HEALTHCAREREALTY

3310 West End Avenue, Suite 700

Nashville, Tennessee 37203

P 615.269.8175 F 615.269.8461

www.healthcarerealty.com

June 30, 2021

Ms. Jennifer Monick

Mr. Frank Knapp

Office of Real Estate and Construction

Division of Corporation Finance

United States Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549-3561

VIA: EDGAR

RE:     Healthcare Realty Trust Incorporated

    Form 10-K for the fiscal year ended December 31, 2020

    Filed February 10, 2021

    File No. 001-11852

Dear Ms. Monick and Mr. Knapp:

This letter is offered in response to the letter, dated June 21, 2021, from the staff of the Division of Corporation Finance (the “Staff”) to Healthcare Realty Trust Incorporated (the “Company”) regarding the above referenced filing.

The Company’s responses to the Staff’s comments follow:

FORM 8-K FILED MAY 5, 2021

Exhibits

Comment No. 1:"We note your disclosure of the value of your real estate properties in Exhibit 99.1. Please tell us what consideration you gave to disclosing the valuation methodologies used, to disclosing significant assumptions and inputs that were used in your valuation, and to providing a sensitivity analysis for such assumptions and inputs."

Response:

We assume that the comment refers to the sentence in the last paragraph of our earnings press release that reads "As of March 31, 2021, the Company owned 228 real estate properties in 24 states totaling 16.5 million square feet and was valued at approximately $5.9 billion." The phrase "was valued" represented the Company's value and not the value of the real estate properties. The valuation of $5.9 billion refers to the Company's enterprise value, which is calculated as equity market capitalization plus the principal amount of outstanding debt on the Company's condensed consolidated balance sheet, as of such date. The inputs used in this calculation are derived from the Company's financial statements and the market value of the Company's stock as reported on the New York Stock Exchange. We will clarify the valuation methodology in future filings.

Should you wish to further discuss your comments and our responses thereto, please feel free to call me at (615) 269-8175.

Sincerely,
 

/s/ J. Christopher Douglas

J. Christopher Douglas

Executive Vice President and Chief Financial Officer 

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