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      July 19, 2024

      VIA EDGAR SUBMISSION

      Division of Corporate Finance

      U.S. Securities and Exchange Commission

      Washington, D.C. 20549

      Attn: Joyce Sweeney and Kathleen Collins

      Re: GoHealth, Inc.

      Form 10-K for the Year Ended December 31, 2023

      Form 8-K furnished May 9, 2024

      File No. 001-39390

      Dear Ms. Sweeney and Ms. Collins:

      On behalf of GoHealth, Inc. (the “Company”, “we”, “management”), I am hereby submitting responses to the comments of the staff (the “Staff”) of the U.S. Securities and
        Exchange Commission (the “SEC”) set forth in your letter dated June 13, 2024 with respect to the above- referenced Annual Report on Form 10-K (the “10-K”) and 8-K, as well as the Form 8-K/A furnished March 14, 2024. For your convenience, the text
        of each of the Staff’s comments is set forth in bold font below and is followed by the Company’s response to the comment. Terms not otherwise defined in this letter have the meanings set forth in the 10-K.

      Form 10-K for the Year Ended December 31, 2023

      Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 46

            1.

              You present a measure of Adjusted EBITDA margin both here and in your Form 8-K earning releases without presenting the most directly comparable GAAP measure of net income (loss) margin with
                equal or greater prominence. Please revise. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations (Non-GAAP C&DIs).

      Response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that the Company will, in future filings, present Net Income (Loss) Margin, with
        equal or greater prominence, whenever Adjusted EBITDA margin is presented, consistent with Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.

      Key Business Performance and Operating Metrics, page 49

            2.

              We note that your measure of Sales per Submission includes adjustments for lookback adjustments, which appears to create a measure based on non-GAAP revenue. Please explain how you calculate
                the adjustments, including the difference between the two lookback adjustments for 2021, and tell us the amount of such adjustments used in your calculations for each period presented. In your response provide us with a hypothetical example
                of a transaction to demonstrate the impact of the revenue and subsequent lookback adjustment on the Sales per Submission. Explain the basis for the lookback

          222 W Merchandise Mart Plaza Ste 1740 | Chicago, IL 60654 | 1.888.250.3409 | www.gohealth.com

      adjustments used in determining Sales per Submission and specifically address how you considered whether such adjustments substitute
        individually tailored measurement methods for those of GAAP revenue. Refer to Question 100.04 of the Non-GAAP C&DIs.

      Response: The Company respectfully advises the Staff that, upon further consideration, the Company believes that Sales per Submission is not a non-GAAP financial measure,
        as it does not represent a measure of the Company’s total historical or future financial performance, financial position, or cash flow. Instead, management uses this metric to measure the performance of the Submissions generated in a reporting
        period, and accordingly the Company believes that Sales per Submission should be viewed as an operating or statistical measure excluded from non-GAAP financial measures under Item 10(e)(4) of Regulation S-K. In addition, this metric does not
        replace or adjust any GAAP metric, nor is there any directly comparable GAAP metric. As stated above, it is intended to present average performance on a per-Submission basis over time and not the financial performance of the Company for a reporting
        period. The Company has historically elected to present a detailed calculation of this metric starting with Medicare Revenue per Submission, for the purpose of increasing transparency with investors and providing investors with the information
        regarding how the Company calculates this metric and undertakes to continue to provide such information in the future. Further, the Company will revise the “Non-GAAP Financial Measures” section under “Item 7. Management’s Discussion and Analysis of
        Financial Conditions and Results of Operations,” as well as any other section in which this information may be presented, to remove references to this metric as a non-GAAP financial measure.

