SecProbe.io

United States securities and exchange commission logo
May 16, 2024
James Cleary
Executive Vice President and Chief Financial Officer
Cencora, Inc.
1 West First Avenue
Conshohocken, PA 19428
Re:Cencora, Inc.
Form 10-K for Fiscal Year Ended September 30, 2023
Response Dated April 18, 2024
File No. 001-16671
Dear James Cleary:
            We have reviewed your April 18, 2024, response to our comment letter 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. Unless
we note otherwise, any references to prior comments are to comments in our April 5, 2024,
letter.
Form 10-K for Fiscal Year Ended September 30, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources
Cash Flows, page 38
1.Refer to your response to prior comment 2. From the example provided therein it remains
unclear the factors that caused the variance in operating cash flows between fiscal 2023
and 2022 and the extent of their effect. You cite an increase in revenue as a factor for the
increase in operating cash flows. Typically it is not the increase in the amount of revenue
reported in a period that affects operating cash flows but the amount of revenue collected
in the period that does. In this regard, we note the increased negative impact on operating
cash flows of accounts receivable of approximately $1.1 billion. In connection with this,
you did not address the variance in expenses on operating cash flows. Furthermore, it
appears the affect of revenues and expenses is covered by your cited factor of increased

 FirstName LastNameJames Cleary
 Comapany NameCencora, Inc.
 May 16, 2024 Page 2
 FirstName LastName
James Cleary
Cencora, Inc.
May 16, 2024
Page 2
net income plus non-cash expenses between the periods. Your example cites the positive
impact on fiscal 2023 operating cash flows of reduced opioid settlements of $252 million,
but we note offsetting negative impact on fiscal 2023 of increased income tax paid of
$218 million and interest paid of $52 million. Your example further cites net negative
working capital account balances increased in fiscal 2023 due to increased revenue, net of
the impact of the timing of cash receipts and disbursements, but the correlative effect of
these and reasoning for such is not clear. In this regard, we note the negative increase of
inventory in fiscal 2023 of $1.5 billion and positive increase of accounts payable in fiscal
2023 of $2.8 billion. Please further consider the guidance previously cited in identifying
material underlying factors that actually changed operating cash between periods.
            Please contact Patrick Kuhn at 202-551-3308 or Doug Jones at 202-551-3309 if you have
questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services