SEC Comment Letter 0000000000-23-010975 to CHEMED CORP (CHE) (CIK 0000019584) (CHE)
CHEMED CORP (CHE) (CIK 0000019584)
Date: Oct. 5, 2023 · CIK: 0000019584 · Accession: 0000000000-23-010975
AI Filing Summary & Sentiment
File numbers found in text: 001-08351
Letter
United States securities and exchange commission logo October 5, 2023 David Williams Executive Vice President and Chief Financial Officer CHEMED CORP 255 E. Fifth Street, Suite 2600 Cincinnati, Ohio 45202 Re:CHEMED CORP Form 10-K for Fiscal Year Ended December 31, 2022 Filed February 27, 2023 File No. 001-08351 Dear David Williams: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Unaudited Consolidating Summaries and Reconciliations of Adjusted EBITDA, page 90 1.We note that you are excluding licensed healthcare retention bonuses from net income to calculate adjusted EBITDA, adjusted net income and adjusted diluted earnings per share. We further note you have continued to include this adjustment for the six-months ended June 30, 2023. Please tell us your consideration of the guidance in Question 100.01 of the Non-GAAP Financial Measures Compliance & Disclosure Interpretations.
FirstName LastNameDavid Williams Comapany NameCHEMED CORP October 5, 2023 Page 2 FirstName LastName David Williams CHEMED CORP October 5, 2023 Page 2 In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Tracey Houser at 202-551-3736 or Jeanne Baker at 202-551-3691 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
October 5, 2023
David Williams
Executive Vice President and Chief Financial Officer
CHEMED CORP
255 E. Fifth Street, Suite 2600
Cincinnati, Ohio 45202
Re:CHEMED CORP
Form 10-K for Fiscal Year Ended December 31, 2022
Filed February 27, 2023
File No. 001-08351
Dear David Williams:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Unaudited Consolidating Summaries and Reconciliations of Adjusted EBITDA, page 90
1.We note that you are excluding licensed healthcare retention bonuses from net income to
calculate adjusted EBITDA, adjusted net income and adjusted diluted earnings per share.
We further note you have continued to include this adjustment for the six-months ended
June 30, 2023. Please tell us your consideration of the guidance in Question 100.01 of the
Non-GAAP Financial Measures Compliance & Disclosure Interpretations.
FirstName LastNameDavid Williams
Comapany NameCHEMED CORP
October 5, 2023 Page 2
FirstName LastName
David Williams
CHEMED CORP
October 5, 2023
Page 2
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact Tracey Houser at 202-551-3736 or Jeanne Baker at 202-551-3691 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services