March 2026
Diana Craig, Director, Benefits Compliance
Under the San Francisco Health Care Security Ordinance (“HCSO”), employers with 20 or more employees nationwide (50 or more for non-profits) are required to make minimum health care expenditures for employees who regularly work at least 8 hours per week in the city and county of San Francisco and who have been employed for more than 90 days. An Annual Reporting Form (“ARF”) is also due to the San Francisco Office of Labor Standards Enforcement (“OLSE”) by approximately April 30 of the following year. To help employers comply with this requirement, the OLSE frequently hosts and records webinars about completing the ARF.
As a reminder, for employers with fully insured plans, expenditures must be made on a quarterly basis for covered employees declining coverage (without a valid OLSE waiver) or if the employer contribution for elected coverage is less than the required expenditure. Quarterly expenditure payments are due 30 days after the end of each quarter. For the first quarter (January 1 to March 31), the deadline is April 30. For the second quarter (April 1 to June 30), the deadline is July 30. For the third quarter (July 1 to September 30), the deadline is October 30. Finally, for the fourth quarter (October 1 to December 31), the deadline is January 30.
For employers with self-funded plans, quarterly expenditures are required for covered employees who decline coverage (without a valid OLSE waiver) but the expenditure for employees covered by self-funded plans is determined at the end of the calendar year and any shortfall is then paid during the subsequent February as a “top-off” payment.
The annual reporting form for 2026 is due to the OLSE by ~ April 30, 2026. Employers are encouraged to sign up for email reminders from OLSE.
Employer action items
- Prepare and submit the 2025 ARF.
- Make any required quarterly expenditure payments for the first quarter (January 1 to March 31) by April 30.
Additional Information and resources
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