IMA Compliance Alert

San Francisco Health Care Security Ordinance  (HCSO)

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.

New final rules in October 2017 resulted in a new voluntary employee waiver form (for those with coverage through another employer), new poster, and changes for self-funded plan calculations (starting in 2018, must be based on actual expenditures rather than COBRA applicable premiums).

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

Which Employers Must Comply?
A Covered Employer has 20+ employees (50+ if non-profit) with one or more working in San Francisco (including telecommuters). Sign up for San Francisco labor updates here.

What Must Employers Spend on Health Care to Comply?
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).

When and How Do Employers Report?

Every April employers must submit data from the prior calendar year. The calendar year 2017 report is due Monday, April 30, 2018. Instructions and a PDF preview are also available. A webinar held Thursday, April 5, 2018, at 10:00 AM Pacific, will have the recording available on the main HCSO
website Monday, April 9, 2018. Employers should maintain records for four years.

Please let your IMA Benefits team know if you have any questions.