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October 25, 2023
Brian M. Bonnell
Chief Financial Officer
ICU Medical, Inc.
951 Calle Amanecer
San Clemente, CA 92673
Re:ICU Medical, Inc.
Form 10-K for the fiscal year ended December 31, 2022
Form 10-Q for the quarterly period ended June 30, 2023
Form 8-K dated February 27, 2023
File No. 001-34634
Dear Brian M. Bonnell:
            We have limited our review of your filings to the financial statements and related
disclosures and have the following comments.
            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.
Form 10-K for the fiscal year ended December 31, 2022
Consolidated Financial Statements
Note 1. Revenue Recognition, page 73
1.We note you estimate variable consideration related to rebates, chargebacks and product
returns. Please provide in future filings the qualitative and quantitative information about
the significant judgments and changes in judgments that significantly affect the
determination of your transaction price, as set forth in ASC 606-10-50-1(b), 50-17(b), and
50-20(a). Please provide us any intended revisions and the calculations used to determine
variable consideration for the periods presented.
Form 10-Q for the quarterly period ended June 30, 2023
Liquidity and Capital Resources, page 49
2.You set forth in your disclosure "during the six months ended June 30, 2023, our cash and

 FirstName LastNameBrian M. Bonnell
 Comapany NameICU Medical, Inc.
 October 25, 2023 Page 2
 FirstName LastName
Brian M. Bonnell
ICU Medical, Inc.
October 25, 2023
Page 2
cash equivalents and short-term investment securities increased by $15.3 million from
$213.0 million at December 31, 2022 to $197.7 million at June 30, 2023. This increase
was primarily due to cash generated from operations." We note, however, you
experienced a decrease during that time frame. Please correct your discussion in future
filings.
3.You disclose that "net income plus adjustments for non-cash net expenses contributed
$151.7 million." Please tell us whether you consider this reference a non-GAAP measure
and how you arrived at this determination. Please provide us any intended revisions to
your disclosure, as applicable. Refer to Item 10(e) of Regulation S-K.
Form 8-K dated February 27, 2023
Exhibit 99.1
Use of Non-GAAP Financial Information, page 6
4.Please describe for us in further detail the "quality system and product-related
remediation" costs and the "quality and regulatory initiatives and remediation" costs
incurred during 2022 and 2023, and explain to us how you have considered Non-GAAP
Financial Measures Compliance & Disclosure Interpretations 100.01 as part of making an
adjustment for these costs in determining your non-GAAP measures.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Michael Fay at 202-551-3812 or Brian Cascio, Accounting Branch Chief,
at 202-551-3676 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services