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United States securities and exchange commission logo
July 22, 2022
Kirkland B. Andrews
Chief Financial Officer
Evergy, Inc.
1200 Main Street
Kansas City, Missouri 64105
Re: Evergy, Inc.
Form 10-K for the
Fiscal Year ended December 31, 2021
Filed February 25,
2022
File No. 001-38515
Dear Mr. Andrews:
We have reviewed your filing 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, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Executive Summary
Non-GAAP Measures, page 38
1. We note that you
identify several non-GAAP measures in your Executive Summary
though do not mention
Utility Gross Margin, which you also identify as a non-GAAP
measure for Evergy
Inc., Evergy Kansas Central, Inc., and Evergy Metro, Inc. in your
tabulations of
operating results on pages 45, 55,and 58. We see that you define the
measure on page 44 as
operating revenues less fuel and purchased power costs and
amounts billed by the
SPP for network transmission costs.
We also see that you
utilize these non-GAAP measures within MD&A in your analyses of
operating results.
Based on your disclosures, these measures appear to exclude amounts
that would be
attributable to a GAAP measure of cost of revenue, as would be reflected in
Kirkland B. Andrews
Evergy, Inc.
July 22, 2022
Page 2
a GAAP measure of gross margin. We believe that you should identify
gross margin as
the most comparable GAAP measure in providing the disclosures required
by Item
10(e)(1)(i)(A) and Item 10(e)(1)(i)(B) of Regulation S-K.
Please revise your Executive Summary to include disclosures that
encompass these non-
GAAP measures along with the most directly comparable GAAP-based
measures. Please
submit the revisions that you propose to address these prominence and
reconciliation
requirements, utilizing gross margin as the most comparable GAAP
measure.
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 Lily Dang at (202) 551-3867 or Mark Wojciechowski at
(202) 551-
3759 if you have questions regarding comments on the financial statements and
related
matters. Please contact Karl Hiller - Branch Chief at (202) 551-3686 with any
other questions.
FirstName LastNameKirkland B. Andrews Sincerely,
Comapany NameEvergy, Inc.
Division of
Corporation Finance
July 22, 2022 Page 2 Office of Energy &
Transportation
FirstName LastName