April 3, 2020

Brandon T. O'Brien
Chief Financial Officer
CorVel Corporation
2010 Main Street, Suite 600
Irvine, California 92614

       Re: CorVel Corporation
           Form 10-K for the Fiscal Year Ended March 31, 2019
           Filed June 7, 2019
           File No. 000-19291

Dear Mr. O'Brien:

        We have reviewed your March 18, 2020 response to our comment letter and
have the
following comment. In our comment, we ask you to provide us with information so
we may
better understand your disclosure.

       Please respond to this comment within 10 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. Unless we note otherwise, our references to prior comments are to
comments in
our February 20, 2020 letter.

Form 10-K for the Fiscal Year ended March 31, 2019

Remaining Performance Obligations, page 54

1.    We acknowledge your response to prior comment 2 and your intent to remove
disclosure
      of contract assets from the second table in Note 2 (presumably the first
table on page 54).
      Please address the following:
        Clarify for us whether you believe that your unbilled receivables are
contract assets
          as defined in ASC 606-10-20 or whether they are receivables that are
due you
          unconditionally for services already rendered except for physical
invoicing and the
          passage of time.
        Tell us how your planned removal of $18,434,000 of contract assets from
the first
          table on page 54 is appropriate as it appears that this amount is
necessary to tie to the
          total accounts receivable, net on your balance sheet.
 Brandon T. O'Brien
CorVel Corporation
April 3, 2020
Page 2
              As previously requested in prior comment 2, tell us which
unbilled receivables were
              included in the $34.7 million of remaining performance
obligations at March 31,
              2019. Otherwise tell us how your disclosure complies with the
guidance in ASC 606-
              40-50-13 and 50-14.
              Tell us whether you believe you previously overstated both
unbilled receivables and
              deferred revenues.
              Provide us draft revised Note 2 disclosure as of March 31, 2019
reflecting the
              changes you intend to make and ultimately provide in your
upcoming Form 10-K.

        You may contact Bonnie Baynes at (202) 551-4924 or Mark Brunhofer at
(202) 551-
3638 if you have any questions.



FirstName LastNameBrandon T. O'Brien                         Sincerely,
Comapany NameCorVel Corporation
                                                             Division of
Corporation Finance
April 3, 2020 Page 2                                         Office of Finance
FirstName LastName