San Francisco Health Care Security Ordinance (HCSO):

Annual Reporting Due May 2

The deadline to complete the San Francisco Health Care Security Ordinance Annual Reporting for 2024 is May 2, 2025. Employers failing to submit the form by 5/2/25 face penalties of up to $500 per quarter.

The 2024 Annual Reporting Form (ARF) will be available online here starting April 1.  It’s a good idea to preview the ARF  before you begin as once you begin the annual reporting form online, you will not be able to save and return to it later. The SF.gov website states that employers can sign up for the HCSO Email List to receive a notification each year when the Annual Reporting Form is available.

Which employers must comply? An employer is covered by the Health Care Security Ordinance (HCSO) for any calendar quarter if it meets the following three conditions:

1. Employs one or more workers within the geographic boundaries of the City and County of San Francisco;
2. The company is required to obtain a valid San Francisco business registration certificate pursuant to Article 12 of the Business and Tax Regulations Code
3. The company is a for-profit business with 20 or more persons performing work or a nonprofit organization with 50 or more persons performing work. This includes all persons working for the entity, regardless of whether they are located in San Francisco or outside of the city.

Businesses must meet the Employer Spending Requirements (ESR) by making health care contributions on behalf of all covered employees.

A “covered employee” is an individual that meets the following conditions:

1. Employed for at least 90 days
2. Regularly works at least 8 hours per week within the geographic boundaries of San Francisco
3. Does not meet one of the five exemption criteria described here.

If you have any questions, please contact Michelle Cammayo or visit the HCSO website.

IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information. This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.

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