PREPARED BY: ALICIA PLATT DATE OF MEETING: 06/01/2026
SUBJECT:
TITLE
CONSIDER ADOPTING RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN PABLO ADOPTING AN ADMINISTRATIVE POLICY ESTABLISHING AFFORDABLE CARE ACT (ACA) LOOK BACK MEASUREMENT METHOD AND AFFORDABILITY SAFE HARBORS FOR CERTAIN UNREPRESENTED EMPLOYEES
CEQA: This proposed action is not a project as defined by CEQA.
Label
CITY MANAGER RECOMMENDATION
Recommendation
Adopt Resolution
BODY
COMPLIANCE STATEMENTS
FY 2025-2027 Council Priority Workplan Compliance Statements:
This item is not specifically identified in the Council's Priority Workplan but is necessary to ensure the City's compliance with Affordable Care Act requirements and related IRS reporting obligations.
CEQA Compliance Statement
This proposed action is not a project as defined by CEQA.
BACKGROUND
The Affordable Care Act ("ACA") requires applicable large employers, including the City of San Pablo ("City"), to offer affordable health coverage providing minimum value to substantially all full-time employees and their dependents and to comply with related IRS reporting requirements. Failure to comply may subject the City to penalties under Sections 4980H and 6056 of the Internal Revenue Code.
The proposed Administrative Policy establishes the City's use of the federal "Look Back Measurement Method Safe Harbor" to determine full-time employee status for ACA compliance and reporting purposes and authorizes the use of ACA affordability safe harbors, including the Rate of Pay, Form W-2, and Federal Poverty Line methodologies.
The Policy applies to certain unrepresented employees not covered by employment agreements. Employee classifications under the Policy are established solely for ACA compliance purposes and do not affect any other employment status, compensation, benefits, or bargaining rights.
Adoption of the Policy will formalize ACA compliance procedures, provide administrative consistency, support IRS reporting obligations, and...
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