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CORRESP
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CORRESP

Evergy, Inc.

1200 Main Street

Kansas City, MO 64105

 May 17, 2024

 VIA
EDGAR

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 Office of Energy &
Transportation

 100 F Street, N.E.

 Washington, D.C. 20549

Attn:
 Jenifer Gallagher

Yong Kim

RE:
 Evergy, Inc.

Form 10-K for the Fiscal Year ended December 31, 2023

Filed February 29, 2024

File No. 001-38515

To the Staff of the Division of Corporation Finance:

The following is the response of Evergy, Inc. (the “Company” or “Evergy”) to the letter of the staff (the
“Staff”) of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Commission”), dated May 3, 2024 (the “Comment Letter”), concerning the Company’s Form 10-K for the fiscal year ended December 31, 2023, filed with the Commission on February 29, 2024.

To assist in your review, the Staff’s comment is repeated below in bold face type with the Company’s response set forth immediately
following.

 Form 10-K for the Fiscal Year ended December 31, 2023

Management’s Discussion and Analysis of Financial Condition and Results of Operations Adjusted Earnings
(non-GAAP) and Adjusted EPS (non-GAAP), page 38

1.
 We understand from your disclosure in Note 4 on page 104 that in connection with settling various issues
with the Kansas Corporation Commission during 2023, you agreed to return $96.5 million to customers of Evergy Kansas Central over a three year period, and that you accounted for the matter by recognizing a regulatory liability and a reduction
in revenues in corresponding amounts. In Note 2 on page 99, you refer to a similar accounting event in 2022 regarding Sibley Station, involving a rate case amended final order to return $68.0 million to customers of Evergy Missouri West over a
four-year period, although disclosures on pages 108 and 110 indicate the regulatory liability was $108.0 million, while disclosure on page 40 indicates it was $51.4 million.

We note that your reconciliation shows that in compiling your non-GAAP Adjusted Earnings measure
you have adjustments pertaining to each of these matters, including an add-back of $96.5 million to net income for 2023, and an add-back of $51.4 million to
net income in 2022, both of which appear to effectively reverse the accounting that was required and applied under generally accepted accounting principles.

 1

 Evergy, Inc.

1200 Main Street

 Kansas City, MO
64105

 You explain that you believe the resulting measure provides a meaningful basis
for evaluating operations because it excludes items that you do not believe are indicative of your ongoing performance, or that have created earnings volatility. However, you do not explain how excluding the adverse effects of these
economic accounting events in compiling your non-GAAP performance measure would yield a measure that could be fairly characterized as providing a meaningful basis for evaluating operations.

As the funds will be returned to customers over several future periods, it is also unclear how you would fairly characterize recognition of
the adverse effects as not indicative of your ongoing performance, or how you would otherwise advise investors of the adverse effects in such future periods. For example, we note that you have not included an adjustment in compiling the 2023 non-GAAP measure for any portion of the reduction to the regulatory liability pertaining to Sibley Station. We also note that you have not provided commentary regarding earlier disclosures of the non-GAAP measures that reflected the favorable effects of the revenues that have now been reversed.

Given that these adjustments appear to effectively change the recognition and measurement principles that are required to be applied under
generally accepted accounting principles, unless you are able to show how these would not be contrary to the guidance in the answer to Question 100.04 of our Compliance & Disclosure Interpretations regarding
non-GAAP measures, it appears that you would need to amend your filing to revise your computations of the non-GAAP measures. You may view this guidance at:
https://www.sec.gov/corpfin/ non-gaap-financial-measures.htm.

 Please also revise your
disclosures on pages 38, 47, and 58 that characterize recognition of the $96.5 million regulatory liability as a “deferral of revenues” to utilize terminology or descriptions that are representationally faithful of this accounting
event.

 The Company respectfully acknowledges the Staff’s comment regarding its
non-Generally Accepted Accounting Principles (“GAAP”) adjustments of $96.5 million in 2023 related to its Corporate-Owned Life Insurance (“COLI”) program and $51.4 million in 2022
related to the Sibley Station retirement. Accordingly, the Company has organized its response to the Staff in the following order:

a.
 Background Information

b.
 Why the Company’s non-GAAP adjustments for the COLI program and
the Sibley Station retirement presented within Evergy’s Form 10-K for the fiscal year ended December 31, 2023, are appropriate, including sections denoting:

i.
 Why excluding amounts associated with the COLI program and the Sibley Station retirement refunds in
compiling the Company’s non-GAAP Adjusted Earnings measure provides a meaningful basis for evaluating its ongoing operations;

ii.
 Why the Company’s non-GAAP adjustments for the COLI program and
the Sibley Station retirement refunds do not change the recognition and measurement principles required under GAAP and are not contrary to the guidance in Question 100.04 of the Commission’s Compliance & Disclosure Interpretations
(“C&DIs”); and

 2

 Evergy, Inc.

