mobility, such as rehabilitation or physical therapy providers, must meet a 20% threshold.

2. MDE Acquired Before July 8, 2024: MDE in place before July 8, 2024, does not need to be immediately replaced or retrofitted to comply with the new requirements by July 8, 2026. Rather, covered providers must ensure that MDE, and care more generally, is readily accessible to individuals with disabilities. Alternative compliance methods may include reassigning services, home visits, or alternate accessible sites. 

3. Examination Tables and Weight Scales: By July 8, 2026, each covered provider that uses examination tables or weight scales must have at least one accessible examination table and one accessible weight scale in place, even if it has not otherwise acquired new MDE. However, if a covered provider does not use examination tables or weight scales in delivering care, the covered provider should consider the accessibility of its MDE and care more generally.  

4. Qualified Staff: Covered providers must also maintain qualified staff who can operate accessible MDE.

Noncompliance and Enforcement. 

HHS Office for Civil Rights may investigate complaints, conduct compliance reviews, and seek corrective action where covered providers fail to provide accessible MDE or otherwise deny individuals with disabilities equal access to care. Noncompliance may expose providers to required remediation, monitoring, reputational risk, and potential loss of, or conditions on, federal financial assistance. Noncompliance may also increase the risk of litigation and complaints where patients are delayed, referred elsewhere, or denied services because accessible equipment or trained staff are unavailable.

There are pathways for demonstrating equivalent facilitation where providers use alternative designs, products, or technologies. Further, covered providers are not required to take action that would fundamentally alter the delivery of care or impose an undue financial burden; however, the provider bears the burden of demonstrating the foregoing.

Next Steps. 

Covered providers should: (i) inventory existing MDE, (ii) identify gaps against the applicable 10% or 20% threshold, (iii) confirm that any post-July 8, 2024 acquisitions meet the standards, (iv) ensure accessible examination tables and weight scales are in place before the July 8, 2026 deadline if part of their practice, and (v) train clinical and support staff on accessible-equipment use and patient-transfer procedures. Compliance should ultimately be addressed in light of each covered provider’s specific facts, resources, equipment inventory, and specialties. 

Contact the authors for more information.