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May 6, 2020
Rick Poulton
President and Chief Financial Officer
Allscripts Healthcare Solutions, Inc.
222 Merchandise Mart Plaza , Suite 2024
Chicago , IL 60654
Re:Allscripts Healthcare Solutions, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed March 2, 2020
File No. 001-35547
Dear Mr. Poulton:
            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, 2019
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Provider
Year Ended December 31, 2019 Compared with the Year Ended December 31, 2018, page 49
1.Please elaborate on the nature of the "known attrition" within the EIS and other
businesses."  Disclose the nature of the attrition, the extent it is from contract cancellations
or modifications for lesser value, the financial impact of attrition on 2019 and future
periods, and the period of time over which you expect to recognize the remaining value of
the affected contracts (if any).  Refer to Item 303(a)(3) of Regulation S-K.
Veradigm
Year Ended December 31, 2019 Compared with the Year Ended December 31, 2018, page 50
2.We note Veradigm's revenue growth is due to an increase in organic sales.  In your

 FirstName LastNameRick Poulton
 Comapany NameAllscripts Healthcare Solutions, Inc.
 May 6, 2020 Page 2
 FirstName LastName
Rick Poulton
Allscripts Healthcare Solutions, Inc.
May 6, 2020
Page 2
earnings call, you indicated that "media buy drives a decent chunk of some of the
revenues."  In future filings, please discuss the nature of media buys and how they drive
Veradigm's organic sales.  Also, please disclose your revenue recognition policy for media
buys in the applicable note to the financial statements, if material.
Liquidity and Capital Resources , page 51
3.Please discuss your progress toward and the anticipated effects of your transition away
from LIBOR.  Further disclose whether your current credit facility provides for a
replacement rate.  Refer to https://www.sec.gov/news/public-statement/libor-transition.
            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 Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert
Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology