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    Unit 2901, 29F, Tower C

    Beijing Yintai Centre

    No. 2 Jianguomenwai Avenue

    Chaoyang District, Beijing 100022

    People’s Republic of China

    Phone: 86-10-6529-8300

    Fax: 86-10-6529-8399

    Website: www.wsgr.com

    中国北京市朝阳区建国门外大街2号

    银泰中心写字楼C座29层2901室

    邮政编码:
    100022

    电话:
    86-10-6529-8300

    传真:
    86-10-6529-8399

    网站:
    www.wsgr.com

VIA EDGAR

July 14, 2023

Division of Corporation Finance

Office of Industrial Applications and Services

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Concord Medical Services Holdings Ltd

Responses to the Staff’s Comments
on

Form 20-F for the Fiscal Year Ended
December 31, 2022

Filed April 19, 2023

File No. 001-34563

Ladies and Gentlemen,

On behalf of Concord Medical Services Holdings
Ltd (the “Company”), we submit this letter in response to a comment letter from the staff (the “Staff”)
of the Securities and Exchange Commission dated June 29, 2023 relating to the above referenced filing in connection with the Form 20-F
for the fiscal year ended December 31, 2022 filed on April 19, 2023.

The Staff’s comments are repeated below in
bold and are followed by the Company’s responses.

Form 20-F filed April 19, 2023

Conventions That Apply to this Annual Report
on Form 20-F, page 1

 1. We note your defined term “China” excludes “Taiwan and the special administrative
regions of Hong Kong and Macau.” Please clarify that the legal and operational risks associated with operating in China discussed
elsewhere in the annual report also apply to operations in Hong Kong and Macau.

RESPONSE: In response to the
Staff’s comment, the Company undertakes to revise the disclosure in the following manner (marked by underlines) in future filings.

“China” or “PRC”
refers to the People’s Republic of China, and only in the context of describing the industry matters, the PRC laws, rules, regulations,
regulatory authorities, and any PRC entities or citizens under such rules, laws and regulations and other legal or tax matters in this
annual report, excludes Taiwan and the special administrative regions of Hong Kong and Macau;

July 14, 2023

Page 2

Part I, Item 3. Key Information, page 3

 2. At the onset of Part 3, provide prominent disclosure about the legal and operational risks associated with being based in or having
the majority of the company’s operations in China. Your disclosure should make clear whether these risks could result in a material
change in your operations and/or the value of your securities or could significantly limit or completely hinder your ability to offer
or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless. Your disclosure
should address how recent statements and regulatory actions by China’s government, such as those related to the use of variable
interest entities and data security or anti-monopoly concerns, have or may impact the company’s ability to conduct its business,
accept foreign investments, or list on a U.S. or other foreign exchange.

RESPONSE: In response to
the Staff’s comment, the Company undertakes to supplement hind the disclosure in the following manner (to the extent
applicable by the relevant time) in future filings.

ITEM 3. KEY INFORMATION

PRC Regulatory Risks and Requirements

We face various legal and operational risks
and uncertainties related to doing business in China as we conduct substantially all of our operations in China through our PRC subsidiaries.
We are subject to complex and evolving laws and regulations in China. We and our PRC subsidiaries are required to obtain certain licenses,
permits and approvals from relevant governmental authorities in China in order to operate our business. As of the date of this annual
report, as advised by our PRC counsel, Jingtian & Gongcheng Attorneys At Law, we and our PRC subsidiaries have obtained the requisite
licenses, permits and approvals from the PRC government authorities that are material for our business operations, including, among others,
medical institution practicing licenses, large medical equipment procurement licenses, radiotherapy permits and radiation safety permits.
Given the uncertainties of interpretation and implementation of relevant laws and regulations and the enforcement practice by relevant
government authorities, and the promulgation of new laws and regulations and amendment to the existing ones, we may be required to obtain
additional licenses, permits, filings, or approvals for our business operations in the future. We cannot assure you that we or our PRC
subsidiaries will be able to obtain, in a timely manner or at all, or maintain such licenses, permits or approvals, and we or our PRC
subsidiaries may also inadvertently conclude that such permissions or approvals are not required. Any lack of or failure to maintain
requisite licenses, permits or approvals applicable to us or our PRC subsidiaries may have a material adverse impact on our business,
results of operations, financial condition and prospects and cause the value of our securities to significantly decline or become worthless.
See “Item 3. Key Information—D. Risk Factors—Risks Related to Our Business and Industry—We conduct our business
in a heavily regulated industry.”

