Is Your Urgent Care Ready for the 2026 ADA Mandate?

Published on December 31, 2025

Urgent Message: Urgent care facilities must ensure their medical diagnostic equipment and staff training protocols meet new ADA accessibility standards by the July 8, 2026, deadline.

Key Words: Americans with Disabilities Act; Medical Diagnostic Equipment; Accessible Exam Tables; Staff Training; Urgent Care Compliance

Alan A. Ayers, MBA, MAcc

Ensuring equal access to healthcare services isn’t just a goal, it’s a legal mandate. The Americans with Disabilities Act (ADA)¹ assures everyone has equal access to healthcare by setting the necessary accessibility standards for medical facilities.² Because nearly all urgent cares receive Department of Health and Human Services (HHS) funding, they must comply with new ADA requirements for Medical Diagnostic Equipment (MDE) by July 8, 2026. This article outlines the specific changes and details the steps urgent care operators must take to comply.

Background

The new ADA-related accessibility rules apply to a wide range of healthcare providers, including state-run facilities and private urgent cares that accept federal funding. To simplify, this article will use the term “covered entities” to refer to all facilities that must comply with these new mandates.³

A new Department of Justice (DOJ) rule issued in April 2024 now legally mandates new accessibility standards for urgent care centers and officially adopts the technical “blueprints” for accessible MDE that were first published in 2017. These MDE standards provide specific design criteria for equipment like examination tables, chairs, weight scales, and radiological equipment.⁴ They also require features such as low seat heights, patient support rails, sufficient clearance for mobility aids, and appropriate transfer surfaces and armrests.⁵

The goal, as stated by the U.S. Access Board, is to decrease the risk of litigation and promote health equity by providing dignified, safe access to care.⁶ The new 2024 rule also adds a crucial new mandate: Healthcare practices must now adequately train staff to operate this accessible MDE and assist with transferring and positioning individuals with disabilities.⁷

As a result, facilities must consider how to retrofit or build compliant spaces and acquire equipment that accommodates assistive devices like Hoyer lifts. Importantly, facilities will not be “grandfathered” in to avoid these new requirements.⁸

Although the rule specifically applies to state and local government healthcare facilities, assuming all urgent cares accept some form of federal funding (eg, Medicare or Medicaid), the new rule will also be applicable to private urgent care facilities. HHS notes that entities that participate in Medicare, Medicaid, or other grant or funding programs from HHS are covered by these new requirements.⁹

Key Changes to ADA Requirements for Medical Diagnostic Equipment

The DOJ’s final rule has specific requirements concerning MDE, including:¹⁰

• Entities’ newly acquired MDE must meet the MDE standards. The rule generally requires all MDE that covered entities purchase, lease, or otherwise acquire after October 8, 2024, to be accessible, until the entities have the amount of accessible MDE specified in the rule. Entities may elect to obtain more accessible MDE, provided that they have the number specified in the rule.

• Entities must meet certain requirements for their existing MDE. Covered entities must also address barriers that result from a lack of existing accessible MDE, however, entities do not necessarily have to make all of their existing MDE accessible. This means that your overall service must be accessible, even if not every single piece of equipment is. A patient with a disability must be able to get the care you offer, even if it requires directing them to a specific, accessible exam room or scale.

• Entities that use examination tables and weight scales must have at least 1 accessible examination table and weight scale.  Facilities that use examination tables must purchase, lease, or otherwise acquire at least 1 examination table that meets the MDE standards, unless the entity already has such a table. Likewise, urgent cares that use a weight scale must purchase, lease, or otherwise acquire at least 1 weight scale that meets the MDE standards, unless the entity already has such a scale.

• Entities must make certain that their services, programs, and activities that use MDE are accessible to individuals with disabilities. Covered entities cannot deny healthcare services to a patient with a disability that they would otherwise provide because they lack accessible MDE. Entities cannot require a patient with a disability to bring another person with them to help if patients without disabilities are not required to do the same.¹¹

• Entities must employ staff qualified to operate accessible MDE. The rule requires covered entities to ensure their staff can successfully operate accessible MDE, assist with transfers and positioning of individuals with disabilities, and execute the rule’s requirements for existing MDE. At all times when services are provided to the public, covered entities are expected to have staff who can operate accessible MDE.

What is the Result of the New ADA Rule?

The equipment most impacted by the new requirements includes, but is not limited to examination tables and chairs, weight scales, x-ray machines. The Access Board’s MDE standards provide precise technical specifications for accessible equipment, so look for the following key features.

