From the Parking Lot to the Patient Portal
What ADA Compliance Actually Covers in a Hospital
By Debbie Lindstrom, ADAC — ADA Coordinator, Forsyth County, Georgia. Firefighter, arson investigator, and Life Safety Coordinator for the Northside health care system before she took the accessibility side. A walk through what a hospital actually owes its patients — from the parking lot to the patient portal.
Stanislav Samek
Founder of Samektra Safety Management & Training in Gwinnett County, Georgia, and the editor behind LifeSafetyWiki. The piece below is published as Debbie wrote it — the diagram, the compliance dates, the citations and the cross-links around it are ours.
A word before you read this one
If you work in life safety, you have a mental model of what ADA compliance means, and I would bet money on what is in it: a ramp, a parking space, a restroom grab bar, and the 48-inch reach range you argue about when somebody mounts a fire extinguisher too high. That was my model too.
Debbie Lindstrom sent me the piece below, and it moved my understanding of the subject considerably further than I expected. She is an ADA Coordinator for Forsyth County, Georgia — which means she does this full time, as the job, not as the last item on an inspection checklist.
But she did not come to it from the legal side. She came up through the fire service: firefighter, then arson investigator, then Life Safety Coordinator for the Northside health care system. She has pulled hose, worked fire scenes, and walked hospital corridors on the compliance side before she ever wrote an accessibility finding. That is why this piece reads the way it does — she is not explaining the ADA to facility people from the outside. She was one of us first, and she opens with a line that tells you exactly where she is standing now:
“We are Title II (government), so our requirements are different than yours.”
That is the whole problem in one sentence. The ADA does not treat a county health clinic and the private hospital across the street the same way, and almost nobody outside the accessibility world can tell you why. Debbie can, and then she does something I have not seen anyone else do: she follows the obligation all the way from the parking lot to the patient portal — through the exam table, out to the EV charger, and into the vendor’s mobile app — and shows that it is one continuous duty, not four unrelated ones.
The EV charging section is the part I think most facility people have never considered. Your hospital probably installed chargers in the last few years. Nobody asked the accessibility question when they went in. Debbie asks it here, and then asks the harder follow-up: what happens when the charger is perfect but the app you have to use to start it is not?
Debbie Lindstrom, ADAC
ADA Coordinator, Forsyth County, Georgia. A career that started on the fire side and crossed over: firefighter, then arson investigator, then Life Safety Coordinator for the Northside health care system, and now an ADAC-credentialed ADA Coordinator — the certification administered through the Great Plains ADA Center and the University of Missouri. She has read hospital buildings for fire and life safety and she reads them now for accessibility, which is why she can trace a single obligation from the parking lot through the exam room, out to the EV charger, and into the patient portal — and show that it was one duty the whole way.
ADA Requirements in the Hospital Setting
By Debbie Lindstrom, ADAC — ADA Coordinator, Forsyth County, Georgia
We are Title II (government), so our requirements are different than yours.
Key ADA Requirements for Private Hospitals
Because they fall under Title III, private hospitals are required to implement the following:
- Physical Accessibility: Facilities must comply with the ADA Standards for Accessible Design, which covers accessible parking, ramps, elevators, and wide pathways.
- Effective Communication: Hospitals must provide auxiliary aids and services—such as sign language interpreters, Braille materials, or accessible technology—to ensure effective communication with patients who have vision, hearing, or speech disabilities.
- Accessible Medical Equipment: Medical diagnostic equipment, including adjustable exam tables, weight scales, and imaging equipment, must be accessible to patients with mobility disabilities.
- Policy Modifications: Hospitals must make reasonable modifications to their policies and procedures to ensure equal access (e.g., allowing service animals or making exceptions to visiting hours for caregivers assisting a disabled patient).
Exemptions and Limitations
While Title III is broad, private hospitals do have a few legal protections:
- Undue Burden: A hospital is not required to provide a specific accommodation if it would result in an undue financial or administrative burden.
