San Francisco Health Care Security Ordinance Annual Reporting Due April 30, 2019

The deadline to complete the San Francisco Health Care Security Ordinance (HCSO) Annual Reporting for 2018 is April 30, 2019.

The 2018 Annual Reporting Form will be available online by April 1, 2019. Employers that fail to file by the April 30 deadline will face penalties of up to $500 per quarter.

Tips for completing the Annual Reporting Form can be found here, however, please note that the website has not been updated to reflect the 2018 Annual Reporting Form. The link provided will reference the 2017 Annual Reporting Form.

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;
  • Is required to obtain a valid San Francisco business registration certificate pursuant to Article 12 of the Business and Tax Regulations Code;
  • 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 (an individual that has been employed for more than 90 days and regularly works at least 8 hours per week in San Francisco).

New Rules for Employers with Self-insured Medical Plans

Employers with self-insured medical plans should be aware of new rules for calculating required healthcare expenditures.

Employers with self-funded plans may no longer use the Cobra premium rate to calculate, and must instead calculate the expenditure based on claims incurred by the individual.

If you have any questions regarding this topic, please feel free to contact me or visit the HCSO website.

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About Michelle Cammayo, Compliance National Practice Leader, Employee Benefits

Michelle Cammayo has close to 20 years of Employee Benefits experience specializing in all lines of health and welfare benefits. Today, Michelle works closely with clients and partners to provide guidance in areas of the law including ERISA, HIPAA, COBRA, FMLA and PPACA. She is also the IMA National Practice Leader for Compliance and endeavors to ensure IMA helps its clients manage and eliminate risk in the most effective manner. She is passionate about educating others and her passion for this shined in the COVID era where Michelle conducted weekly and then monthly webinars providing guidance to employers. Her podcast, Cammayo’s Compliance Talk, has gained popularity in the last three years to become a favorite amongst our clients. She also contributes regularly to our Blog and has authored several articles for industry-related newsletters. Michelle’s consultative approach with employers provides practical advice as employers endeavor to be compliant.

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