Correspondence 0001360604-23-000053 from Healthcare Realty Trust Inc (HR) (CIK 0001360604) (HR)
Healthcare Realty Trust Inc (HR) (CIK 0001360604)
Date: June 20, 2023 · CIK: 0001360604 · Accession: 0001360604-23-000053
AI Filing Summary & Sentiment
File numbers found in text: 001-35568
Referenced dates: May 5, 2023
Letter
VIA EDGAR Division of Corporate Finance Office of Real Estate & Construction Form 10-K for the year ended December 31, 2022 Form 8-K Filed March 1, 2023 File Nos. 001-35568
Dear Mr. Cline & Mr. Esquivel:
This letter responds on behalf of Healthcare Realty Trust Incorporated, a Maryland corporation (the “Company”), to the letter dated May 5, 2023 (the “Letter”) setting forth comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on the Company’s Form 10-K for the year ended December 31, 2022 (the “10-K”) and related earnings release and supplemental information on Form 8-K (the “8-K”), each filed on March 1, 2023.
The Company provided a response on May 18, 2023 to the letter dated May 5, 2023. In furtherance of the Company’s response on May 18, 2023, the Company hereby provides that it will modify its future disclosure as follows:
•In the Company’s Supplemental Report which is provided in Exhibit 99.2 on its Form 8-K, the Company will
◦Add a prominent explanatory note to provide the reasoning for including the results of Legacy HTA properties into the Company’s same store metrics.
◦Change the moniker of “Same Store” to “Merger Combined Same Store” to add clarity.
◦Add a footnote to all pages that have Merger Combined Same Store metrics indicating that these metrics include Legacy HTA properties that meet the Company-defined same store criteria.
•In the Company’s future periodic reports, the Company will enhance disclosure to explain what properties are included in Merger Combined Same Store and why. In
addition, the Company will add further detail in the same store reconciliation on Legacy HR same store NOI.
If you have any questions or comments, please feel free to contact me by telephone at (615) 269-8175.
Sincerely,
/s/ J. Christopher Douglas
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CORRESP 1 filename1.htm Document HEALTHCARE REALTY 3310 West End Avenue, Suite 700 Nashville, TN 37203 P 615.269.8175 www.healthcarerealty.com June 20, 2023 VIA EDGAR Mr. Paul Cline Mr. Isaac Esquivel Division of Corporate Finance Office of Real Estate & Construction U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Healthcare Realty Trust Incorporated Form 10-K for the year ended December 31, 2022 Form 8-K Filed March 1, 2023 File Nos. 001-35568 Dear Mr. Cline & Mr. Esquivel: This letter responds on behalf of Healthcare Realty Trust Incorporated, a Maryland corporation (the “Company”), to the letter dated May 5, 2023 (the “Letter”) setting forth comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on the Company’s Form 10-K for the year ended December 31, 2022 (the “10-K”) and related earnings release and supplemental information on Form 8-K (the “8-K”), each filed on March 1, 2023. The Company provided a response on May 18, 2023 to the letter dated May 5, 2023. In furtherance of the Company’s response on May 18, 2023, the Company hereby provides that it will modify its future disclosure as follows: •In the Company’s Supplemental Report which is provided in Exhibit 99.2 on its Form 8-K, the Company will ◦Add a prominent explanatory note to provide the reasoning for including the results of Legacy HTA properties into the Company’s same store metrics. ◦Change the moniker of “Same Store” to “Merger Combined Same Store” to add clarity. ◦Add a footnote to all pages that have Merger Combined Same Store metrics indicating that these metrics include Legacy HTA properties that meet the Company-defined same store criteria. •In the Company’s future periodic reports, the Company will enhance disclosure to explain what properties are included in Merger Combined Same Store and why. In addition, the Company will add further detail in the same store reconciliation on Legacy HR same store NOI. If you have any questions or comments, please feel free to contact me by telephone at (615) 269-8175. Sincerely, /s/ J. Christopher Douglas J. Christopher Douglas EVP, Chief Financial Officer