- Fundamental Alteration: Accommodations that would fundamentally alter the nature of the goods, services, or facilities provided are not required.
A Note on Public vs. Private
It is worth noting that the ADA divides health care coverage based on entity type. While private hospitals fall under Title III, hospitals and clinics operated by state or local governments fall under Title II of the ADA. Additionally, many U.S. hospitals are also subject to Section 504 of the Rehabilitation Act because they accept federal funds like Medicare and Medicaid.
Electric Vehicle Charging Stations
Under the ADA and Section 504 of the Rehabilitation Act, EV chargers must be accessible to people with disabilities. Sites must feature an 11-foot-wide by 20-foot-long vehicle space, a 5-foot-wide access aisle, and operating controls between 15 and 48 inches high with no tight grasping required.
Electric Vehicle (EV) charging stations must adhere to core accessibility parameters to comply with the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act (which ensures nondiscrimination in programs receiving federal funds).
Specific structural and design requirements include:
- Accessible Routes: Charging stations must connect to building entrances and other site facilities via a firm, slip-resistant accessible route with no abrupt level changes or steep slopes (max slope 1:48).
- Space Dimensions: Accessible charging spaces must measure at least 11 feet wide and 20 feet long. They must be accompanied by an adjacent, clearly marked access aisle that is at least 5 feet wide.
- Operable Parts: All payment screens, card readers, connectors, buttons, and plugs must be positioned between 15 and 48 inches above the ground. Operation must not require tight grasping, pinching, or twisting of the wrist.
- Cable Management: Charging cables should not cross the access aisle or interfere with a clear path of travel. They must be light enough to easily manage and accommodate drivers with limited upper body strength.
- Information and Communication Technology (ICT): Payment interfaces and digital components must also comply with Section 508 of the Rehabilitation Act if the facility is developed or used by the federal government.
WCAG 2.1 AA
Hospitals in Georgia must adhere to WCAG 2.1 AA standards for all digital assets. Enforced under Title II of the ADA and Section 504 of the Rehabilitation Act, this mandate requires patient portals, appointment schedulers, and mobile apps to be accessible to users with disabilities.
Key Requirements
- Core Accessibility Principles: Digital content must be perceivable, operable, understandable, and robust.
- Scope of Compliance: Includes public-facing websites, patient forms, uploaded documents (e.g., PDFs), videos (require closed captioning), and internal digital platforms.
- Vendor & Third-Party Responsibility: Third-party integrations (like telehealth portals or payment gateways) must also meet these standards.
- Deadlines: State and local government-run hospitals (or those receiving federal financial assistance) are required to have compliant web properties.
Resources & Checklists
- Georgia Standards: Review the state’s technical requirements on the Georgia Digital Accessibility Standards page.
- Federal Mandate: Learn more about how the Department of Health and Human Services (HHS) enforces these rules for healthcare providers through the HHS Section 504 Final Rule.
Medicare, Medicaid, and the Private Hospital
Even though it is private, a hospital that accepts Medicare and Medicaid must adhere to strict digital accessibility standards. Because it receives federal financial assistance, the hospital is governed by Section 504 of the Rehabilitation Act, which is enforced by the Department of Health and Human Services (HHS).
This means the hospital’s websites, mobile apps, and patient portals must adhere to the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA.
Privately owned and operated hospitals are defined as places of public accommodation under Title III of the Americans with Disabilities Act (ADA). While the ADA generally requires hospitals to make their services, programs, and activities accessible to people with disabilities, these explicit WCAG requirements are enforced under the Section 504 mandate.
Third-Party Charging Networks
Most EV chargers rely on third-party networks (e.g., ChargePoint, Blink, EVgo) via their own mobile apps to locate stations, initiate charging, and handle payments.
- The Rule: The strict HHS Section 504 rule generally targets the hospital’s own digital products.
