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March 12, 2024
Andrew Brophy
Principal Financial Officer
HEALTHCARE SERVICES GROUP INC
3220 Tillman Drive, Suite 300
Bensalem, PA 19020
Re:HEALTHCARE SERVICES GROUP INC
Item 2.02 Form 8-K filed February 14, 2024
File No. 000-12015
Dear Andrew Brophy:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
            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
the 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.
Item 2.02 Form 8-K filed February 14, 2024
Exhibit 99.1
Reconciliations of Non-GAAP Financial Measures, page 6
1.We have the following comments related to certain adjustments made to arrive at your
non-GAAP adjusted revenues, adjusted segment revenues, adjusted segment margins,
adjusted costs of services provided, adjusted selling, general and administrative expense,
adjusted net income, adjusted diluted earnings per share, and EBITDA excluding items
impacting comparability ("Adjusted EBITDA"):
•We note that client restructurings include changes to contracts with existing
customers for which the Company has either recorded a reduction to revenue or an
increase to bad debt expense due to clients entering bankruptcy, receivership, or out-
of-court workouts. We further note from disclosures in your Form 10-K that the
revenue portion of this adjustment relates to your adjustment to reflect the change in
estimate for price concessions based on new facts and circumstances related to a
client’s out-of-court restructuring. Such adjustment appears necessary to present your
revenues in accordance with GAAP. We also note a portion of this adjustment relates

 FirstName LastNameAndrew Brophy
 Comapany NameHEALTHCARE SERVICES GROUP INC
 March 12, 2024 Page 2
 FirstName LastName
Andrew Brophy
HEALTHCARE SERVICES GROUP INC
March 12, 2024
Page 2
to bad debt expense. In this regard, we note your risk factor indicating that the
Company has substantial investment in the creditworthiness and financial condition
of its customers as well as your cautionary statement regarding forward-looking
statements which addresses this risk and other risks arising from your providing
services to the healthcare industry and primarily providers of long-term care. As
such, this adjustment appears to relate to normal costs incurred to operate your
business. With reference to Questions 100.01 and 100.04 of the Compliance and
Disclosure Interpretations (“C&DIs”) on Non- GAAP Financial Measures, provide
your basis for these adjustments or confirm that you will no longer present them; and
•Your bad debt expense adjustments reflect the difference between GAAP bad debt
expense (CECL) and historical write-offs as a percentage of adjusted revenues. Your
self-insurance adjustments reflect changes in the accrued insurance claims liability
after considering your updated actuarial estimates for projected incurred losses on
past claims. Your gain/loss on deferred compensation adjustment, net represents the
changes in fair market value of investments held on behalf of the participating
employees. Each of these adjustments appear to result in tailored accounting
measures and therefore not consistent with Question 100.04 of the C&DIs. Please
advise or confirm you will no longer present these adjustments.
            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 Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services