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HEALTHLYNKED CORP.

1265 Creekside Parkway, Suite 302

Naples, Florida 34108

Tel: (800) 928-7144

June 1, 2022

By EDGAR Transmission

Frank Wyman

Division of Corporation Finance

Office of Life Sciences

U.S. Securities and Exchange Commission

    Re:

    HealthLynked Corp

    Form 10-K for the Fiscal Year Ended December 31, 2021

    Filed March 31, 2022

    File No. 000-55768

Dear Mr. Wyman,

We hereby submit the responses of HealthLynked Corp.
(the “Company”) to the comments of the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) set forth in the Staff’s letter, dated May 25, 2022, providing the Staff’s comments
with respect to the above referenced Form 10-K (the “Form 10-K”).

For the convenience of the Staff, each of the Staff’s
comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise, references
in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

Item 9A. Controls and Procedures, page 31

 1. The Item 9A presentation in your Form 10-K for the fiscal year ended December 31, 2021 excludes an
assessment and effectiveness conclusion for internal control over financial reporting. Please amend your Form 10-K to include all of the
information required by Items 307 and 308 of Regulation S-K.

Response: We propose to add the following language
to the Item 9A presentation by amendment to the 10-K, immediately preceding the subsection entitled “Changes in Internal Control
over Financial Reporting”:

“Management’s
Report on Internal Control over Financial Reporting

Our management is responsible for establishing
and maintaining adequate internal control over financial reporting and for the assessment of the effectiveness of internal control over
financial reporting. As defined by the SEC, internal control over financial reporting is a process designed by, or under the supervision
of our Principal Executive and Financial Officer and implemented by our Board of Directors, management and other personnel, to provide
reasonable assurance regarding the reliability of financial reporting and the preparation of our financial statements in accordance with
U.S. generally accepted accounting principles.

Because of its inherent limitations,
internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness
to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of
compliance with the policies or procedures may deteriorate.

Management assessed the effectiveness
of our internal control over financial reporting as of December 31, 2021. In making this assessment, management used the criteria set
forth by the Committee of Sponsoring Organizations of the Treadway Commission in Internal Control—Integrated Framework issued in
2013. Based on the evaluation of our internal control over financial reporting as of December 31, 2021, management, with the participation
of our Chief Executive Officer and Chief Financial Officer, concluded that as of such date, our internal control over financial reporting
was effective based on those criteria.”

Notes to Consolidated Financial Statements

Note 2 - Significant Accounting Policies

Revenue Recognition, page F-9

 2. Please revise your future filings to include all of the disclosures required by ASC 606-10-50, as applicable,
and provide us a draft of your intended disclosure revisions. Specifically, address the following:

·  Regarding net patient service revenues, explain the nature of the services provided, while
clarifying why some of your performance obligations are satisfied over time while others are satisfied at a point in time. Provide the
qualitative and quantitative disclosure about the significant judgments and changes in judgments, including inputs and assumptions, related
to your accounting for contractual adjustments, discounts and price concessions and the amount of subsequent settlements with your third
party payers as set forth in ASC 606-10-50-1(b), 50-17, and 50-20.

·  Regarding Medicare shared savings revenue, provide us your analysis of principal versus
agent considerations, and revise your disclosures as appropriate. We refer you to ASC 606-10-55-36 through 55-40. Explain to us the apparent
disconnect between your statement on page F-10 that you bear all costs of the ACO operations until revenue is recognized, and your disclosure
on page F-11 that states that shared savings expense is recognized in the period in which the shared savings revenue is recognized, i.e.
in the period in which the CMS notifies you of the exact amount of shared savings to be paid. Refer us to the technical guidance upon
which you relied.

Response:

Net Patient Service Revenues

With respect to net patient service revenues, we have
added a description of the nature of the services provided, clarified which performance obligations are satisfied at a point in time and
which are satisfied over time, and provided qualitative and quantitative disclosure about the significant judgments related to our accounting
for contractual adjustments, discounts and price concessions and the amount of subsequent settlements with your third party payers.

