November 26, 2019

Renato Negro
Vice President and Controller
Avanos Medical, Inc.
5405 Windward Parkway, Suite 100 South
Alpharetta, Georgia 30004

       Re: Avanos Medical, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed February 26, 2019
           File No. 001-36440

Dear Mr. Negro:

       We have reviewed your filing 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, 2018

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Operating Profit (Loss), page 24

1.    We note that gross profit increased from 55% in 2017 to 60% in 2018. In
future filings,
      please disclose the reason for significant changes in gross profit. Refer
to Item 303(a)(3)
      of Regulation S-K.
Item 8. Financial Statements and Supplementary Data
Note 1. Revenue Recognition and Accounts Receivable, page 39

2.    We note your disclosure of revenue attributable to chronic care and pain
management on
      page 61. Please explain to us your consideration of ASC 606-10-50-5 and
55-89 through
      55-91 relating to your determination that disaggregation of revenues into
additional
      categories is not required. For example, you disclose that surgical pain,
interventional
      pain, digestive health and respiratory health are separate categories and
that each
 Renato Negro
Avanos Medical, Inc.
November 26, 2019
Page 2
         accounted for more than 10% of sales and on page 2 that competitors
are fragmented by
         product category. Similarly, you referred to "significant growth
potential for Acute
         Pain," "headwinds continue in Acute Pain," and that "Acute Pain
performed in-line with
         our expectations" as part of recent 2018 and 2019 earnings call
presentations. Also, tell us
         how you considered the disclosure requirements of ASC 280-10-50-40.
Note 13. Commitments and Contingencies
Legal Matters, page 56

3.       For each of the significant matters described in your disclosure,
please explain to us your
         evaluation of the requirement of ASC 450-20-50-4(b). For any matters
where you
         otherwise would be required to disclose that you cannot make an
estimate of the possible
         loss or range of loss, provide us the basis for your determination.
        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 Michael Fay, Staff Accountant, at (202) 551-3812 or Brian
Cascio,
Accounting Branch Chief, at (202) 551-3676 with any questions.



FirstName LastNameRenato Negro                                 Sincerely,
Comapany NameAvanos Medical, Inc.
                                                               Division of
Corporation Finance
November 26, 2019 Page 2                                       Office of Life
Sciences
FirstName LastName