Healthy Airport Ordinance

HEALTHY AIRPORT ORDINANCE (HAO) UPDATES – 6/3/26

In November 2025, the City enacted amendments to the Healthy Airport Ordinance (Ordinance 234-25) that introduced a new method of compliance designed to provide employers with covered employees more flexibility.

Starting February 26, 2026, employers of employees covered by SFO’s QSP will have three compliance options for the remainder of the 2026 calendar year:

First Option
Offer a compliant family health plan meeting the same requirements as before.

Second Option
Make payments to SF City Option.

• Effective July 1, 2026, pay $12.95 per hour worked (up to $518 per week) on behalf of the employee to the City Option Program.

Third Option
Tiered “Irrevocable Health Care Expenditure” approach, which sets minimum spending levels based on each employee’s household size:

Effective 2/28/26

• $6.17/hour (max $246.80/week) for employees with no dependents
• $12.33/hour (max $493.20/week) for employees with one dependent
• $17.44/hour (max $697.60/week) for employees with two or more dependents

Effective 1/1/27

• $6.55/hour (max $262.00/week), for employees with no dependents.
• $13.10/hour (max $524.00/week), for employees with one dependent.
• $18.55/hour, (max $742.00/week), for employees with two or more dependents.

Under the new tiered approach, employers may count a wide range of health-related expenses toward the required Irrevocable Health Care Expenditure, as long as the funds are not recoverable by the employer. Covered expenses include payments to third-party administrators or insurers for health coverage, out-of-pocket claims paid by the employer for specific employees, and the actuarial value of self-funded or self-insured health plans. Employers may also reimburse employees directly for documented health care costs or contribute to Medical Reimbursement Accounts.

From February 26, 2026, through December 31, 2026, employers can comply using any of the three methods listed above. Beginning January 1, 2027, the tiered irrevocable expenditure method will be the only compliance option.

This gives covered employers all of 2026 to either maintain your current approach or transition early to the new system.

HAO Updates for 2026 Webinar

• HAO Webinar video, recorded February 18, 2026
• HAO Webinar slides for February 18, 2026

Healthy Airport Ordinance Frequently Asked Questions posted February 25, 2026.