TEXT-EXTRACT 2 filename2.txt November 29, 2018 David Williams Executive Vice President and Chief Financial Officer Chemed Corporation 255 East Fifth Street Suite 2600 Cincinnati, OH 45202 Re: Chemed Corporation Form 10-K for the Year Ended December 31, 2017 Filed February 26, 2018 File No. 001-08351 Dear Mr. Williams: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Year Ended December 31, 2017 Management's Discussion and Analysis of Financial Condition and Results of Operations Reconciliation of Adjusted Net Income, page 101 1. We note you present certain adjustments in your non-GAAP performance measures Adjusted Net Income and Adjusted Diluted Earnings Per Share net of income taxes both here and at page 36 of your Form 10-Q for the quarter ended September 30, 2018. Please revise to present the effect of income taxes as a separate adjustment and expand your disclosure to clearly explain how the tax effects of non-GAAP adjustments are calculated. Refer to Question 102.11 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations issued April 4, 2018. David Williams Chemed Corporation November 29, 2018 Page 2 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. You may contact Brian McAllister, Staff Accountant, at (202) 551-3341 or Craig Arakawa, Accounting Branch Chief, at (202) 551-3650 with any questions. Sincerely, FirstName LastNameDavid Williams Division of Corporation Finance Comapany NameChemed Corporation Office of Beverages, Apparel and November 29, 2018 Page 2 Mining FirstName LastName