Health industries: 2017 SEC comment letter trends

SEC comment letter trends , PwC US Nov 28, 2017

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We provide an analysis of SEC staff comment letters to help executives understand key trends relevant to financial reporting in the health industries sector, including Pharmaceutical & life sciences and Health services companies.


We are very pleased to present you with the latest installment of our comment letter trends publication in which we analyze recent SEC comment letters in the Health Industries sector. We analyzed over 1,400 comments received by Pharmaceutical & Lifesciences and Health services companies in the past year.

This publication focuses on what key stakeholders value in your disclosures, and will assist you with your SEC reporting by providing a summary of the most recent comment letter trends.

Our review of the comment letters indicates a focus by the SEC staff on transparent and accurate financial reporting through clear discussion in the MD&A, an understanding of revenue recognition policies, and compliance with SEC rules, including those pertaining to non-GAAP measures.

We hope that you find the insights useful in navigating your upcoming financial reports and the year-end reporting process. Please feel free to contact your PwC engagement team, the contacts listed at the back of this publication, or us to discuss the information in this publication or to address any questions you may have. 

To have a deeper discussion, please contact:

Laura Robinette

US Pharmaceutical and Life Sciences Assurance Leader, Raleigh, NC, PwC US

+1 (919) 791 4100


Tim Weld

Health Services Assurance Leader, New York, PwC US

+1 (646) 471 2477


Contact us

Valerie Wieman
Partner, National Professional Services Group, PwC US

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