SEC Comment Letter 0000000000-25-001611 to Acadia Healthcare Company, Inc. (ACHC) (CIK 0001520697) (ACHC)
Acadia Healthcare Company, Inc. (ACHC) (CIK 0001520697)
Date: Feb. 12, 2025 · CIK: 0001520697 · Accession: 0000000000-25-001611
AI Filing Summary & Sentiment
File numbers found in text: 001-35331
Letter
February 12, 2025 Heather Dixon Chief Financial Officer Acadia Healthcare Company, Inc. 6100 Tower Circle Suite 1000 Franklin, Tennessee 37067 Re:Acadia Healthcare Company, Inc. Form 8-K filed February 27, 2024 Response dated January 21, 2025 File No. 001-35331 Dear Heather Dixon: We have reviewed your filing and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 8-K filed February 27, 2024 Exhibit 99, page 10 1.We note the draft disclosures you provided in response to comment 2. Please expand these disclosures to provide a more fulsome discussion of your Same Facility Results and Facility Results to address the following: •Clearly explain the purpose and what you are trying to convey for each presentation. •Discuss the limitations of these presentations, especially as it relates to Adjusted EBITDA; an explanation about how you address these limitations; and a statement that the presentations should not be used to evaluate your performance as a whole. •For the adjustments to arrive at Same Facility Adjusted EBTIDA and Facility Adjusted EBITDA, provide a more robust discussion of the nature of the specific costs being excluded and how you determined these costs.
February 12, 2025 Page 2 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. Please contact Tayyaba Shafique at 202-551-2110 or Tracey Houser at 202-551-3736 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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February 12, 2025
Heather Dixon
Chief Financial Officer
Acadia Healthcare Company, Inc.
6100 Tower Circle
Suite 1000
Franklin, Tennessee 37067
Re:Acadia Healthcare Company, Inc.
Form 8-K filed February 27, 2024
Response dated January 21, 2025
File No. 001-35331
Dear Heather Dixon:
We have reviewed your filing and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 8-K filed February 27, 2024
Exhibit 99, page 10
1.We note the draft disclosures you provided in response to comment 2. Please expand
these disclosures to provide a more fulsome discussion of your Same Facility Results
and Facility Results to address the following:
•Clearly explain the purpose and what you are trying to convey for each
presentation.
•Discuss the limitations of these presentations, especially as it relates to Adjusted
EBITDA; an explanation about how you address these limitations; and a
statement that the presentations should not be used to evaluate your performance
as a whole.
•For the adjustments to arrive at Same Facility Adjusted EBTIDA and Facility
Adjusted EBITDA, provide a more robust discussion of the nature of the specific
costs being excluded and how you determined these costs.
February 12, 2025
Page 2
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.
Please contact Tayyaba Shafique at 202-551-2110 or Tracey Houser at 202-551-3736
if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services