July 14, 2023

Page 3

Furthermore, in connection with our historical
issuance of securities to foreign investors, under currently effective PRC laws, regulations, and regulatory rules, as of the date of
this annual report, we (1) are not required to obtain permissions from the China Securities Regulatory Commission (the “CSRC”),
(2) are not required to proactively go through cybersecurity review by the Cyberspace Administration of China (the “CAC”),
and (3) have not been requested to obtain such permissions by any PRC authority.

However, the PRC government has indicated
an intent to exert more oversight and control over offerings that are conducted overseas and/or foreign investment in China-based issuers,
and initiated various regulatory actions and made various public statements, some of which are published with little advance notice. For example, we face risks associated with regulatory approvals on overseas
offerings and oversight on cybersecurity and data privacy, which may impact our ability to conduct certain business, accept foreign investments,
or list and conduct offerings on a U.S. or other foreign stock exchange. These risks could result in a material adverse change in our
operations and the value of the ADSs, significantly limit or completely hinder our ability to offer or continue to offer securities to
investors, or cause the value of such securities to significantly decline or become worthless.

On December 28, 2021, the CAC and
various other PRC regulatory authorities jointly revised and promulgated the Measures for Cybersecurity Review (the “Review
Measures”), which became effective on February 15, 2022. Pursuant to the Review Measures, “critical information
infrastructure operators” who purchase network products and services that affect or may affect national security shall be
subject to a cybersecurity review, and any “network platform operators” carrying out data processing activities that
affect or may affect national security should also be subject to the cybersecurity review requirements. The Review Measures also
provide that if a “network platform operator” holding personal information of more than one million users intends to go
public in a foreign country, it must apply for a cybersecurity review. In addition, the relevant PRC government authorities may
initiate cybersecurity review if they determine certain network products, services, or data processing activities affect or may
affect national security. We currently do not have over one million users’ personal information and do not anticipate that we
will be collecting over one million users’ personal information in the foreseeable future. In addition, as of the date of this
annual report, we have not been informed by any PRC government authorities that we will be deemed as a critical information
infrastructure operator or a network platform operator engaging in relevant data processing activities which affect or may affect
national security of the PRC, nor have we been involved in any investigations on cybersecurity review made by the CAC. However, if
we are not able to comply with the cybersecurity and data privacy requirements in a timely manner, or at all, we may be subject to
government enforcement actions and investigations, fines, penalties, or suspension of our non-compliant operations, among other
sanctions, which could materially and adversely affect our business and results of operations.

July 14, 2023

Page 4

On February 17, 2023, the CSRC promulgated
the Trial Measures of the Overseas Securities Offering and Listing by Domestic Companies (the “Overseas Listing Trial Measures”)
and the related guidelines, which became effective on March 31, 2023. The Overseas Listing Trial Measures has comprehensively improved
and reformed the existing regulatory regime for overseas offering and listing of securities by PRC domestic companies and regulated both
direct and indirect overseas offering and listing of securities by PRC domestic companies by adopting a filing-based regulatory regime.
The CSRC provided further notice related to the Overseas Listing Trial Measures that companies that had already been listed on overseas
stock exchanges prior to March 31, 2023 are not required to make immediate filings for its listing, but are required to make filings
for subsequent offerings in accordance with the Overseas Listing Trial Measures, i.e., to file with the CSRC within three business days
after the closing of such subsequent offerings. As we had been listed on NYSE prior to March 31, 2023, we are not required to make immediate
filing with the CSRC in connection with our listing. However, we could be subject to the filing requirements with the CSRC if we conduct
subsequent offerings. As the Overseas Listing Trial Measures was newly published, and there is uncertainty with respect to the filing
requirements and implementation, we cannot assure you that we would be able to complete the filing procedures, obtain the approvals or
complete other compliance procedures in a timely manner, or at all, or that any completion of filing or approval or other compliance
procedures would not be rescinded. Any such failure would subject us to sanctions by the CSRC or other PRC regulatory authorities.