- The Catch: Under Title III of the ADA, the hospital cannot offer a public amenity (like parking/charging) that is structurally inaccessible to individuals with disabilities. If a patient cannot charge their car because the vendor’s app fails WCAG standards, the hospital faces direct legal exposure for failing to provide an accessible public accommodation.
The Physical Charger Touchscreen (Kiosk & ADA Rules)
If the EV charger has an interactive touchscreen display built into the hardware, it is classified as a kiosk or an electronic user interface.
- HHS Section 504 Kiosk Rules: The Section 504 framework explicitly includes accessibility mandates for hardware kiosks on hospital grounds. While WCAG is traditionally for web/mobile software, the digital interface on the screen must provide equivalent accessible communication (such as speech-to-text, audio guidance, or high contrast text).
- U.S. Access Board Standards: The physical screen, card readers, and buttons are heavily governed by the U.S. Access Board’s EV Standards. These rules dictate physical reach ranges, operable parts, and communication.
The three clocks
Debbie’s piece describes the shape of the obligation. What a document like hers cannot carry — because the dates keep moving — is the calendar. There are three separate compliance clocks running on this material, they run at different speeds, and two of them changed in the last four months. If you are working from any compliance calendar written before spring 2026, it is wrong.
| Clock | What it requires | Who | Date | Status |
|---|---|---|---|---|
| Accessible medical diagnostic equipment | At least one accessible exam table and one accessible weight scale meeting 36 CFR Part 1195 (M301 / M303) | HHS Section 504 recipients — anyone billing Medicare or Medicaid | July 8, 2026 | PASSED — enforceable now |
| Accessible medical diagnostic equipment | Same scoping, under the DOJ Title II rule | State and local government hospitals and clinics | August 9, 2026 | DAYS AWAY |
| Digital — WCAG 2.1 AA | Web content, mobile apps and kiosks conform to WCAG 2.1 Level A and AA | Title II public entities, population 50,000+ | April 26, 2027 | EXTENDED +1 YR |
| Digital — WCAG 2.1 AA | Same standard, under HHS Section 504 | Recipients with 15+ employees | May 11, 2027 | EXTENDED +1 YR |
| EV charging station design | The 11 ft × 20 ft space and 5 ft aisle as an enforceable standard | All covered entities, eventually | No date | NPRM ONLY — not final |
Sources: HHS Section 504 final rule (89 Fed. Reg. 40066); DOJ interim final rule of April 20, 2026 (91 Fed. Reg. 20902); HHS OCR interim final rule of May 7, 2026; U.S. Access Board EV charging NPRM of September 3, 2024. Smaller entities get later dates in every row — April 26, 2028 under Title II, May 10, 2028 under Section 504.
The one that will surprise people. The exam-table and weight-scale deadline is not coming — it arrived on July 8, 2026 and is enforceable today. If your facility bills Medicare or Medicaid and cannot point to at least one height-adjustable exam table and one wheelchair-accessible weight scale that meet the MDE standards, you are out of compliance right now, not next year. Meanwhile the deadline everyone was bracing for — the WCAG one — is the one that moved. Both digital deadlines were pushed a full year in spring 2026. It is an easy pair of facts to get exactly backwards.
What is enforceable today versus what is recommended
One clarification worth adding to Debbie’s EV section, because the distinction decides whether a finding survives a challenge. The numbers she cites come from two different places with two very different legal weights:
| Provision | Source | Weight |
|---|---|---|
| Operable parts 15 in. – 48 in.; no tight grasping, pinching or twisting; 5 lbf max | 2010 ADA Standards §308, §309 | Enforceable standard |
| Accessible route connecting the charger to entrances and site facilities | 2010 ADA Standards §206, §402–§403 | Enforceable standard |
| Clear floor or ground space at the charger (30 in. × 48 in.) | 2010 ADA Standards §305 | Enforceable standard |
| Not offering an amenity a person with a disability cannot use | Title II / Title III nondiscrimination; Section 504 | Enforceable duty |
| 11 ft × 20 ft vehicle charging space; 5 ft access aisle; 1:48 slope | Access Board technical assistance document (2022, rev. 2023) | Recommendation |
The Access Board document says it outright: where it uses “should” or “recommends,” those provisions are “not legally binding.” That does not make them optional in practice — they are the federal government’s stated view of what accessible looks like, they are what a plaintiff’s expert will cite, and the September 2024 NPRM proposes to make them binding. Build to them. Just do not write them up as a code violation, because they are not one yet.
