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Accessible medical equipment: exam tables, scales and what clinics must have
When the Department of Justice wrote its rule, many commenters said they had been unable to get care, or got an incomplete exam, because a provider had no accessible examination table or weight scale (ADA title II rule on medical diagnostic equipment (28 CFR 35), appendix E, section 35.211(c)). Since 2024, two federal rules deal with exactly that. The Department of Health and Human Services (HHS), under Section 504, and the Department of Justice (DOJ), under title II of the ADA, require clinics and hospitals they cover to have accessible medical diagnostic equipment: at least one examination table that lowers to a transfer height of 17 to 19 inches and at least one accessible weight scale, and 10 percent of each type of equipment over time (HHS Section 504 rule (45 CFR 84), 45 CFR 84.92(b) and (c); ADA title II rule on medical diagnostic equipment (28 CFR 35), 28 CFR 35.211(b) and (c)). The measurements come from the U.S. Access Board’s Standards for Accessible Medical Diagnostic Equipment (Standards for Accessible MDE, 2017 text, M301 to M307). This guide gives them section by section, with who has to comply and by when.
This guide summarizes the sources it cites; it is not legal advice. The official texts are the reference.
What counts as accessible medical equipment
Both rules use the same definition. Medical diagnostic equipment, MDE for short, is equipment used in, or in conjunction with, medical settings by health care providers for diagnostic purposes. It includes examination tables, examination chairs (dental and eye exam chairs among them), weight scales, mammography equipment, x-ray machines and other radiological equipment (HHS Section 504 rule (45 CFR 84), 45 CFR 84.10; ADA title II rule on medical diagnostic equipment (28 CFR 35), 28 CFR 35.104). Equipment counts as accessible when it meets the Standards for Accessible MDE, which the two rules define as the Access Board’s 36 CFR part 1195 in its January 9, 2017 version, except for two sunset provisions, M301.2.2 and M302.2.2 (HHS Section 504 rule (45 CFR 84), 45 CFR 84.10; ADA title II rule on medical diagnostic equipment (28 CFR 35), 28 CFR 35.104).
The Access Board wrote the measurements, but it does not enforce them: as it issued them, the standards are not mandatory on health care providers or manufacturers, and other agencies may adopt them (U.S. Access Board page on the MDE standards). The standards themselves say that the enforcing authority decides how many pieces of equipment, and of which type, have to comply (Standards for Accessible MDE (36 CFR 1195), M201.1). That is what the HHS and DOJ rules of 2024 did.
The standards sort equipment by the position the patient is in, not by its name (Standards for Accessible MDE (36 CFR 1195), M101.2):
- Lying down (supine, prone or on the side): examination tables and imaging beds, in M301 (Standards for Accessible MDE (36 CFR 1195), M301.1).
- Seated: examination chairs, in M302 (Standards for Accessible MDE (36 CFR 1195), M302.1).
- Seated in a wheelchair: scales with a wheelchair platform, or a mammography unit you use without leaving the chair, in M303 (Standards for Accessible MDE (36 CFR 1195), M303.1).
- Standing: a standing scale, for example, in M304 (Standards for Accessible MDE (36 CFR 1195), M304.1).
