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CORRESP
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Correspondence

 SIMPSON THACHER &
BARTLETT

 ICBC TOWER, 35TH
FLOOR

 3 GARDEN ROAD

HONG KONG

(852) 2514-7600

 FACSIMILE (852) 2869-7694

 DIRECT DIAL NUMBER

(852) 2514-7630

 E-MAIL ADDRESS

lchen@stblaw.com

 VIA EDGAR

December 22, 2015

 Larry
Spirgel, Assistant Director

 Celeste M. Murphy, Legal Branch Chief

Carlos Pacho, Senior Assistant Chief Accountant

 Christine Adams,
Senior Staff Accountant

 Lahdan Rahmati, Law Clerk

 Division
of Corporation Finance

 Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549

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 Ms. Spirgel, Ms. Murphy, Mr. Pacho, Ms. Adams and
Ms. Rahmati:

 On behalf of our client, Concord Medical Services Holdings Limited, a company incorporated under the laws of the Cayman
Islands (the “Company”), we hereby respond to the comment letter the Company received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), dated
December 8, 2015, regarding the financial statements and related disclosures in the Company’s annual report on Form 20-F for the year ended December 31, 2014 that was filed by the Company with the Commission on April 27, 2015
(the “2014 Form 20-F”).

 Set forth below are the Company’s responses to the Staff’s comments contained in the
December 8, 2015 letter. For ease of the Staff’s reference, we have reproduced the Staff’s comments in italicized boldface type below and keyed the Company’s responses correspondingly.

Leiming Chen   Daniel Fertig   Adam C. Furber   Anthony D. King   Celia C.L. Lam   Chris K.H.
Lin   Jin Hyuk Park   Kathryn King Sudol   Christopher K.S. Wong   Resident Partners

SIMPSON THACHER & BARTLETT, HONG KONG IS
AN AFFILIATE OF SIMPSON THACHER & BARTLETT LLP WITH OFFICES IN:

 NEW YORK

BEIJING

HOUSTON

LONDON

LOS ANGELES

PALO ALTO

SÃO PAULO

SEOUL

TOKYO

WASHINGTON, D.C.

 SIMPSON THACHER & BARTLETT

 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
claims 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.

The Company acknowledges the Staff’s comment and will provide the requested disclosure in a separate risk factor with respect to
malpractice insurance for the specialty cancer hospitals that the Company expects to open in the next few years in its annual report on Form 20-F for the year ending December 31, 2015 (the “2015 Form 20-F”), which is expected
to be filed with the Commission before the end of April 2016, under “Item 3. Key Information—D. Risk Factors—Risks Related to Our Company”. The Company proposes to make the following amendments to the relevant risk factors to
address the Staff’s comment (the proposed additions are in italics and underlined and the proposed deletions are in strikethrough each against the current disclosure in the 2014 Form 20-F):

“There may be corrupt practices in the healthcare industry in China, which may place us at a competitive disadvantage
if our competitors engage in such practices and may harm our reputation if our hospital partners and the medical personnel who work in our centers, over whom we have limited control, engage in such practices.

There may be corrupt practices in the healthcare industry in China. For example, in order to secure agreements with hospital
partners or to increase direct sales of medical equipment or patient referrals, our competitors, other service providers or their personnel or equipment manufacturers may engage in corrupt practices in order to influence hospital personnel or other
decision-makers in violation of the anti-corruption laws of China and the U.S. Foreign Corrupt Practices Act, or the FCPA. We have adopted a policy regarding compliance with the anti-corruption laws of China and the FCPA to prevent, detect and
correct such corrupt practice.

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 SIMPSON THACHER & BARTLETT

 However, as competition persists and intensifies in our industry, we may lose
potential hospital partners, patient referrals and other opportunities to the extent that our competitors engage in such practices or other illegal activities. In addition, our partner hospitals or the doctors or other medical personnel who work in
our network of centers may engage in corrupt practices without our knowledge to procure the referral of patients to centers in our network. Although our policies prohibit such practices, we have limited control over the actions of our hospital
partners or over the actions of the doctors and other medical personnel who work in our network of centers since they are not employed by us. If any of them were to engage in such illegal practices with respect to patient referrals or other matters,
we or the centers in our network may be subject to sanctions or fines and our reputation could be adversely affected by any negative publicity stemming from such incidents.

We could also face increased exposure to liability claims at our specialty cancer hospitals, including claims for
medical malpractice. We may need to obtain medical malpractice insurance and other types of insurance that we do not currently carry, each of which could increase our expenses and decrease our profitability. In addition, there can be no assurance
that such insurance will be available at a reasonable price or that we will be able to maintain adequate levels of liability insurance coverage, if at all. In addition, our specialty cancer hospitals will also be required to obtain various quotas,
permits and authorizations, which are currently the responsibility of our hospital partners under our existing agreements. See “—Risks Related to Our Industry—Healthcare administrative authorities in China currently set procurement
quotas for certain types of medical equipment” and “—Risks Related to Our Industry—We or our hospital partners may be unable to obtain various permits and authorizations from regulatory authorities in China relating to our
medical equipment, which could delay the installation or interrupt the operation of our equipment.

Finally, if our plans change for any reason or the anticipated timetable or costs of development change for our
specialty cancer hospitals, our business and future prospects may be negatively impacted. There can be no assurance that the planned specialty cancer hospitals will be completed or that, if completed, they will achieve sufficient patient cases to
generate positive operating margins. In addition, as our currently planned specialty cancer hospitals are to be established through joint ventures with other parties, we also may not be successful in cooperating with such joint venture partners in
operating our specialty cancer hospitals. See “—Risk Factors Related to Our Business —We may not be able to effectively manage the expansion of our operations through any new acquisitions or joint ventures, which we may not be able to
successfully execute.