We propose to revise our future filings with the disclosure
regarding net patient service revenues that follows. Redline edits against the disclosure in the 10-K (Note 2, “Significant Accounting
Policies”) are provided for the convenience of the Staff.

“Patient
service revenue is earned for GYN services provided to patients at our NWC facility, functional medicine services provided to patients
at our NCFM facility, and physical therapy services provided to patients at our BTG facility. Patient service revenue is reported
at the amount that reflects the consideration to which the Company expects to be entitled in exchange for providing patient care. These
amounts are due from patients and third-party payors (including health insurers and government programs) and include variable consideration
for retroactive revenue adjustments due to settlement of audits, reviews, and investigations. Generally, the Company bills patients and
third-party payors within days after the services are performed and/or the patient is discharged from the facility. Revenue is recognized
as performance obligations are satisfied.

Performance obligations are determined based
on the nature of the services provided by the Company. Revenue for performance obligations satisfied over time,
which includes prepaid BTG physical therapy bundles for which performance obligations are satisfied over time as visits are incurred,
is recognized based on actual charges incurred in relation to total expected charges. The Company believes that this method provides a
faithful depiction of the transfer of services over the term of the performance obligation based on the inputs needed to satisfy the obligation.
Revenue for performance obligations satisfied at a point in time, which includes all patient service revenue
other than BTG physical therapy bundles, is recognized when goods or services are provided at the
time of the patient visit, and at which time the Company does
not believe it is is not required to provide additional goods or services to the patient.

The Company determines the transaction price
based on standard charges for goods and services provided, reduced by contractual adjustments provided to third-party payors, discounts
provided to uninsured patients in accordance with the Company’s policy, and/or implicit price concessions provided to uninsured
patients. The Company determines its eEstimates of contractual adjustments
and discounts require significant judgment and are based on the Company’s
current contractual agreements, its discount policies, and historical experience. The Company determines its estimate of implicit
price concessions based on its historical collection experience with this class of patients. There were no
material changes during the years ended December 31, 2022 or 2021 to the judgments applied in determining the amount and timing of patient
service revenue.”

Medicare Shared Savings Revenue

Principal vs Agent Considerations

With respect to Medicare shared savings revenue, we
have analyzed the principal versus agent considerations in ASC 606-10-55-36 through 55-40. Through our wholly owned subsidiary, ACO Health
Partners LLC (“AHP”), we operate an accountable care organization (“ACO”) as defined in by the Medicare
Shares Savings Program (the “MSSP”) as administered by the Center for Medicare and Medicaid Services (the “CMS”).
The MSSP allows for the creation of ACOs, which are organizations that agree to take responsibility for the efficiency of healthcare services
provided by a group of participating healthcare providers under Medicare. The ACO is held accountable for the efficiency of the healthcare
services of its participating providers as measured against prescribed MSSP benchmarks. If the ACO’s covered patient population
meets the MSSP benchmarks, the ACO then receives an incentive payment, as determined by the CMS, for each plan year that the ACO operates.
A portion of the inventive payment is then paid to the participating providers and the balance is retained by AHP.

In this arrangement, AHP is the provider, the CMS
is the customer and the ACO participating physicians are the other parties involved in delivering the service (the provision of Medicare-based
medical services in a manner that meet the benchmarks set by CMS). Pursuant to ASC 606-10-55-37, an entity that is a principal may engage
another party to satisfy some or all of the performance obligation on its behalf. Here, AHP enters into contracts with ACO providers to
act as participating providers in the Company’s ACO. These participating providers contracts place restrictions and requirements
on the providers to assure that such providers are working to contribute to the ACO’s total pool of patient lives meeting the CMS
benchmarks. Such restrictions and requirements include agreement in the contract for the participating provider to take the following
actions on behalf of the ACO: (1) make care available to its patients, (2) refer patients to other Company ACO member physicians, (3)
participate in all CMS required reporting functions, (4) notify patients and post signs and notices of participation in the program in
their offices, (5) complete annual ACO training and outreach initiatives, (6) comply with the ACO’s reporting requirements, and
(7) collaborate with the ACO’s care coordination team to manage efficiency of patient care with the goal of meeting the MSSP benchmarks.
In the event that the participating provider fails to meet the requirements outlined in their contract, AHP may withhold payment of from
the MSSP pool and may terminate the agreement within 90 days. The participating physicians’ performance obligations are clearly
spelled out and the participating physicians have a clear incentive to uphold such obligations. The contractual requirement and financial
motivation of the participating physicians to provide support in delivering the service to the CMS is strong evidence that the ACO is
a principal in the transaction.

