Letter to ACL Grantees on Section 504 Rule

September 25, 2024

ACL and the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) released a joint letter to ACL grantees on the historic May 2024 final rule implementing Section 504 of the Rehabilitation Act of 1973. The comprehensive update — the first since the initial regulation was put into place more than 50 years ago — is a powerful tool to combat discrimination based on disability in health care and human services.

For ACL’s networks and entities receiving ACL funding, this rule has special significance. It advances our mission to expand community living for disabled people, including the nearly 50% of older adults who have disabilities. It also creates new compliance requirements for recipients of federal funding from HHS, including all ACL grantees.

The letter highlights a new section-by-section fact sheet created by OCR that can help ACL grantees understand the Section 504 rule and their compliance obligations as covered entities. The fact sheet addresses important obligations, including:

  • Web, mobile, and kiosk accessibility: Web content and mobile apps must comply with the specific technical standards of the Web Content Accessibility Guidelines 2.1 levels A and AA (WCAG 2.1 AA), the internationally recognized private standard that the rule adopts.
  • Reasonable modifications and effective communication requirements: Section 504 now includes regulatory provisions that mirror long-standing requirements under the ADA for public and private health care and social service providers. Recipients that are covered by both Section 504 and the ADA will now have many of the same disability nondiscrimination obligations under both laws. For example, recipients must take appropriate steps to ensure that communications with individuals with speech, hearing, and vision disabilities are as effective as communications with others. They must also make reasonable modifications to policies and procedures to accommodate people with disabilities unless they can demonstrate a modification would fundamentally alter the nature of the program or activity.
  • Requirements for implementing the new rule: Recipients with 15 or more employees must designate an individual to coordinate efforts to comply with the rule and must adopt grievance procedures that provide for a prompt and equitable resolution of complaints. They must also provide accessible information to employees, applicants, and participants on the rule’s protections against discrimination.
ACL grantees with questions about the Section 504 rule are encouraged to contact their project officer and send a copy of the message to 504@acl.hhs.gov.

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