San Francisco Health Care Security Ordinance: 2019 Annual Reporting Form Requirement Cancelled

In a welcome reprieve, the City of San Francisco is cancelling an employer requirement to submit the 2019 annual reporting form, which would have been due April 30, 2020.

Employers must continue, however, to make required health care expenditures on behalf of their covered employees per usual.

Which employers are subject to the San Francisco ordinance?

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:

  • Employed for at least 90 days
  • Regularly works at least eight hours per week within the geographic boundaries of San Francisco
  • Does not meet one of the five exemption criteria described here by referencing Q9.

If you have any questions, please contact me or visit the HCSO website.


Michelle Cammayo

About Michelle Cammayo

Michelle Cammayo has more than 13 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 also oversees the Compliance Department at Bolton & Company to ensure we are helping our clients manage and eliminate risk with regards to employee benefit compliance.

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