Accessible exam tables: transfer height of 17 to 19 inches
An accessible examination table has a transfer surface, the part you move onto from a wheelchair, that goes up and down. These are the requirements of section M301, as HHS and the DOJ apply them:
| Element | Requirement | Section |
|---|---|---|
| Low transfer position | 17 inches (430 mm) minimum and 19 inches (485 mm) maximum, measured from the floor to the top of the uncompressed transfer surface | Standards for Accessible MDE, 2017 text, M301.2.1, item A |
| High transfer position | 25 inches (635 mm) | Standards for Accessible MDE, 2017 text, M301.2.1, item B |
| Positions in between | at least 4 more transfer positions between the low and the high one, at least 1 inch (25 mm) apart | Standards for Accessible MDE, 2017 text, M301.2.1, item C |
| Size of the transfer surface | at the end of the table: 28 inches (710 mm) wide and 17 inches (430 mm) long minimum; along its side: 28 by 28 inches (710 × 710 mm) minimum | Standards for Accessible MDE (36 CFR 1195), M301.2.3.1 and M301.2.3.2 |
| Open sides | two unobstructed sides for the transfer; an obstruction no more than 3 inches (75 mm) deep is allowed if it does not stick up above the surface, and a temporary one if it can be moved out of the way | Standards for Accessible MDE (36 CFR 1195), M301.2.4 |
| Something to hold | transfer supports, within 1 1/2 inches (38 mm) of the edge, with the top of the grip 6 to 19 inches (150–485 mm) above the transfer surface | Standards for Accessible MDE (36 CFR 1195), M301.3.1, M305.2.1 and M305.2.3 |
| Stirrups and reclining | where there are stirrups, leg supports too; where the table reclines, head and back support | Standards for Accessible MDE (36 CFR 1195), M301.3.2 and M301.3.3 |
| Patient lift | usable with a portable floor lift: a clearance in the base 39 inches (990 mm) wide, 6 inches (150 mm) high and 36 inches (915 mm) deep, or a clearance around a base no wider than 26 inches (660 mm) at the edge | Standards for Accessible MDE (36 CFR 1195), M301.4, M301.4.1 and M301.4.2 |
The transfer surface is the part of the equipment onto which a patient who uses a mobility device or aid moves on and off (Standards for Accessible MDE (36 CFR 1195), M102.1). Its height is measured from the floor to the top of the surface, uncompressed, so a soft pad that sinks under you does not count in the table’s favor (Standards for Accessible MDE, 2017 text, M301.2.1).
The same 17 to 19 inches also appears in ADA toilet height, but that is the toilet seat in a restroom, under another rule. Here it is the table, and the table has to move: one fixed height does not meet M301.2.1.
Why 17 to 19 inches, and not 17
If you look up 36 CFR part 1195 today, the low transfer position reads “17 inches”, and M301.2.2 says “[Reserved]” (Standards for Accessible MDE (36 CFR 1195), M301.2.1 and M301.2.2). That is the Access Board’s final rule of July 25, 2024 (U.S. Access Board page on the MDE standards). The 2017 text read 17 inches minimum and 19 inches maximum, and M301.2.2, the sunset, said that range would cease to have effect on January 10, 2022 (Standards for Accessible MDE, 2017 text, M301.2.1 and M301.2.2); in 2022 the Board extended it three years (U.S. Access Board page on the MDE standards).
HHS and the DOJ adopted the 2017 version without the sunset provisions (HHS Section 504 rule (45 CFR 84), 45 CFR 84.10; ADA title II rule on medical diagnostic equipment (28 CFR 35), 28 CFR 35.104). The DOJ explains why: had it kept them, there would be no enforceable minimum low transfer height, since its rule came after January 10, 2022. So under its rule, an entity buying accessible equipment can choose a table that lowers to anywhere between 17 and 19 inches, and it still has to make its services usable whether its table lowers to 17 or to 19 (ADA title II rule on medical diagnostic equipment (28 CFR 35), appendix E, section 35.104).
In short: 17 to 19 inches is what HHS and the DOJ enforce today; 17 inches is the Access Board’s current text, which neither rule has adopted.
Accessible weight scales for wheelchair users
A wheelchair scale is equipment used by a patient seated in a wheelchair, so it follows M303: a platform large enough for the chair, which the patient rolls onto and faces the same way as anyone else being weighed (Standards for Accessible MDE (36 CFR 1195), M303.2 and M303.2.1).
