San Francisco’s HCSO Annual Reporting Updates (Article)
Employers subject to San Francisco’s Health Care Security Ordinance (“HCSO”) are required to annually report their health care expenditures to the Office of Labor Standards Enforcement (OLSE). Covered employers must submit their 2014 Annual Reporting Form by April 30, 2015. According to the OLSE’s website, the 2014 Annual Reporting Form will be available on its website by April 1, 2015. Employers who fail to submit an annual report on time may be subject to penalties of $500 for each quarter that the violation occurs.
Excepted benefit HRAs
The 2014 reporting form has been updated to reflect the requirements for excepted benefits HRAs. Employers are required to report aggregate information on allocations, reimbursements, and “true-up” spending, where applicable.
In addition, OLSE has extended the deadline for employers to “true-up” funds made to excepted benefit HRAs. If an employer allocated funds to an excepted benefits HRA for payable hours in 2014 and such allocations are made based on an average of 20 work hours or more per week to that account, then employees must be allowed up to 90 days to submit reimbursement requests for eligible expenses incurred in 2014. The deadline for “truing-up” excepted benefit HRAs has been extended from January 30, 2015 to April 10, 2015. This means that employers have until April 10, 2015 to make health care expenditures for amounts that have not been reimbursed to employees who incurred expenses in the 2014 calendar year.
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