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CORRESP
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CORRESP

 November 21, 2023

 VIA
EDGAR

 United States Securities and Exchange

 Commission
Division of Corporate Finance

 Office of Real Estate and Construction

100 F Street, NE

 Washington, D.C. 20549

Attn: Ms. Jennifer Monick

 Mr. Mark
Rakip

Re:
 Medical Properties Trust, Inc.

MPT Operating Partnership, L.P.

Form 10-K for the Year Ended December 31, 2022

File No. 001-32559

 Dear Ms. Monick
and Mr. Rakip:

 This letter is being furnished in response to the comments of the Staff (the “Staff”) of the Securities and Exchange
Commission in connection with the Commission’s comment letter dated November 7, 2023 to R. Steven Hamner, Executive Vice President and Chief Financial Officer of Medical Properties Trust, Inc. (the “Company”) with respect to the
Company’s Form 10-K for the Year Ended December 31, 2022. To assist you in reviewing our responses, we have preceded each response below with a copy (in bold type) of the Staff’s comment as
stated in your letter.

 Form 10-K for the Year Ended December 31, 2022

Significant Tenants

 Total Assets by
Operator, page 13

1.
 We note your response to our prior comment 1 wherein you stated that at December 31, 2022, total assets
of your top five operators are generally comprised of real estate assets, mortgage loans, investments in unconsolidated real estate joint ventures, investments in unconsolidated operating entities, and other loans. We note your inclusion of a table
labeled total assets by operator on page 21 of your Form 10-Q for the quarterly period ended June 30, 2023. However, we are unable to locate disclosure clarifying the nature of the assets that are
associated with an operator (i.e. real estate assets, mortgage loans, investments in unconsolidated real estate joint ventures, investments in unconsolidated operating entities, and other loans). Please confirm that in future periodic filings you
will include the previously requested disclosure clarifying the nature of the assets associated with an operator, or tell us why you believe such clarifying disclosure is not necessary.

We respectfully acknowledge the Staff’s comment. Beginning with the Company’s Form 10-Q
for the Quarter Ended September 30, 2023 (the “Q3 2023 10-Q”), we disclosed the nature of the assets that are associated with our operators. This disclosure is included on page 24 of our Q3 2023
10-Q as Footnote (1) under the total assets by operator table in Note 3 and reads as follows: “Total assets by operator are generally comprised of real estate assets, mortgage loans, investments in
unconsolidated real estate joint ventures, investments in unconsolidated operating entities, and other loans.” We will continue to include this disclosure in our future periodic filings.

2.
 Please tell us when you expect to amend your Form 10-K for the
fiscal year ended December 31, 2022 to include audited financial statements of Steward Health Care System LLC as of and for the year ended December 31, 2022.

We will file the audited financial statements of Steward Health Care System LLC (“Steward”) as of and for the year ended
December 31, 2022 via Form 10-K/A promptly upon receipt of such audited financial statements and respective auditor consents. Based on recent discussions with Steward, we expect to receive the audited
financial statements and auditor consents prior to December 31, 2023.

 Should you have any questions or further comments, please contact the
undersigned at 205-969-3755.

Very truly yours,

MEDICAL PROPERTIES TRUST, INC.

 MPT OPERATING PARTNERSHIP, L.P.

 by Medical
Properties Trust, Inc., the sole member of its general partner

/s/ R. Steven Hamner

R. Steven Hamner

Executive Vice President and Chief Financial Officer