SEC Company Response from TIVITY HEALTH, INC. (CIK 0000704415) — Apr 28, 2005
TIVITY HEALTH, INC. (CIK 0000704415)
Date: April 28, 2005 · CIK: 0000704415 · Accession: 0000704415-05-000064
AI Filing Summary & Sentiment
File numbers found in text: 000-19364
Referenced dates: April 5, 2005
Letter
VIA EDGAR Ms Ibolya Ignat United States Securities and Exchange Commission 850 Fifth Street, N.W. Washington, DC 20549 Form 10-K for the fiscal year ended August 31, 2004 File No. 000-19364
RE: American Healthways, Inc.
Dear Ms Ignat:
This letter is a supplement to our response letter dated April 5, 2005 relating to American Healthways, Inc. (the “Company”) Form 10-K for the fiscal year ended August 31, 2004.
With regard to our response to Question 3 concerning whether fees may be refundable to the customer regardless of our performance to date, we will disclose in the Summary of Critical Accounting Policies for Revenue Recognition that performance-based fees are not refundable for any reason other than performance to date in the contract year not meeting contractual targets. We will also disclose that historically, refunds for not meeting contractual targets have not been material.
With regard to our response to Question 4 concerning the information required by paragraph 37 of SFAS 131, it is impracticable for us to report revenue by each of the Company’s programs due to the following:
•
The Company’s various disease management programs are routinely bundled in a variety of configurations and sold to customers as a single service and often at a single price. In instances where multiple programs are sold at a single price, the programs are delivered together at the same time and over the same periods of time. Accordingly, we do not believe that EITF 00-21 is applicable to these arrangements because there are no undelivered items;
•
In its general-purpose financial statements, the Company’s revenues are reported as a single amount by customer with no distinction by program;
•
All programs provided by the Company to external customers are considered care enhancement services and accordingly are all similar in nature.
We confirm that beginning with our Annual Report on Form 10-K for the fiscal year ended August 31, 2005, we will disclose that it is impracticable for us to report revenues by program.
If you have any additional questions or comments, please contact me at 615–665–1122 or by FAX at 615–665–7739.
Sincerely yours,
/s/ Mary A. Chaput
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CORRESP
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April 20, 2005
VIA EDGAR
Ms Ibolya Ignat
United States Securities
and Exchange Commission
850 Fifth Street, N.W.
Washington, DC 20549
RE:
American Healthways, Inc.
Form 10-K for the fiscal year ended August 31, 2004
File No. 000-19364
Dear Ms Ignat:
This letter is a supplement to our response letter dated April 5, 2005
relating to American Healthways, Inc. (the
“Company”) Form 10-K for the fiscal year ended August 31, 2004.
With regard to our response to Question 3 concerning whether fees may be refundable to the customer regardless of
our performance to date, we will disclose in the Summary of Critical Accounting Policies for Revenue Recognition
that performance-based fees are not refundable for any reason other than performance to date in the contract year
not meeting contractual targets. We will also disclose that historically, refunds for not meeting contractual
targets have not been material.
With regard to our response to Question 4
concerning the information required by paragraph 37 of SFAS 131, it is
impracticable for us to report revenue by each of the Company’s programs due to the following:
•
The Company’s various disease management programs are routinely bundled in a variety of configurations
and sold to customers as a single service and often at a single price. In instances where multiple programs
are sold at a single price, the programs are delivered together at
the same time and over the same periods of time. Accordingly, we do not believe that EITF 00-21 is
applicable to these arrangements because there are no undelivered items;
•
In its general-purpose financial statements, the Company’s revenues are reported as a single amount by
customer with no distinction by program;
•
All programs provided by the Company to external customers are considered care enhancement services and
accordingly are all similar in nature.
We confirm that beginning with our Annual Report on Form 10-K for the
fiscal year ended August 31, 2005, we will
disclose that it is impracticable for us to report revenues by program.
If you have any additional questions or comments, please contact
me at 615–665–1122 or by FAX at 615–665–7739.
Sincerely yours,
/s/ Mary A. Chaput
Mary A. Chaput
Executive Vice President and Chief
Financial Officer
cc:
Ben R. Leedle, Jr.
James H. Cheek, III
Cynthia Y. Reisz