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AMN HEALTHCARE SERVICES, INC.

2999 Olympus Boulevard, Suite 500

Dallas, TX 75019

December 11, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, NE

Washington, DC 20549

    Attn:
    Stephen Kim and Lyn Shenk

    RE:

    AMN Healthcare Services, Inc. Form 10-K for the Fiscal Year ended December
    31, 2023

    File No. 001-16753

Dear Mr. Kim and Ms. Shenk:

This letter sets forth
the response of AMN Healthcare Services, Inc. (the “Company,” “AMN,” “we” or “us”) to
the comment letter of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission
(the “Commission”), issued to the Company on November 12, 2024, with respect to the above-referenced Form 10-K for the fiscal
year ended December 31, 2023 (the “Form 10-K”).

For your convenience, the
Staff’s comments are set forth in bold, followed by responses by the Registrant.

Form 10-K for Fiscal Year Ended December 31, 2023

Management’s Discussion and Analysis of Financial Condition
and Results of Operations Results of Operations, page 26

 1. We note your response to prior comment 3 and your belief that changes
in metrics, rather than the absolutes of the metrics, are most relevant. To clarify, our prior comment sought quantification of the impact
on revenue of factors to which changes are attributed, rather than quantification of the underlying metrics themselves. As an example,
you attributed the change in nurse and allied solutions segment revenue to factors including changes in average number of travelers on
assignment, average bill rate, and billable hours. These factors pertain to changes in price and volume. Please supplement your disclosure
to quantify, in absolute dollars, the impact of factors to which changes are attributed, including changes in price, volume, and
acquisitions. Refer to Item 303(b)(2)(iii) of Regulation S-K.

Response:

The Company respectfully
acknowledges the Staff’s comment. In response to the Staff’s comment, the Company intends to revise its disclosures by quantifying,
in absolute dollars, the impact of factors to which changes in its metrics are attributed, including changes in price, volume, and acquisitions,
as applicable.

A sample of the Company’s
proposed disclosure revisions appear below for the information previously presented in the Form 10-K, with additions to the Company’s
existing disclosure shown in double underline and deletions
shown as strikethroughs.

Comparison of
Results for the Year Ended December 31, 2023 to the Year Ended December 31, 2022

Revenue.
Revenue decreased 28% to $3,789.3 million for 2023 from $5,243.2 million for 2022, attributable to a decline in revenue across
our segments with the greatest decline in our nurse and allied solutions segment.

Nurse and allied solutions
segment revenue decreased 34% to $2,624.5 million for 2023 from $3,982.5 million for 2022. The $1,357.9 million decrease was primarily
attributable to a $624.5 million decline driven by a 17% decrease
in the average number of travelers on assignment, a $560.7 million decline
driven by an approximately 15% decrease in the average bill rate, a
$120.1 million decline driven by a 3% decrease in billable hours during the year ended December 31, 2023, and an approximately
$99.0 million decrease in labor disruption revenue.

Physician and leadership
solutions segment revenue decreased 4% to $669.7 million for 2023 from $697.9 million for 2022. The $28.2 million decrease was attributable
to lower revenue in our interim leadership, physician permanent placement and executive search businesses, which was partially offset
by higher revenue in our locum tenens business. Revenue in our locum tenens business grew $36.7
million (or 9%) during 2023 primarily due to the
favorable impact of $42.2 million as a result of a 10% increase in the revenue per day filled on an organic basis and additional
revenue of $13.2 million in connection with the MSDR acquisition, partially offset by a $18.7
million decline driven by a 4% decrease in the number of days filled on an organic basis. OurAs
a result of declining demand, revenue in our interim leadership business experienced ana
decline of $47.9 million (or approximately 26% decline),
while our physician permanent placement and executive search businesses declined $17.0
million (or 20%) during 2023.

Technology and workforce
solutions segment revenue decreased 12% to $495.0 million for 2023 from $562.8 million for 2022. The $67.8 million decrease was primarily
attributable to a decline within our VMS business, partially offset by growth within our language services business. Revenue for our
VMS business declined $96.2 million (or 36%)
for similar reasons as nurse and allied solutions segment revenue, while our language services business grew $44.0
million (or 20%) primarily due to growth
of $52.1 million as a result of a 24% increase in minutes during 2023.

