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October 26, 2021
Michael Greiner
Senior Vice President and Chief Financial Officer
Avanos Medical, Inc.
5405 Windward Parkway
Alpharetta, Georgia 30004
Re:Avanos Medical, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2020
Filed February 19, 2021
File No. 001-36440
Dear Mr. Greiner:
            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 the Fiscal Year Ended December 31, 2020
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations and Related Information, page 20
1.We note there is no discussion of operating expense line items for each period in MD&A.
For example, selling and general expenses declined from $399.1 million to $332.6 million
from 2019 to 2020, but there is no discussion of the reason for this decrease. Please revise
your disclosure in future filings to comply with Item 303(b) of Regulation S-K, which sets
forth "where the financial statements reflect material changes from period-to-period in one
or more line items, including where material changes within a line item offset one another,
describe the underlying reasons for these material changes in quantitative and qualitative
terms."  Please provide us your intended revised disclosure.
2.We note you incurred $14.9 million, $56.3 million, and $9.2 million in post divestiture
transition charges for the past three years, related to your April 2018 divestiture.  Please

 FirstName LastNameMichael Greiner
 Comapany NameAvanos Medical, Inc.
 October 26, 2021 Page 2
 FirstName LastName
Michael Greiner
Avanos Medical, Inc.
October 26, 2021
Page 2
describe to us in greater detail the nature of the charges for each of the years and quantify
any significant components of the charges.  Revise your disclosure in future filings,
consistent with your response, as appropriate.
3.We note you discuss Adjusted Gross Profit for 2020 vs. 2019, but not Gross Profit
presented under GAAP for these periods.  We do not believe this presentation complies
with Item 10(e)(1)(i)(A) of Regulation S-K which requires a "a presentation, with equal or
greater prominence, of the most directly comparable financial measure or measures
calculated and presented in accordance with GAAP."  Please revise in future filings. As
part of your revised disclosures, describe the underlying reasons in quantitative and
qualitative terms, including further description and amounts related to the impact from
product mix, write-off of obsolete inventory and higher costs associated with COVID-19
efforts.
Item 8. Financial Statements and Supplementary Data
Revenue Recognition and Accounts Receivable, page 34
4.Please revise future filings to disclose qualitative and quantitative disclosure about the
significant judgments and changes in judgments, including inputs and assumptions,
related to your accounting for returns, rebates and incentives, as set forth in ASC 606-10-
50-1(b), 50-17, and 50-20.  Provide us your intended revised disclosure.
5.We note that you disaggregate revenue attributable to Chronic Care and Pain Management
in response to ASC 606-10-50-5.  To help us better understand the basis for your
presentation, please provide us the financial information (1) used to prepare the Fourth
Quarter 2020 Earnings Call presentation and (2) provided to your chief operating decision
maker to evaluate your 4th quarter and annual 2020 results.  In addition, please identify
for us the unprofitable lines of business in which exiting was initiated, as referred to on
page 19 and elsewhere.
            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 Michael Fay at 202-551-3812 or Brian Cascio, Accounting Branch
Chief, at 202-551-3676 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences