OLSE Email: Health Care Security Ordinance (HCSO) News

Dear Employer or Representative:

Please be advised of the following changes related to the Health Care Security Ordinance.

1. 2014 Excepted Benefit HRA “True-up” Deadline Extended to April 10, 2015
If an employer allocated funds to an excepted benefits HRA on behalf of employees covered by the Health Care Security Ordinance (HCSO) for hours payable in 2014; and If the employer made allocations for more than an average of 20 hours per week to that account, Then the following change is effective immediately:

To allow employees 90 days to submit reimbursement requests for eligible expenses incurred in calendar year 2014, the deadline for “truing up” excepted benefits HRAs has been extended from January 30, 2015 to April 10, 2015.

This means that employers have until April 10, 2015 to make replacement Health Care Expenditures for allocations in excess of an average of 20 hours per week that were not actually reimbursed to the employee for expenses that employee incurred in calendar year 2014.

See updated HCSO Administrative Guidance Section P, Question 5 for more information.

2. Updated Reporting for Excepted Benefits HRAs

The Office of Labor Standards Enforcement (OLSE) has updated the anticipated 2014 reporting requirements for excepted benefits HRAs. On the HCSO Annual Reporting Form (due April 30, 2015), employers will be required to provide aggregate information on allocations, reimbursements, and “true-up” spending, if applicable.

Please note that employers are responsible for maintaining records demonstrating that valid expenditures were made for each individual Covered Employee.

The 2014 Annual Reporting Form will be due on April 30, 2015, and the form will be available on the HCSO website by April 1, 2015.

See updated HCSO Administrative Guidance Section P, Question 4 for more information.

You can also contact the Office of Labor Standards Enforcement HCSO compliance team at (415) 554-7892 or email us at hcso@sfgov.org for with questions about the HCSO.


The HCSO Compliance Team
Office of Labor Standards Enforcement
General Services Agency
City and County of San Francisco
(415) 554-7892

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