The deadline to complete the San Francisco Health Care Security Ordinance Annual Reporting for 2021 is May 2, 2022. Employers failing to file by 5/2/22 face penalties of up to $500 per quarter.

The 2021 Annual Reporting Form is available online here.  It is a good idea to review the instructions before you begin as once you begin the annual reporting form online, you will not be able to save it and return to it later.

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:

  • Employs one or more workers within the geographic boundaries of the City and County of San Francisco;
  • The company is required to obtain a valid San Francisco business registration certificate pursuant to Article 12 of the Business and Tax Regulations Code
  • 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:

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

Written by: Michelle Cammayo

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.