SEC Comment Letter for eHealth, Inc. (EHTH) (CIK 0001333493) (EHTH) — Oct 3, 2019
eHealth, Inc. (EHTH) (CIK 0001333493)
Date: Oct. 3, 2019 · CIK: 0001333493 · Accession: 0000000000-19-014266
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33071
Letter
October 3, 2019 Derek N. Yung Chief Financial Officer eHealth, Inc. 2625 Augustine Drive, Second Floor Santa Clara, CA 95054 Re:eHealth, Inc. Form 10-K for the Fiscal Year Ended December 31, 2018 Filed March 14, 2019 File No. 001-33071 Dear Mr. Yung: We have reviewed your September 23, 2019 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our September 5, 2019 letter. Form 10-K for the Fiscal Year Ended December 31, 2018 Financial Statements Consolidated Statements of Stockholders' Equity, page 81 1.Refer to your response to our prior comment 1. Please confirm for us that you will separately disclose the total cumulative effect of adoption of ASC 606 on your retained earnings as of the earliest period presented in your Form 10-Q for the period ended September 30, 2018 and your Form 10-K for the fiscal year ended December 31, 2019 on the face of the Statement of Stockholders' Equity or within a footnote on that financial statement.
FirstName LastNameDerek N. Yung Comapany NameeHealth, Inc. October 3, 2019 Page 2 FirstName LastName Derek N. Yung eHealth, Inc. October 3, 2019 Page 2 Notes to Consolidated Financial Statements Note 1 - Summary of Business and Significant Accounting Policies Commission Revenue, page 86 2.Refer to your response to our prior comment 2. Given the significance of the estimated average policy life in your determination of the constrained lifetime value of commissions recognized currently as commission revenue, please provide draft disclosure to be included in future periodic filings disclosing the estimated average policy life for your major categories of plan types. You may contact Rolf Sundwall at 202-551-3105 or Mary Mast at 202-551-3613 if you have any questions. Sincerely, Division of Corporation Finance Office of Finance
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October 3, 2019
Derek N. Yung
Chief Financial Officer
eHealth, Inc.
2625 Augustine Drive, Second Floor
Santa Clara, CA 95054
Re:eHealth, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed March 14, 2019
File No. 001-33071
Dear Mr. Yung:
We have reviewed your September 23, 2019 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in
our September 5, 2019 letter.
Form 10-K for the Fiscal Year Ended December 31, 2018
Financial Statements
Consolidated Statements of Stockholders' Equity, page 81
1.Refer to your response to our prior comment 1. Please confirm for us that you will
separately disclose the total cumulative effect of adoption of ASC 606 on your retained
earnings as of the earliest period presented in your Form 10-Q for the period ended
September 30, 2018 and your Form 10-K for the fiscal year ended December 31, 2019 on
the face of the Statement of Stockholders' Equity or within a footnote on that financial
statement.
FirstName LastNameDerek N. Yung
Comapany NameeHealth, Inc.
October 3, 2019 Page 2
FirstName LastName
Derek N. Yung
eHealth, Inc.
October 3, 2019
Page 2
Notes to Consolidated Financial Statements
Note 1 - Summary of Business and Significant Accounting Policies
Commission Revenue, page 86
2.Refer to your response to our prior comment 2. Given the significance of the estimated
average policy life in your determination of the constrained lifetime value of commissions
recognized currently as commission revenue, please provide draft disclosure to be
included in future periodic filings disclosing the estimated average policy life for your
major categories of plan types.
You may contact Rolf Sundwall at 202-551-3105 or Mary Mast at 202-551-3613 if you
have any questions.
Sincerely,
Division of Corporation Finance
Office of Finance