HHS Section 504 Final Rule: New Antidiscrimination Measures in Healthcare Treatment and Accessibility
Covered Entities, Technology Access, Medical Equipment, Treatment and Valuation Assessments, Recordkeeping, and More

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Health
- event Date
Wednesday, January 8, 2025
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
This CLE webinar will provide a comprehensive overview of the U.S. Department of Health and Human Services Office for Civil Rights' (HHS-OCR) recently enacted final rule with key revisions to the regulations implementing Section 504 of the Rehabilitation Act of 1973 (Section 504). The panel will discuss the final rule's requirements, how these may interact with other antidiscrimination statutes, and the impact these may have on covered entities' operations. The panel will also discuss enforcement measures and best practices for compliance.
Faculty

Mr. Baker is a strategic partner and trusted advisor to managed care organizations, health insurance issuers, plan sponsors, and pharmacy benefit managers because he helps them navigate an increasingly complex and challenging body of federal and state laws and policy considerations. His practice spans federal healthcare programs, such as Medicaid Managed Care and Medicare Advantage, and commercial health insurance under both the Affordable Care Act and ERISA, from legislation and rulemaking through implementation and controversy.
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Ms. Carey brings extensive experience advising healthcare clients on a wide range of regulatory, transactional, and reimbursement issues. She partners with a wide range of clients, from independent providers and ambulatory surgery centers to academic medical centers and private equity investors, to navigate the evolving healthcare landscape. Ms. Carey’s practice is particularly focused on the development and operation of ambulatory surgery centers, certificate of need applications, and value-based care arrangements. She also advises clients in emerging areas such as artificial intelligence in healthcare, palliative care, and the creation of new physician residency and anesthesia assistant programs. Ms. Carey’s deep knowledge of the corporate practice of medicine, Stark Law, Anti-Kickback Statute, EMTALA, HIPAA, and state-specific fee-splitting laws enables her to structure transactions that are both compliant and commercially strategic. Her transactional work is informed by a nuanced understanding of payer-provider dynamics, sharpened by her previous roles at Anthem and other managed care organizations.
Description
For the first time in nearly 50 years, HHS-OCR recently finalized revisions to the regulations implementing Section 504 advancing broad protections for individuals with disabilities when seeking healthcare treatment and updating language to be read consistently with other antidiscrimination statutory provisions such as those under the ADA. Effective July 8, 2024, the final rule broadly applies to all recipients of federal financial assistance from HHS including hospitals, healthcare providers, and social service agencies, among others.
Key provisions of the final rule include: (1) standards for all newly purchased, leased, or otherwise acquired medical diagnostic equipment; (2) ensuring accessibility to technology methods used to deliver healthcare; and (3) prohibiting value assessment measures and/or medical treatment decisions based on stereotypes or preconceived notions about individuals with disabilities. The rule also contains notable exceptions and exemptions.
Given the final rule's potential impact on covered entities' operations, counsel should understand the final rule's requirements, including possible interaction with ACA Section 1557 and the ADA, to assist their clients with compliance obligations.
Listen as our expert panel provides a comprehensive overview of HHS-OCR's final rule revising Section 504 regulations. The panel will address the impact on covered entities and best practices for assisting clients to prepare for compliance.
Outline
- Introduction
- Section 504
- History of the final rule
- The final rule
- Purpose
- Covered entities
- Amended definition of disability
- Prohibited types of discrimination
- Value assessment measures and medical treatment
- Technology standards
- Accessible medical equipment
- Exceptions, exemptions, and reasonable modifications
- Recordkeeping requirements
- Other
- Enforcement
- Interaction with ACA Section 1557 and ADA
- Compliance timeline
- Practitioner takeaways
Benefits
The panel will review these and other important considerations:
- Who are covered entities under the final rule?
- What are the final rule's requirements related to accessibility to technology used by covered entities?
- How may the final rule impact value assessment and medical treatment of covered individuals with disabilities?
- What are key exemptions/exceptions to the final rule?
- How will the agency enforce the rule, and what are possible penalties for noncompliance?
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