SecProbe.io

Dece mber 26, 2012

Via E -mail
Mr. Adam Jigang Sun
Chief Financial Officer
Concord Medical Services Holding
18/F, Tower A, Global Trade Center
36 North Third Ring Road East, Dongcheng  District
Beijing 100013
People’s Republic of China

 Re: Concord Medical Services Holding
  Form 20-F for the Fiscal Year Ended December 31, 2011
Filed April 25 , 2012
File No. 001-34563

Dear Mr. Sun :

We have limited our review to only your financial statements and related disclosures and
do not intend to expand our review to other portions of your document .  In our comment s, we ask
you to provide us with information so we may better understand your disclosure .

Please respond to this letter  within  10 business days  by providing the requested
information or by advising us when you will provide the requested response .  If you do not
believe that a comment applies to your facts and circumstances, please  tell us why in your
response. Please furnish us a letter on EDGAR under the form type label CORRESP that key s
your responses to our c omment s.

After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.

Item 5.  Operating and Financial Review a nd Prospects
Critical Accounting Policies
Accounts receivable and allowance for doubtful accounts, page 63

1. Please consider providing  disclosure  in future filings that addresses the following:
 How often management evaluate s receivables for collectability.
 Include in a tabular format  the aging of your accounts receivable.  At a
minimum, the disclosure should indicate the past due amounts and a
breakdown by payor classification.  If your tracking system does not have the
capacity to provide an aging schedule of your receivables, disclose that fact
and clarify how this affects your ability to estimate your allowance for
doubtful accounts.

Mr. Adam Jigang Sun
Concord Medical Services Holdings Limited
December 26, 2012
 Page 2

  Any material uncertainties affecting the future realization  of revenues such as
the uncertainties surrounding the receipt of payments from hospitals .
 Your strategy related to collecting past due amounts .
 Your standard credit terms and , if applicable,  explain why days’ sales in
accounts receivable exceed those ter ms.
 Your policy with respect to determining when a receivable is recorded as a
bad debt and ultimately written off including the fo llowing matters:
 Whether or not and to what extent you use specific identification for
recording bad debts;
 The threshold am ount and age for account balance write -offs;
 Whether or not and to what extent your write -off pro cess is automated or
manual;
 Whether or not accounts are written -off prior to going to legal or
collection agencies.  If not, quantify the amount included in accounts
recei vable and the related allowance; and
 The day’s sales outstanding for each period presented  and d iscuss the
reasons for significant changes from the prior period.

Results of Operations, page 64

2. Please consider providing  in future filings a schedule of lease expirations for each of
the next five years, starting with the next fiscal year that include s the number of
leases that will expire, the annual revenues represented by the expiring leases and the
percentage of annual re venues  represented by such leases.

Consolidated Financial Statements
Notes to the Consolidated Financial Statements

3. You disclose that you account for all of your lease rentals and management service
arrangements as operating leases.  Please provide the disclosures for operating leases
where you are the lessor as required by ASC 840 -20-50-4b. and 4c.

2.  Summary of Significant Accounting Policies
Revenue Recognition
1 Lease  and management services, page F -21

4. You disclose that you develop radiotherapy and diagnostic imaging centers through
agreements with top -tier hospitals in China and enter into long term lease and
management services agreements with the hospitals to lease medical equipment to be
used in the centers and to manage the centers in conjunction with the hospital
partners.  When est ablishing your revenue recognition policy for the share of profits
derived pursuant to these arrangements, you concluded that your lease and
management services arrangements contain a lease and a non -lease deliverable, the
non-lease deliverable being the m anagement service element.  You acknowledge that
the arrangement consideration should be allocated between the lease element and the

Mr. Adam Jigang Sun
Concord Medical Services Holdings Limited
December 26, 2012
 Page 3

 management service element on a relative fair value basis but because all of the
consideration is earned through the contin gent rent feature discussed on page F -21,
you appear to have allocated no amount to the management services element. Please
provide us with your analysis supporting your determination that all of the
arrangement consideration should be allocated to the lea se element.  Tell us how your
revenue recognition policy considers the requirements of ASC Topic 605 -25 and
ASC 840  as applicable to the specifics of your agreements.  Please cite the specific
accounting literature by topic and paragraph that supports y our accounting.

5. You disclose on page 62 that you have entered into both leases and management
service arrangements with independent hospitals consisting of terms that range from 6
to 20 years .  You also disclose on page F -18 that you depreciate leased med ical
equipment over the shorter of the term of the contract or 6 to 20 years.  Since the
estimated useful life of 6 to 20 years is very broad please help us understand how you
determined the appropriate useful life of lease medical equipment, including how  you
determined that the assets would provide economic benefit to you for this period.
Please also disclose your accounting policy for recogni zing losses associated with
unprofitable lease and management service agreements .

We urge all persons who are respon sible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing  include the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and ad equacy of the disclosures they have made.

 In responding to our comment, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;
 staff comments or  changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person u nder the federal securities laws of the United States.

Please contact Ibolya Ignat , Staff Accountant, at (202) 551 -3656 or Gus Rodriguez,
Accounting Branch Chief , at (202) 551 -3752 if you have questions regarding the comments.  In
this regard, do not hesi tate to contact me at (202) 551 -3679.

Sincerely,

        /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant