SEC Comment Letter for RadNet, Inc. (RDNT) (CIK 0000790526) (RDNT) — Oct 30, 2013
RadNet, Inc. (RDNT) (CIK 0000790526)
Date: Oct. 30, 2013 · CIK: 0000790526 · Accession: 0000000000-13-059598
AI Filing Summary & Sentiment
Referenced dates: September 20, 2013
Letter
October 30 , 2013 Via E -mail Mr. Howard G. Berger , M.D. Chief Executive Officer RadNet, Inc. 1510 Cotner Avenue Los Angeles, CA 90025
Re: RadNet, Inc. Form 10 -K for the Year Ended December 31, 2012 Filed March 18 , 2013 Amendment No. 1 to Form 10 -K for the Year Ended December 31, 2012 Filed April 1, 2013 Response dated October 11, 2013 File No. 001 -33307
Dear Mr. Berger :
We have reviewed your response letter and have the following comments. In some of our comments , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your fi ling, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in you r response.
After reviewing the information you provide in response to these comments, we may have additional comments.
Form 10 -K for the Year Ended December 31, 2012
Note 2 – Summary of Significant Accounting Policies, page 58
Revenues , page 58
1. We note your response to comment eight of our letter dated September 20, 2013 that although you attempt to collect deductibles and co -payments from patients with insurance at the time of service, this attempt to collect is not an assessment of the patient’ s ability to pay. In accordance with ASC 954 -605-50-4(a), please provide draft disclose to be included in future filings to clearly address your policy to assess collectability in
Howard G. Berger RadNet , Inc. October 30 , 2013 Page 2
determining the timing and amount of patient service fee revenue to be recog nized at the time of service.
Amendment No. 1 to Form 10 -K for the Year Ended December 31, 2012
Report of the Independent Registered Public Accounting Firm, page 3
2. We note your response to comment 15 of our letter dated September 20, 2013 . In your amended filing, please provide the financial statement disclosures you agreed to provide in future filings.
You may conta ct Myra Moosariparambil , Staff Accountant, at (202) 551 -3796 or Dean Suehiro , Senior Staff Accountant, at (202) 551 -3384 if you have q uestions regarding comments on the financial statements and related matters . Please contact me at (202) 551 -3871 with any other questions.
Sincerely,
/s/Tia L. Jenkins
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October 30 , 2013 Via E -mail Mr. Howard G. Berger , M.D. Chief Executive Officer RadNet, Inc. 1510 Cotner Avenue Los Angeles, CA 90025 Re: RadNet, Inc. Form 10 -K for the Year Ended December 31, 2012 Filed March 18 , 2013 Amendment No. 1 to Form 10 -K for the Year Ended December 31, 2012 Filed April 1, 2013 Response dated October 11, 2013 File No. 001 -33307 Dear Mr. Berger : We have reviewed your response letter and have the following comments. In some of our comments , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your fi ling, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in you r response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 10 -K for the Year Ended December 31, 2012 Note 2 – Summary of Significant Accounting Policies, page 58 Revenues , page 58 1. We note your response to comment eight of our letter dated September 20, 2013 that although you attempt to collect deductibles and co -payments from patients with insurance at the time of service, this attempt to collect is not an assessment of the patient’ s ability to pay. In accordance with ASC 954 -605-50-4(a), please provide draft disclose to be included in future filings to clearly address your policy to assess collectability in Howard G. Berger RadNet , Inc. October 30 , 2013 Page 2 determining the timing and amount of patient service fee revenue to be recog nized at the time of service. Amendment No. 1 to Form 10 -K for the Year Ended December 31, 2012 Report of the Independent Registered Public Accounting Firm, page 3 2. We note your response to comment 15 of our letter dated September 20, 2013 . In your amended filing, please provide the financial statement disclosures you agreed to provide in future filings. You may conta ct Myra Moosariparambil , Staff Accountant, at (202) 551 -3796 or Dean Suehiro , Senior Staff Accountant, at (202) 551 -3384 if you have q uestions regarding comments on the financial statements and related matters . Please contact me at (202) 551 -3871 with any other questions. Sincerely, /s/Tia L. Jenkins Tia L. Jenkins Senior Assistant Chief Accountant Office of Beverages, Apparel, and Mining