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  Stradley Ronon Stevens & Young, LLP

2005 Market Street

Suite 2600

Philadelphia, PA 19103

Telephone 215.564.8000

Fax 215.564.8120

www.stradley.com

Joel
D Corriero

Partner

jcorriero@stradley.com

215.564.8528

December
16, 2022

Via
EDGAR Transmission

Mr.
Sonny Oh

U.S.
Securities and Exchange Commission

Division
of Investment Management – Disclosure Review and Accounting Office

100
F Street, N.E.

Washington,
D.C. 20549

 Re: Milliman
                                            Variable Insurance Trust (the “Trust”)

    Registration
                                            Statement on Form N-1A

    File
                                            No. 333-257356 / 811-23710

Dear
Mr. Oh:

I
am writing in response to comments you provided on December 12, 2022, to Post-Effective Amendment No. 15 to the Trust’s Registration
Statement on Form N-1A (the “Amendment”), which was filed pursuant to Rule 485(a)(1) under the Securities Act of 1933 (the
“Securities Act”) on October 28, 2022, to register shares of the series of the Trust identified on Appendix A attached hereto
(each, a “Fund,” and collectively, the “Funds”). We will respond to comments provided to the Amendment in the
form of a Post-Effective Amendment filed pursuant to Rule 485(b) under the Securities Act prior to or upon the effectiveness of the Amendment.
I have reproduced your comments below, followed by our responses. All capitalized terms not otherwise defined in this letter have the
meanings given to them in the Amendment.

General
Comments

 1. Comments
                                            made with respect to a particular named Fund, to the extent applicable, apply to all other
                                            Funds in the Amendment. Where a comment is made in one location (e.g., summary section or
                                            the prospectus), it is applicable to all similar disclosure appearing elsewhere in the Amendment
                                            (e.g., statutory prospectus or the Statement of Additional Information (“SAI”)).

RESPONSE:
The Trust acknowledges the staff’s comment.

Philadelphia,
PA • Malvern, PA • Cherry Hill, NJ • Wilmington, DE • Washington, DC • New York, NY • Chicago, IL

A
Pennsylvania Limited Liability Partnership

 2. Please
                                            ensure that all information in the Amendment that is currently incomplete and/or bracketed
                                            will be completed in the next filed Post-Effective Amendment pertaining to the Funds.

RESPONSE:	The
Trust acknowledges the staff’s comment and confirms that all information will be completed in the next Post-Effective Amendment
pertaining to the Funds that is filed pursuant to Rule 485(b) under the Securities Act.

Prospectus
Comments

Fund
Summary

Fees
and Expenses of the Fund

 3. Please
                                            provide a completed fee table and expense example in your response for each Fund.

RESPONSE:	Each
Fund is anticipated to have the same expenses and, therefore, the below fee table and expense example apply to all Funds:

Fees
and Expenses of the Fund

This
table describes the fees and expenses that you may pay if you buy, hold and sell shares of the Fund (“Shares”). This
table and the example below do not include any fees or sales charges imposed by your variable product. If they were included, the expenses
listed below would be higher.

Annual
Fund Operating Expenses

(expenses
that you pay each year as a percentage of the value of your investment)

    Class
    3

    Management Fees
    0.49%

    Distribution
    and Service (12b-1) Fees
    0.25%

    Other Expenses(1)
    0.50%

    Total Annual
    Fund Operating Expenses
    1.24%

    Fee Waiver and/or
    Expense Reimbursement(2)
    (0.15)%

    Total Annual
    Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement
    1.09%

 (1) “Other
                                            Expenses” are based on estimated amounts for the current fiscal year.

