United States securities and exchange commission logo
May 25, 2022
George O'Leary
Chief Financial Officer
HealthLynked Corp
1265 Creekside Parkway, Suite 302
Naples, Florida 34108
Re: HealthLynked Corp
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed March 31,
2022
File No. 000-55768
Dear Mr. O'Leary:
We have limited our review of your filing 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 possible 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 comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2021
Item 9A. Controls and Procedures , page 31
1. The Item 9A
presentation in your Form 10-K for the fiscal year ended December 31, 2021
excludes an assessment
and effectiveness conclusion for internal control over financial
reporting. Please amend
your Form 10-K to include all of the information required by
Items 307 and 308 of
Regulation S-K.
Notes to Consolidated Financial Statements
Note 2 - Significant Accounting Policies
Revenue Recognition, page F-9
2. Please revise your
future filings to include all of the disclosures required by ASC 606-10-
50, as applicable, and
provide us a draft of your intended disclosure revisions.
Specifically, address
the following:
Regarding net
patient service revenues, explain the nature of the services provided,
George O'Leary
HealthLynked Corp
May 25, 2022
Page 2
while clarifying why some of your performance obligations are
satisfied over time
while others are satisfied at a point in time. Provide the
qualitative and quantitative
disclosure about the significant judgments and changes in
judgments, including
inputs and assumptions, related to your accounting for
contractual adjustments,
discounts and price concessions and the amount of subsequent
settlements with your
third party payers as set forth in ASC 606-10-50-1(b), 50-17, and
50-20.
Regarding Medicare shared savings revenue, provide us your
analysis of principal
versus agent considerations, and revise your disclosures as
appropriate. We refer you
to ASC 606-10-55-36 through 55-40. Explain to us the apparent
disconnect between
your statement on page F-10 that you bear all costs of the ACO
operations until
revenue is recognized, and your disclosure on page F-11 that
states that shared
savings expense is recognized in the period in which the shared
savings revenue is
recognized, i.e. in the period in which the CMS notifies you of
the exact amount of
shared savings to be paid. Refer us to the technical guidance
upon which you relied.
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 Frank Wyman at 202-551-3660 or Ibolya Ignat at
202-551-3636 with
any questions.
FirstName LastNameGeorge O'Leary Sincerely,
Comapany NameHealthLynked Corp
Division of
Corporation Finance
May 25, 2022 Page 2 Office of Life
Sciences
FirstName LastName