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                               September 25, 2020

       David Duckworth
       Chief Financial Officer
       Acadia Healthcare Company, Inc.
       6100 Tower Circle, Suite 1000
       Franklin, TN 37067

                                                        Re: Acadia Healthcare
Company, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2019
                                                            Filed February 28,
2020
                                                            File No. 001-35331

       Dear Mr. Duckworth:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Fiscal Year Ended December 31, 2019

       Item 7. Management   s Discussion and Analysis of Financial Condition
and Results of
       Operations
       Results of Operations
       Segments, page 49

   1.                                                   We note that you
present changes in same facility operating data for the United Kingdom
                                                        segment excluding the
elderly care division. Please tell us and revise your future filings to
                                                        disclose the rationale
for excluding your elderly care division and quantify and disclose
                                                        the impact of excluding
it from your same facility results. Otherwise, to the extent your
                                                        elderly care division
did not have a meaningful impact on your same facility operating
                                                        data; please disclose
that fact in your filing.
 David Duckworth
FirstName LastNameDavid   Duckworth
Acadia Healthcare Company, Inc.
Comapany 25,
September NameAcadia
              2020     Healthcare Company, Inc.
September
Page 2    25, 2020 Page 2
FirstName LastName
2.       We note that while the United Kingdom same facility results saw
revenue growth, total
         revenue and EBITDA margin for this segment decreased during the fiscal
year. Please tell
         us and revise future filings to explain the additional factors that
contributed to these
         decreases to provide a complete picture of the trends in your segments
results. Refer to
         Item 303(A)(3)(ii) of Regulation S-K and Section III.B.3 of our
Release No. 33-8350.
Critical Accounting Policies
Goodwill and Indefinite-Lived Intangible Assets, page 60

3.       We note that you recorded a $325.9 million goodwill impairment for the
United Kingdom
         facilities during the year ended December 31, 2018. For each reporting
unit that is at risk
         of failing step one of the goodwill impairment, please revise your
MD&A in future filings
         to provide the percentage by which your fair value exceeded the
carrying value as of the
         date of the most recent test and describe any potential events and/or
changes in
         circumstances, such as the recent pandemic, that could reasonably be
expected to
         negatively affect any key assumptions. If you have determined that the
estimated fair
         value substantially exceeds the carrying value of your reporting
units, please disclose such
         determination. Refer to Section V of SEC Release 33-8350.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Tara Harkins at (202) 551-3639 or Lynn Dicker, Senior
Accountant, at
(202) 551-3616 with any questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Life
Sciences