 …

When we open our specialty cancer hospitals, we expect to face the risk of increased exposure to liability claims and
our malpractice insurance may not be sufficient to cover such increased liability exposure.

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 SIMPSON THACHER & BARTLETT

 Our specialty cancer hospitals are currently under development. We
expect to open the first of such hospitals by early 2016. Once we start operating these hospitals, it is possible that claims against us for medical malpractice in these hospitals may arise from time to time. We may obtain the types of insurance
that we do not currently carry for the coverage of additional liability exposure associated with the operation by us of these hospitals once these hospitals are in operation. However, there can be no assurance that such insurance coverage will be
available at a reasonable price or that we will be able to maintain adequate levels of liability insurance coverage, if at all. Any failure for us to maintain sufficient liability insurance coverage for our operation of these hospitals at a
reasonable price could subject us to substantial cost and diversion of resources arising out of liability claims and such insurance coverage could also increase our expenses and decrease our profitability, which would have an adverse effect on our
business, financial condition and results of operations.”

 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.

 The Company acknowledges the Staff’s comment and will provide in the 2015 Form 20-F (and in other
future annual reports as applicable) under “Item 4. Information on the Company—B. Business Overview—Our Hospital Business—Specialty Cancer Hospitals” the following revised disclosure to discuss its expected financing plans
for the expansion of specialty cancer hospitals (the proposed additions are in italics and underlined and the proposed deletions are in strikethrough):

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 SIMPSON THACHER & BARTLETT

 “We are currently in the process of establishing specialty cancer
hospitals that will focus on providing radiotherapy services as well as diagnostic imaging services, chemotherapy and surgery. We intend for these specialty cancer hospitals to provide a complete and coordinated treatment program for cancer
patients. We intend for these hospitals to be centers of excellence in our network providing cancer treatments to patients using the latest radiotherapy technology in China. Typically, in China the various specialist doctors such as surgeons,
radiation oncologists or medical oncologists who provide care to a given cancer patient do not collaborate. We believe that the quality of cancer treatment will be greatly improved at our specialty cancer hospitals, because we will employ and manage
the various specialist doctors directly and thereby promote the appropriate coordination of their services for the benefit of cancer patients. We believe that these hospitals will play an important role in further strengthening our reputation as the
leading provider of radiotherapy services in China and developing our corporate brand. These specialty cancer hospitals will be majority owned and operated by us. We will purchase all of the medical equipment for these hospitals and will employ and
manage all of the personnel, including doctors, nurses, medical technicians and administrative personnel. The specialty cancer hospitals will be licensed as for-profit hospitals in China and will be subject to the relevant PRC laws and regulations
and permits requirements. As for-profit hospitals, the medical service fees of our specialty cancer hospitals will not be subject to price controls but will be subject to certain taxes not applicable to non-profit hospitals. We plan to fund the
development of our specialty cancer hospitals with proceeds raised from our initial public offering with bank loans and cash on hand.”

The Company respectfully advises the Staff that the language “with proceeds raised from our initial public offering” that was in the
Company’s 2014 Form 20-F is an inadvertent error as the Company had used all of its net proceeds from its initial public offering. The Company advises the Staff that it will amend this the 2015 Form 20-F to reflect the proposed revised
disclosure set forth above.

 The Company will also revise the discussions in the 2015 Form 20-F (and in other future annual reports as
applicable) under “Item 5. – Operating and Financial Review and Prospects – B. Liquidity and Capital Resources – Acquisitions and Capital Expenditures” as follows to disclose its expected capital expenditure requirements
related to expansions, the expected timing of such requirements and expected sources of financing.

 “We estimate that
our expected aggregate capital expenditures in 2015 2016 will be approximately RMB[●] 300 million to
RMB[●]500 million, which we will use mainly for new hospital project constructions the continued expansion of our network of radiotherapy and diagnostic imaging centers, including
for the establishment of free-standing radiotherapy cancer centers and our premium specialty cancer hospital. We intend to open three to five specialty cancer hospitals each year for the next three years, and expect the capital
expenditure required to support such expansion to be approximately RMB150 million to RMB250 million per year from 2016. Our expected sources of funding for these projects are approximately 70% from bank loans and approximately 30% from cash flows
from operations. As of December 31, 2015, we had bank credit lines totaling RMB[●]billion (US$[●] million), of which RMB[●] billion had not been utilized. There are no financing terms among
our bank loan terms which will have an adverse effect on our operations.

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 SIMPSON THACHER & BARTLETT

 We believe that our current levels of cash and cash flows from operations
will be sufficient to meet our anticipated cash needs for at least the next 12 months.”

 The Company advises the Staff that, as of the
date of this response letter, its expected aggregate capital expenditures in 2015 are approximately RMB220 million, of which approximately RMB40 million has been used for the establishment of its specialty cancer hospital in Datong. The Company
further advises the Staff that as of December 31, 2014, the Company had bank credit lines totaling RMB2.8 billion (US$456.3 million), of which RMB1.9 billion had not been utilized.

Item 5. Operating and Financial Review and Prospects

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 diagnostic equipment 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 2013. Considering the net decrease in the 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 Form 20-F requires a description of any
significant economic changes that materially affected the amount of reported income from continuing operations, indicating the extent to which income was so affected. In addition, the instructions to Item 5 refer to the 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