Employee Benefits

Deadline for San Francisco Health Care Security Ordinance is approaching

April 14, 2025

Legal Alert

The annual San Francisco Health Care Security Ordinance (SF HCSO) reporting by employers that have employees who work in the City of or County of San Francisco is due by May 2, 2025. Employers should be aware of the upcoming deadline even if they are not located in San Francisco.  
 
The SF HCSO requires large and medium-sized employers to provide covered employees with benefits equal to or greater than the expenditure rate. Covered employees are those who have been employed for more than 90 days and who regularly work at least eight hours per week within the City of and County of San Francisco.  

Who must report 

An employer is subject to the requirements of the HCSO if the following are true of the employer, regardless of location. 

  • It employs one or more workers within the City of and County of San Francisco. 
  • It is required to obtain a San Francisco business registration certificate from the Office of the Treasurer and Tax Collector. Based on the regulations, it appears the most employers, even with only one remote employee, should register with the city or county of San Francisco
  • It can be classified as a large or medium-sized business (see below). 

Counting employees 

Include all persons performing work for compensation during a quarter: 

  • Regardless of their status, e.g. seasonal, permanent/temporary, full-/part-time, contracted/commissioned, documented/undocumented; 
  • Even if they work outside of San Francisco; 
  • Even if they are not considered a covered employee. 
  • Also include owners performing work for compensation. 

Fluctuating number of employees during a quarter 

If a business’s number of employees fluctuates during a quarter, employer size is determined according to the average number of persons per week performing work for compensation during the applicable quarter. 

  • To calculate the average number of persons, add the number of employees for each of 13 weeks in the quarter and divide by 13. 

Employer size

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For eligible employees, employers can either pay for benefits equal to or exceeding the expenditure rate, make payments to the SF City Option, or submit a combination of both based on their hours worked in San Francisco. 
 
Employers can contact their Alera Group representative for our whitepaper on this topic. 
 
More information can also be found on the SF.gov website dedicated to the SF HCSO at sf.gov/information--health-care-security-ordinance.  

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