Via Facsimile and U.S. Mail
Mail Stop 6010
July 22, 2005
Mr. William B. Yarmuth
Chairman, President and CEO
Almost Family, Inc.
9510 Ormsby Station Road, Suite 300
Louisville, KY 40223
Re: Almost Family, Inc.
Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 31, 2005
File No. 1-09848
Dear Mr. Yarmuth:
We have limited our review of your filing to those issues we
have addressed in our comments. In our comments, we ask you to
provide us with information so we may better understand your
disclosure. After reviewing this information, we may or may not
raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Form 10-K for Fiscal Year Ended December 31, 2004
Managements Discussion and Analysis of Financial Condition and
Results of Operations
Overview
1. With regards to your VN segment revenues, you indicate that VN
Medicare revenues are generated on a per episode basis rather than
a
fee per visit or day of care. Please provide us in disclosure-type
format how you recognize revenue on a per episode basis in order
to
evaluate your accounting and disclosure in your financial
statements.
Critical Accounting Policies
Receivable and Revenue Recognition:
2. Please provide us the following disclosures in disclosure-type
format to help us evaluate the adequacy of your disclosure:
a. State if your billing system generates contractual adjustments
based on fee schedules for the patient`s insurance plan for each
patient encounter or if an estimate of contractual allowances is
made. If an estimate is made, state what factors are considered
in
determining the estimate.
b. Your policy for collecting co-payments.
c. For each period presented, quantify the amount of changes in
estimates of prior period contractual adjustments that you
recorded
during the current period. For example for 2004 this amount would
represent the amount of the difference between estimates of
contractual adjustments for services provided in 2003and the
amount
of the new estimate or settlement amount that was recorded during
2004
d. Quantify the reasonably possible effects that a change in
estimate
of unsettled amounts from 3rd party payors as of the latest
balance
sheet date could have on financial position and operations.
e. In a comparative tabular format, the payor mix concentrations
and
related aging of accounts receivable. The aging schedule may be
based on management`s own reporting criteria (i.e. unbilled, less
than 30 days, 30 to 60 days etc.) or some other reasonable
presentation. At a minimum, the disclosure should indicate the
past
due amounts and a breakdown by payor classification (i.e.
Medicare,
Medicaid, Managed care and other, and Self-pay). We would expect
Self-pay to be separately classified from any other grouping. If
your billing system does not have the capacity to provide an aging
schedule of your receivables, clarify how this affects your
ability
to estimate your allowance for bad debts.
f. If you have amounts that are pending approval from third party
payors (i.e. Medicaid Pending), the balances of such amounts,
where
they have been classified in your aging buckets, and what payor
classification they have been grouped with. If amounts are
classified outside of self-pay, clarify us why this classification
is
appropriate, and disclose the historical percentage of amounts
that
get reclassified into self-pay.
Allowance for Doubtful Accounts:
3. Please provide us, in disclosure-type format, the steps you
take
in collecting accounts receivable, your policy with respect to
determining when a receivable is recorded as a bad debt , and when
a
write off is recorded including the threshold (amount and age) for
account balance write-offs.
Financial Statements
Note 6. Income Taxes
4. Please provide us a detailed analysis of the basis for the one-
time reduction in the estimated tax liabilities of $854,000.
Note 9. Commitments and Contingencies
Legal Proceedings
5. Please tell us why you believe a ruling in favor for the
plaintiff
in the Franklin litigation case would not require an accrual under
SFAS 5.
6. We note that you have a receivable from a broker that is in
Chapter 7 bankruptcy proceedings. Please tell us why you have not
written off the entire accounts receivable balance.
* * * *
Please provide us the supplemental information requested
within
10 business days of the date of this letter or tell us when you
will
provide a response prior to the expiration of the 10-day period.
Please furnish a letter with your supplemental responses that keys
your response to our comments. Please file your letter on EDGAR
under the form type label CORRESP.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Sasha Parikh, Staff Accountant, at (202)
551-
3627 or Mary Mast, Review Accountant, at (202) 551-3613 if you
have
questions regarding the comments. In this regard, do not hesitate
to
contact me, at (202) 551-3679.
Sincerely,
Jim B. Rosenberg
Senior Assistant Chief
Accountant
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William Yarmuth
Almost Family Inc.
July 22, 2005
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