The Rehabilitation Act of 1973 was the first civil rights law that included protections for people with disabilities, with Section 504 of this Act prohibiting discrimination on the basis of disability in a variety of programs that receive federal funds. In 2024, over 50 years after the act was originally published, a new update to Section 504 was finalized. One of the key components of this change includes requirements for accessible medical diagnostic equipment.
The US Access Board, the independent federal agency that develops accessibility guidelines and standards, finalized standards that would increase accessibility of medical diagnostic equipment in 2017. However, until the updates to Section 504 last year, these standards for medical equipment were not enforceable by any government agency – essentially meaning that they were recommendations for healthcare providers but there were no requirements or law stating healthcare providers had to have accessible equipment. Thanks to the updates to Section 504, for the first time there are legal requirements about what equipment must be accessible and what amount of accessible equipment healthcare providers must have.
So, what does this mean for patients with disabilities? Below are answers to some common questions about this update and requirements for healthcare providers.
What equipment is covered by 504?
The Section 504 updates focus on standards for medical diagnostic equipment, which is any medical equipment that is used for diagnosing health conditions. This includes equipment such as examination tables and chairs, weight scales, mammography equipment, x-rays and other imaging and radiology equipment. It does not include things like sitting chairs in waiting rooms or exam rooms, or hospital beds.
Is there any equipment that does not have to be accessible?
Some equipment cannot be made accessible because of how the equipment works. For example, some x-ray machines or tables that are used with MRI machines cannot lower to a height that can be used to transfer out of a wheelchair because there are parts of the equipment used for imaging below the table or bed surface that is vital to the equipment serving its medical purpose. In these cases, healthcare providers should have other means to ensure patients with disabilities are able to use this same equipment, such as using a mechanical lift to help transfer a patient onto the equipment.
How do I know if equipment is accessible?
The specific standards and requirements are different for different types of equipment and very complex. In general, equipment should be able to be used by people with disabilities as easily as people without disabilities, and should allow people with disabilities to use, get onto and off of equipment as independently as they are able. For an examination table, this includes the table being able to be raised and lowered to heights that work for transfers from wheelchairs and other mobility devices, arm rests or railings that can be used for support during transfers, and certain requirements for sizing for different aspects of the table.
Do all healthcare providers have to have accessible examination tables and/or wheelchair accessible scales?
It depends on what equipment a provider or practice already has. If a provider or location does not currently have or use this type of equipment, then they are not required to have an accessible version of the equipment. For example – many mental or behavioral health providers do not have traditional examination tables and instead use furniture such as couches or chairs, which are not covered by the new requirements. Similarly, not every healthcare provider or practice has or uses weight scales as part of their care and treatment, such as dental offices. For these providers and practices, they do not have to have accessible examination tables or wheelchair scales if they do not have or use this equipment for other patients.
Additionally, Section 504 allows for “equivalent facilitation,” which means that healthcare providers can use other methods to provide the same service to a patient with a disability as long as it is as accessible, or more accessible, than the requirements. For example, there are some types of examination tables that have a scale built into them that could be used in place of a wheelchair accessible scale.
How much accessible equipment are healthcare providers required to have?
How many total accessible versions of equipment depends on the total number of that equipment that is available at that location. For most healthcare providers, this will be 10% or at least one of the total number of available equipment. For healthcare providers that primarily treat conditions that impact mobility, such as Physical Therapy or Orthopedics, this increases to 20% of the total number being accessible.
When do healthcare providers have to have accessible equipment?
Section 504 has specific dates for accessible examination tables and wheelchair accessible scales. For these two pieces of equipment, healthcare providers who currently have this equipment must have at least one accessible version in place by July, 2026.
For all other equipment, when new equipment is purchased or leased then an accessible version of the equipment should be purchased if it is available until healthcare providers have reached the total amounts required as described above. This includes locations that would need more than one accessible examination table or wheelchair scale.
Increasing availability of accessible medical equipment is an important step towards health equity for people with disabilities. While it may take some time for all healthcare providers to get accessible medical equipment, people with disabilities should be sure their providers know what equipment they may need. Be sure this is documented in their patient record so that they will have access to accessible equipment when it is available.
Today's blog is provided by Advisory Committee Member Holly Darnell. Holly is the ADA Coordinator for UCHealth Medical Group.