SecProbe.io

Mail Stop 3561
March 23 , 2016

Richard A. Montoni
Chief Executive Officer
MAXIMUS , Inc.
1891 Metro Center
Reston, VA 20190

Re: MAXIMUS, Inc.
 Form 10-K for Fiscal Year Ended September  30, 2015
Filed November 16, 2015
File No. 1-12997

Dear Mr. Montoni :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your r esponse.

After reviewing your response to these  comments, we may have additional comments.

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Summary of Consolidated Financial Results

1. Please pr ovide greater transparency of the underlying reasons for your organic growth in
revenues and profitability on a consolidated and segment basis  for each year presented .
Specifically describe in this discussion the drivers of your organic revenue growth (i. e.
sales to new customer s, increased sales to existing customers, new service and produ ct
offerings, and/or pricing).

2. We note that cost of sales is material to your results and varies between periods as a
percentage of revenues but you do not provide a direct discussion and analysis of this line
item.  Please revise your disclosure to provide a direct comparative discussi on and
analysis of these costs on a consolidated and segment basis for each year presented in
addition to your current disclosure that is in the context of gross profit  margin .  In doing

Richard A. Montoni
MAXIMUS, Inc.
March 23 , 2016
Page 2

 so, please disclose the material components of which these costs cons ist.  Your disclosure
should quantify and analyze the impact of each significant component of cost of sales that
caused this line item to materially vary between comparative periods, with explanation of
the associated underlying reasons.  This disclosure s hould be presented in a manner to
allow investors to discern the relative contribution of each component cited to the total
change in cost of sales.

3. Please revise your disclosure to provide a comparative discussion and analysis of selling,
general and a dministrative expenses on a consolidated  and segment basis for each year
presented .  Your disclosure should quantify and analyze the impact of each significant
component of selling, general and administrative expenses that caused this line item to
material ly vary between comparative periods, with explanation of the associated
underlying reasons.

Critical Accounting Policies and Estimates, page 33

4. We note your disclosure that changes in cost estimates related to cost -plus pricing
arrangements may result in significant changes to revenues.  P lease revise your disclosure
in future filings to discuss how accurate your estimates have been in the past, how much
the estimates have changed in the past and whether the estimates are reasonably likely to
change in the future, and provide an analysis of the sensit ivity of the cost estimates  to
change based on other outcomes that are reasonably likely to occur and would have a
material effect. Further, please provide similar disclosure with respect to performance -
based volume estimates to the extent changes in volume estimates are material.  Please
refer to the Commission Guidance Regarding Management´s Discussion and Analysis of
Financial Condition and Results of Operations, Release No 34 -48960.

Non-GAAP and other measures, page 35

5. In future filings please describe in greater detail why management believes that the
presentation of non -GAAP measures (including free cash flow, adjusted diluted earnings
per share, EBITA, Adjusted EBITDA) provides useful information to  investors regarding
your financial position and results of operations.  Please refer to paragraph (1)(i)(C) of
item 10(e) of Regulation S -K.  Please note that this comment also applies to filings on
Form 10 -Q and Form 8 -K that contain disclosure of non -GAAP financial measures.

Item 8. Financial Statements and Supplementary Data

6. Debt, page 58

6. We note your credit agreement requires you to comply with certain financial covenants
and other covenants including a maximum total leverage ratio and a minimum fixed
charge coverage ratio.  Please tell us whether the credit agreement covenants and/or othe r
provisions of the agreement restrict or limit your ability to pay dividends, and your

Richard A. Montoni
MAXIMUS, Inc.
March 23 , 2016
Page 3

 consideration of providing the disclosures required by Rule 4 -08(e)(1) and (2) of
Regulation S -X.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the co mpany
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Yolanda Guobadia at (202) 551 -3562 or me at (2 02) 551 -3344 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Michael Kennedy  at (202) 551 -3832 or Jennifer Lopez -Molina  at (202) 551 -3792 with
any other questions.

Sincerely,

 /s/ William H. Thompson

 William  H. Thompson
Accounting Branch Chief
Office of Consumer Products