M. Timothy Elder
Direct Tel: 404-815-3532
Direct Fax: 404-685-6832
telder@sgrlaw.com
April 2, 2015
VIA EDGAR TRANSMISSION
Jim B. Rosenberg
Senior Assistant Chief Accountant
Securities and Exchange Commission
Judiciary Plaza
100 F Street, N.E.
Mail Stop 6010
Washington, D.C. 20549
Re: | SunLink Health Systems, Inc. |
Form 10-K for the Fiscal Year Ended June 30, 2014
Filed September 26, 2014
File No. 001-12607
Dear Mr. Rosenberg:
We have today electronically filed with the Securities and Exchange Commission on behalf of SunLink Health Systems, Inc. (“SunLink” or the “Company”) this response to the Staff’s oral comment of March 10, 2015 with respect to your comments on the Company’s Form 10-K for the fiscal year ended June 30, 2014 (the “Form 10-K”) pursuant to your review thereof.
Form 10-K for the Fiscal Year Ended June 30, 2014
Item 9A. Controls and Procedures, page 68
1. | Please refer to your response to Comment 1. Please clarify if you used the 1992 or 2013 framework of the Commission of Sponsoring Organizations of the Treadway Commission in your assessment of internal controls. |
Jim B. Rosenberg
Senior Assistant Chief Accountant
Securities and Exchange Commission
April 2, 2015
Page 2
The Company used the 1992 framework for the period ending June 14, 2014. The Company revised the disclosure set forth in its amended Form 10-K/A filed yesterday to expressly reference the 1992 disclosure. The Company supplementally advises the Staff that the Company’s adoption of the 2013 framework for subsequent reporting periods is not expected to materially affect its internal controls.
Closing Comments
If the Staff has any questions concerning this response letter, please contact the undersigned at 404-815-3532 or my partner, Howard E. Turner, at 404-815-3594.
Very truly yours, |
/s/ M. Timothy Elder |
Smith, Gambrell & Russell, LLP |
Attorneys for SunLink Health Systems, Inc. |
MTE: fls
cc: | Mark J. Stockslager, SunLink |
Robert M. Thornton, SunLink
Howard E. Turner, Esq.