Brian Beals, LLC

Section 504 Digital Accessibility · Patient-Facing Document Inventory & Conformance
Punta Gorda, FL · nationwide
brian@brianbeals.com
brianbeals.com/accessibility/healthcare
(941) 979-6282
SBA-Certified Service-Disabled Veteran-Owned Small Business · Evaluation Only, Never Remediation
The deadline. The HHS final rule at 45 CFR Part 84 requires WCAG 2.1 Level AA for web content, mobile apps, and electronic documents. Recipients with 15 or more employees must comply by May 11, 2027, under 15 by May 10, 2028. Billing Medicare or Medicaid makes an organization a recipient of federal financial assistance, which is what brings the rule to nearly every provider. Enforcement runs through HHS OCR, and Section 504 also carries a private right of action.

Company Snapshot

SDVOSBSBA-Certified
CertifiedAugust 2026
UEINJLEHNAQATJ6
CAGE22XM3
Founded2026 · Florida
LocationPunta Gorda, FL
Independent evaluator. No remediation services offered, at any price.

Standard Applied

WCAG2.1 Level AA
Rule45 CFR Part 84
ReportVPAT 2.5 / ACR
AlsoTitle II · 508

Scope Covered

DocumentsPDF & Office
FormsIntake & fillable
WebPages & templates
PortalPatient-facing
MobileApps & responsive
Third partyVendor VPAT review

Codes

541512Computer Systems Design
541511Custom Programming
541519Other IT Services
541611Management Consulting
80101507IT Consultation
81112000Data Services

A veteran-owned consultancy that tells a health center or health system how many patient-facing documents it actually has, which ones the rule reaches, and what to do with each. The deliverable is a count and a prioritized list, not a repair invoice. Delivered by one principal with an enterprise data and automation background.

Services

Baseline Patient-Facing Document Inventory

Every document discovered across the organization’s web properties and clinic microsites, each one probed for tag structure, declared language, headings, table headers, alternative text, document title, and whether the file is scanned paper with no readable text at all, then checked against veraPDF, the ISO reference validator for PDF/UA-1. The validator finds what no tag count can: content drawn on the page and never tagged, which assistive technology does not reach at all. Its results are reported as WCAG success criteria and never as a PDF/UA verdict, because the rule obligates WCAG 2.1 AA and PDF/UA is a wider standard no recipient is held to. Reading order and alt-text quality are not machine-detectable; they are reviewed by a person on a sample the probe selects, and the report says so on its face. Each document is then sorted by whether a patient uses it to apply for, access, or take part in a program, which is the line the rule actually draws. Deliverable is a count, a prioritized remediation specification a vendor can bid against, and a dated record of what was known and when. Fixed fee, scoped to the number of web properties.

Accessibility Conformance Report

All 50 WCAG 2.1 Level A and AA success criteria evaluated against the public site, each one marked Supports, Partially Supports, Does Not Support, or Not Applicable, each one evidenced. Issued in VPAT 2.5 format, the same document a procurement office already requires from software vendors. Dated and signed, with the method and its limits stated on the face of the report.

Annual Re-Inventory

Re-crawl, re-probe, and a delta against the prior baseline. A document library drifts in one direction: every form published without tags moves the count backward, and nobody publishing it is thinking about tags. A count taken once was true once.

Program Support

Published accessibility statement naming the standard and conformance level, a grievance path, procurement language requiring an ACR before purchase, and content governance so newly published material stops regressing.

Differentiators

  • The legacy-document exemption is narrower than it reads. The rule exempts documents published before the compliance date, and the exemption stops at any document used to apply for, access, or take part in a program. Intake, consent, financial assistance, and portal documents stay in scope regardless of age. Most organizations plan against the exemption rather than against the carve-out inside it.
  • Evaluation only, never the remediation. A conformance claim written by whoever repaired the documents is self-assessment. Staying out of the repair is what lets the report mean something, and it produces a specification a remediation vendor bids against rather than a per-page quote nobody can check.
  • A tagged PDF is not a conforming PDF. Most checkers ask only whether tags exist. A document can carry them and still be unreadable: no headings, tables with no header cells, images with no alternative text. That is what an auto-tag pass leaves behind, and often what an organization receives after paying to have it fixed.
  • Triage before spend. Remediation is priced per page. A library carries documents that are obsolete, duplicated, superseded, or should never have been PDFs. Sorting that out first is the cheapest money in the program, and it is the step that gets skipped.
  • The report says what it did not check. Reading order, meaningful alternative text, and focus order are not machine-detectable. An unanswered criterion reports as Not Evaluated, never as Supports.
  • Built for volume. An enterprise data and automation background applied to cataloging and classifying document libraries that run to five figures.
  • No overlay, no platform license, no per-page quota. There is no product behind the recommendation, so the recommendation follows the findings.

Demonstrated Capability

Method. Findings are measured, not estimated. Where a check cannot be made honestly, for example text over a photograph where the background color is unknowable from the page, it is reported as indeterminate rather than asserted. A finding a client can disprove costs more than a finding never made.

Past performance. Newly formed, with no accessibility contract past performance to date. The reference implementation above is the firm’s own site, evaluated and remediated end to end under the same method proposed here, with the resulting report available on request. Manual assistive-technology validation at depth and high-volume document remediation are delivered with a specialist partner. Available to subcontract the assessment, inventory, and program layer under a remediation prime.