SEC Comment Letter 0000000000-23-011557 to CHEMED CORP (CHE) (CIK 0000019584) (CHE)
CHEMED CORP (CHE) (CIK 0000019584)
Date: Oct. 23, 2023 · CIK: 0000019584 · Accession: 0000000000-23-011557
AI Filing Summary & Sentiment
File numbers found in text: 001-08351
Referenced dates: October 16, 2023
Letter
United States securities and exchange commission logo October 23, 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 Response Letter Dated October 16, 2023 File No. 001-08351 Dear David Williams: We have reviewed your October 16, 2023 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our October 5, 2023 letter. 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 your response to our comment. The retention bonus program was implemented for your licensed healthcare professionals, who have a direct impact on revenue generation, and therefore represents cash compensation, which is a normal, recurring operating expense. As such, we request that you discontinue including this adjustment in any future presentations of your non-GAAP measures for any period presented in accordance with Rule 100(b) of Regulation G as interpreted by Question 100.01 of the Non-GAAP Financial Measures Compliance & Disclosure Interpretations, as updated December 13, 2022.
FirstName LastNameDavid Williams Comapany NameCHEMED CORP October 23, 2023 Page 2 FirstName LastName David Williams CHEMED CORP October 23, 2023 Page 2 Please contact Tracey Houser at 202-551-3736 or Jeanne Baker at 202-551-3691 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
October 23, 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
Response Letter Dated October 16, 2023
File No. 001-08351
Dear David Williams:
We have reviewed your October 16, 2023 response to our comment letter 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. Unless
we note otherwise, any references to prior comments are to comments in our October 5, 2023
letter.
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 your response to our comment. The retention bonus program was implemented
for your licensed healthcare professionals, who have a direct impact on revenue
generation, and therefore represents cash compensation, which is a normal, recurring
operating expense. As such, we request that you discontinue including this adjustment in
any future presentations of your non-GAAP measures for any period presented in
accordance with Rule 100(b) of Regulation G as interpreted by Question 100.01 of the
Non-GAAP Financial Measures Compliance & Disclosure Interpretations, as updated
December 13, 2022.
FirstName LastNameDavid Williams
Comapany NameCHEMED CORP
October 23, 2023 Page 2
FirstName LastName
David Williams
CHEMED CORP
October 23, 2023
Page 2
Please contact Tracey Houser at 202-551-3736 or Jeanne Baker at 202-551-3691 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services