SEC Comment Letter for CORVEL CORP (CRVL) (CIK 0000874866) (CRVL) — Apr 6, 2020
CORVEL CORP (CRVL) (CIK 0000874866)
Date: April 6, 2020 · CIK: 0000874866 · Accession: 0000000000-20-002933
AI Filing Summary & Sentiment
File numbers found in text: 000-19291
Letter
April 3, 2020 Brandon T. O’Brien Chief Financial Officer CorVel Corporation 2010 Main Street, Suite 600 Irvine, California 92614 Re:CorVel Corporation Form 10-K for the Fiscal Year Ended March 31, 2019 Filed June 7, 2019 File No. 000-19291 Dear Mr. O’Brien: We have reviewed your March 18, 2020 response to our comment letter and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within 10 business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our February 20, 2020 letter. Form 10-K for the Fiscal Year ended March 31, 2019 Remaining Performance Obligations, page 54 1.We acknowledge your response to prior comment 2 and your intent to remove disclosure of contract assets from the second table in Note 2 (presumably the first table on page 54). Please address the following: •Clarify for us whether you believe that your unbilled receivables are contract assets as defined in ASC 606-10-20 or whether they are receivables that are due you unconditionally for services already rendered except for physical invoicing and the passage of time. •Tell us how your planned removal of $18,434,000 of contract assets from the first table on page 54 is appropriate as it appears that this amount is necessary to tie to the total accounts receivable, net on your balance sheet.
FirstName LastNameBrandon T. O’Brien Comapany NameCorVel Corporation April 3, 2020 Page 2 FirstName LastName Brandon T. O’Brien CorVel Corporation April 3, 2020 Page 2 •As previously requested in prior comment 2, tell us which unbilled receivables were included in the $34.7 million of remaining performance obligations at March 31, 2019. Otherwise tell us how your disclosure complies with the guidance in ASC 606- 40-50-13 and 50-14. •Tell us whether you believe you previously overstated both unbilled receivables and deferred revenues. •Provide us draft revised Note 2 disclosure as of March 31, 2019 reflecting the changes you intend to make and ultimately provide in your upcoming Form 10-K. You may contact Bonnie Baynes at (202) 551-4924 or Mark Brunhofer at (202) 551- 3638 if you have any questions. Sincerely, Division of Corporation Finance Office of Finance
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April 3, 2020
Brandon T. O’Brien
Chief Financial Officer
CorVel Corporation
2010 Main Street, Suite 600
Irvine, California 92614
Re:CorVel Corporation
Form 10-K for the Fiscal Year Ended March 31, 2019
Filed June 7, 2019
File No. 000-19291
Dear Mr. O’Brien:
We have reviewed your March 18, 2020 response to our comment letter and have the
following comment. In our comment, we ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment within 10 business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in
our February 20, 2020 letter.
Form 10-K for the Fiscal Year ended March 31, 2019
Remaining Performance Obligations, page 54
1.We acknowledge your response to prior comment 2 and your intent to remove disclosure
of contract assets from the second table in Note 2 (presumably the first table on page 54).
Please address the following:
•Clarify for us whether you believe that your unbilled receivables are contract assets
as defined in ASC 606-10-20 or whether they are receivables that are due you
unconditionally for services already rendered except for physical invoicing and the
passage of time.
•Tell us how your planned removal of $18,434,000 of contract assets from the first
table on page 54 is appropriate as it appears that this amount is necessary to tie to the
total accounts receivable, net on your balance sheet.
FirstName LastNameBrandon T. O’Brien
Comapany NameCorVel Corporation
April 3, 2020 Page 2
FirstName LastName
Brandon T. O’Brien
CorVel Corporation
April 3, 2020
Page 2
•As previously requested in prior comment 2, tell us which unbilled receivables were
included in the $34.7 million of remaining performance obligations at March 31,
2019. Otherwise tell us how your disclosure complies with the guidance in ASC 606-
40-50-13 and 50-14.
•Tell us whether you believe you previously overstated both unbilled receivables and
deferred revenues.
•Provide us draft revised Note 2 disclosure as of March 31, 2019 reflecting the
changes you intend to make and ultimately provide in your upcoming Form 10-K.
You may contact Bonnie Baynes at (202) 551-4924 or Mark Brunhofer at (202) 551-
3638 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Finance