| Element | Requirement | Section |
|---|---|---|
| Width | 36 inches (915 mm) minimum; 32 inches (815 mm) on a raised platform, up to 4 inches (100 mm) above the platform | Standards for Accessible MDE (36 CFR 1195), M303.2.2 |
| Depth | 48 inches (1220 mm) with entry and exit at one end only; 40 inches (1015 mm) if you roll on at one end and off at the other; 60 inches (1525 mm) with side entry | Standards for Accessible MDE (36 CFR 1195), M303.2.3 |
| Slope | the platform surface no steeper than 1:48 in any direction | Standards for Accessible MDE (36 CFR 1195), M303.2.5 |
| Getting on | a lip up to 1/4 inch (6.4 mm) can be vertical; from 1/4 to 1/2 inch (13 mm), beveled at 1:2 at most; higher than that, a ramp no steeper than 1:12 (1:8 for a rise of 2 1/2 inches, 64 mm, at most), 36 inches (915 mm) wide | Standards for Accessible MDE (36 CFR 1195), M303.3 |
| Edges and rails | a platform raised more than 1 1/2 inches (38 mm) has edge protection 2 inches (51 mm) high on the sides without entry; a ramp rising more than 6 inches (150 mm) has handrails on both sides | Standards for Accessible MDE (36 CFR 1195), M303.2.6 and M303.3.3.5 |
| Standing supports, if the scale is also used standing | supports on two sides of the standing surface; where they are horizontal, the grip runs along at least 80 % of the platform with one entry that is also the exit, and the full length on a roll-through scale; a vertical support is 18 inches (455 mm) long minimum | Standards for Accessible MDE (36 CFR 1195), M304.2.2, M305.3.1.2 and M305.3.1.3 |
For patients weighed standing, the standing surface is slip resistant, with supports on two sides; a horizontal support has its grip 34 to 38 inches (865–965 mm) above the standing surface (Standards for Accessible MDE (36 CFR 1195), M304.2 and M305.3.2.1). A wheelchair scale that also has its own seat does not have to meet the seated rules of M302 as well (Standards for Accessible MDE (36 CFR 1195), M302.1, exception).
Exam chairs, mammography, imaging and controls
- Examination chairs (dental, eye, ear, nose and throat): the same adjustable transfer surface, low position at 17 to 19 inches and high one at 25 inches (Standards for Accessible MDE, 2017 text, M302.2.1), at least 21 inches wide and 17 inches (430 mm) deep, with transfer possible from two adjoining sides (Standards for Accessible MDE (36 CFR 1195), M302.2.3 and M302.2.4).
- Mammography: components used to examine a body part have to work for a patient seated in a wheelchair, and the breast platform adjusts continuously from 26 to 42 inches (660–1065 mm) above the floor (Standards for Accessible MDE (36 CFR 1195), M303.4 and M303.4.1).
- CT, PET and other scanners with a bore: the transfer surface may be 21 inches (535 mm) wide, but never narrower than the patient surface (Standards for Accessible MDE (36 CFR 1195), M301.2.3.1 and M301.2.3.2, exceptions).
- Instructions: where the equipment itself gives the patient instructions, it does so in at least two of three ways: audible, visible or tactile (Standards for Accessible MDE (36 CFR 1195), M306.1). That matters to a blind patient as much as to a deaf one.
- Controls for the patient: tactilely discernible without activating them, usable with one hand, without tight grasping, pinching or twisting of the wrist, and with 5 pounds (22.2 N) of force at most (Standards for Accessible MDE (36 CFR 1195), M307.2 to M307.4).
- The one exception: in the rare cases where complying would change features the diagnosis needs and prevent the intended use, the equipment complies as far as practicable (Standards for Accessible MDE (36 CFR 1195), M201.2).
How many accessible exam tables and scales a clinic needs
The two rules use the same numbers, counted for each type of equipment in use (HHS Section 504 rule (45 CFR 84), 45 CFR 84.92(b); ADA title II rule on medical diagnostic equipment (28 CFR 35), 28 CFR 35.211(b)):
| Where | Minimum | Section |
|---|---|---|
| Doctors’ offices, clinics, emergency rooms, hospitals, outpatient and multi-use facilities | at least 10 % of the units of each type of equipment, and never fewer than one | HHS Section 504 rule (45 CFR 84), 84.92(b)(1); ADA title II rule on medical diagnostic equipment (28 CFR 35), 35.211(b)(1) |
| Rehabilitation facilities, outpatient physical therapy and other programs that specialize in conditions that affect mobility | at least 20 % of each type, and never fewer than one | HHS Section 504 rule (45 CFR 84), 84.92(b)(2); ADA title II rule on medical diagnostic equipment (28 CFR 35), 35.211(b)(2) |
| Hospitals and facilities with several departments, clinics or specialties | the accessible units spread in proportion among the departments that use the equipment | HHS Section 504 rule (45 CFR 84), 84.92(b)(3); ADA title II rule on medical diagnostic equipment (28 CFR 35), 35.211(b)(3) |
| Any provider that uses exam tables or scales | at least one accessible exam table if it uses exam tables, and one accessible weight scale if it uses scales, unless it already has them | HHS Section 504 rule (45 CFR 84), 84.92(c)(1) and (2); ADA title II rule on medical diagnostic equipment (28 CFR 35), 35.211(c)(1) and (2) |
So a small practice with three exam tables needs one accessible table, and so does a practice with one table (HHS Section 504 rule (45 CFR 84), 84.92(c); ADA title II rule on medical diagnostic equipment (28 CFR 35), 35.211(c)). The 10 % comes as the provider buys, leases or renews equipment (HHS Section 504 rule (45 CFR 84), 84.92(a); ADA title II rule on medical diagnostic equipment (28 CFR 35), 35.211(a)): a hospital with 40 tables gets to at least four that way, and they are spread among the departments that use tables (HHS Section 504 rule (45 CFR 84), 84.92(b)(3); ADA title II rule on medical diagnostic equipment (28 CFR 35), 35.211(b)(3)). It does not have to make every table it already had accessible (HHS Section 504 rule (45 CFR 84), 84.93(a)(1); ADA title II rule on medical diagnostic equipment (28 CFR 35), 35.212(a)(1)). Other designs are allowed if they give substantially equivalent or greater access, and the provider has to show that they do (HHS Section 504 rule (45 CFR 84), 84.92(d); ADA title II rule on medical diagnostic equipment (28 CFR 35), 35.211(d)).
Deadlines: new equipment, the first table and the first scale
| Obligation | HHS, Section 504 (45 CFR part 84) | DOJ, ADA title II (28 CFR part 35) |
|---|---|---|
| Every piece bought, leased or renewed meets the standards, until the 10 % or 20 % is reached | after July 8, 2024 (HHS Section 504 rule (45 CFR 84), 84.92(a)) | after October 8, 2024 (ADA title II rule on medical diagnostic equipment (28 CFR 35), 35.211(a)) |
| At least one accessible exam table and one accessible scale | within 2 years after July 8, 2024 (HHS Section 504 rule (45 CFR 84), 84.92(c)) | within two years after August 9, 2024 (ADA title II rule on medical diagnostic equipment (28 CFR 35), 35.211(c)) |
Both two-year deadlines ran out in the summer of 2026. Equipment bought before the rules does not all have to be replaced: each program, taken as a whole, has to be accessible, which can be done by moving a service to an accessible room or site, by home visits or by buying accessible equipment, giving priority to the most integrated setting (HHS Section 504 rule (45 CFR 84), 84.93; ADA title II rule on medical diagnostic equipment (28 CFR 35), 35.212).
A provider does not have to take a step that would fundamentally alter its program or cause undue financial and administrative burdens, but it has to prove it: the head of the entity or their designee decides, in a written statement of reasons, and the provider still has to find another way to serve the patient (HHS Section 504 rule (45 CFR 84), 84.92(e) and 84.93(a)(2); ADA title II rule on medical diagnostic equipment (28 CFR 35), 35.211(e) and 35.212(a)(2)).
The equipment is not enough on its own. Staff must be able to operate it, help with transfers and positioning, and carry out the duty of access with older equipment (HHS Section 504 rule (45 CFR 84), 84.94; ADA title II rule on medical diagnostic equipment (28 CFR 35), 35.213).