For 2023 and 2022,
revenue under our MSP arrangements comprised approximately 54% and 64% of our consolidated revenue, 72% and 81% for nurse and allied solutions
segment revenue, 20% and 18% for physician and leadership solutions segment revenue, and 2% and 2% of our technology and workforce solutions
segment revenue, respectively.

(j) Insurance Reserves, page 45

 2. We note your response to prior comment 5. You state you provide professional
liability coverage as part of your service offering to clients. You disclose in note (j) Insurance Reserves, that this expense in included
in selling, general, and administrative expenses in the statement of comprehensive income. Given that professional liability coverage
is part of your service offering to clients, please explain your basis for classifying the expense as SG&A rather than cost of revenue.

Response:

The Company respectfully
acknowledges the Staff’s comment.

As disclosed in the section
titled “Critical Accounting Policies and Estimates,” in Part II, Item 7 of the Form 10-K, the majority of the Company’s
accrual for professional liability consists of incurred but not yet reported (“IBNR”) losses. The IBNR losses represent cumulative
losses from professional liability claims since the occurrence date through the end of the reporting period, and are estimated based on
semi-annual actuarial studies obtained by the Company. Expense recognized for the Company’s accrual for professional liability,
inclusive of adjustments to the accrual based on each semi-annual actuarial study, was $5.5 million, $7.2 million and $7.2 million for
the years ended December 31, 2023, 2022 and 2021, respectively.

The average time between
the occurrence and final resolution of the Company’s professional liability claims is approximately 5 years. Therefore, the
ultimate settlement of the Company’s professional liability claims may vary significantly from the Company’s estimates
if future changes in claim frequency or severity differ from historical trends and actuarial assumptions. Such changes could have a
material effect on the Company’s consolidated financial condition or results of operations. This is different from expenses
for workers compensation for healthcare professionals, which is generally correlated to period payroll expense, and which the
Company therefore recognizes in cost of revenue. Classifying the expense recognized for the Company’s professional liability
accrual, inclusive of actuarial adjustments, as cost of revenue could cause noticeable fluctuations in the Company’s reported
gross margin that are not correlated to period revenue, particularly at the reportable segment level. In the Company’s view,
this presentation could also cause confusion among the Company’s investors and would not be aligned with the goals of cost of
sales by analogy to Accounting Standards Codification Topic 330, Inventory, and paragraph number QC4 of FASB Concept Statement No.
8, i.e., to (a) match costs to related revenues, (b) apply cost of sales treatment consistently across accounting periods,
and (c) create comparable financials that provide investors useful information.

The Company believes it
would not be representationally faithful of the underlying economics to recognize the expense for the Company’s professional
liability accrual (inclusive of actuarial adjustments) in gross margin due to the lack of correlation to period revenue. Therefore,
the Company has elected to classify the expense as selling, general and administrative expenses in the statement of comprehensive
income.

Notes to Consolidated Financial Statements

(k) Revenue Recognition, page 45

 3. We note your response to prior comment 6. You state you record revenue
on a gross basis with respect to both (a) direct staffing of locum tenens physicians, and (b) language services business’ utilization
of contract interpreters. We assume, based on your disclosure on page 2, that both of these categories of revenue are derived from non-employees.

Please provide us with your analysis
of principal versus agent considerations under ASC 606 for of these two categories, or non-employee portions thereof as applicable. In
your response, please tell us:

 · The specified goods or services
(as determined from the end consumer's perspective), including your consideration of the “distinct" guidance in paragraphs
25-19 to 25-22 if there are multiple specified goods or services

 · The relevant contractual
terms (rights and obligations) between you and both the end consumer and the other party involved in providing the specified goods or
services (i.e., the supplier)

 · Based solely on the definition
of control in paragraph 25-25 and the explanation of how control is obtained in paragraph 55-37A, your assessment of whether and how you
controlled the specified goods or services before transferred to the end consumer

 · If control was not clear
based on the above guidance and you required additional evidence to reach a control conclusion:

 o Your assessment of each of
the following indicators of control in paragraph 55-39 and all other relevant facts and circumstances:

 § Primary responsibility for
fulfillment

 § Inventory risk

 § Discretion in pricing

 o Your assessment of whether
and how evidence related to these indicators of control supported that you controlled the specified good or service before transferred
to the end consumer

If there are multiple specified goods or
services, provide the information in the third and fourth bullets separately for each specified good or service.

