guide
ACA for healthcare: requirements, priorities, and audit checklist
ACA compliance for healthcare sites requires applying Accessible Canada Act to the specific failure points typical of the healthcare industry — including patient portal logins without screen-reader-accessible mfa, telehealth video without captions or sign-language interpreter integration, symptom checkers built as inaccessible single-page apps.
Does ACA apply to healthcare sites?
The Accessible Canada Act (ACA, 2019) requires federally regulated entities — federal government, banks, telecom, broadcasting, transportation — to identify, remove and prevent accessibility barriers, with the explicit goal of "a Canada without barriers by 2040" and detailed regulations layered on top including the ICT regulations referencing EN 301 549.
Healthcare accessibility — the lay of the land
HHS's May 2024 final rule under Section 1557 explicitly requires healthcare entities receiving federal funding to conform to WCAG 2.1 AA for web content, mobile apps, and kiosks. Compounding this, HIPAA places privacy constraints on accessibility solutions (overlays cannot legally re-transmit patient health information).
Where ACA bites hardest in healthcare sites
• Patient portal logins without screen-reader-accessible MFA
• Telehealth video without captions or sign-language interpreter integration
• Symptom checkers built as inaccessible single-page apps
• PDF clinical forms not tagged for accessibility
• Appointment scheduling calendars unusable by keyboard
Remediation priorities
• Patient-portal login and account management
• Appointment scheduling and telehealth flows
• Clinical content (medication info, treatment guides)
• Provider directories and search
• Insurance forms and benefits explanations
How to comply with ACA on a Healthcare site
1. Publish an accessibility plan: Every federally regulated entity must publish a multi-year accessibility plan, updated every three years.
2. Establish a feedback mechanism: Accept and respond to accessibility complaints.
3. File progress reports: Annual progress report between plans.
4. Meet technical ICT requirements: Reference EN 301 549 for digital products and services.
Sources
- Accessible Canada Act — Government of Canada
- HHS Section 1557 Final Rule (Web Accessibility) — US HHS Office for Civil Rights
FAQ
Frequently asked questions
Cited answers. Sourced. Updated as standards and case law change.
Does ACA apply to healthcare websites?
The Accessible Canada Act (ACA, 2019) requires federally regulated entities — federal government, banks, telecom, broadcasting, transportation — to identify, remove and prevent accessibility barriers, with the explicit goal of "a Canada without barriers by 2040" and detailed regulations layered on top including the ICT regulations referencing EN 301 549.
What are the most common ACA failures in healthcare sites?
Patient portal logins without screen-reader-accessible MFA Telehealth video without captions or sign-language interpreter integration Symptom checkers built as inaccessible single-page apps
What conformance level should a healthcare site target?
WCAG 2.2 Level AA is the consensus target for legal compliance and the level referenced by virtually every national accessibility law.
What does HHS Section 1557 require for accessibility?
The May 2024 final rule requires entities receiving federal financial assistance from HHS — virtually all hospitals, clinics, and insurers — to conform to WCAG 2.1 AA for web content, mobile apps, and kiosks. Compliance deadlines stagger from May 2025 through May 2027 based on entity size.
Can a healthcare site use an accessibility widget?
Widgets are problematic in healthcare for two reasons: (1) WCAG conformance must be at source level, not via overlay; (2) HIPAA-covered information transmitted to a third-party overlay vendor may itself create a breach. Most healthcare CISOs disallow third-party overlay widgets.
Does WCAG 2.1 cover telehealth video?
Yes — Criterion 1.2.4 requires real-time captions for live audio content, which includes telehealth visits. 1.2.6 (Sign Language, AAA) is recommended for healthcare emergency content.
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