December 20, 2024

Brian C. Evanko
Chief Financial Officer
The Cigna Group
900 Cottage Grove Road
Bloomfield, CT 06002

       Re: The Cigna Group
           Form 10-K for the Fiscal Year Ended December 31, 2023
           Form 10-Q for the Quarterly Period Ended June 30, 2024
           Response dated November 21, 2024
           File No. 001-38769
Dear Brian C. Evanko:

        We have reviewed your November 21, 2024 response to our comment letter
and have
the following comments.

       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 October
22, 2024 letter.

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
 December 20, 2024
Page 2

           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.

2.    We note your response to prior comment 6 regarding your aggregation of
U.S.
      Healthcare and International Healthcare operating segments. Please
address the
      following:
          Your response indicates the historical margins (i.e., pre-tax
adjusted income from
          operations divided by total adjusted revenues) for these operating
segments have
          ranged from the high single digits to the low double digits, and U.S.
Healthcare
          has generally performed at the higher end of that range relative to
International
          Health while management expects further margin convergence over the
long-
          term. Please provide us with the actual margins for each of these two
operating
          segments in historical periods presented in your financial statements
and explain
          how you analyzed the similarity of the long-term average margins,
including
          when you expect convergence to occur over the long-term. As part of
your
          response, please include your consideration of the implementation
guidance in
          ASC 280-10-55-7A.
          We also note your response indicates that variations in the financial
performance
          of the two operating segments are expected due to factors such as the
type of
          products offered, local regulatory capital requirements, and customer
location and
          demographics. In addition to the economic similarity, please explain
how you
          considered this variation in your analysis of the qualitative factors
in ASC 280-
          10-50-11a to 11e.
Segment Reporting, page 48

3.    We note on pages 48 and 49 that your Adjusted SG&A expense ratio by
segment is
      calculated using the applicable segment   s selling, general and
administrative expenses
      excluding certain special items. Please tell us whether you believe
Adjusted SG&A
      expense ratio by segment is a non-GAAP measure considering Question
104.03 of the
      C&DIs on Non-GAAP Financial Measures. Where applicable, include in your
future
      filings a reconciliation to the most directly comparable GAAP measure for
each non-
      GAAP measure and disclose the reasons why management believes such
non-GAAP
      measure provides useful information to investors required by Item 10(e)
of Regulation
      S-K.
 December 20, 2024
Page 3

       Please contact Mengyao Lu at 202-551-3471 or Robert Klein at
202-551-3847 if you
have questions regarding comments on the financial statements and related
matters.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Finance