SEC Comment Letter for Evolent Health, Inc. (EVH) (CIK 0001628908) (EVH) — May 17, 2017
Evolent Health, Inc. (EVH) (CIK 0001628908)
Date: May 17, 2017 · CIK: 0001628908 · Accession: 0000000000-17-017407
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Letter
Mailstop 3233 May 17, 201 7 Via E-mail Mr. Nicholas McGrane Chief Financial Officer Evolent Health, Inc. 800 N. Glebe Road, Suite 500 Arlington, VA 22203
Re: Evolent Health, Inc. Form 10-K for the fiscal year e nded December 31, 201 6 Filed March 3, 201 7 File No. 001 -37415
Dear Mr. McGrane :
We have limited our review of your filing s 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 p ossible 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 c omments, we may have additional comments.
Form 10 -K for the fiscal year ended December 31, 2016
Item 9A. Controls and Procedures
Management’s Report on Internal Control over Financial Reporting, page 104
1. In future filings, please specify if managemen t applied the criteria of the Updated 2013 Framework or the 1992 Framework issued by COSO when assessing the effectiveness of the Company's internal control over financial reporting. Reference is made to Item 308(a)(2) of Regulation S -K.
Mr. Nicholas McGrane Evolent Health, Inc. May 17, 201 7 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.
You may contact Jeffrey Lewis, Staff Accountant, at (20 2) 551 -6216 or the undersigned at (202) 551 -3468 with any questions.
Sincerely,
/s/ Wilson K. L ee
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Mailstop 3233
May 17, 201 7
Via E-mail
Mr. Nicholas McGrane
Chief Financial Officer
Evolent Health, Inc.
800 N. Glebe Road, Suite 500
Arlington, VA 22203
Re: Evolent Health, Inc.
Form 10-K for the fiscal year e nded December 31, 201 6
Filed March 3, 201 7
File No. 001 -37415
Dear Mr. McGrane :
We have limited our review of your filing s 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 p ossible 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 c omments, we may have additional comments.
Form 10 -K for the fiscal year ended December 31, 2016
Item 9A. Controls and Procedures
Management’s Report on Internal Control over Financial Reporting, page 104
1. In future filings, please specify if managemen t applied the criteria of the Updated 2013
Framework or the 1992 Framework issued by COSO when assessing the effectiveness of
the Company's internal control over financial reporting. Reference is made to Item
308(a)(2) of Regulation S -K.
Mr. Nicholas McGrane
Evolent Health, Inc.
May 17, 201 7
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.
You may contact Jeffrey Lewis, Staff Accountant, at (20 2) 551 -6216 or the undersigned
at (202) 551 -3468 with any questions.
Sincerely,
/s/ Wilson K. L ee
Wilson K. Lee
Senior Staff Accountant
Office of Real Estate and
Commodities