SecProbe.io

Mail Stop 3030
September 30, 2015

Via E -mail
Douglas A. Michels
President and  Chief Executive  Officer
OraSure Technologies, Inc.
220 East First Street
Bethlehem, Pennsylvania  18015

Re: OraSure Technologies, Inc.
Form 10-K for the fiscal year ended December 31, 2014
Filed March 12 , 2015
File No. 001-16537

Dear M r. Michels :

We have reviewed your filing 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comments , we may have  additional comments.

Form 10 -K for the Fiscal Year Ended December 31, 2014

Item 8.   Financial   Statements

Note 2. Summary of Significant Accounting Policies

Revenue Recognition, page F -10

1. We note that you reduce your revenues from the OraQuick® In-Home HIV test for
customer allowances for cooperative advertising, discounts, rebates and
chargebacks.   Please describe to us the significant terms and conditions of these programs
and how you account for these programs under ASC 605 -50 and any other applicable
authoritative literat ure.  Also address how you determined the proper income statement
classification for each program under ASC 605 -50-45.

Douglas A. Michels
OraSure Technologies, Inc.
September 30, 2015
Page 2

 2. We note that in connection with your Master Program Services and Co -Promotion
Agreement with AbbVie Bahamas Ltd., you are eligible to re ceive up to $75 million in
exchange for exclusive rights and other services.   We further note that you are
recognizing the $75 million ratably on a monthly basis over the life of the
agreement.   Please address the following:

 Describe the “other services” you must provide under the agreement and explain how
the performance of these services impacted your revenue recognition.
 Explain to us any conditions that must be met in order to receive the full $75 million.
 Explain to us how you determined that it is appropriate to recognize the full $75
million over the term of the agreement.
 Tell us the payment terms for the $75 million.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filin g includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff commen ts or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any pe rson under the federal securities laws of the United States.

You may contact Eric Atallah at (202) 551 -3663 or Kate Tillan, Assistant Chief
Accountant , at (202) 551 -3604  if you have questions regarding comments on the financial
statements and related matt ers.  You may also reach me at (202) 551 -3671.

Sincerely,

 /s/ Kate Tillan for

Martin James
Senior Assistant Chief Accountant
Office of Electronics and Machinery