 3. At the onset of Part 3, provide a clear description of how cash is transferred through your organization.
Disclose your intentions to distribute earnings. Quantify any cash flows and transfers of other assets by type that have occurred between
the holding company and its subsidiaries, and direction of transfer. Quantify any dividends or distributions that a subsidiary have made
to the holding company and which entity made such transfer, and their tax consequences. Similarly quantify dividends or distributions
made to U.S. investors, the source, and their tax consequences. Your disclosure should make clear if no transfers, dividends, or distributions
have been made to date. Describe any restrictions on foreign exchange and your ability to transfer cash between entities, across borders,
and to U.S. investors. Describe any restrictions and limitations on your ability to distribute earnings from the company, including your
subsidiaries, to the parent company and U.S. investors.

RESPONSE: In response to
the Staff’s comment, the Company undertakes to supplement the disclosure in the following manner (to the extent applicable by
the relevant time) in future filings.

July 14, 2023

Page 5

ITEM 3. KEY INFORMATION

PRC Regulatory Risks and Requirements

……

Cash Flows Through Our Organization

Concord Medical is a Cayman Islands
holding company with no material operations of its own. We conduct our operations primarily through our PRC subsidiaries. As a result,
although other means are available for us to obtain financing at the holding company level, the ability of Concord Medical to pay dividends
to the shareholders and to service any debt it may incur may depend upon dividends primarily paid by our PRC subsidiaries. If any of
our PRC subsidiaries incurs debt on its own behalf, the instruments governing such debt may restrict its ability to pay dividends to
Concord Medical. In addition, under PRC laws and regulations, our PRC subsidiaries are permitted to pay dividends to Concord Medical
only out of their retained earnings, if any, as determined in accordance with PRC accounting standards and regulations. Furthermore,
our PRC subsidiaries are required to make appropriations to certain statutory reserve funds or may make appropriations to certain discretionary
funds, which are not distributable as cash dividends except in the event of a solvent liquidation of the PRC subsidiaries.

Under PRC laws and regulations, our
PRC subsidiaries are subject to certain restrictions with respect to paying dividends or otherwise transferring any of their net assets
to us. Remittance of dividends by a wholly foreign-owned enterprise out of China is also subject to examination by the banks designated
by State Administration of Foreign Exchange (“SAFE”). These restrictions are benchmarked against the paid-up capital and
the statutory reserve funds of our PRC subsidiaries. For risks relating to the fund flows of our operations in China, see “Item
3. Key Information—D. Risk Factors—Risks Related to Doing Business in China—Governmental control of currency conversion
may limit our ability to use our revenues effectively and the ability of our PRC subsidiaries to obtain financing” and “Item
3. Key Information—D. Risk Factors—Risks Related to Doing Business in China—We rely on dividends paid by our subsidiaries
for our cash needs, and any limitation on the ability of our subsidiaries to make payments to us could materially adversely affect our
ability to conduct our business.” In 2020, 2021 and 2022, no dividends or distributions were made to Concord Medical by our PRC
subsidiaries.

Under PRC laws, Concord Medical may
fund our PRC subsidiaries only through capital contributions or loans, subject to satisfaction of applicable government registration
and approval requirements. In 2020, 2021 and 2022, Concord Medical and our intermediate holding companies received cash of RMB220.8 million,
RMB49.4 million and RMB18.0 million (US$2.6 million), respectively, from our PRC subsidiaries. In 2020, 2021 and 2022, Concord Medical
and our intermediate holding companies transferred cash of RMB227.2 million, RMB123.9 million and RMB13.5 million (US$2.0 million), respectively,
to our PRC subsidiaries. In 2020, 2021 and 2022, there were no capital contributions, loans or other transfer of cash or assets within
our organization.

July 14, 2023

Page 6

Under the Cayman Islands laws, Concord
Medical is not subject to tax on income or capital gains. Upon payments of dividends to our shareholders, no Cayman Islands withholding
tax will be imposed. For purposes of illustration, the following discussion reflects the hypothetical taxes that might be required to
be paid in mainland China and Hong Kong, assuming that: (1) we have taxable earnings and (2) we determine to pay a dividend
in the future:

    Tax calculation(1)

    Hypothetical pre-tax earnings(2)
      100.0 %

    Tax on earnings at statutory rate of 25%(3)
      (25.0 )%

    Net earnings available for distribution
      75.0 %

    Withholding tax at standard rate of 10%(4)
      (7.5 )%

    Net distribution to shareholders
      67.5 %

 (1) For purposes of this hypothetical example,
                                            the tax calculation has been simplified. The hypothetical book pre-tax earnings