The 11 by 20 space and the 15-to-48 band, drawn
The three numbers from Debbie’s EV section in plan and elevation. Note which is which: the space and aisle dimensions on the left are Access Board recommendations; the 15-to-48-inch band on the right is an enforceable reach range under the 2010 ADA Standards and applies to every operable part — the screen, the card reader, the buttons, the connector, and the plug.
Watch the Access Board explain it
If you want this straight from the source, the Joint Office of Energy and Transportation recorded a full session with Juliet Shoultz, a Transportation Systems Engineer at the U.S. Access Board — the agency that wrote the recommendations Debbie cites. She walks through the ADA, ABA and Section 508 requirements that already apply and the new recommendations layered on top, with the site-layout cases that cause the most trouble in practice.
“Designing for Accessible EV Charging Stations” — Joint Office of Energy and Transportation, recorded May 18, 2023, featuring U.S. Access Board Transportation Systems Engineer Juliet Shoultz. Video published by the Joint Office of Energy and Transportation; embedded here with credit.
Where this lands for a facility team
Debbie writes from the coordinator’s chair. Translated into the language of the people who actually walk the building, here is what her piece asks you to go look at:
- Find the exam table and the scale. Not “we have accessible rooms” — find the specific height-adjustable table and the specific wheelchair-accessible scale, confirm they meet the MDE standards, and write down where they are. That deadline is behind you.
- Measure your EV chargers. Screen, card reader, connector holster, cable hook. Anything a driver has to touch, above 48 inches or below 15 inches, is a reach-range problem today — independent of the still-pending EV rulemaking.
- Walk the route, not just the space. A perfectly dimensioned charging space reached only by stepping over a curb or a cable is not accessible. Cable slack lying across the access aisle is the single most common finding on an otherwise-compliant install.
- Open your own patient portal on a screen reader. You have until 2027 now, which feels like a long time and is not, because remediation of an existing portal is measured in quarters and usually involves a vendor.
- Read the charging vendor’s contract. This is Debbie’s sharpest point. Ask the network operator for an accessibility conformance report, require WCAG 2.1 AA conformance in the agreement, and make sure there is a way to start and pay for a session that does not require the app at all.
- Know which title you are. Public hospital authority, county clinic, private non-profit, private for-profit taking Medicare — each one lands in a different combination of Title II, Title III, and Section 504, with different dates. Debbie’s opening line was not small talk; it was the whole framework.
SUGGESTED PROMPT
“I manage facilities for a private hospital that bills Medicare and Medicaid. Walk me through my ADA and Section 504 obligations across four areas: (1) accessible medical diagnostic equipment and whether the July 8 2026 deadline applies to us, (2) EV charging stations we installed in our visitor lot — what's enforceable now versus recommended, (3) our patient portal and WCAG 2.1 AA with the extended 2027 deadline, and (4) what to require from our EV charging network vendor in the contract.”
Have a piece like this in you? LifeSafetyWiki publishes practitioner essays and field observations from people who do this work for a living. We keep your words, add the citations, and put your name and bio on it — the way this one was done. Read more about Debbie Lindstrom, start a thread in the community, or see the rest of the contributors.
Frequently Asked Questions
Is a private hospital covered by ADA Title II or Title III?
Does taking Medicare or Medicaid really trigger federal accessibility requirements?
Are the 11-foot by 20-foot EV charging space dimensions actually required?