1200 Main Street

 Kansas City, MO
64105

iii.
 Why the Company is not including any non-GAAP adjustments for the
COLI program and the Sibley Station retirement refunds in future periods as customer rate refunds begin.

c.
 The Company’s agreement with the Staff’s comment regarding the “deferral of revenues”
terminology

a.
 Background Information

Regulated Operations Accounting: The Company’s regulatory liabilities for the COLI program and the Sibley Station
retirement were both recognized in accordance with ASC 980-405-25-1(a) and ASC 450-20-25-2. The recognition of both regulatory liabilities resulted in a corresponding reduction to revenues in the applicable current periods because both regulatory
liabilities were related to revenues previously collected from customers both in the applicable current and prior periods. The subsequent reduction of these regulatory liabilities, when the amounts are refunded to customers in rates, does not affect
future earnings.

 COLI Program: The COLI program was initiated in the
mid-1980’s following the inclusion of Wolf Creek Nuclear Generating Station (“Wolf Creek”) in Evergy Kansas Central, Inc’s (“Evergy Kansas Central”) retail rates. Evergy Kansas
Central is a wholly-owned subsidiary of Evergy. The COLI program was designed to generate income that would reduce the impacts to customer rates related to the construction of Wolf Creek. The reduction to customer rates under this program was
accomplished through the establishment of agreed-upon annual reductions to Evergy Kansas Central’s revenue requirement to be charged to customers (“COLI rate credits”), throughout the life of the COLI program.

In April 2023, Evergy Kansas Central filed a rate case application with the Kansas Corporation Commission (“KCC”). Evergy Kansas
Central’s request included a proposed resolution to terminate the COLI program. In September 2023, Evergy Kansas Central, KCC staff and other intervenors reached a unanimous settlement agreement to settle all rate case issues, including the
termination of the COLI program. The settlement agreement included a refund to Evergy Kansas Central customers of $96.5 million by reducing customer rates over the three year period 2024-2026 to account for the difference between the originally
expected cumulative amount of COLI rate credits approved at the inception of the COLI program and the actual amount of COLI rate credits received by customers from 1987 through December 31, 2023. As a result of the settlement agreement, Evergy
Kansas Central recorded a $96.5 million regulatory liability with a corresponding reduction to revenues in 2023 for the obligation to refund amounts of revenues previously collected from customers related to the COLI program.

Sibley Station Retirement: In November 2018, Evergy Missouri West, Inc. (“Evergy Missouri West”), a wholly-owned
subsidiary of Evergy, retired Sibley Station, a coal-fired generating station. Subsequent to Sibley Station’s retirement, Evergy Missouri West continued to collect amounts in rates from customers for Sibley Station related to (i) non-fuel operation and maintenance costs and other costs, and (ii) return on investment. In October 2019, the Public Service Commission of the State of Missouri (“MPSC”) issued an Accounting
Authority Order (“AAO”) requiring Evergy Missouri West to record as a regulatory liability the amounts in rates from customers for Sibley Station related to (i) non-fuel operation and
maintenance costs and other costs, and (ii) return on investment. After receiving the AAO in 2019, Evergy Missouri West recorded a Sibley Station regulatory liability for non-fuel operations and
maintenance costs and other costs still being collected in rates from customers with a corresponding reduction to revenues as Evergy Missouri West determined them to be probable of refund since these costs

 3

 Evergy, Inc.

1200 Main Street

 Kansas City, MO
64105

 were no longer being incurred by the Company. Evergy Missouri West, however, did not at that
time record a regulatory liability for amounts collected in rates for the return on investment component of Sibley Station still being collected in rates from customers as it determined that the return on investment was not probable of refund
because (i) the retirement of Sibley Station was prudent and economically beneficial to ratepayers, (ii) the Sibley Station AAO did not prescribe customer rate treatment for the return on investment component (only that it needed to be
separately tracked for future MPSC regulatory determination), and (iii) there was no prior regulatory precedent for the refund of return on investment revenues associated with a retired generating station in Missouri.

In 2022, the MPSC issued an amended final rate order settling the treatment of Evergy Missouri West’s unrecovered investment in Sibley
Station. The order required Evergy Missouri West to refund to customers, over the years 2023-2026, the revenues collected related to both non-fuel operations and maintenance costs and other costs as well as
the return on investment associated with Sibley Station following its retirement.

