Your First 90 Days as a 1557 Coordinator

Inventory before you announce anything. The order below is ranked by exposure reduced per hour spent.

Somebody handed you this role, and the first instinct — I've watched a lot of new coordinators do this — is to announce a program. A kickoff email. A task force. Don't. Before you tell anyone what you're building, find out what you're actually standing on.

Here's the order that reduces the most exposure per hour spent, and it's deliberately unglamorous.

Week 1: verify what's already overdue

Start here, because it's the part most new coordinators skip entirely: some of your Section 1557 obligations aren't upcoming, they're already due. Confirm a coordinator is formally designated (that's you — make it official, not implied). Confirm written policies and a grievance procedure exist. Confirm the annual nondiscrimination notice and its language-access companion are published. Confirm training records are current.

Whatever's missing from that list goes on a gap sheet with an owner next to it, today. These aren't projects. They're overdue items, and they're also the cheapest fixes in this entire series.

At the same time: test your complaint route by sending it something yourself, and add accessibility-specific triage to whatever compliance intake process you already run. Open the intake log and the alternate-format fulfillment log. Back-load any complaints that are already sitting unanswered in someone's inbox — they exist, and they're your real first priorities.

Weeks 2-4: find out what you own, twice

Inventory every patient portal, app, telehealth platform, kiosk, and document flow — consent forms, discharge instructions, benefit statements, appointment reminders — with a named owner for each. Ask every department "what else do you use?" and then ask again, because the second pass always finds something the first one missed.

Run a parallel inventory nobody thinks to do in week one: count your medical diagnostic equipment. Exam tables, weight scales, anything covered by the Access Board's accessibility standards (opens in new window). Check what share is currently accessible against what's required, and get the gap into your equipment procurement pipeline alongside the digital clauses from later in this series.

Weeks 3-4: find who signs contracts, and get on that route

Most of your digital surface is vendor product — the patient portal, the EHR's patient-facing modules, telehealth. The signature moment is your only real leverage, and it happens exactly once per contract. Get the accessibility clause language into your standard procurement templates now, not after the next renewal cycle.

Month 2: build the two gates, and set the one gate everyone in this sector forgets

Stand up a pre-publication check so new patient-facing content stops arriving broken, and a vendor review workflow so nothing new gets bought broken either. Inflow beats backlog — the backlog is finite, the inflow isn't, unless you close it.

And before any of that remediation work goes to an outside vendor: patient documents contain protected health information, and you cannot send them out for accessibility remediation without a Business Associate Agreement in place. Full stop. Build that gate into procurement before the first vendor conversation, not after — it should make the in-house-versus-outsource decision for you automatically, every time.

Month 2: meet your local disability organization

Not personas — actual people, actual patients, who've likely been trying to get someone's attention already. Offer a standing invitation and pay them for structured testing time, the same way you'd pay any other consultant. One real working relationship will surface more genuine barriers than a quarter of automated scanning.

Month 3: triage, score honestly, and make the ask

Triage your document estate — consent forms, discharge instructions, and billing communications first, since those carry the clearest clinical and legal stakes. Score your program's maturity honestly rather than generously. Then take one page to whoever sits on your compliance committee: what exists, what it costs, what happens at three different funding levels.

If you only do four things this quarter: confirm the overdue 1557 basics are actually in place, log every complaint, get accessibility language into your contracts, and stop broken content at the point of publication. Almost none of it costs money, and together it removes most of your avoidable exposure.

This isn't legal advice on which regimes reach your specific organization — verify that against your own counsel, since it depends on your entity type and funding sources. If you want a fast first look at how a specific portal page or PDF actually holds up, ask Luke to check it before you bring it to your compliance committee. Our accessibility statement shows this same discipline applied to our own site.

Previous: the law behind the job · Next: document inventory and triage

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Sources: HHS Final Rule — Nondiscrimination in Health Programs and Activities (opens in new window) · U.S. Access Board — Medical Diagnostic Equipment Standards (opens in new window) · Web Content Accessibility Guidelines (WCAG) 2.1 (opens in new window) · HHS Guidance on Section 1557 (opens in new window)