When the SEC's staff reviews a filing, it writes to the company with numbered questions, and the company answers each one in a letter.
SEC publishes the exchange once the review is over, at least 20 business days later. Below: what the staff asked CVS, and the company's answer to each question, quoted from the letters.
A question is not an accusation; most reviews end with the company adding detail to its next filing.
Segment Analysis · Health Care Benefits Segment, page 79
SEC asked
Your disclosure in the last paragraph on page 80 indicates that "[b]ased on the Company's membership at December 31, 2022, 21% of the Company's Medicare Advantage members were in plans with 2023 star ratings of at least 4.0 stars, compared to 87% of the Company's Medicare Advantage members being in plans with 2022 star ratings of at least 4.0 stars based on the Company's membership at December 31, 2021." We alsoRest of the question
note that your 2023 star ratings will be used to determine which of your Medicare Advantage plans have four stars or higher and qualify for bonus payments in 2024. Please revise to quantify, if material, the impact that the significant decline in your plans with four stars or higher could have on your bonus payments in future periods.
From the SEC's correspondence on EDGAR: staff letters (form UPLOAD) and company letters (form CORRESP), 21 letters filed since 2018-01-22.
Questions and answers are matched by their numbers; topics come from words in each question. The reports are compared word for word (same form, before the first SEC letter against the first report after the company's reply). No AI.
Work on CVS in a spreadsheet:
Excel workbook (a sheet per section, ten years by column, charts, links to the filings) ·
CSV.
For a Google Sheet that stays up to date, paste =IMPORTDATA("https://tickdelta.com/company/CVS/export.csv") into a cell.