 (2) The
                                            Fund’s investment adviser, Milliman Financial Risk Management LLC (“Milliman”),
                                            has contractually agreed to waive advisory fees and/or reimburse expenses to the extent necessary
                                            to limit the Fund’s total annual Fund operating expenses (excluding taxes, interest,
                                            brokerage fees and commissions, Rule 12b-1 fees, acquired fund fees and expenses, short-sale
                                            dividend expenses, and extraordinary or non-routine expenses not incurred in the ordinary
                                            course of the Fund’s business) to 0.84% of the Fund's average daily net assets (the
                                            “Expense Limitation Agreement”) until at least April 29, 2024. During
                                            its term, the Expense Limitation Agreement cannot be terminated or amended to increase the
                                            applicable limit without approval of the Board of Trustees of the Trust (the “Board”).
                                            Milliman may recoup from the Fund any advisory fees waived or expenses reimbursed pursuant
                                            to the Expense Limitation Agreement for a period of three years from the date on which such
                                            waiver or reimbursement occurred; provided, however, that such recoupment shall not be made
                                            if it would cause the Fund’s total annual Fund operating expenses to exceed the lesser
                                            of (a) the expense limitation in effect at the time of the reimbursement, or (b) the expense
                                            limitation in effect at the time of recoupment, if any.

      2

Example

This
example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds. This example assumes
that you invest $10,000 in the Fund for the time periods indicated and then sell all of your Shares at the end of those periods. This
example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain at current levels
and that the Expense Limitation Agreement and Fee Waiver remain in place for their contractual periods. Although your actual costs may
be higher or lower, your costs, based on these assumptions, would be:

    1
    Year
    3
    Years

    Class
    3
    $111
    $370

This
example does not include any fees or sales charges imposed by your variable product. If they were included, the expenses listed above
would be higher.

Principal
Investment Strategies

 4. Please
                                            confirm that the disclosure related to the investment process for selecting stocks is accurate,
                                            as it closely follows the process that was formerly disclosed for selecting options.

RESPONSE:	The
Trust confirms that the investment process disclosure is accurate.

 5. The
                                            disclosure indicates that the Funds may transact in over-the-counter (“OTC”)
                                            options. Please confirm whether the Funds will only transact in OTC options based on U.S.
                                            platforms. If these may be on foreign platforms, the staff may have additional comments.

RESPONSE:	The
Trust confirms that any OTC options transactions would be conducted only on U.S. platforms.

 6. The
                                            fourth paragraph of the Principal Investment Strategies section refers to “indices
                                            or exchange-traded funds….” Please include risk disclosure corresponding to
                                            these investments.

RESPONSE:	The
Trust notes that such reference is only with respect to the reference assets underlying each Fund’s options positions and, therefore,
appropriate risk disclosure is included in the Funds’ “Derivatives Risk” section.

 7. Please
                                            confirm whether Brexit and/or LIBOR Risk disclosure is applicable.

RESPONSE:	The
Trust has reviewed the risks in the prospectus and believe additional disclosure on Brexit and/or LIBOR is not necessary.

      3

 8. The
                                            fourth paragraph of the Principal Investment Strategies section refers to a “resulting
                                            Cap.” Please include additional disclosure either in the Item 4 or Item 9 section of
                                            the prospectus describing how the Cap results from the Hedging Strategy.

RESPONSE:	The
Trust will revise the relevant portion of the Item 9 disclosure as follows:

In
addition, implementation of the Buffer Hedging Strategy could result in a Fund foregoing some of the upside returns on its long equity
exposure because of the impact options writing would have on the Fund’s portfolio. Namely, when Milliman writes options contracts,
it gives the purchasers of those options contracts (“Options Buyers”) the right to exercise those options contracts
in return for a premium payment. The Options Buyers will typically exercise their options contracts if the strike prices of such options
are exceeded by the value of their reference assets (in the case of the Funds, such reference assets are generally common stocks included
in the Funds’ portfolios). As a result, a Fund’s ability to profit from increases in the value of its equity portfolio is
limited because, in rising markets, the Options Buyers likely will exercise those options contracts once the values of the reference
assets of such options rise to or above the options’ respective strike prices.  because Accordingly,
the options contracts used written to effect the Buffer Hedging Strategy will result in
a Cap to limit the Fund’s potential upside returns, thus resulting in a “Cap.”

