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SEC Comment Letter for MAXIMUS, (MMS) — Mar 13, 2026

MAXIMUS, INC.
Date: March 13, 2026 · CIK: 0001032220 · Accession: 0000000000-26-002616

Financial Reporting Regulatory Compliance Revenue Recognition

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File numbers found in text: 001-12997

Date
March 13, 2026
Author
Division of
Form
UPLOAD
Company
MAXIMUS, INC.

Letter

Re: Maximus, Inc. Form 10-K for the Fiscal Year Ended September 30, 2025 Filed November 20, 2025 File No. 001-12997 Dear David W. Mutryn:

March 13, 2026

David W. Mutryn Chief Financial Officer Maximus, Inc. 1600 Tysons Boulevard McLean , Virginia 22102

We have limited our review of your filing to the financial statements and related disclosures and have the following comment(s).

Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.

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

Form 10-K for the Fiscal Year Ended September 30, 2025 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP and Other Measures, page 45

1. 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. 2. 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. March 13, 2026 Page 2

Notes to Consolidated Financial Statements Note 3: Business Segments, page 62

3. 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). 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.

Please contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at 202-551-3307 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Trade &
Services

Show Raw Text
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<TEXT>
 March 13, 2026

David W. Mutryn
Chief Financial Officer
Maximus, Inc.
1600 Tysons Boulevard
McLean , Virginia 22102

 Re: Maximus, Inc.
 Form 10-K for the Fiscal Year Ended September 30, 2025
 Filed November 20, 2025
 File No. 001-12997
Dear David W. Mutryn:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for the Fiscal Year Ended September 30, 2025
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Non-GAAP and Other Measures, page 45

1. 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.
2. 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.
 March 13, 2026
Page 2

Notes to Consolidated Financial Statements
Note 3: Business Segments, page 62

3. 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).
 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.

 Please contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at
202-551-3307
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
</TEXT>
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