MAXIMUS, INC. (MMS)

Staff comment: Please begin the reconcilation of Adjusted EBITDA presented on page 46 with net income, the most directly comparable GAAP measure pursuant to Item 10(e)(1)(i)(B) of Regulation S-K and Questions 102.10(b) and 103.02 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures (C&DI's). Additionally, we note the presentation of Adjusted EBITDA margin. Please present the comparable measure computed on a GAAP basis pursuant to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the C&DI's. letter →

Staff comment: We note that you believe providing measures that exclude the impact of amortization is useful to investors in evaluating your core operations and results; however, these measures include revenue from core operations generated in part by acquired assets. Please revise to clarify that although amortization of intangible assets acquired through acquisitions is being excluded from the non-GAAP measures, the revenue generated from these assets is still included in the measure. letter →

Staff comment: Please tell us how your disclosure complies with the requirement to disclose how the chief operating decision maker uses the reported measures of segment profit or loss in assessing segment performance and deciding how to allocate resources pusuant to ASC 280-10-50-30(f). letter →