SEC Comment Letter for MAXIMUS, INC. (MMS) (CIK 0001032220) (MMS) — Jun 3, 2010
MAXIMUS, INC. (MMS) (CIK 0001032220)
Date: June 3, 2010 · CIK: 0001032220 · Accession: 0000000000-10-030822
AI Filing Summary & Sentiment
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Letter
Mail Stop 3010 June 3, 2010 Mr. David N. Walker Chief Financial Officer Maximus, Inc. 11419 Sunset Hills Road Reston, VA 20190
Re: Maximus, Inc. Form 10-K for the fiscal year ended September 30, 2009 File No. 1-12997
Dear Mr. Walker:
We have reviewed your first response letter filed on May 19, 2010 and have the following additional comment. Where indi cated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inappl icable or a revision is unnecessary. Please be as detailed as necessary in your explan ation. In our comment, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we ma y or may not raise additional comments.
Form 10-K for the fiscal year ended September 30, 2009
Financial Statements
13. Shareholders’ Equity, page 55 1. We note your response to prior comment three and request that you provide us with a more robust analysis of material ity related to the $2.2 million stock-based compensation charge recorded during the first quarter of fi scal 2008. In your response, please provide us with a thorough materiality analysis which is performed at the segment level and which addresses the impact to both income from continuing operations and net income. Additionally, help us to understand what you, your investors and analysts were focusing on during the earnings calls during 2007 and 2008. Please tell us if th e focus was on earnings including or
Mr. Walker Maximus, Inc. June 3, 2010 Page
excluding these “unusual and infrequently occurring items.” Your response should include excerpts from your earnings calls. Finally, provide us with samples of analyst reports for 2007, 2008 and 2009 and be sure to provide samples from the quarters that were most relevant to the $2.2 million adjustment. As appropriate, please respond to our comm ent within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your response to our comment and provides any requeste d information. Detailed letters greatly facilitate our review. Please understand th at we may have additional comments after reviewing your response to our comment.
You may contact Howard Efron, Staff Accountant, at (202) 551-3439 or me at (202) 551-3295 if you have questions regard ing comments on the financial statements and related matters. S i n c e r e l y , Jennifer Monick Senior Staff Accountant
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Mail Stop 3010 June 3, 2010 Mr. David N. Walker Chief Financial Officer Maximus, Inc. 11419 Sunset Hills Road Reston, VA 20190 Re: Maximus, Inc. Form 10-K for the fiscal year ended September 30, 2009 File No. 1-12997 Dear Mr. Walker: We have reviewed your first response letter filed on May 19, 2010 and have the following additional comment. Where indi cated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inappl icable or a revision is unnecessary. Please be as detailed as necessary in your explan ation. In our comment, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we ma y or may not raise additional comments. Form 10-K for the fiscal year ended September 30, 2009 Financial Statements 13. Shareholders’ Equity, page 55 1. We note your response to prior comment three and request that you provide us with a more robust analysis of material ity related to the $2.2 million stock-based compensation charge recorded during the first quarter of fi scal 2008. In your response, please provide us with a thorough materiality analysis which is performed at the segment level and which addresses the impact to both income from continuing operations and net income. Additionally, help us to understand what you, your investors and analysts were focusing on during the earnings calls during 2007 and 2008. Please tell us if th e focus was on earnings including or Mr. Walker Maximus, Inc. June 3, 2010 Page 2 excluding these “unusual and infrequently occurring items.” Your response should include excerpts from your earnings calls. Finally, provide us with samples of analyst reports for 2007, 2008 and 2009 and be sure to provide samples from the quarters that were most relevant to the $2.2 million adjustment. As appropriate, please respond to our comm ent within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your response to our comment and provides any requeste d information. Detailed letters greatly facilitate our review. Please understand th at we may have additional comments after reviewing your response to our comment. You may contact Howard Efron, Staff Accountant, at (202) 551-3439 or me at (202) 551-3295 if you have questions regard ing comments on the financial statements and related matters. S i n c e r e l y , Jennifer Monick Senior Staff Accountant