What are your plans to address these challenges? Summary: This guidance provides additional views of the Division of Corporation Finance regarding operations, liquidity, and capital resources disclosures companies should consider with respect to business and market disruptions related to COVID-19. In these cases, we remind companies of the principles explained in recent Commission guidance related to metrics.[8]. We understand that companies may be considering how to report the evolving impact of COVID-19 in light of unexpected nonrecurring charges and expenses. — Telehealth groups ask for more leeway: Virtual care advocates slipped a telehealth provision into the emergency funding package enacted last week. Further, the Commission has neither approved nor disapproved its content. How has COVID-19 impacted your financial condition and results of operations? We remind companies that providing forward-looking information in an effort to keep investors informed about material developments, including known trends or uncertainties regarding COVID-19, can be undertaken in a way to avail companies of the safe harbors in Section 27A of the Securities Act and Section 21E of the Exchange Act for this information. — Coronavirus stresses antiquated health IT: The U.S. health care system is on the leading edge of many technologies, except, crucially, when it comes to information sharing. The HHS Office for Civil Rights, the agency enforcing the HIPAA privacy law, reminded health care providers, insurers and their associates last month that coronavirus disclosures should be limited to the "minimum necessary" amount of information to prevent a serious and imminent public health threat.
Do you expect the anticipated impact of COVID-19 to materially change the relationship between costs and revenues? While we have observed companies making some of these disclosures in their earnings releases, we encourage companies to evaluate whether any of the information, in light of its potential materiality, should also be included in MD&A.
Do you expect that COVID-19 will impact future operations differently than how it affected the current period? Do your financing arrangements contain terms that limit your ability to obtain additional funding? How is your overall liquidity position and outlook evolving? 9, COVID-19 may materially impact a number of disclosures that a company should consider, such as disclosure controls and procedures and internal control over financial reporting. Do those terms and conditions limit your ability to seek other sources of financing or affect your cost of capital? 9 with guidance regarding additional disclosure considerations. The Division continues to monitor how companies are disclosing the effects and risks of COVID-19 on their businesses, financial condition, and results of operations and is supplementing CF Disclosure Guidance Topic No. Among other things, U.S. GAAP requires disclosures about whether there is substantial doubt about a company’s ability to continue as a going concern, the conditions and events that raise such doubt, management’s evaluation of those conditions or events, and any plans to alleviate such doubt. Have COVID-19-related circumstances such as remote work arrangements adversely affected your ability to maintain operations, including financial reporting systems, internal control over financial reporting and disclosure controls and procedures? 33-10459 (Feb. 26, 2018), available at https://www.sec.gov/rules/interp/2018/33-10459.pdf. Please continue to submit questions or seek guidance on other topics by completing an online form and directing it to the appropriate office and continue to submit requests for no-action, interpretive, or exemptive letters by online form. Are any decreases in cash flow from operations having a material impact on your liquidity position and outlook? (Adam also wrote about 2020 rival Bernie Sanders' warning about the crisis, which he said was "on a scale of a major war," and that "we must act accordingly."). CORONAVIRUS CRISIS BRINGS HEALTH IT CHALLENGES TO LIGHT—Antiquated health IT systems could add yet another snarl to the already troubled effort to test for coronavirus, eHealth's Darius Tahir writes.