      Submissions, the denominator used to calculate this metric, as defined in our filings, is either (i) a completed application with our licensed agent that is submitted to
        the health plan partner and subsequently approved by the health plan partner during the indicated period, excluding applications through our Non-Encompass BPO Services or (ii) a transfer by our agent to the health plan partner through the Encompass
        operating model during the indicated period. The numerator used to calculate this metric represents the sum of revenues estimated to be collected over the life of only those Submissions as defined above (i.e., during the relevant period). As the
        intent of this metric is to measure the performance of Submissions generated in a reporting period, the Company adjusts for Lookback Adjustments to align revenues with the Submissions being analyzed. Lookback Adjustments represent out-of-period
        adjustments required under ASC 606 that do not relate to the Submissions of the reporting period in which the adjustment was recorded. If the revenues are not adjusted for the Lookback Adjustments the numerator and denominator would not represent
        the same population of Submissions. The Company believes that the metric provides useful information when evaluating the Company’s Submission performance over time and within the Company for managing the business.

      For additional background, and as stated in Company’s SEC filings, the Company records commissions revenue based on the expected total estimated lifetime value of commissions
        (“LTV”) estimated to be received from health plans, net of an estimated constraint. The LTV is inclusive of initial commissions and any renewal commissions to be received on such placements as long as the policyholder remains with the same
        insurance product. In accordance with ASC 606-10-32-14, on a quarterly basis the Company monitors and updates this estimate, at a vintage level, for outstanding vintages by reviewing and monitoring changes in the data used to estimate the LTV, and
        the cash received for each vintage as

          222 W Merchandise Mart Plaza Ste 1740 | Chicago, IL 60654 | 1.888.250.3409 | www.gohealth.com

      compared to the original estimates. Consistent with ASC 606-10-32-8 and 32-9, the Company analyzes these differences and, to the extent it believes differences in the
        estimates of the cash received are indicative of an increase or decrease to prior period LTVs and the related revenues previously recognized, the Company adjusts revenues for the affected vintages at the time such determination is made and when it
        is probable that a significant reversal in the amount of cumulative revenue recognized will not occur. Such an adjustment is referred to as a “Lookback Adjustment.”

      To further address the Staff’s comment, “Lookback Adjustments reported during the indicated period per Submission” refers to the Lookback Adjustment recorded in the indicated
        period but related to prior period Submissions on a per Submission basis. “Lookback Adjustments attributed to 2021 per Submission” refers to the Lookback Adjustment recorded subsequent to 2021, but related to 2021 Submissions, on a per submission
        basis. There were no Lookback Adjustments recorded related to 2022 or 2023 Submissions.

      The amount of Lookback Adjustments used in the Company’s calculations for each period presented are as follows:

              ($s in thousands)

              Twelve months

              ended

              Dec. 31,2023

              Twelve months

              ended

              Dec. 31,2022

              Twelve months

              ended

              Dec. 31,2021

              Lookback Adjustments reported during the indicated periods

              -

              $252,301(a)

              $165,296(b)

              Lookback Adjustments attributed to 2021

              -

              -

              ($208,848)

      (a) Of the amount presented, $208,848 relates to Submissions sold in 2021 and the remaining $43,453 relates to Submissions sold in 2020 and prior periods

      (b)The $165,296 relates to Submissions sold in 2020 and prior periods

      Hypothetically, if during the twelve months ended December 31, 2023, the Company recorded a Lookback Adjustment of $50 million related to calendar year 2022 sales, the above
        table would be revised as follows:

              ($s in thousands)

              Twelve months

              ended

              Dec. 31,2023

              Twelve months

              ended

                Dec. 31,2022

              Twelve months

              ended

              Dec. 31,2021

              Lookback Adjustments reported during the indicated periods

              $50,000

              $252,301

              $165,296

              Lookback Adjustments attributed to 2021 and 2022

              -

              ($50,000)

              ($208,848)

      Assuming total submissions in this hypothetical example of 826,159 and 862,656 for 2023 and 2022, respectively, the Sales per Submission related to Lookback adjustments would
        be presented as follows:

          222 W Merchandise Mart Plaza Ste 1740 | Chicago, IL 60654 | 1.888.250.3409 | www.gohealth.com

              Twelve months

              ended

              Dec. 31,2023

              Twelve months

              ended

              Dec. 31,2022

              Twelve months

              ended

              Dec. 31,2021

              Lookback adjustments reported during the indicatedperiods per Submission

              $61

              $292

              $151

              Lookback Adjustments attributed to 2021 and 2022 perSubmission

              ($58)

              ($190)

            3.

