IMA Compliance Alert

Changes to San Francisco Health Care Security Ordinance (SFHCSO) for 2018

1.8.18

While the SFHCSO requires employers to comply with new health care expenditure rates every year,
2018 also introduces a new poster, new voluntary employee waiver form, and new way for self-funded
plans to calculate their expenditures as outlined in section 5.9 of the revised rules.

Previously, self-funded plans could use the COBRA applicable premium to calculate required health
care expenditures. That will no longer be permitted as of January 1, 2018. The new self-funding
calculation essentially allows the employer to meet the expenditure requirement by paying enough in
actual non-refundable fixed costs or paid claims, either on all employees or just the San Francisco
employees, when converted to an hourly expense rate.

As a reminder, the mandatory annual reporting due April 30, 2018, will cover the calendar year 2017
information. These new requirements are all for 2018, which will not be reportable until April 2019 but
need to be complied with now.