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April 12, 2023
David Mutryn
Chief Financial Officer
Maximus, Inc.
1600 Tysons Boulevard
McLean, VA 22102
Re:Maximus, Inc.
Form 10-K for Fiscal Year Ended September 30, 2022
Filed November 22, 2022
File No. 001-12997
Dear David Mutryn:
            We have limited our review of your filing to the financial statements and related
disclosures and 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 business days by providing the requested
information or advise 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 response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended September 30, 2022
Risk Factors
If we fail to accurately estimate the factors upon which we base our contract pricing, we may
generate less profit ..., page 15
1.You disclose on page 16, "It is a challenge across the industry in how we estimate wage
inflation rates ..., particularly for fixed-price contracts."  In your CEO's remarks in the
company's earnings call on November 22, 2022, he stated your government contracts
typically include labor escalators of 2% to 3% but market conditions have led you to raise
wages in the 4% to 5% range that puts pressure on your margins.  Please update this risk
factor if recent inflationary pressures have materially impacted your operations and
financial results.  Consider incorporating the impact of wage inflation on your contract
pricing, and the profitability on your fixed-price and performance-based contracts.

 FirstName LastNameDavid Mutryn
 Comapany NameMaximus, Inc.
 April 12, 2023 Page 2
 FirstName LastName
David Mutryn
Maximus, Inc.
April 12, 2023
Page 2
Non-GAAP and Other Measures, page 37
2.You disclose here and in the Form 10-Q for the period ended December 31, 2022 your
Credit Agreement includes the defined term "Consolidated EBITDA" and calculation
of "Adjusted EBITDA" conforms to the Credit Agreement.  Please explain to us and
disclose how these measures relate to compliance with the Credit Agreement, including
any associated amounts or limits and actual or reasonably likely effects of compliance or
noncompliance.  Your current disclosure appears to be in the context of a non-GAAP
measure rather a material term of a material agreement that is material to investors'
understanding of your financial condition and/or liquidity.  Refer to Question 102.09 of
the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures for
reference.

3.In the second bullet on page 38 you state "The measure of Adjusted EBITA is a step in
calculating Adjusted EBITDA."  Please explain to us and in your disclosure what this
means.
4.In note 8 to the consolidated financial statements you disclose the terms of the Credit
Agreement.  However, we do not see any mention of "Consolidated EBITDA" or
"Adjusted EBITDA" in those terms.  If these measures are truly key terms of the Credit
Agreement, revise your disclosure in the notes to the financial statements in this regard.
Notes to Consolidated Financial Statements
Note 2. Significant Accounting Policies
Revenue Recognition, page 48
5.For your performance-based contract revenue in the Outside the U.S. Segment, you
disclose you have variable fees based on future outcomes.  You state payments occur over
several months based on future events for which you are required to estimate the outcome
fees ahead of their realization and collection and you recognize the estimated fee over the
period of delivery.  Please explain to us and disclose (i) whether the estimate of this
variable consideration is typically constrained and (ii) the methods, inputs and
assumptions you use in determining the transaction price, including estimating variable
consideration and assessing whether the estimate of the variable consideration is
constrained.  Refer to ASC 606-10-50-12.b and 20a and b.

 FirstName LastNameDavid Mutryn
 Comapany NameMaximus, Inc.
 April 12, 2023 Page 3
 FirstName LastName
David Mutryn
Maximus, Inc.
April 12, 2023
Page 3
            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 Robert Shapiro at 202-551-3273 or Doug Jones at 202-551-3309 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services