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THE CIGNA GROUP

900 Cottage Grove Road

Bloomfield, Connecticut 06002

VIA EDGAR

January 16, 2025

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Mengyao Lu and Robert Klein

RE: The Cigna Group

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

 Form 10-Q for the Quarterly Period Ended September 30, 2024

 Response dated November 21, 2024

 File No. 001-38769

Ladies and Gentlemen,

The Cigna Group (the "Company") submits this letter in response to the comments contained in the correspondence of the Staff (the "Staff") of the United States Securities and Exchange Commission (the "Commission"), dated December 20, 2024 (the "Comment Letter"), relating to the Form 10-K for the fiscal year ended December 31, 2023 (the "2023 Form 10-K"), Form 10-Q for the quarterly period ended September 30, 2024, and our prior response dated November 21, 2024.

For reference purposes, the text of the comments in the Comment Letter have been reproduced herein (in bold), with the Company's response below each numbered comment.

Form 10-Q for the Quarterly Period Ended September 30, 2024

Note 17 - Segment Information, page 32

1.We note your response to prior comment 6 that you considered the economic characteristics of the Pharmacy Benefits Services and Specialty and Care Services operating segments to be similar and that the aggregation meets the objective and basic principles of segment reporting under ASC 280. Please address the following points:

•Please elaborate how the aggregation of these two operating segments helps investors understand your performance and assess prospects for future cash flows. In doing so, please consider providing a balanced assessment of both supporting and contradicting evidence such as your communications with investors, industry reports or other analyses by users of your financial statements. For example, we note from the quarterly investor presentations in 2024 published on your website that your Specialty and Care Services growth ranged from 8% to 12%, while your Pharmacy Benefit Services growth ranged from 2% to 4%. We also note that in your earnings calls, management and analysts discussed the significant growth in your Specialty and Care Services on various occasions.

•Please provide us with the actual margins for each of these two operating segments in historical periods presented in your financial statements and further explain how you analyzed the similarity of the long-term average margins.

•Your response indicates that the historical margins as calculated as pre-tax adjusted income from operations divided by total adjusted revenues ranged from 3% to 5%. Please tell us how you considered the similarity of economic characteristics on both an absolute and relative basis and your basis for expecting the operating segments to exhibit similar long-term financial performance.

We acknowledge the Staff's comment requesting further elaboration. We considered both the economic similarities and differences in assessing the aggregation of the Pharmacy Benefit Services and the Specialty and Care Services operating segments. Management's expanded conclusions related to the operating segments' similar long-term financial performance

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expectations in accordance with ASC 280-10-50-11 and ASC 280-10-55-7A and how these determinations led to our decision to aggregate the two Evernorth Health Services ("Evernorth") operating segments into one reportable segment are detailed below.

How aggregating operating segments helps investors understand performance and assess future cash flow prospects

We believe that our decision to aggregate the Evernorth operating segments helps investors understand performance and assess future cash flow prospects based on the breadth and interaction of the products and services offered by these operating segments and the related value they bring to Evernorth's shared customer base. Evernorth's strategy is to go to market with a full suite of products and services that both (a) enables our customers to combine our products and services to create a comprehensive benefit offering designed to manage prescription drugs and provide independent and coordinated health solutions and capabilities and (b) addresses the needs of a shared customer base, ultimately benefiting both Evernorth operating segments. Evernorth's ability to deliver this broad array of healthcare services on both a standalone or combined basis between its two operating segments enables us to drive incremental growth.

The Pharmacy Benefits Services operating segment is comprised of our businesses that contribute steady, predictable growth, create value for our clients and customers by developing formularies, ensure adequate access to care and negotiate with pharmaceutical companies and pharmacies to bring down the cost of drugs. The Specialty and Care Services operating segment is comprised primarily of our emerging businesses in very attractive markets, which offer products and services designed to achieve cost savings and better health outcomes by working together as a complete solution that targets various points of the pharmaceutical supply and delivery chain to better control the overall cost of prescription drugs supported by related health products and services. The specific products and services offered and sold through these two operating segments may differ in design and execution but share the same ultimate goal of providing value to our Evernorth customers by helping achieve their health needs at a lower cost through an attractive product offering.