Which clinics and hospitals the rules cover
- HHS, Section 504: programs or activities that receive federal financial assistance from HHS, and the recipients that run them (HHS Section 504 rule (45 CFR 84), 45 CFR 84.90). A recipient can be a state or local agency or a public or private institution or organization (HHS Section 504 rule (45 CFR 84), 45 CFR 84.10).
- DOJ, ADA title II: health care services, programs and activities of public entities, the state and local governments of the title (ADA title II rule on medical diagnostic equipment (28 CFR 35), 28 CFR 35.210 and appendix E).
- Private practices under title III: the DOJ says title III entities are not the subjects of its rule, and that it will keep considering medical equipment under title III (ADA title II rule on medical diagnostic equipment (28 CFR 35), appendix E). A private office that takes HHS funds is still covered by the HHS rule.
What to ask before a medical appointment
A call to the office before you go saves a wasted trip. Ask about the room where you will be seen, not the building in general:
- The table. Is there a height-adjustable exam table, and does it lower to 17 to 19 inches (Standards for Accessible MDE, 2017 text, M301.2.1)? Is it in the department you are booked into (HHS Section 504 rule (45 CFR 84), 84.92(b)(3))?
- The scale. Is there a scale you can roll onto in your wheelchair, with a platform at least 36 inches wide (Standards for Accessible MDE (36 CFR 1195), M303.2.2)?
- Help with the transfer. Will someone trained help you transfer and position, or is a patient lift available (HHS Section 504 rule (45 CFR 84), 84.94; Standards for Accessible MDE (36 CFR 1195), M301.4)?
- Imaging. For a mammogram, can it be done seated in your wheelchair (Standards for Accessible MDE (36 CFR 1195), M303.4)?
- Getting in. Is there accessible parking, a step-free entrance, a door wide enough (ADA door width) and an accessible restroom (ADA bathroom requirements)?
If you use a guide dog, what a hospital may and may not ask is in guide dogs, and how the ADA titles fit together is in ADA compliance.
Clinics and hospitals in Braillito Maps
An accessible exam table is no use if you cannot get through the front door. Braillito Maps is a community map that answers ten questions about each place: step-free entrance or ramp, wide doorway, accessible restroom, accessible parking, tactile paving, braille signage, braille menu, audible signals, guide dogs welcome and a quiet environment.
For a clinic, a pharmacy or a hospital, five of them are about getting in and getting around: the step-free entrance, the wide doorway, the accessible restroom, the parking and whether your guide dog is welcome. Braille signage and audible signals help blind patients find the right floor and hear their name when it is called. Each answer is yes, no or no data until someone knows, and the score of a place is the number of yes answers out of ten, always shown with its number, never by color alone.
The checklist has no question about exam tables or scales, so those you ask the office, with the list above. When you find a clinic that works, add it or update it, so the next patient finds it already checked; if what a place says is wrong, it can be reported. Meet Braillito Maps.
Frequently asked questions
What is accessible medical equipment?
Medical diagnostic equipment, such as exam tables, exam chairs, weight scales, mammography and x-ray equipment, that meets the Access Board’s Standards for Accessible Medical Diagnostic Equipment, 36 CFR part 1195 in its January 9, 2017 version (HHS Section 504 rule (45 CFR 84), 45 CFR 84.10; ADA title II rule on medical diagnostic equipment (28 CFR 35), 28 CFR 35.104).
How low does an accessible exam table go?
Its low transfer position is 17 to 19 inches (430–485 mm) from the floor to the top of the uncompressed transfer surface, and it also rises to 25 inches (635 mm), with at least four positions in between (Standards for Accessible MDE, 2017 text, M301.2.1). That is the range HHS and the DOJ enforce (ADA title II rule on medical diagnostic equipment (28 CFR 35), appendix E, section 35.104).
How many accessible exam tables does a hospital need?