• Adjustable height: The new rule requires an adjustable low-transfer height of 17 to 19 inches for equipment like exam tables and chairs. This specific range is designed to align with the seat height of most wheelchairs, facilitating safer, more independent transfers for patients with mobility disabilities. The standards also mandate a high adjustable position of at least 25 inches to accommodate different procedures and provider needs. This rule does not necessarily require replacing all equipment. Instead, it mandates that at least 10% of the total number of diagnostic units of each type at a facility, but no fewer than 1 unit, must meet these new standards. By the July 8, 2026, deadline, this means an urgent care must have, at minimum, at least 1 accessible exam table and 1 accessible weight scale.¹²
• Transfer surfaces and supports: This standard requires equipment to have a dedicated, appropriately sized transfer surface as well as sturdy supports for transfers.¹³ For exam chairs, the transfer surface must be at least 21 inches wide and 17 inches deep. For exam tables, it must be at least 28 inches wide and 17 inches deep. The area must also allow for an unobstructed transfer from a mobility device, typically on 2 adjoining sides. Sturdy transfer supports (like armrests or grab bars) must be available. These supports must be able to resist 250 pounds of force, be located within 1.5 inches of the transfer surface, and be movable or removable to not block the transfer.
• Wheelchair accessibility: This standard applies to equipment like scales, x-ray machines, and other imagers designed to be used by a patient while remaining in their wheelchair. For weight scales, this means a “roll-on” platform that is at least 36 inches wide and 48 inches deep with a ramp that is not steeper than 1:12, and edge protection. For x-ray machines, the equipment must provide a clear “wheelchair space” of at least 36 inches wide and at least 48 inches deep to allow the patient to position themselves correctly for the scan. Beyond the equipment itself, this standard also requires adequate clear floor space around the diagnostic machine—generally 30 by 48 inches—to allow a patient to maneuver and approach it.¹⁴
• Lift compatibility: This standard applies to equipment like examination tables and chairs. “Compatibility” means the equipment must be designed with specific physical clearance for a portable patient lift. This includes clear space under the base—at least 6 inches high and 39 inches wide—to allow the legs of a lift (like a Hoyer lift) to roll in, as well as clear space around the base for positioning.
• Accessible controls: This standard, which applies to controls used by the patient, requires that operable parts be accessible to people with a wide range of disabilities. This governs both the location and operation of the control. Controls must be placed within an accessible reach range (typically 15 to 48 inches from the floor). They must also be operable with 1 hand, not require tight grasping, pinching, or twisting of the wrist, and activate with 5 pounds of force or less. The new rule does not obligate changes that would result in a fundamental alteration or cause undue financial and administrative burdens.¹⁵

Key Compliance Deadlines

• July 8, 2026 (for most private urgent cares): If your urgent care accepts Medicare or Medicaid, you must have at least 1 examination table and at least 1 weight scale that are fully accessible to patients with disabilities. This also means you must train your staff on how to use this new equipment and how to properly assist patients in getting on and off it.
• August 9, 2026 (for government-owned urgent cares): This deadline applies to urgent care centers that are run by the state or local government. The requirement is the same: these public facilities must also have at least 1 accessible examination table and 1 accessible weight scale in operation by this date. Staff training is also required.

The July 8, 2026, deadline is not a distant suggestion; it is a firm, fast-approaching mandate. Urgent care operators must act now to ensure compliance. The first step is to conduct a thorough audit of all current MDE, specifically identifying noncompliant exam tables and weight scales. Based on this audit, a capital plan must be implemented to purchase, lease, or acquire at least 1 compliant exam table and 1 compliant weight scale before the 2026 date.

Concurrently, operators must develop and deploy a formal staff training program. This training must cover not only how to operate the new equipment but also the proper, dignified procedures for assisting patients with transfers and positioning. Proactively addressing both equipment and training is the only way to meet the “program accessibility” requirement, prevent service denial, reduce litigation risk, and ultimately provide equitable care to all patients.

References

1. Americans with Disabilities Act of 1990, as amended, 42 USC §12187.
2. ADA National Network. What Is the Americans with Disabilities Act (ADA)? Updated October 2025. Mudrick NR, Breslin ML, et al. Accessible medical diagnostic equipment in primary care: assessing its geographic distribution for disability equity. Disabil Health J. 2023.
3. Jones JR. Americans with Disabilities Act (ADA) Requirements for Health Care Providers. Jones Health Law. Iezzoni LI, Stein MA. New rules requiring accessible medical diagnostic equipment—updates to Section 504 disability civil rights regulations. JAMA. 2024.
4. US Department of Health and Human Services, Office for Civil Rights; Administration for Community Living. Standards for Accessible Medical Diagnostic Equipment. Updated July 23, 2025.
5. US Access Board. Medical Diagnostic Equipment Accessibility Standards: About the Accessibility Standards for Medical Diagnostic Equipment.
6. Id.
7. US Department of Justice. Standards for Accessible Medical Diagnostic Equipment. Access Board standards codified at 36 CFR Part 1195 (rev. July 1, 2017). The rule defines medical diagnostic equipment as equipment used by health care providers for diagnostic purposes (e.g., exam tables, exam chairs, dental chairs, weight scales, mammography equipment, X-ray machines).
8. ADA National Network. Health Care and the Americans with Disabilities Act. Updated November 2025.
9. US Department of Health and Human Services. New Requirements for Accessible Medical Diagnostic Equipment. “The requirements apply to doctors, dentists, hospitals, clinics, emergency rooms, and other health care providers that use medical diagnostic equipment in providing their services.”
10. US Department of Justice, Civil Rights Division, Disability Rights Section. Fact Sheet: New Rule on the Accessibility of Medical Diagnostic Equipment Used by State and Local Governments. August 8, 2024.
11. CME Corp. Navigating ADA Requirements for Medical Diagnostic Equipment. August 5, 2025.
12. Henry Schein. ADA Medical Equipment: What Your Practice Needs to Know.
13. Midmark. ABCs of the Accessible Exam Room.
14. Martynov Y. All You Need to Know About ADA Wheelchair Requirements. Route Genie.
15. American College of Radiology. DOJ Finalizes Rule on Accessible Medical Diagnostic Equipment. August 13, 2024.