Management, investors, industry analysts and others assess growth opportunities and future cash flow prospects at the Evernorth Health Services reportable segment level. As noted in our 2024 quarterly investor presentations, our annual earnings growth expectations in Specialty and Care Services range from 8% to 12%, while earnings growth expectations in Pharmacy Benefit Services range from 2% to 4%. While the Specialty and Care Services segment is currently growing at a higher rate, these businesses are intrinsically symbiotic - growth in these two businesses is supported by the marketing of our products and services both individually and as a complete Evernorth product offering. We evaluate and underwrite the economics of new and renewal client opportunities at the aggregate Evernorth level, not at the individual operating segment level. The higher earnings growth of the Specialty and Care Services operating segment is driven, in part, by the customer base of the Pharmacy Benefit Services operating segment - as Pharmacy Benefit Services earnings grow, so too does Specialty and Care Services earnings.  For example, in 2023, nearly 60% of the specialty pharmacy services business revenue was generated by customers of the Pharmacy Benefit Services operating segment.

As noted above, our Pharmacy Benefit Services operating segment includes our more mature businesses, which is reflected in the lower earnings growth ranges. Our Specialty and Care Services includes our emerging businesses that have not reached full maturity and as a result are growing at a faster pace. The specialty and care industry overall is experiencing prolific growth, driven by significant advancements and the introduction of biosimilars as well as complex and high-cost new drugs to the market. Due to their higher price and rapid introduction, these changes have a larger impact on the specialty and care services industry than they do on the pharmacy benefit services industry, which is reflected in our growth rates. However, these market forces do impact both operating segments, as reflected in our growth projections for each of the operating segments, albeit with a larger impact on Specialty and Care Services. These facts align with the general principles of segment aggregation in line with the commentary set forth in ASC 280-10-55-7A, "In other words, if the segments do not currently have similar gross margins and sales trends but the economic characteristics and the other five criteria are met and the segments are expected to again have similar long-term average gross margins and sales trends, the two segments may be aggregated." The long-term growth rates for both Evernorth operating segments are expected to differ for the forecasted future, as Specialty and Care Services continues to grow and mature in part by leveraging the Pharmacy Benefit Services’ shared customer base.  The ability of each operating segment to leverage the complete suite of product and service offerings to drive their respective growth forecasts indicates these businesses are inherently similar, a position that has been recognized by the users of our financial statements as foundational to our business.

The following discussion points, which are used by the Company, industry analysts and investors to describe the economic value proposition and future cash flow prospects enhanced by the relationship between the two Evernorth Health Services operating segments, collectively further support aggregation:

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•Both segments have historically generated and are expected to continue to generate a similar annual pre-tax margin of 3-5%. As noted above, growth in both Evernorth operating segments is supported in part by the sale of products across a shared customer base as a complete product offering; growth in one business promotes the growth in the rest of our businesses. This element is further discussed below in response to the Staff’s comment.

•Industry reports have generally observed the ability of Evernorth to capitalize on future growth opportunities based on the dynamic product offerings of its two operating segments. Our ability to deliver a broad array of healthcare services on both a standalone or combined basis between our two Evernorth operating segments enables us to drive incremental growth. For instance, a leading investment bank noted, "the company has a broad array of healthcare services solutions under the Evernorth umbrella that can be delivered on a stand-alone basis or combined with other offerings to enable more integrated care management. We believe [Cigna's] ability to aggregate and integrate point solutions should streamline the purchasing process for employers while also enabling them to configure services offerings based on their unique needs – both of which could potentially drive incremental growth."

