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ABD Compliance Alert - 2017 San Francisco HCSO Annual Reporting Form Released with an April 30 Filing Deadline


2017 San Francisco HCSO Form Released

If you are a San Francisco employer, April signals the start of data collection to complete the 2017 Health Care Security Ordinance (HCSO) Annual Reporting Form.  The due date for this filing is April 30, 2018.

Employers Required to File

You are a covered employer and are required to file if you met the following three conditions in 2017:

  •  employed one or more workers within the geographic boundaries of the City and County of San Francisco;
  •  were required to obtain a valid San Francisco business registration certificate pursuant to Article 12 of the Business and Tax Regulations Code, and
  • employed 20 or more persons worldwide (for profit) or a nonprofit organization that employed 50 or more persons worldwide.

Below are links to the necessary information.

The penalty for failure to submit the form is $500 for each quarter that the violation occurs.

Some of the key information required to be completed in the report include:

  • San Francisco Business Account Number
  • Total number of employees in each quarter (nationwide)
  • Number of employees covered by the HCSO in each quarter (SF only)
  • Total number of HCSO covered employees (and dependents) enrolled in the company’s medical/dental/vision plan in each quarter
  • Total amount of employer-share of medical/dental/vision plan premium paid for all HCSO covered employees (and dependents) in each quarter
  • Quarterly city option contributions (number of persons and amount spent)
  • Quarterly employer HSA contributions for HCSO covered employees (number of persons and amount contributed)
  • Fair Chance Ordinance reporting (related to hiring and employment process for individuals with arrest and conviction records)

Covered employers must meet the following obligations:

1. Satisfy the Employer Spending Requirement by making required health care expenditures on behalf of all covered employees (generally those who have been employed for more than 90 days, regularly work at least 8 hours per week in San Francisco, and for whom no exception applies) at the following rates:

Employer Size

Number of Employees

2017 Expenditure Rate

2018 Expenditure Rate

Large

100 + employees

$2.64/hour payable

$2.83 per hour payable

Medium

Businesses w/20 – 99 employees

Non-profits w/50 – 99 employees

$1.76/hour payable

$1.89 per hour payable

Small

Businesses w/0-19 employees

Non-profits w/0-49 employees

Exempt

Exempt


2. Maintain records sufficient to establish compliance with the employer spending requirement

3. Post an HCSO Notice in all workplaces with covered employees
4.  Submit the Annual Reporting form by April 30th each year.

Reminder: New Voluntary Waiver Form

There is a new Employee Voluntary Waiver Form for use as of November 1, 2017.  This is an updated version of the form that permits employees to voluntarily waive their right to employer health care expenditures under the HCSO.

See our previous Compliance Alert for full details on what’s changed with the new waiver form, why employees might sign it, and action items for employers.

For more information on all of the HSCO requirements, check out the SF OLSE’s official HSCO website.  HCSO will be holding an instructional webinar on how to complete the 2017 Employer Annual Reporting Form Thursday, April 5, 2018 at 10:00 Pacific Time.  Space is limited to 500 people.  Register here.

For more information, check out the  recording of the ABD Office Hours Presentation:  The San Francisco Health Care Security Ordinance:  A Refresher Course in the HCSO Basics for the SF Employers.  

Disclaimer: The intent of this analysis is to provide the recipient with general information regarding the status of, and/or potential concerns related to, the recipient’s current employee benefits issues. This analysis does not necessarily fully address the recipient’s specific issue, and it should not be construed as, nor is it intended to provide, legal advice. Furthermore, this message does not establish an attorney-client relationship.  Questions regarding specific issues should be addressed to the person(s) who provide legal advice to the recipient regarding employee benefits issues (e.g., the recipient’s general counsel or an attorney hired by the recipient who specializes in employee benefits law).

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