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UPLOAD Filing

Surgery Partners, Inc.
Date: July 10, 2025 · CIK: 0001638833 · Accession: 0000000000-25-007251

Financial Reporting Revenue Recognition Regulatory Compliance

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File numbers found in text: 001-37576

Referenced dates: July 8, 2025

Date
July 10, 2025
Author
Services
Form
UPLOAD
Company
Surgery Partners, Inc.

Letter

Re: Surgery Partners, Inc. Form 10-K for Fiscal Year Ended December 31, 2024 Response Letter Dated July 8, 2025 File No. 001-37576 Dear David T. Doherty:

July 10, 2025

David T. Doherty Executive Vice President and Chief Financial Officer Surgery Partners, Inc. 340 Seven Springs Way, Suite 600 Brentwood , Tennessee 37027

We have reviewed your July 8, 2025 response to our comment letter and have the following comment.

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 June 26, 2025 letter.

Form 10-K for Fiscal Year Ended December 31, 2024 9. Income Taxes, page F-26

1. We note your response to comment 2. With reference to your consolidated statements of operations, please help us better understand how you determined that you were in a cumulative 3-year pre-tax income position as of December 31, 2023 but a pre-tax loss position as of December 31, 2024. Also confirm that you will provide expanded disclosures to communicate to investors the facts and circumstances for the periods presented that support your accounting in future filings. Please contact Tracey Houser at 202-551-3736 or Nudrat Salik at 202-551-3692 if you have questions regarding comments on the financial statements and related matters. July 10, 2025 Page 2

Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services

Show Raw Text
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<TEXT>
 July 10, 2025

David T. Doherty
Executive Vice President and Chief Financial Officer
Surgery Partners, Inc.
340 Seven Springs Way, Suite 600
Brentwood , Tennessee 37027

 Re: Surgery Partners, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2024
 Response Letter Dated July 8, 2025
 File No. 001-37576
Dear David T. Doherty:

 We have reviewed your July 8, 2025 response to our comment letter and
have the
following comment.

 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 June 26,
2025 letter.

Form 10-K for Fiscal Year Ended December 31, 2024
9. Income Taxes, page F-26

1. We note your response to comment 2. With reference to your consolidated
statements
 of operations, please help us better understand how you determined that
you were in a
 cumulative 3-year pre-tax income position as of December 31, 2023 but a
pre-tax loss
 position as of December 31, 2024. Also confirm that you will provide
expanded
 disclosures to communicate to investors the facts and circumstances for
the periods
 presented that support your accounting in future filings.
 Please contact Tracey Houser at 202-551-3736 or Nudrat Salik at
202-551-3692 if
you have questions regarding comments on the financial statements and related
matters.
 July 10, 2025
Page 2

 Sincerely,

 Division of Corporation Finance
 Office of Industrial Applications and
 Services
</TEXT>
</DOCUMENT>