SecProbe.io

May 16, 2018
Douglas Sharp
Chief Financial Officer
Insperity, Inc.
19001 Crescent Springs Drive
Kingwood, Texas 77339
Re:Insperity, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2017
Form 10-Q for the Fiscal Quarter Ended March 31, 2018
Filed April 30, 2018
File No. 001-13998
Dear Mr. Sharp:
            We have reviewed your May 3, 2018 response to our comment letter and have the
following comment.  Please comply with the following comment in future filings.  Confirm in
writing that you will do so and explain to us how you intend to comply.  We may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to this comment 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 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.
Form 10-Q for the Fiscal Quarter Ended March 31, 2018
Results of Operations
Revenues, page 17
1.We note your response to comment one.  We also note your disclosure in your 10-Q that
states, "Our growth in the number of worksite employees paid is affected by three primary
sources: new client sales, client retention and the net change in existing clients through
worksite employee new hires and layoffs. During the first three months of 2018, the
number of worksite employees paid from new client sales, the net change in existing
clients and client retention improved as compared to the first three months of 2017."  In
contrast, your disclosure in your 8-K filed on April 30, 2018 states, "The continued

 FirstName LastNameDouglas Sharp
 Comapany NameInsperity, Inc.
 May 16, 2018 Page 2
 FirstName LastName
Douglas Sharp
Insperity, Inc.
May 16, 2018
Page 2
double-digit worksite employee growth was the result of strong new client sales driven by
an increase in the number of trained Business Performance Advisors, a continuing high
level of client retention, and an improvement in the net hiring of worksite employees by
our client base. Worksite employees paid from new sales increased 23% over the first
quarter of 2017 on a 15% increase in the average number of trained Business Performance
Advisors. Client attrition totaled only 8% during the heavy first quarter client renewal
period, an improvement over the first quarter of 2017." In this regard, using both
quantitative and qualitative factors, please disclose specifically how you were able to
generate increases in worksite employees.  Disclose whether you believe that you can
sustain the growth in worksite employees in the future.  Refer to Item 303 of Regulation
S-K and the Commission’s Guidance Regarding Management’s Discussion and Analysis
of Financial Condition and Results of Operations, SEC Release No. 33-8350.

            You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or Carlos
Pacho, Senior Assistant Chief Accountant at 202-551-3835 if you have questions regarding
comments on the financial statements and related matters.  Please contact Joshua Shainess,
Staff Attorney at 202-551-7951 or Kathleen Krebs, Special Counsel at 202-551-3350 with any
other questions.
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