              Please address the following as it relates to your measure of Cost per Submission:

            •

              Clarify whether this measure is intended to represent cost of revenues on a per submission basis or something else. In this regard, we note you present a measure of adjusted gross margin per
                submission.

      Response: The Company respectfully advises the Staff that, upon further consideration, the Company believes that Cost per Submission is not a non-GAAP financial measure, as
        it does not represent a measure of the Company’s total historical or future financial performance, financial position, or cash flow. Instead, management uses this metric to measure the cost of the Submissions generated in a reporting period, and
        accordingly the Company believes that Cost per Submission should be viewed as an operating or statistical measure excluded from non-GAAP financial measures under Item 10(e)(4) of Regulation S-K. This metric does not replace or adjust any GAAP
        metric, nor is there any comparable GAAP metric. It is intended to present average cost on a per Submission basis over time and not the performance of the Company for a reporting period. The Company has historically elected to present a detailed
        calculation of this metric starting with Operating Expense per Submission, for the purpose of increasing transparency with investors and providing investors with the necessary information regarding how the Company calculates this metric and,
        undertakes to continue to provide such information in the future. The Company will rename this metric in future filings as “Direct Cost per Submission”. Further, the Company will revise the “Non-GAAP Financial Measures” section under “Item 7.
        Management’s Discussion and Analysis of Financial Conditions and Results of Operations,” as well as any other section in which this information may be presented, to remove references to this metric as a non-GAAP financial measure.

      The definition of Submissions, which is the denominator used to calculate this metric, is set forth in our response to Comment 2, above. The numerator used to calculate
        this metric represents the sum of operating expenses that are directly related to the generation of Submissions in a given reporting period. Such expenses include revenue share, marketing and advertising, and customer care and enrollment costs,
        excluding stock-based compensation costs. Revenue share represents payments related to health plans sold to consumers who were enrolled by partners with whom the Company has commission revenue sharing arrangements. Marketing and advertising expense
        consists primarily of expenses associated with acquiring consumers through the Company’s direct, online advertising and marketing partner channels as well as through online, television, and direct mail advertisements. Customer care and

          222 W Merchandise Mart Plaza Ste 1740 | Chicago, IL 60654 | 1.888.250.3409 | www.gohealth.com

      enrollment expenses primarily consist of compensation and benefits costs for enrollment personnel who assist consumers during the health plan enrollment and application
        processes.

      Indirect operating costs, as further explained below, are not directly attributable to the acquisition of consumers and are primarily fixed costs that do not directly generate
        Submissions. To effectively measure the performance of the Submissions over time, it is important to align Submissions with the costs directly incurred to generate those Submissions.

      In regard to your reference to the presented measure of adjusted gross margin per submission, please refer to comment #4 below.

            •

              Describe the technology and general and administrative costs included in the indirect operating expense adjustment. To the extent these include normal cash operating expenses, tell us how
                you considered the guidance in Question 100.01 of the NonGAAP C&DIs.

      Response: As discussed in our response to the first bullet of Comment 3, above, Cost per Submission represents an operating or statistical measure and not a non-GAAP
        financial measure. Cost per Submission includes direct costs, as described above, and excludes technology and administrative costs as, the latter are primarily fixed costs and a) do not directly generate Submissions and b) do not tend to fluctuate
        with the number of submissions in a period. Technology expense consists of compensation and benefits costs for personnel associated with developing and enhancing the Company’s technology platform, data analytics and business intelligence, as well
        as maintaining the Company’s online presence and integrations with health plan partners and federal marketplaces. General and administrative expenses include compensation and benefits costs for employees working in the Company’s executive, finance,
        legal, human resources, and facilities departments. These expenses also include depreciation and amortization.

            •

              Explain how you determine the costs related to lookback adjustments considering the lookback adjustments appear to be subsequent re