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United States securities and exchange commission logo
April 30, 2024
Lee Bienstock
Chief Executive Officer
DocGo Inc.
35 West 35th Street, Floor 6
New York, New York 10001
Re: DocGo Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2023
Filed February 28,
2024
Form 8-K dated
February 28, 2024
File No. 001-39618
Dear Lee Bienstock:
We have limited our review of your filings to the financial
statements and related
disclosures and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Consolidated Financial Statements
Accounts Receivable, page F-16
1. Please clarify for us
your accounting and disclosure under ASC 326-20-50-10, 50-11 and
50-13. In this regard,
both ASC 326-20-50-11 and 50-13 require disclosure by portfolio
segment, which is "the
level at which an entity develops and documents a systematic
methodology to
determine its allowance for credit losses." We note your customers
include large
municipalities which might not share risk characteristics with other types of
customers when
measuring credit losses. Refer to ASC 326-20-15-2(a)(3) regarding the
scope of the Subtopic
and ASC 326-20-30-2 and 55-5 for further guidance. Also refer to
ASC 606-10-32-14 and
ASC 606-10-32-42 through 32-45 for changes in the transaction
price that impact
revenue but are not recorded as credit losses. Please provide us any
revised disclosure for
future filings.
Lee Bienstock
FirstName
DocGo Inc.LastNameLee Bienstock
Comapany
April NameDocGo Inc.
30, 2024
April 230, 2024 Page 2
Page
FirstName LastName
Revenue Recognition, page F-18
2. We note that revenues are recorded net of estimated contractual
allowances for claims
subject to contracts with responsible paying entities and that you
estimate contractual
allowances at the time of billing based on contractual terms,
historical collections or other
arrangements. Please clarify which arrangements contain variable
consideration and
whether the estimate of variable consideration is typically
constrained, as set forth in ASC
606-10-50-12(b). In addition, ASC 606-10-50-1(b) sets forth that an
entity shall disclose
qualitative and quantitative information about the significant
judgments, and changes in
the judgments, made in applying the guidance in ASC 606, to enable
users of financial
statements to understand, in part, the amount and uncertainty of
revenue and cash flows
arising from contracts with customers. ASC 606-10-50-17(b) sets forth,
in part, that an
entity shall disclose and explain the judgments that significantly
affect the determination
of the amount of revenue and ASC 606-10-50-20 sets forth, in part,
that an entity shall
disclose information about the methods, inputs, and assumptions in
determining the
transaction price. Your disclosure does not appear to fully address
the disclosure
requirements as it appears to not include fact-specific details.
Please revise your disclosure
in future filings to address the referenced disclosure requirements.
Please provide us any
revised disclosure that you will include in future filings.
3. We note you disaggregate revenue into the United States and United
Kingdom geographic
markets, as well as into the Mobile Health Services and Transportation
Services major
segments / services lines. Please provide us your evaluation of ASC
606-10-50-5 and 55-
89 through 55-91. In this regard, for example, we note references in
your filing to
municipal customers and references in an investor presentation to
contract terms that tend
to be one year with auto renew feature for municipal contracts, 2-3
years for state
programs and 3+ years for federal contracts. We also note in the
investor presentation
disaggregation of revenues for government, hospitals, payers and
events. On page 25 you
set forth that "DocGo ultimately bills a number of different payors,
including private
insurance, Medicare and Medicaid, the healthcare provider or facility
and self-pay
patients." On page F-19 we note your reference to ancillary services,
such as shelter. In
light of these possibly different types of categories and the examples
in ASC 606-10-55-
91, please explain to us how you evaluated your facts and
circumstances when selecting
the type of category (or categories) to use to disaggregate revenue.
Lee Bienstock
DocGo Inc.
April 30, 2024
Page 3
Form 8-K dated February 28, 2024
Ex-99.1
4. We note you present gross margin in your earning release and that it
excludes depreciation
and amortization. Since the measure excludes depreciation and
amortization, it appears to
be a non-GAAP measure. In future filings, please revise the
description of your measure
to adjusted gross margin and provide the disclosures required by Item
10(e)(1)(i) of
Regulation S-K.
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.
Please contact Christie Wong at 202-551-3684 or Michael Fay at
202-551-3812 with any
questions.
Sincerely,
FirstName LastNameLee Bienstock
Division of
Corporation Finance
Comapany NameDocGo Inc.
Office of
Industrial Applications and
April 30, 2024 Page 3 Services
FirstName LastName