Response:

The Company respectfully
acknowledges the Staff’s comment.

In response to the first
portion of the Staff’s comment, we confirm that both categories of revenue (direct staffing of locum tenens physicians and language
services business’ utilization of contract interpreters) are derived from non-employee independent contractors.

Below, the Company has
provided its analysis of principal versus agent considerations applicable under ASC 606 for each category of revenue, with each paragraph
setting forth the Company’s response to each sequential bullet in the Staff’s comment above.

Direct Staffing of
Locum Tenens Physicians

The Company’s locum
tenens staffing services consist of providing the Company’s clients with professional services by locum tenens physicians on a temporary
assignment basis. An application of the “distinct” guidance in paragraphs 25-19 through 25-22 is not required as this does
not consist of multiple services.

The Company first contracts
with its clients to provide the temporary locum tenens staffing services, and subsequently contracts with the locum tenens physicians
who will perform the services. The locum tenens physicians are typically designated as independent contractors of the Company, as expressly
noted in the Company’s service contracts with its clients of the locum tenens services. The Company sources, credentials and contracts
directly with the locum tenens physicians as independent contractors in accordance with applicable legal requirements. Typically, the
Company’s clients are billed based on negotiated hourly rates for services provided by the locum tenens professionals. The Company
maintains separate obligations and contractual relationships with its clients and locum tenens physicians.

The Company contracts directly
with the locum tenens physicians upon matching them with open positions under client contracts, giving the Company control over the specified
services prior to transfer to the Company’s clients, in accordance with paragraph 25-25. Specifically, consistent with Example 46A
in paragraph 55-324E, the Company has the ability to direct the locum tenens physicians to provide the services on its behalf to clients
in accordance with paragraph 55-37A(b).

Accordingly, control by
the Company is clear based on the definition in paragraph 25-25 and guidance in paragraph 55-37A. However, even if the Company were required
to conduct a further analysis under paragraph 55-39, the factors in that section support that the Company acts as principal in the transaction
for revenue recognition purposes:

 · Contrary to a managed services
program (“MSP”) relationship that involves a third-party subcontractor, in the case of direct staffing of locums tenens physicians,
the Company is primarily responsible for fulfilling the promise to provide the locum tenens staffing services to its clients, which is
evidenced by the fact that the Company is responsible for resolving issues with clients related to the services provided; and

 · The Company has discretion in
establishing prices for its locum tenens staffing services to its clients and separately negotiates compensation arrangements with locum
tenens physicians.

The fact that the Company has mitigated its
inventory risk with respect to the service by contracting with locum tenens physicians after executing its contracts with its clients
does not preclude the Company from determining that it has obtained control of the service before transfer to its clients.

Given the foregoing factors,
the Company has concluded that it acts as a principal with respect to its direct staffing of locum tenens physicians.

Language Services Business’
Utilization of Contract Interpreters

The Company’s language
services business provides remote interpreting (“VRI”) and over-the-phone interpreting (“OPI”) services to the
Company’s clients for patient-provider interactions, with the ultimate objective of providing access to healthcare interpretation
services to providers of the Company’s clients. The management and scheduling of VRI and OPI services, along with the delivery of
interpretation services, are supported by the Company’s proprietary technology platforms, which enable real-time routing of video
and audio calls for the Company’s clients’ providers to connect directly with a medically qualified interpreter. VRI services
are accessible on any device and OPI services are similarly enabled by, and delivered along with, the technology platforms. In consideration
of the “distinct” guidance in paragraphs 25-19 through 25-22, the VRI and OPI services, which include the technology platforms,
along with the interpretation services are accounted for as a single, combined performance obligation as (a) the control of each promised
service transfers over the same period of time and (b) the pattern of transfer of control for each promised service is the same.

The Company contracts with
its clients to provide interpretation services, which define the price and scope of services. Separately, the Company supplements its
employee workforce of medically qualified interpreters by engaging third-party interpreters (“contract interpreters”) to provide
VRI and OPI services to its clients. Pursuant to the terms of the Company’s contracts with its contract interpreters, contract interpreters
must be available for video and audio calls to perform the in