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[HRT Letterhead]

June 10, 2005

Mr. Steven Jacobs, Accounting Branch Chief

Mr. Josh Forgione, Staff Accountant

Division of Corporation Finance

United States Securities and Exchange Commission

450 Fifth Street N.W., Mail Stop 4561

Washington DC 20549

VIA:      Facsimile and EDGAR

Re:      Healthcare Realty Trust Incorporated

Dear Mr. Jacobs and Mr. Forgione:

This letter is intended to supplement our letter to you dated June 6, 2005. Healthcare Realty
Trust Incorporated (“Company”) has identified four accounting errors during the course of its 2004
audit that will result in restatements of its previously issued audited financial statements.

The purpose of this letter is to provide to you a thorough explanation of the restatements and to
describe in more detail the reasons for the delay in filing the Company’s restated financial
statements. In this letter, we will discuss each restatement matter and the remedial measures the
Company has since taken and expects to implement to reasonably assure that similar errors will not
occur in the future. Exhibit A, attached hereto, contains a summary quantification of the effects
of the restatements on the Company’s financial statements (except for a notes receivable matter
which is discussed below and is still being quantified).

RESTATEMENT MATTERS

The accounting errors concern the following:

    (a)
    Restricted stock measurement and amortization;

    (b)
    Capitalized costs on properties developed for one health system;

    (c)
    Accounts receivable related to four properties; and

    (d)
    Notes receivable.

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The accounting adjustments reduce net income in the prior periods but are expected to have the
effect of increasing net income in future periods. The Company described the first three of these
four restatements in Forms 8-K filed on March 23, 2005 and March 31, 2005. The restatements are
discussed below in the chronological order of their identification. Although not described in this
letter, the Company will also be restating its financial statements for discontinued operations, as
required by SFAS 144, which has no impact on net income.

With respect to the four accounting errors identified during the audit process with KPMG LLP
(“KPMG”) for the year 2004, the Company has concluded that it will make the appropriate adjustments
to the prior year financial statements. As a result of these restatement matters, the Company has
concluded that it has a material weakness in internal control and has since taken remedial action,
as described below, to reasonably assure that similar errors will not occur in the future.

(a) Restricted Stock Measurement and Amortization

This matter relates to an adjustment the Company had initially recognized and recorded in the third
quarter of 2004 as a cumulative adjustment to restricted stock amortization and deferred
compensation. Certain amendments, related to the retirement provisions in the employment
agreements of three executive officers that were effective as of January 1, 2000, impacted the
measurement dates and amortization periods related to restricted stock reserved for future release
to those officers.

Under the original employment agreements for executive officers entered into in 1993 and 1994, the
Company measured compensation expense on restricted stock awards when the awards were granted by
the compensation committee of the Board of Directors, and then amortized the deferred compensation
cost over the stated vesting period. The Company believes this accounting was correct from 1993
until the effective dates of the amendments described in the next paragraph.

After consultation between the Company and a compensation consultant, an amendment was made in late
1999 to the employment agreements of the Company’s three executive officers, effective January 1,
2000, that granted these officers rights to all shares reserved for issuance to them under the plan
upon achievement of retirement eligibility. Because of the officers’ economic disincentive to
retire prior to the vesting date (resulting from tax recognition of stock received), management
failed to realize that the amendment created a new measurement date and impacted the amortization
period. Therefore, the accounting department made no change to the established practice of
measuring deferred compensation expense when the restricted stock awards were actually granted by
the compensation committee, and then amortizing the resulting deferred compensation cost over the
stated vesting period.

Upon re-examination, following KPMG raising the issue, the Company determined that the employment
agreement amendments effective January 1, 2000 caused a new measurement date for all of the shares
reserved for issuance to these three officers under

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the plan as of January 1, 2000, and the deferred compensation expense should be amortized over the
shorter of the stated vesting period or the period between January 1, 2000 and the year when the
impacted officers achieve the age of 65.

As a result of the January 1, 2000 amendments, management subsequently concluded that the non-cash
amortization of restricted stock for those officers for the years ended December 31, 2000, 2001,
2002 and 2003 was understated by approximately $0.7 million, $0.5 million, $0.4 million and $0.7
million, respectively. Further, the Company concluded that the deferred compensation balance on
its balance sheet was understated by $3.4 million and the additional paid in capital balance was
understated by $4.6 million as of December 31, 2001, due to the change in the measurement dates and
the understatement of amortization expense. There was no impact to total stockholders’ equity as a
result of these adjustments.

During the third quarter of 2004, management concluded that these adjustments were not material to
prior or current years’ consolidated financial statements and, therefore, adjusted the balances
cumulatively in the third quarter. However, in light of the other restatements subsequently
identified and discussed herein, the Company concluded it would be appropriate to reverse the
cumulative adjustment recorded in the third quarter and to restate the prior periods for these
adjustments.

The Company understands that it failed to recognize that the amendments to the employment
agreements triggered a new measurement date of stock compensation under applicable accounting
literature. Throughout 2004, and in future years, all officer employment agreements and amendments
have been and will continue to be reviewed by senior accounting personnel for possible accounting
implications. Further, the accounting department has taken steps to ensure that all future
restricted stock awards are amortized over the shorter of the stated vesting period or the period
between the measurement date and the date when the officer achieves access to the shares based on
the officer’s employment agreement.

(b) Capitalized Costs on Properties Developed for One Health System

On February 25, 2005, KPMG raised an issue relating to the accounting for amounts that were
capitalized by the Company with respect to four construction projects initiated under agreements
with a sponsoring health system beginning in 2001. Under each agreement with this sponsoring
health system, the Company constructed and owns the building, and the sponsoring health system
ensures a minimum return to the Company on its aggregate investment basis in exchange for certain
rights of the sponsoring health system related to the use and occupancy of the buildings. The
costs at issue were referred to as “sponsor mobilization allowances” under the terms of the
agreements and were reimbursed to the sponsoring health system during the two-year lease-up phase
following completion of the core and shell of each building. The funds advanced as sponsor
mobilization allowances were made available upon receipt of invoices from the sponsoring health
system. In return, the agreements provided that the sponsor mobilization allowances paid by the
Company would increase the Company’s investment

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basis upon which the sponsor ensures a minimum return. Originally, the Company capitalized these
sponsor mobilization allowances as additional costs of the property under Statement of Financial
Accounting Standards No. 67, “Accounting for Costs and Initial Rental Operations of Real Estate
Projects” (“SFAS No. 67”).

KPMG questioned the capitalization of these costs and, upon re-examination, the Company concluded
that some of the costs reimbursed to the sponsor were not direct construction-related costs and,
therefore, were not capitalizable under SFAS No. 67. Therefore, the Company concluded that it
should reverse these capitalized costs against the revenue recorded by the Company related to the
sponsor.

The error related to a unique contractual obligation outside the normal process of cost
capitalization. In the typical process of cost capitalization, the Company maintains an effective
project accounting system for identifying and accounting for costs that are appropriately
capitalized to construction projects. These amounts are reviewed and updated quarterly.

This restatement, net of related depreciation, reduced real estate properties, net, and cumulative
net income by approximately $0.2 million at December 31, 2001, and reduced real estate assets, net,
income from continuing operations and net income by approximately $5.0 million and $3.3 million for
the years ended December 31, 2002 and 2003, respectively.

For 2005 and future years, the Company and the health system sponsor have agreed that the Company
will no longer fund this type of cost.

(c) Accounts Receivable Related to Four Properties

On or about March 4, 2005, KPMG raised an issue concerning the accounting for accounts receivable
related to four properties. The Company’s original accounting for these receivables was based, in
part, on the “successor debtor” rules outlined in Statement of Financial Accounting Standards No.
15, “Accounting by Debtors and Creditors for Troubled Debt Restructurings” (“SFAS No. 15”).

Upon re-examination, the Company concluded that the debtor did not meet the definition of a
troubled debtor under SFAS No. 15, and that it should also have evaluated the collectibility of the
receivables in light of two other accounting pronouncements, specifically Statements of Financial
Accounting Standards No. 114 and No. 5 (“SFAS No. 114 and No. 5”), in which case the Company should
have assessed collectibility based only upon the ability of the “original debtor,” not the
successor debtor, to repay. Because the collectibility of the receivables from the original debtor
was not assured, the Company should have reserved or written off the receivables in prior periods,
and will do so in the restatement.

