SEC Comment Letter for Change Healthcare Inc. (CIK 0001756497) — Aug 5, 2020
Change Healthcare Inc. (CIK 0001756497)
Date: Aug. 5, 2020 · CIK: 0001756497 · Accession: 0000000000-20-007151
AI Filing Summary & Sentiment
File numbers found in text: 001-38961
Letter
United States securities and exchange commission logo August 5, 2020 Fredrick Eliasson Executive Vice President and Chief Financial Officer Change Healthcare, Inc. 3055 Lebanon Pike Suite 1000 Nashville, TN 37214 Re:Change Healthcare, Inc. Form 10-K for the fiscal year ended March 31, 2020 Filed June 4, 2020 File No. 001-38961 Dear Mr. Eliasson: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the fiscal year ended March 31, 2020 Notes to the Consolidated Financial Statements 9. Goodwill and Intangible Assets, page 125 1.We note you performed an interim goodwill impairment test due to the expected impacts of COVID-19 on your financials results. Please tell us whether you also evaluated your intangible assets balance for recoverability due to this significant adverse change in the business climate. Refer to guidance in ASC 350-30-35-14 and ASC 360-10-35-21(c). In addition, please revise to include your intangible asset impairment policy in your financial statement footnotes.
FirstName LastNameFredrick Eliasson Comapany NameChange Healthcare, Inc. August 5, 2020 Page 2 FirstName LastName Fredrick Eliasson Change Healthcare, Inc. August 5, 2020 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 Brittany Ebbertt, Senior Staff Accountant, at 202-551-3572 or Christine Dietz, Senior Staff Accountant, at 202-551-3408 with any questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
August 5, 2020
Fredrick Eliasson
Executive Vice President and Chief Financial Officer
Change Healthcare, Inc.
3055 Lebanon Pike
Suite 1000
Nashville, TN 37214
Re:Change Healthcare, Inc.
Form 10-K for the fiscal year ended March 31, 2020
Filed June 4, 2020
File No. 001-38961
Dear Mr. Eliasson:
We have reviewed your filing and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the fiscal year ended March 31, 2020
Notes to the Consolidated Financial Statements
9. Goodwill and Intangible Assets, page 125
1.We note you performed an interim goodwill impairment test due to the expected impacts
of COVID-19 on your financials results. Please tell us whether you also evaluated your
intangible assets balance for recoverability due to this significant adverse change in the
business climate. Refer to guidance in ASC 350-30-35-14 and ASC 360-10-35-21(c). In
addition, please revise to include your intangible asset impairment policy in your financial
statement footnotes.
FirstName LastNameFredrick Eliasson
Comapany NameChange Healthcare, Inc.
August 5, 2020 Page 2
FirstName LastName
Fredrick Eliasson
Change Healthcare, Inc.
August 5, 2020
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 Brittany Ebbertt, Senior Staff Accountant, at 202-551-3572 or Christine
Dietz, Senior Staff Accountant, at 202-551-3408 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology