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April 26, 2024
Kenneth McGrath
Chief Financial Officer
ORASURE TECHNOLOGIES INC
220 East First Street
Bethlehem, Pennsylvania 18015
Re:ORASURE TECHNOLOGIES INC
Form 10-K filed March 11, 2024
Item 2.02 Form 8-K filed February 27, 2024
Response filed April 10, 2024
File No. 001-16537
Dear Kenneth McGrath:
            We have reviewed your April 10, 2024 response to our comment letter and have the
following comments.
            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. Unless
we note otherwise, any references to prior comments are to comments in our March 20,
2024 letter.
Item 2.02 Form 8-K filed February 27, 2024
Exhibit 99.1
Orasure Technologies GAAP to Non-GAAP Reconcilation, page 10
1.We note your response to prior comment 2. The underlying facts and circumstances that
lead to the inventory reserve adjustments, including your decision to terminate the
manufacturing of your Covid-19 products in Thailand, do not appear to be outside the
normal course of your operations. With reference to Question 100.01 of the Compliance
and Disclosure Interpretations for Non-GAAP Financial Measures, please confirm that
you will no longer exclude these inventory impairments from your non-GAAP measures.

2.We note that you include an adjustment for accelerated depreciation in your determination
of non-GAAP cost of goods sold, gross margin, operating income, net income (loss) and

 FirstName LastNameKenneth McGrath
 Comapany NameORASURE TECHNOLOGIES INC
 April 26, 2024 Page 2
 FirstName LastName
Kenneth McGrath
ORASURE TECHNOLOGIES INC
April 26, 2024
Page 2
earnings (loss) per share. Confirm that you will no longer exclude accelerated depreciation
from your non-GAAP measures. While the useful lives of the machinery and equipment
utilized for InteliSwab® production in Thailand were shortened, the assets continued to
contribute to revenue generation through the end of their useful lives.
            Please contact Jeanne Baker at 202-551-3691 or Al Pavot at 202-551-3738 if you have
questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services