 As a result of the 2022 amended final rate order, in
2022, Evergy Missouri West recorded a $68.0 million reduction to operating revenues and a corresponding increase to its Sibley Station regulatory liability for revenues collected from customers for return on investment in Sibley Station since
December 2018. Within the 2022 amended final rate order, the MPSC agreed with Evergy Missouri West’s regulatory liability balance for non-fuel operations and maintenance costs and other costs and as such,
no additional reduction to operating revenues was recorded in 2022 related to these amounts apart from what Evergy Missouri West had already recognized for amounts collected in rates.

In order to aid the Staff’s understanding of the amount of the Company’s non-GAAP adjustment
for the Sibley Station return on investment refund on page 40 of Evergy’s Form 10-K and to reconcile that amount with other related figures that appear on pages 99, 108 and 110 of Evergy’s Form 10-K, please see the following table:

 Sibley Station
Retirement

Year of
Recognition
(Regulatory
Liability)

Regulatory
Liability
Balance
(12/31/2022)

2022
Earnings
Impact(a)(b)
(Pre-Tax)

(millions)

 Return on Investment

2022

$
68.0

$
51.4

 Non-Fuel Operations and Maintenance Costs and Other
Costs

2019 - 2022

40.0

— 

 Total

$
108.0

$
51.4

a
 The $51.4 million earnings impact for return on investment consists of the $68.0 million reduction to
revenues for recognition of a regulatory liability for amounts collected from customers since December 2018 for return on investment in Sibley Station less the $16.6 million of revenues from customers recognized in 2022 for return on
investment.

b
 The non-fuel operations and maintenance costs and other costs item does
not have a 2022 earnings impact because the revenues from customers were offset by the concurrent reduction to revenues of an equal amount for recognition of a regulatory liability.

Computation of the Company’s non-GAAP adjustments for the COLI Program and the
Sibley Station Retirement: The non-GAAP adjustment amount of $96.5 million in 2023 related to the refund of amounts for the COLI program is the earnings impact included
in the Company’s 2023 GAAP earnings. The non-GAAP adjustment of $51.4 million in 2022 related to the refund of amounts for the Sibley Station retirement is the earnings impact included in the
Company’s 2022 GAAP earnings. These amounts were recorded in accordance with GAAP and excluded from the GAAP amount of earnings and Earnings Per Share (“EPS”) to determine the Company’s
non-GAAP measure of Adjusted Earnings and Adjusted EPS.

 4

 Evergy, Inc.

1200 Main Street

 Kansas City, MO
64105

 The adjustment for the Sibley Station retirement was inclusive of both the positive impact of
the revenues from customers in addition to the negative impact of the reduction to revenues recorded for the initial accrual of the regulatory liability for future refund to customers and was consistently applied for all periods presented for
Adjusted Earnings and Adjusted EPS. The Company would respectfully refer the Staff to page 40 of its Form 10-K for the fiscal year ended December 31, 2022, where it adjusted out the $12.4 million
positive impact of revenues collected from customers for Sibley Station’s return on investment in its calculation of 2021 Adjusted Earnings and Adjusted EPS.

Regarding the Company’s calculation of its non-GAAP adjustment of the COLI program refund, the
Company did not adjust out the impact of revenues from customers in 2023 and 2022 related to the COLI program. The impact to 2023 and 2022 Adjusted Earnings and Adjusted EPS would have been $2.7 million (or $0.01 per share) and
$1.9 million (or $0.01 per share), respectively. These amounts represent less than 1% of 2023 and 2022 Adjusted Earnings and Adjusted EPS of $815.6 million ($3.54 per share) and $853.8 million ($3.71 per share), respectively, and are
immaterial to the relevant interim and annual periods.

b.
 Why the Company’s non-GAAP adjustments for the COLI program
and the Sibley Station retirement presented within Evergy’s Form 10-K for the fiscal year ended December 31, 2023, are appropriate, including sections denoting:

i.
 Why excluding amounts associated with the COLI program and the Sibley Station retirement refunds in
compiling the Company’s non-GAAP Adjusted Earnings measure provides a meaningful basis for evaluating its ongoing operations In response to the Staff’s comment regarding “you do not
explain how excluding the adverse effects of these economic accounting events in compiling your non-GAAP performance measure would yield a measure that could be fairly characterized as providing a meaningful
basis for evaluating operations”, the Company believes its current non-GAAP presentation is useful and relevant as it is aligned with how operating results are reviewed, both internally by management
and the board of directors and externally by lenders and investors, and because it assists investors with their evaluation of the Company’s earnings on an ongoing basis. To provide a useful and relevant
non-GAAP presentation of Adjusted Earnings and Ad