San Francisco Health Care Security Ordinance Annual Reporting Delayed

The deadline to complete the San Francisco Health Care Security Ordinance (SFHCSO) Annual Reporting for 2020 has been delayed.

The San Francisco Office of Labor Standards Enforcement (OLSE) released a notice delaying the deadline by a minimum of six months, to at least October 31, 2021 (the original deadline was April 30, 2021).

It is important to note that the extended deadline is meant to accommodate pending legislation that would waive the requirement to report for 2020. If the legislation is approved, this will be welcome relief once again—stay tuned for updates.

For background, the SFHCSO reporting requirement was canceled last year (for 2019) due to the pandemic.

The employer is still required to make the necessary expenditures.

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, AND
  • 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 has been employed for more than 90 days and who regularly works at least 8 hours per week in San Francisco. There are five possible employee exemption described in question #9.

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

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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