Principal
Risks

 9. Please
                                            confirm that the principal risks that were deleted from the initial filing (i.e., Investment
                                            Objective Risk, FLEX Options Risk, and Options Premiums Risk) are no longer applicable to
                                            the Funds.

RESPONSE:
The Trust confirms that those risks were intentionally removed and that applicable risk factors are included in the revised Principal
Risks section for each Fund.

 10. Please
                                            reinsert into Growth-Oriented Stocks Risk the statement that “[t]hese risks may be
                                            even greater in the case of smaller capitalization stocks.”

RESPONSE:
The Trust will reinsert the statement as requested.

 11. We
                                            noticed that Clearing Member Default Risk was removed or combined into the general Derivatives
                                            Risk. We think you should retain that risk or include it as a sub-section to Derivatives
                                            Risk instead.

RESPONSE:
The Trust has reviewed the Derivatives Risk disclosure and believes it is appropriate as drafted and highlights the relevant principal
risks to investors.

Performance

 12. Please
                                            supplementally provide the staff with the name of the broad-based index the Funds intend
                                            to use in the performance section.

RESPONSE:
Each Fund intends to use the S&P 500® Index as its broad-based index.

      4

Additional
Information About the Funds and the Risks of Investing

Additional
Information About the Funds’ Investments

 13. The
                                            second paragraph of this section provides that the Funds may invest in emerging markets,
                                            which is not disclosed in the Item 4 section of the prospectus. Please add emerging markets
                                            disclosure to the Principal Investment Strategies and Principal Risks sections
                                            for each Fund.

RESPONSE:
The Trust confirms that any potential investment by the Funds in emerging markets would not be a principal investment strategy; hence
the reference to those investments being “to a more limited extent,” as provided in the existing disclosure. Accordingly,
the Trust does not believe any revisions to the Item 4 section are necessary.

 14. The
                                            fifth paragraph of this section provides that the adviser may seek to achieve the Fund’s
                                            Hedging Strategy by using swaps. Please add corresponding disclosure regarding swaps to the
                                            summary principal investment strategy and principal risks sections.

RESPONSE:
The Trust confirms that any potential investment by the Funds in swaps would not be a principal investment strategy, which is why
this disclosure is only in the “Additional Information about the Funds’ Investments” section and is included after
the full discussion of the Hedging Strategy and the use of options. Accordingly, the Trust does not believe any revisions to the Item
4 section are necessary.

Additional
Information About the Risks of Investing in the Funds

 15. Several
                                            risks are missing from the prior filing. Please confirm all such risks are not applicable
                                            to this filing as revised.

RESPONSE:
The Trust confirms that those risks were intentionally removed and that applicable risk factors are included in the revised Additional
Information About the Risks of Investing in the Funds section.

 16. Derivatives
                                            Risk refers to both options contracts and swaps. Please revise this risk to also discuss
                                            the risks of investing in swaps.

RESPONSE:
The Trust confirms that the Derivatives Risk disclosure includes risks applicable to swaps, which are over-the-counter derivatives.

 17. The
                                            staff believes that the Operational Risk disclosure is not unique to the Fund and does not
                                            relate to its principal investment strategy and therefore should be deleted from the prospectus.

RESPONSE:
The Trust confirms that the Operational Risk disclosure will be removed from the prospectus.

      5

Management
and Organization

Investment
Adviser

 18. The
                                            amount of the investment adviser’s assets under management is as of June 30, 2022.
                                            Please update the information with a more recent date from the date of the prospectus.

RESPONSE:
The Trust confirms that it will update the data as of a more recent date.

 19. Pursuant
                                            to Item 10(a)(1)(iii) of Form N-1A, with respect to the discussion regarding the basis of
                                            the Board approving the Advisory Agreement, please identify the period end date to be covered
                                            by the applicable report.

RESPONSE:	The
Trust acknowledges the staff’s comment and confirms that the applicable report will be identified in the first prospectus filed
after a Fund commences investment operations.

Investment
Sub-Adviser

 20. Confirm