United States securities and exchange commission logo
April 5, 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
File No. 001-16671
Dear James Cleary:
We have limited our review of your filing to the financial
statements and related
disclosures 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.
Form 10-K for Fiscal Year Ended September 30, 2023
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations
Fiscal Year Ended September 30, 2023 compared to the Fiscal Year Ended
September 30, 2022,
page 31
1. So investors have a
better understanding of the relative impact of each of the factors
listed, please quantify
all material individual factors cited. For example, you disclose
without quantification
that revenue in International Healthcare Solutions increased from
the prior fiscal year
due to increased sales at Alliance Healthcare, increased revenue from
[y]our
less-than-wholly-owned Brazil full-line distribution business, incremental
revenue
from [y]our January
2023 acquisition of PharmaLex, and increased sales at [y]our
Canadian business, and
these increases were offset in part due to the June 2022 divestiture
of [y]our Brazil
specialty business. You also disclose [y]our European distribution
business' revenue in
the current fiscal year was negatively impacted by unfavorable
foreign currency
exchange rates in comparison to the prior fiscal year without
quantification. Refer
to Item 303(b) of Regulation S-K and section III.D of Release No.
James Cleary
Cencora, Inc.
April 5, 2024
Page 2
33-6835 for guidance.
Liquidity and Capital Resources
Cash Flows, page 38
2. The reported amount of net cash provided by operating activities
increased $1.2 billion, or
approximately 45%, in fiscal 2023 compared to fiscal 2022. Please
provide an analysis of
the reason(s) for this variance. Refer to item 303(b) regarding
analysis of material
changes in line items from period to period. Also refer to the
introductory paragraph of
section IV.B and B.1 of Release No. 33-8350 for guidance regarding the
content of the
analysis. For example, when preparing the discussion and analysis of
operating cash
flows, address material changes in the underlying drivers (e.g., cash
receipts from the sale
of goods and services and cash payments to acquire materials for
manufacture or goods
for resale) rather than merely describe items identified on the face
of the statement of cash
flows, such as the reconciling items used in the indirect method of
presenting cash flows.
Notes to Consolidated Financial Statements
Note 2. Acquisitions and Equity Method Investment
PharmaLex Acquisition, page 59
3. In several areas in MD&A you disclose the acquisition of Pharmalex
impacted your
results. Regarding this acquisition, please tell us of your
consideration of providing the
disclosures required by ASC 805-10-50-2(h) as well as 2(f).
Note 15. Business Segment Information, page 78
4. Please disclose total assets for each of your reportable segments
pursuant to ASC 280-10-
50-2.
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.
Please contact Patrick Kuhn at 202-551-3308 or Doug Jones at
202-551-3309 with any
questions.
FirstName LastNameJames Cleary Sincerely,
Comapany NameCencora, Inc.
Division of
Corporation Finance
April 5, 2024 Page 2 Office of Trade
& Services
FirstName LastName