December 20, 2024

Heather Dixon
Chief Financial Officer
Acadia Healthcare Company, Inc.
6100 Tower Circle
Suite 1000
Franklin, Tennessee 37067

       Re: Acadia Healthcare Company, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2023
           Form 8-K filed February 27, 2024
           Response dated December 6, 2024
           File No. 001-35331
Dear Heather Dixon:

       We have reviewed your filing and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 8-K Filed February 27, 2024
Exhibit 99

1.     We note your response to prior comment 3, along with the draft
presentations
       provided in Annexes A through C. In Annex B, please present Profit
margin with
       equal or greater prominence of your presentation of Adjusted EBITDA
margin.
2.     In Annex A, we note your presentations of same facility results and
facility results for
       profit margin, adjusted EBITDA margin, profit margin excluding income
from
       provider relief fund, and adjusted EBTIDA margin excluding income from
provider
       relief fund, all of which are non-GAAP measures. Please revise the title
of profit
       margin to clearly identify it as a non-GAAP measure for both
presentations. Please
       expand the associated reconciliations provided in Annex C to begin with
the most
       directly comparable US GAAP measure and provide us with the revised
       reconciliations. Refer to Item 10(e)(1)(i)(B) of Regulation S-K for
guidance.
3.     We note your response to prior comment 5, which provides the same
information in
 December 20, 2024
Page 2

       Note 16 to your third quarter of fiscal year 2024 Form 10-Q. As
previously requested,
       please provide us with a comprehensive explanation, including
quantification, for
       each of the components included in the transaction, legal and other
costs adjustment to
       your various non-GAAP performance measures and provide expand
disclosures for
       the adjustment.
        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.

        Please contact Tayyaba Shafique at 202-551-2110 or Tracey Houser at
202-551-3736
if you have questions regarding comments on the financial statements and
related matters.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services