At least 10 % of each type of equipment in use, never fewer than one, spread in proportion among the departments that use it; 20 % in facilities that specialize in conditions that affect mobility (HHS Section 504 rule (45 CFR 84), 45 CFR 84.92(b); ADA title II rule on medical diagnostic equipment (28 CFR 35), 28 CFR 35.211(b)). It gets there as it buys, leases or renews equipment (HHS Section 504 rule (45 CFR 84), 45 CFR 84.92(a); ADA title II rule on medical diagnostic equipment (28 CFR 35), 28 CFR 35.211(a)), and it does not have to make every table it already had accessible (HHS Section 504 rule (45 CFR 84), 45 CFR 84.93(a)(1); ADA title II rule on medical diagnostic equipment (28 CFR 35), 28 CFR 35.212(a)(1)).
When did clinics have to get an accessible exam table and scale?
Within two years after July 8, 2024, for programs funded by HHS, and within two years after August 9, 2024, for state and local governments, unless they already had them (HHS Section 504 rule (45 CFR 84), 45 CFR 84.92(c); ADA title II rule on medical diagnostic equipment (28 CFR 35), 28 CFR 35.211(c)).
How big is a wheelchair scale platform?
At least 36 inches (915 mm) wide and, with entry and exit at one end, 48 inches (1220 mm) deep; 40 inches (1015 mm) for a roll-through scale and 60 inches (1525 mm) for side entry (Standards for Accessible MDE (36 CFR 1195), M303.2.2 and M303.2.3).
Do private doctors’ offices have to follow these rules?
The HHS rule covers programs that receive federal financial assistance from HHS (HHS Section 504 rule (45 CFR 84), 45 CFR 84.90), and the DOJ rule covers state and local governments; the DOJ says title III entities are not the subjects of its rule (ADA title II rule on medical diagnostic equipment (28 CFR 35), appendix E).
More accessibility guides
- ADA compliance: a checklist for small businesses, with the 2010 Standards section behind each item.
- Accessibility laws by country: the ADA, the UK Equality Act, the Accessible Canada Act, Australia’s DDA and the EU rules, and what each covers.
- ADA bathroom requirements: toilet height and position, grab bar height, sink height, stall sizes and turning space.
- ADA door width: 32 inches of clear width, maneuvering space, thresholds, hardware and opening force.
- Accessible parking: ADA parking requirements: how many spaces, how wide, the access aisle and the sign.
- ADA toilet height: seat height, distance from the side wall, clear floor space, flush control, toilet paper and stalls.
- Guide dogs: how they work, where they can go under the ADA, and how to act around one.
- ADA Title II: what state and local governments have to make accessible: existing buildings, new construction, streets and curb ramps, parks, programs and the 2024 web rule.
- All accessibility guides
Sources
Every figure in this guide comes from one of these official texts, which we read in October 2026.
- 45 CFR Part 84, Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance (subpart J, Accessible Medical Equipment). U.S. Department of Health and Human Services, in the Electronic Code of Federal Regulations, final rule published May 9, 2024; current text read October 2026.
- 28 CFR Part 35, subpart I, Accessible Medical Diagnostic Equipment, and appendix E. U.S. Department of Justice, in the Electronic Code of Federal Regulations, final rule published August 9, 2024 (89 FR 65187); current text read October 2026.
- 36 CFR Part 1195, Standards for Accessible Medical Diagnostic Equipment (January 9, 2017 text). U.S. Access Board, in the Electronic Code of Federal Regulations (point-in-time version), text in force from January 9, 2017; adopted by HHS and the DOJ in 2024.
- 36 CFR Part 1195, Standards for Accessible Medical Diagnostic Equipment. U.S. Access Board, in the Electronic Code of Federal Regulations, issued January 9, 2017, as amended July 25, 2024; current text read October 2026.
- About the Accessibility Standards for Medical Diagnostic Equipment. U.S. Access Board, read October 2026.
Braillito Maps
Find places with ramps, accessible toilets or tactile paving near you in Braillito Maps
In Braillito Maps, every place answers ten questions: step-free entrance or ramp, wide doorway, accessible restroom, accessible parking, tactile paving, braille signage, braille menu, audible signals, guide dogs welcome and a quiet environment. It is built by the people who need it, and every place gets a score out of ten.
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