SEC Comment Letter 0000000000-24-006519 to HEALTHCARE SERVICES GROUP INC (HCSG) (CIK 0000731012) (HCSG)
HEALTHCARE SERVICES GROUP INC (HCSG) (CIK 0000731012)
Date: June 6, 2024 · CIK: 0000731012 · Accession: 0000000000-24-006519
AI Filing Summary & Sentiment
File numbers found in text: 000-12015
Letter
United States securities and exchange commission logo June 6, 2024 Andrew Brophy Principal Financial Officer HEALTHCARE SERVICES GROUP INC 3220 Tillman Drive, Suite 300 Bensalem, PA 19020 Re:HEALTHCARE SERVICES GROUP INC Item 2.02 Form 8-K filed February 14, 2024 Response filed May 17, 2024 File No. 000-12015 Dear Andrew Brophy: We have reviewed your May 17, 2024 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 April 10, 2024 letter. Item 2.02 Form 8-K filed February 14, 2024 Exhibit 99.1 Reconciliations of Non-GAAP Financial Measures, page 6 1.We note the additional information surrounding your client restructurings. It appears that these price concessions and contract modifications are inherent in the Company's operations. Specifically, as previously noted, you have a substantial investment in the creditworthiness and financial condition of your customers and assume the operational risks arising from providing services to the healthcare industry and primarily providers of long-term care. As such, we do not believe that your client restructuring adjustments are compliant with the guidance in Questions 100.01 and 100.04 of the Compliance and Disclosure Interpretations (“C&DIs”) on Non-GAAP Financial Measures. Please confirm that you will no longer include these adjustments.
FirstName LastNameAndrew Brophy Comapany NameHEALTHCARE SERVICES GROUP INC June 6, 2024 Page 2 FirstName LastName Andrew Brophy HEALTHCARE SERVICES GROUP INC June 6, 2024 Page 2 Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 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
June 6, 2024
Andrew Brophy
Principal Financial Officer
HEALTHCARE SERVICES GROUP INC
3220 Tillman Drive, Suite 300
Bensalem, PA 19020
Re:HEALTHCARE SERVICES GROUP INC
Item 2.02 Form 8-K filed February 14, 2024
Response filed May 17, 2024
File No. 000-12015
Dear Andrew Brophy:
We have reviewed your May 17, 2024 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 April 10, 2024
letter.
Item 2.02 Form 8-K filed February 14, 2024
Exhibit 99.1
Reconciliations of Non-GAAP Financial Measures, page 6
1.We note the additional information surrounding your client restructurings. It appears that
these price concessions and contract modifications are inherent in the Company's
operations. Specifically, as previously noted, you have a substantial investment in the
creditworthiness and financial condition of your customers and assume the operational
risks arising from providing services to the healthcare industry and primarily providers of
long-term care. As such, we do not believe that your client restructuring adjustments are
compliant with the guidance in Questions 100.01 and 100.04 of the Compliance and
Disclosure Interpretations (“C&DIs”) on Non-GAAP Financial Measures. Please confirm
that you will no longer include these adjustments.
FirstName LastNameAndrew Brophy
Comapany NameHEALTHCARE SERVICES GROUP INC
June 6, 2024 Page 2
FirstName LastName
Andrew Brophy
HEALTHCARE SERVICES GROUP INC
June 6, 2024
Page 2
Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services