Moreover, pursuant to ASC 606-10-55-37A, item b.,
an entity is considered a principal if the entity obtains the right to a service to be performed by the other party, which gives the entity
the ability to direct that party to provide the service to the customer on the entity’s behalf. AHP contracts directly with CMS
to provide the service and therefore has the right and the obligation to provide the service to CMS. AHP then separately engages the participating
physicians to assist in delivering the service. The contractual obligations of the participating physicians described in the preceding
paragraph give AHP the right to direct the participating physicians provide the service (the provision of Medicare-based medical services
in a manner that meet the benchmarks set by CMS) to the customer (CMS) on AHP’s behalf. The relationship structure meets the requirement
of ASC 606-10-55-37A, item b., which provides additional strong evidence that the ACO is a principal in the transaction.

Finally, ASC 606-10-55-37A, item c. states the following:
“if an entity provides a significant service of integrating goods or services…provided by another party into the specified
good or service for which the customer has contracted, the entity controls the specified good or service before that good or service is
transferred to the customer. This is because the entity first obtains control of the inputs to the specified good or service (which
include goods or services from other parties) and directs their use to create the combined output that is the specified good or service.”
Here, AHP is approved and engaged by CMS as an ACO with the understanding that the ACO’s purpose (and its value to the customer)
is to contract with multiple participating physicians to improve Medicare efficiency. The participating physicians are contractually obligated
to, among other things, collaborate with AHP’s care coordination team to manage efficiency of patient care with the goal of meeting
the MSSP benchmarks and to comply with AHP’s reporting requirements. This is strong evidence that AHP has control over the inputs
to the specified good or service being provided.

Significant Accounting Policies
Disclosure

With respect to the apparent disconnect regarding
Medicare shared savings expense on page F-10 and F-11, we offer the clarification that there are two types of expenses included in the
line item “Medicare shared savings expense” on the statement of operations: (i) ongoing ACO operating expenses such as salaries,
office rent and overhead, which are not contingent on MSSP performance and which are expensed as incurred throughout the year, and (ii)
an annual provider payment (the “Annual Provider Payment”) that is made from the MSSP revenue received from CMS once a year.
The amount of the Annual Provider Payment can only be determined after the amount of MSSP revenue is known and, therefore, this expense
is only recognized in the period in which it becomes known.

ASC 340-40-25-8 specifies that an entity shall recognize
“General and administrative costs (unless those costs are explicitly chargeable to the customer under the contract)” “as
expenses when incurred.” The ongoing ACO operating expenses are general and administrative and therefore recognized as incurred.

We also considered whether an asset should be recognized
for the costs to incur the contract. ASC 340-40-25-5 states an entity should recognize an asset for the costs incurred to fulfill a contract
only if those costs meet all of the following criteria: a. The costs relate directly to a contract or to an anticipated contract that
the entity can specifically identify (for example, costs relating to services to be provided under renewal of an existing contract or
costs of designing an asset to be transferred under a specific contract that has not yet been approved); b. The costs generate or enhance
resources of the entity that will be used in satisfying (or in continuing to satisfy) performance obligations in the future; c. The costs
are expected to be recovered. Criterion c. of ASC 340-40-25-5 is not met because, notwithstanding that AHP may recover its costs from
an MSSP payment before determining the amount of the Annual Provider Payment, there is no guarantee that such MSSP payment will be earned,
and therefore no reasonable certainty that such costs are recoverable. Therefore, we determined that no asset should be recognized for
costs to fulfill the ACO contract. Because the amount of the Annual Provider Payment is not known until the CMS determination is received,
the expense related to the Annual Provider Payment should