SEC – ‘UPLOAD’ from 5/7/20 re: Allscripts Healthcare Solutions, Inc. – ‘TEXT-EXTRACT’

On:  Thursday, 5/7/20, at 2:17pm ET   ·   Delayed-Release:  Filing ¶  –  Release Delayed to:  6/25/20   ·   Accession #:  0-20-3991

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Delayed-Release Comment or Other Letter from the SEC
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: LETTER      Comment or Other Letter from the SEC                 PDF     29K 
 2: TEXT-EXTRACT  Comment or Other Letter from the SEC (PDF Text)      2±    11K 

‘TEXT-EXTRACT’   —   Comment or Other Letter from the SEC (PDF Text)

United States securities and exchange commission logo                           

May 6, 2020       

Rick Poulton                                                      
President and Chief Financial Officer                             
Allscripts Healthcare Solutions, Inc.                             
222 Merchandise Mart Plaza , Suite 2024                           
Chicago , IL 60654                                                

                                              Re: Allscripts
Healthcare Solutions, Inc.                                                      
                                                         Form 10-K for the
Fiscal Year Ended December 31, 2019                                             
                                                           Filed March 2, 2020
                                                          File No. 001-35547

Dear Mr. Poulton:                                                 

            We have reviewed your filing 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, 2019             

     Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations                                                           
Provider                                                          
    Year Ended December 31, 2019 Compared with the Year Ended December 31,
2018, page 49                                                                   

  1.                                                   Please elaborate on the
nature of the "known attrition" within the EIS and other                        
                                                     businesses." Disclose
the nature of the attrition, the extent it is from contract cancellations       
                                                    or modifications for
lesser value, the financial impact of attrition on 2019 and future              
                                                       periods, and the period
of time over which you expect to recognize the remaining value of               
                                                      the affected contracts
(if any). Refer to Item 303(a)(3) of Regulation S-K.                            
Veradigm                                                          
    Year Ended December 31, 2019 Compared with the Year Ended December 31,
2018, page 50                                                                   

2.                                                   We note Veradigm's   
revenue growth is due to an increase in organic sales. In your                  
Rick Poulton                                                                  
Allscripts Healthcare Solutions, Inc.                                           
May 6, 2020                                                                     
Page 2                                                                          
       earnings call, you indicated that "media buy drives a decent chunk of
some of the                                                                     
       revenues." In future filings, please discuss the nature of media buys
and how they drive                                                              
Veradigm's organic sales. Also, please disclose your revenue  
recognition policy for media                                                    
       buys in the applicable note to the financial statements, if material.
Liquidity and Capital Resources , page 51                                       

3.       Please discuss your progress toward and the anticipated effects of     
your transition away                                                            
   from LIBOR. Further disclose whether your current credit facility
provides for a                                                                  
replacement rate. Refer to                                    
https://www.sec.gov/news/public-statement/libor-transition.                     
     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 Kathryn Jacobson, Senior Staff Accountant at (202)
551-3365 or Robert                                                              
Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions     
regarding                                                                       
comments on the financial statements and related matters.                       

FirstName LastNameRick Poulton                                Sincerely,        
Comapany NameAllscripts Healthcare Solutions, Inc.                              
                                                       Division of
Corporation Finance                                                             
May 6, 2020 Page 2                                            Office of         
Technology                                                                      
FirstName LastName                                                              

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘UPLOAD’ Filing		Date		Other Filings
Release Delayed to:		6/25/20		UPLOAD
Filed on:		5/7/20		8-K,  UPLOAD
		5/6/20		UPLOAD
		3/2/20		10-K,  8-K,  UPLOAD
		12/31/19		10-K,  UPLOAD
		12/31/18		10-K,  8-K
				List all Filings

1 Previous Filing that this Filing References

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 3/02/20  Veradigm Inc.                     10-K       12/31/19  156:33M                                    ActiveDisclosure/FA