SecProbe.io

Mail Stop 3720

December 8 , 2015

Mr. Jianyu Yang
Chief Executive  Officer
Concord Medical Services Holdings Limited
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 Holdings Limited
 Form 20-F for Fiscal Year Ended December 31, 2014
 Filed April 27 , 2015
 File No. 1-34563

Dear Mr. Yang :

We have reviewed your filing an d 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 busine ss days by providing the requested
information or advis e 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.

Item 3. Key Information

Risk Factors, page 9

1. We note that your risk factor heading relates to corrupt practices in the healthcare
industry in China.  We further note your discussion identifies that you face the risk of
increased exposure to liability cla ims because you do not currently carry malpractice
insurance.  In future filings, please disclose this as a separate risk factor or explain why
you believe it is appropriate to include in this particular risk factor.  Refer to Item 503 of
Regulation S -K.  Also please expand your discussion to address more fully the impact
and degree to which this risk factor may adversely impact your business.

Mr. Jianyu Yang
Concord Medical Services Holdings Limited
December 8 , 2015
Page 2

 Item 4. Information On The Company

Specialty Cancer Hospitals, page 40

2. We note that you plan to fund the development of your specialty cancer hospitals with
proceeds raised from your initial public offering and with bank loans.  We further note
disclosure on page 101 that all of the net proceeds from your public offerings had  been
used.  Please explain this apparent inconsistency.   Please enhance your discussion here to
quantify your expected capital expenditure requirements related to expansions, the
expected timing of such requirements, and clearly indicate the measures you  are taking to
obtain suitable financing.  Please be specific in discussing the potential sources of cash
you may be able to obtain and the related impact the financing terms will have on your
operations.

Item 5. Operating and Financial Review and Prosp ects

Results of Operations

Year Ended December 31, 2014 Compared to the Year Ended December 31, 2013, page 72

3. We note that your total net revenue in 2014 increased by 7.8% from 2013 primarily due
to “increased revenue contributions from d iagnostic equip ment patients.”  We also note
from your disclosure  on page 58 that in 2014, although you added 6, you closed 11
centers in your network.  Further, you state that the numbers of your treatment cases
decreased 6.5% and diagnostic cases increased 2.0% from 20 13.  Considering the net
decrease in t he number of diagnostic centers with only a 2.0% increase in diagnostic
cases in 2014, it is not entirely clear how your diagnostic equipment patients accounted
for the 7.8% increase in revenue in 2014.  Item 5.A of Fo rm 20 -F requires a description
of any significant economic changes that materially affected the amount of reported
income from continuing operations, indicating the extent t o which income was so
affected.  In addition, the instructions to Item 5 refer to t he guidance in the Commission's
interpretive release No. 33 -6835 dated May 18, 1989, which requires an analysis of
changes in line items where material and identification and quantification of the extent of
contribution of each of two or more factors when this is necessary to an understanding of
a material change.  Please tell us and revise accordingly in future filings to clearly explain
the underlying drivers affecting reported revenue and expenses and address any trends,
demands, commitments, events or u ncertainties known to management that are
reasonably likely to have material effects on the registrant's financial condition or results
of operations.

Cost of Revenues, page 72

4. We note that you r cost of revenues increased by 26% from 2013 primarily due to the
“increased network depreciation expense s from the new centers. ”  Please tell us in more

Mr. Jianyu Yang
Concord Medical Services Holdings Limited
December 8 , 2015
Page 3

 detail about each expense component that contributed to the increase in 2014.  Further,
tell us how the closure of 11 centers impacted total depreciation expense  in 2014 and how
other operating expenses, including personnel costs, changed as a result of the net
decrease in centers in your network from 2013.

Note 4. Acquisitions and Disposals , page F -22

5. We note that you early adopted the provisions of ASU 2014 -08.  Please revise in future
filings to comply with ASC 205 -20-50-5B(a) and (d) by disclosing:

 the pretax profit or loss of the discontinued operation for the periods in which the
results of operations of the discontinued operation are presented in the s tatement
where net income is reported; and
 the pretax profit or loss attributable to the parent for the periods in which the results
of operations of the discontinued operation are presented in the statement where net
income is reported.

Refer to the example in ASC 205 -20-55-103 for further guidance.

6. Please revise to present the assets and liabilities of the discontinued operations for prior
periods separately in the asset and liability sections of the statement of financial position.
Refer to ASC 20 5-20-45-10.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes 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 adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statemen t 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 under the federal securities laws of the United States.

You may contact Christine Adams , Senior Staff Accou ntant  at (202) 551 -3363 or Carlos
Pacho , Senior Assistant Chief Accountant,  at (202)  551-3835 if you have questions regarding
comments on the financial statements and re lated matters.  Please contact Lahdan Rahmati, Law

Mr. Jianyu Yang
Concord Medical Services Holdings Limited
December 8 , 2015
Page 4

 Clerk , at (202) 551 -8199, or Celeste M. Murphy, Legal Branch Chief, at 202 -551-3257 , or me at
202-551-3810 with any questions.

Sincerely,

 /s/ Celeste M. Murphy for

 Larry Spirgel
Assistant Director
AD Office 11 – Telecommunications