SEC Comment Letter 0000000000-23-003971 to Aveanna Healthcare Holdings, Inc. (AVAH) (CIK 0001832332) (AVAH)
Aveanna Healthcare Holdings, Inc. (AVAH) (CIK 0001832332)
Date: April 20, 2023 · CIK: 0001832332 · Accession: 0000000000-23-003971
AI Filing Summary & Sentiment
File numbers found in text: 001-40362
Letter
United States securities and exchange commission logo April 20, 2023 Jeff Shaner President and Chief Executive Officer Aveanna Healthcare Holdings, Inc. 400 Interstate North Parkway SE Atlanta, Georgia 30339 Re:Aveanna Healthcare Holdings, Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Filed March 16, 2023 File No. 001-40362 Dear Jeff Shaner: We have limited our review of your filing to the financial statements and related disclosures 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 the 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 the comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2022 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations. Non-GAAP Financial Measures, page 67 1.In future filings, please revise to reconcile the non-GAAP measure "Field Contribution" and "Field Contribution Margin" to the most comparable GAAP measure, which appears to be gross margin, even if it is not presented on the face of the Consolidated Statement of Operations. Please also revise the similar reconciliation in Exhibit 99.1 to your Form 8- K.
FirstName LastNameJeff Shaner Comapany NameAveanna Healthcare Holdings, Inc. April 20, 2023 Page 2 FirstName LastName Jeff Shaner Aveanna Healthcare Holdings, Inc. April 20, 2023 Page 2 In closing, 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 Christie Wong, Staff Accountant, at (202) 551-3684 or Brian Cascio, Accounting Branch Chief, at (202) 551-3676 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
April 20, 2023
Jeff Shaner
President and Chief Executive Officer
Aveanna Healthcare Holdings, Inc.
400 Interstate North Parkway SE
Atlanta, Georgia 30339
Re:Aveanna Healthcare Holdings, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed March 16, 2023
File No. 001-40362
Dear Jeff Shaner:
We have limited our review of your filing to the financial statements and related
disclosures 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 the 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 the comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations.
Non-GAAP Financial Measures, page 67
1.In future filings, please revise to reconcile the non-GAAP measure "Field Contribution"
and "Field Contribution Margin" to the most comparable GAAP measure, which appears
to be gross margin, even if it is not presented on the face of the Consolidated Statement of
Operations. Please also revise the similar reconciliation in Exhibit 99.1 to your Form 8-
K.
FirstName LastNameJeff Shaner
Comapany NameAveanna Healthcare Holdings, Inc.
April 20, 2023 Page 2
FirstName LastName
Jeff Shaner
Aveanna Healthcare Holdings, Inc.
April 20, 2023
Page 2
In closing, 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 Christie Wong, Staff Accountant, at (202) 551-3684 or Brian Cascio,
Accounting Branch Chief, at (202) 551-3676 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services