These accounts receivable restatements will reduce other assets and cumulative net income by
approximately $7.2 million cumulatively as of December 31, 2001, and reduce

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(increase) other assets, income from continuing operations and net income by approximately $1.6
million and $(0.5) million for the years ended December 31, 2002 and 2003, respectively.

The Company has reviewed the population of all accounts receivable to ensure that any similar
receivables will be included in the restatement. To provide reasonable assurance that this error
will not recur in the future, when evaluating the collectibility of accounts receivable, the
Company has implemented an additional control that requires a senior corporate accountant to review
accounts receivable to determine whether SFAS No. 15 or SFAS No. 114 and No. 5 should apply.

(d) Notes Receivable

In late May 2005, KPMG raised an issue concerning the accounting for two notes receivable and two
related lease arrangements. The notes receivable and lease arrangements involve two skilled
nursing facilities leased to two affiliates of one operator since 2003. These transactions were
the result of a restructuring transaction whereby the Company acquired the two skilled nursing
facilities in early 2003 by deeds in lieu of foreclosure. The prior operator’s bankruptcy
necessitated that the Company locate or secure successor operators to lease the properties, because
REITs are not permitted to be in the business of operating skilled nursing facilities.
Concurrently, the Company entered into a working capital loan arrangement with the successor
operators to assist in the financial requirements of the restructured properties including the
consequences of a delay in reimbursement from Medicare and Medicaid. The working capital loan was
secured by a lockbox account arrangement whereby cash receipts from the properties were deposited
and remitted to the Company.

As cash receipts from the property were remitted to the Company, the Company and the tenant
acknowledged that the agreements should have included a method for the allocation of the cash
receipts between rent and repayment of the note. The parties discussed this matter and orally
agreed to an allocation which, in the Company’s judgment, would maintain the balance of the note at
a level, when combined with the Company’s investment in the property, that would be commensurate
with the property’s market value. The oral agreement was for the purpose of allocating cash
receipts between rent and the note receivable and created no additional financial exposure to the
Company or contingent liability for the Company. It operated as an amendment to the lease
agreement and the note so that a portion of cash receipts would be applied to the unpaid note
balance rather than recognized as rent. The Company acknowledges that the agreements should have
been amended to reflect the oral agreement and considers its failure to do so a deficiency in its
internal accounting control and is taking remedial action to correct the deficiency.

The Company originally accounted for these transactions as leases and notes in accordance with
their form. However, KPMG advised the Company on May 25, 2005 that it believed these transaction
structures amounted to variable interest entities, or “VIEs,” within the meaning of FIN 46R, which
may require the results of operations of

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the VIEs to be consolidated with the Company’s results of operations. The Company did not
originally consider these to be VIEs because the properties were on the books of the Company and
the Company was recording rental income and notes receivable. These transactions commenced in
April 2003, prior to the effective date of FIN46 and FIN46R.

Upon re-examination of the transaction, the Company has concluded that the transaction structures
should be deemed VIEs and will be restating its previously issued financial statements to
consolidate the operations of these entities.

At the time that these transactions occurred, the Company did not have a review process regarding
the accounting for these types of restructuring and property transactions. In connection with its
implementation of Section 404, the Company is establishing a review process for all arrangements of
this type, involving a restructuring or note receivable, which will be reviewed and approved by
senior corporate accounting personnel and the CFO to ensure that the accounting implications are
fully considered and the final arrangements are accounted for correctly. The Company is also
performing a review of its notes receivable and related leases to reach reasonable assurance that
any other similar arrangements are included in the restatement. With respect to the oral agreement
that was not reduced to writing, we believe our present documented control environment and the
ongoing testing of those controls ensure that, in the future, this type error will be avoided.

Concurrent with the assertion of this potential VIE issue, KPMG also informed the audit committee
on May 25, 2005 that, because of this most recent issue, it no longer had confidence in