IMA Compliance Alert

San Francisco HCSO Reporting Due in April

The City and County of San Francisco passed a law in 2006 that established the HCSO. Since 2008, most employers with even one employee in San Francisco have had an annual reporting obligation to prove they spend a minimum amount of money on health care for employees.

Be sure you are using the most current voluntary employee waiver form (for those with coverage through another employer), worksite poster, and self-funded plan calculations (as of 2018, must be based on actual expenditures rather than COBRA applicable premiums, see main HCSO site for a webinar recording with slide deck and calculation instructions).

A Covered Employer would have 20+ employees (50+ if non-profit) with one or more working in San Francisco (including telecommuters). Sign up for San Francisco labor updates here.
Employers satisfy the Employer Spending Requirement (ESR) by calculating and making required health care expenditures on behalf of all Covered Employees (those employed 91+ days who regularly work 8+ hours per week in San Francisco).

Every April employers must submit data from the prior calendar year. The calendar year 2018 report is due Tuesday, April 30, 2019. Instructions and a PDF preview are also available. A webinar will be held Thu 4/4/19 at 10:00 AM PDT, followed by a webinar for self-funded employers Fri 4/5/19 at 10:00 AM PDT. Recordings will then be available on the main HCSO website shortly after. Employers should maintain records for four years.

If you contract with the city, county, or airport, also be sure to ask your IMA Benefits team about the stricter requirements of the Health Care Administrative Ordinance (HCAO).

Please let your IMA Benefits team know if you have any questions; we will continue to monitor regulator guidance and offer meaningful, practical, timely information.