SEC Comment Letter for AMN HEALTHCARE SERVICES INC (AMN) (CIK 0001142750) (AMN) — Dec 19, 2019
AMN HEALTHCARE SERVICES INC (AMN) (CIK 0001142750)
Date: Dec. 19, 2019 · CIK: 0001142750 · Accession: 0000000000-19-016604
AI Filing Summary & Sentiment
File numbers found in text: 001-16753
Letter
December 19, 2019 Brian M. Scott Chief Financial Officer AMN Healthcare Services, Inc. 12400 High Bluff Drive Suite 100 San Diego, CA 92130 Re:AMN Healthcare Services, Inc. Form 10-K for the Year Ended December 31, 2018 Filed February 21, 2019 Form 8-K filed October 31, 2019 File No. 001-16753 Dear Mr. Scott: We have limited our review of your filing to the financial statements and related disclosures 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 business days by providing the requested information or advise 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 Fiscal Year Ended December 31, 2018 Management's Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources Operating Activities, page 27 1.Please quantify all variance factors cited pursuant to section 501.04 of staff's Codification of Financial Reporting so that investors may readily understand the magnitude of each. Also, please note citing factors such as operating results and changes in balance sheet items may not provide a sufficient basis to understand how operating cash between comparative periods was affected and varied. In this regard, supplement your analysis with the material drivers underlying the factors cited, as appropriate. Refer to section IV.B.1 of Release No. 33-8350 for guidance.
FirstName LastNameBrian M. Scott Comapany NameAMN Healthcare Services, Inc. December 19, 2019 Page 2 FirstName LastName Brian M. Scott AMN Healthcare Services, Inc. December 19, 2019 Page 2 Form 8-K filed October 31, 2019 pursuant to Item 2.02 Press Release issued by the Company on October 31, 2019 for the Quarterly Period Ended September 30, 2019 (Exh. 99.1) Reconciliation of Non-GAAP Items, page 9 2.Please revise the format of your non-GAAP reconciliations here and for the applicable guidance to reconcile from the most comparable GAAP measure to the corresponding non-GAAP measure for equal or greater prominence of the GAAP measure. Refer to Question 102.10 of the staff’s Compliance and Disclosure Interpretations “Non-GAAP Financial Measures" for guidance.
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. You may contact Amy Geddes at 202-551-3304 or Doug Jones at 202-551-3309 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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December 19, 2019
Brian M. Scott
Chief Financial Officer
AMN Healthcare Services, Inc.
12400 High Bluff Drive
Suite 100
San Diego, CA 92130
Re:AMN Healthcare Services, Inc.
Form 10-K for the Year Ended December 31, 2018
Filed February 21, 2019
Form 8-K filed October 31, 2019
File No. 001-16753
Dear Mr. Scott:
We have limited our review of your filing to the financial statements and related
disclosures 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 business days by providing the requested
information or advise 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 Fiscal Year Ended December 31, 2018
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources
Operating Activities, page 27
1.Please quantify all variance factors cited pursuant to section 501.04 of staff's Codification
of Financial Reporting so that investors may readily understand the magnitude of each.
Also, please note citing factors such as operating results and changes in balance sheet
items may not provide a sufficient basis to understand how operating cash between
comparative periods was affected and varied. In this regard, supplement your analysis
with the material drivers underlying the factors cited, as appropriate. Refer to section
IV.B.1 of Release No. 33-8350 for guidance.
FirstName LastNameBrian M. Scott
Comapany NameAMN Healthcare Services, Inc.
December 19, 2019 Page 2
FirstName LastName
Brian M. Scott
AMN Healthcare Services, Inc.
December 19, 2019
Page 2
Form 8-K filed October 31, 2019 pursuant to Item 2.02
Press Release issued by the Company on October 31, 2019 for the Quarterly Period Ended
September 30, 2019 (Exh. 99.1)
Reconciliation of Non-GAAP Items, page 9
2.Please revise the format of your non-GAAP reconciliations here and for the applicable
guidance to reconcile from the most comparable GAAP measure to the corresponding
non-GAAP measure for equal or greater prominence of the GAAP measure. Refer
to Question 102.10 of the staff’s Compliance and Disclosure Interpretations “Non-GAAP
Financial Measures" for guidance.
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.
You may contact Amy Geddes at 202-551-3304 or Doug Jones at 202-551-3309 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services