•Our sell-side analysts regularly produce financial models for our business based on Evernorth Health Services in total and most do not model Pharmacy Benefit Services and Specialty and Care Services separately. This further supports that analysts and investors assess the performance of the Evernorth business as one reportable segment. While many analysts separately discuss the operating segments to provide visibility into current growth targets, they generally assess performance at the reportable segment level largely due to the operating segments' similar products and customer base, as described above.

•As noted by management during our 2024 Investor Day and on our 2024 Q2 earnings call, we have deliberately built a balanced portfolio across the Evernorth platform. About half of Evernorth's pre-tax adjusted income from operations is comprised of our pharmacy benefits capabilities and about half is specialty and care services. With respect to Evernorth's growth opportunities, Evernorth serves a balanced portfolio of clients, including employers, health plans, health systems, and pharmacy benefits organizations. Evernorth's go-to-market strategy is to market the full suite of pharmacy benefit solutions, including products and services from both operating segments. This strategy is further supported by the significant growth in the Specialty and Care Services business that has been driven in part by our Pharmacy Benefits Services clients electing to use Evernorth's specialty and care capabilities.

•In line with the factors outlined above, in our 2024 Investor Day presentation, the key differentiators mentioned for both the Pharmacy Benefit Services and Specialty and Care Services operating segments were clinical expertise as well as supply chain strategy initiatives such as owned operational assets and capabilities and supply chain excellence.

As outlined above, the users of our financial statements and other materials regularly view our Evernorth operations as one reportable segment. We note there are differences between the operating segments that we do discuss in certain external contexts, such as the differing earnings growth rates. ASC 280-10-55-7C indicates that "evaluating similar economic characteristics is a matter of judgement that depends on specific facts and circumstances." In assessing the criteria for aggregation as noted in our previous response to the Staff, we believe that the similar margins along with the structure, nature and manner in which these businesses operate indicate that these businesses are fundamentally similar. Management concluded that aggregating the Pharmacy Benefits Services and Specialty and Care Services operating segments into a reportable segment was consistent with the objectives and basic principles of ASC 280 as well the operating segments' economic and other qualitative similarities indicated in ASC 280-10-50-11.

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Operating Segment Pre-Tax Margin

Pre-tax margin is a key metric used by our chief operating decision maker in assessing each operating segment's performance and is calculated as pre-tax adjusted income from operations divided by total adjusted revenues. Actual historical margins for the Pharmacy Benefits Services and Specialty and Care Services operating segments for the periods presented in the 2023 Form 10-K and Form 10-Q's for the quarterly periods ended March 31, June 30, and September 30, 2024 were as follows:

For one of the periods presented, the Pharmacy Benefit Services margin fell outside of the 3-5% range. However, as described in the Form 10-Q for the quarterly period ended March 31, 2024, this was due to a one-time event (planned investments related to the onboarding of new clients, including one significant new client) and does not change our expectations for longer term projected margins for this operating segment. For all remaining periods presented, the margins for both operating segments were in the 3-5% range.

As shown in the graph above, the absolute historical pre-tax margins of the two Evernorth operating segments were within 1% of each other, which we do not believe is a significant difference. The margins were reflective of the codependency and the similar nature of the products and services between the two operating segments. On a relative basis (calculated as the absolute difference between segment margins divided by the margin for the Pharmacy Benefit Services operating segment for each period in the graph above) excluding the first quarter of 2024 for the factor cited in the paragraph above, margins varied in the range of 3% to 19%. For narrow margin businesses like these, a small absolute difference (1% or less) creates a large relative difference that we do not view as meaningful. Additionally, over the time periods presented in the chart above the Pharmacy Benefit Services average margin was 3.6% and the Specialty and Care Services average margin was 3.8%, which are very similar on both an absolute and relative basis. We continue to believe these margins demonstrate that the operating segments are economically similar, and that aggregation of the operating segments is appropriate.

Similarity of economic characteristics

We assess the performance of both Evernorth operating segments by reviewing the same key financial measures and operational factors, including volume, mix of claims, price, contract affordability services, customer, and