San Francisco Health Care Security Ordinance (HCSO) Annual Reporting Due 5/1/23

The deadline to complete the San Francisco Health Care Security Ordinance Annual Reporting for 2022 is May 1, 2023. Employers failing to submit the form by 5/1/23 face penalties of up to $500 per quarter.

The 2022 Annual Reporting Form (ARF) is available online here.  It’s a good idea to preview the ARF  before you begin as once you begin the annual reporting form online, you will not be able to save 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:

  • Employed for at least 90 days
  • Regularly works at least 8 hours per week within the geographic boundaries of San Francisco
  • Does not meet one of the five exemption criteria described here.

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

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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