When does my hospital have to have an accessible exam table and weight scale?
Did the WCAG 2.1 AA deadline for websites and patient portals pass?
If a third-party app like ChargePoint or EVgo is inaccessible, is that the hospital’s problem?
Does an EV charger touchscreen count as a kiosk?
What is an undue burden defense, and how often does it actually work?
References
1. U.S. Department of Justice, Nondiscrimination on the Basis of Disability by Public Accommodations and in Commercial Facilities, 28 CFR Part 36 (ADA Title III), and 28 CFR Part 35 (ADA Title II). ada.gov — Title III regulations · Title II regulations.
2. 2010 ADA Standards for Accessible Design — §308 reach ranges (15 in. minimum, 48 in. maximum), §309 operable parts (operable with one hand, no tight grasping, pinching, or twisting of the wrist, 5 pounds maximum force), §502 parking spaces and access aisles, §403 walking surfaces. ada.gov — 2010 ADA Standards.
3. U.S. Access Board, Design Recommendations for Accessible Electric Vehicle Charging Stations, technical assistance document, last updated July 17, 2023. Source of the 11 ft (132 in.) by 20 ft (240 in.) vehicle charging space, the adjoining 60 in. access aisle, and the 1:48 maximum surface slope. The document states expressly that “should” and “recommends” denote recommendations that are not legally binding. access-board.gov/tad/ev.
4. U.S. Access Board, Americans With Disabilities Act and Architectural Barriers Act Accessibility Guidelines; EV Charging Stations — notice of proposed rulemaking published September 3, 2024, comments closed November 4, 2024. Not final as of this writing; DOJ adoption would be a separate rulemaking. federalregister.gov — EV charging NPRM.
5. U.S. Department of Health and Human Services, Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance, final rule, 89 Fed. Reg. 40066 (May 9, 2024), effective July 8, 2024 — adopts WCAG 2.1 Level AA for web content, mobile apps and kiosks, and the Standards for Accessible Medical Diagnostic Equipment. federalregister.gov — HHS Section 504 final rule.
6. U.S. Department of Justice, Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities, interim final rule published April 20, 2026, 91 Fed. Reg. 20902. Moves the Title II web compliance date to April 26, 2027 for public entities serving a population of 50,000 or more, and April 26, 2028 for smaller entities and special districts.
7. HHS Office for Civil Rights, interim final rule published May 7, 2026 extending Section 504 web content and mobile application compliance dates by one year — to May 11, 2027 for recipients with 15 or more employees and May 10, 2028 for recipients with fewer than 15. hhs.gov — OCR extends web and mobile accessibility deadline.
8. U.S. Access Board, Standards for Accessible Medical Diagnostic Equipment, 36 CFR Part 1195 — M301 (equipment used by patients in a supine, prone, or side-lying position, i.e. exam tables) and M303 (equipment used by patients seated in a wheelchair, i.e. weight scales). access-board.gov/mde.
9. W3C, Web Content Accessibility Guidelines (WCAG) 2.1 — the four principles Debbie cites: perceivable, operable, understandable, robust. w3.org/TR/WCAG21.
10. U.S. Access Board, Section 508 Standards for Information and Communication Technology — applies to ICT developed, procured, maintained or used by federal agencies. access-board.gov/ict.
11. Joint Office of Energy and Transportation, Designing for Accessible EV Charging Stations, webinar recorded May 18, 2023, featuring U.S. Access Board Transportation Systems Engineer Juliet Shoultz. driveelectric.gov — accessibility webinar.
12. State of Georgia, Georgia Technology Authority — Georgia Digital Accessibility Standards, the state technical requirements Debbie points readers to for digital assets. gta.georgia.gov.
13. ADA Coordinator Certification (ADACC, formerly ACTCP) — administered through the Great Plains ADA Center and the University of Missouri. The credential behind the ADAC after Debbie’s name. adacoordinator.org.
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