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SEC Company Response from RadNet, Inc. (RDNT) (CIK 0000790526) (RDNT) — Nov 13, 2013

RadNet, Inc. (RDNT) (CIK 0000790526)
Date: Nov. 13, 2013 · CIK: 0000790526 · Accession: 0001019687-13-004281

AI Filing Summary & Sentiment

File numbers found in text: 001-33307

Referenced dates: October 30, 2013, September 20, 2013, September 20, 2013

Date
November 13, 2013
Author
Not clearly detected
Form
CORRESP
Company
RadNet, Inc. (RDNT) (CIK 0000790526)

Letter

VIA EDGAR Division of Corporation Finance Amendment No. 1 to Form 10-K for the Year Ended December 31, 2012 Filed April 1, Response dated October 11, 2013 File No. 001-33307

Dear Ms. Jenkins:

Reference is made to the letter dated October 30, 2013 (“Comment Letter”) from the staff of the Division of Corporation Finance (the “Staff”) to RadNet, Inc. (the “Company”). In reply to the Comment Letter, we submit the following responses. For your convenience, we have reprinted the Staff’s original comments, followed by our response.

Comment 1:

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 determining the timing and amount of patient service fee revenue to be recognized at the time of service.

Response:

We propose to include in future filings the following revised critical accounting policy:

Provision for Bad Debts

We provide for an allowance against accounts receivable that could become uncollectible to reduce the carrying value of such receivables to their estimated net realizable value. We estimate this allowance based on the aging of our accounts receivable by each type of payer over an 18-month look-back period, and other relevant factors. A significant portion of our provision for bad debt relates to co-payments and deductibles owed to us from patients with insurance. Although we attempt to collect deductibles and co-payments due from patients with insurance at the time of service, this attempt to collect at the time of service is not an assessment of the patient’s ability to pay nor are revenues recognized based on an assessment of the patient’s ability to pay. There are various factors that can impact collection trends, such as changes in the economy, which in turn have an impact on the increased burden of co-payments and deductibles to be made by patients with insurance. These factors continuously change and can have an impact on collection trends and our estimation process.

Comment 2:

Amendment No. 1 to Form 10-K for the Year Ended December 31,

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.

Response:

The Company takes note of the Staff’s comment and on November 13, 2013, the Company filed Amendment No. 2 to its Form 10-K for the year ended December 31, 2012 and Form 10-Q for the quarter ended September 30, 2013, both of which include the financial statement disclosures the Company agreed to provide in future filings. Included within its Amendment No. 2 to Form 10-K is the corrected report of the Independent Registered Public Accounting Firm.

* * * * *

In connection with responding to the Staff’s comments, the Company acknowledges the following:

· The Company is responsible for the adequacy and accuracy of the disclosure in the filing.

· The Staff’s comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing.

· The Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

By: /s/ Howard G. Berger, M.D.

Name: Howard G. Berger, M.D.

Title: Chief Executive Officer

cc: Myra Moosariparambil, Staff Accountant

Dean Suehiro, Senior Staff Accountant

Linda Michaelson, Esq., Sheppard, Mullin, Richter & Hampton LLP (via email)

Show Raw Text
CORRESP
1
filename1.htm

November 13, 2013

VIA EDGAR

Tia L. Jenkins

Senior Assistant Chief Accountant

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Mail Stop 3720

Washington, DC 20549

 Re: RadNet, Inc.

Form 10-K for fiscal year ended December 31, 2012Filed 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 Ms. Jenkins:

Reference is made to the
letter dated October 30, 2013 (“Comment Letter”) from the staff of the Division of Corporation Finance (the “Staff”)
to RadNet, Inc. (the “Company”). In reply to the Comment Letter, we submit the following responses. For your convenience,
we have reprinted the Staff’s original comments, followed by our response.

Comment 1:

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 determining the timing and amount
of patient service fee revenue to be recognized at the time of service.

    1

Response:

  We propose to include in future filings the following revised critical accounting policy:

Provision for Bad Debts

We provide for an
allowance against accounts receivable that could become uncollectible to reduce the carrying value of such receivables to their
estimated net realizable value. We estimate this allowance based on the aging of our accounts receivable by each type of payer
over an 18-month look-back period, and other relevant factors. A significant portion of our provision for bad debt relates to co-payments
and deductibles owed to us from patients with insurance. Although we attempt to collect deductibles and co-payments due from patients
with insurance at the time of service, this attempt to collect at the time of service is not an assessment of the patient’s
ability to pay nor are revenues recognized based on an assessment of the patient’s ability to pay. There are various factors
that can impact collection trends, such as changes in the economy, which in turn have an impact on the increased burden of co-payments
and deductibles to be made by patients with insurance. These factors continuously change and can have an impact on collection trends
and our estimation process.

Comment 2:

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.

Response:

The Company takes note
of the Staff’s comment and on November 13, 2013, the Company filed Amendment No. 2 to its Form 10-K for the year ended December
31, 2012 and Form 10-Q for the quarter ended September 30, 2013, both of which include the financial statement disclosures the
Company agreed to provide in future filings. Included within its Amendment No. 2 to Form 10-K is the corrected report of the Independent
Registered Public Accounting Firm.

* * * * *

    2

In connection with
responding to the Staff’s comments, the Company acknowledges the following:

 · The Company is responsible for the adequacy and accuracy of the disclosure in the filing.

 · The Staff’s comments or changes to disclosure in response to Staff comments do not foreclose
the Commission from taking any action with respect to the filing.

 · The Company may not assert Staff comments as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

By: /s/ Howard G. Berger, M.D.

       Name: Howard G. Berger, M.D.

       Title: Chief Executive
Officer

cc:    Myra Moosariparambil, Staff Accountant

         Dean Suehiro,
Senior Staff Accountant

         Linda Michaelson,
Esq., Sheppard, Mullin, Richter & Hampton LLP (via email)

    3