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                          June 14, 2024

       Martin J. Bonick
       Chief Executive Officer
       Ardent Health Partners, LLC
       340 Seven Springs Way, Suite 100
       Brentwood, Tennessee 37027

                                                        Re: Ardent Health
Partners, LLC
                                                            Amendment No. 2 to
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted June 3,
2024
                                                            CIK No. 0001756655

       Dear Martin J. Bonick:

            We have reviewed your amended draft registration statement and have
the following
       comments.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

               After reviewing the information you provide in response to this
letter and your amended
       draft registration statement or filed registration statement, we may
have additional
       comments. Unless we note otherwise, any references to prior comments are
to comments in our
       May 22, 2024 letter.

       Amendment No. 2 to Draft Registration Statement on Form S-1

       Consolidated operating statistics, page vi

   1.                                                   We note that you have
revised your disclosure to include metrics for "Adjusted
                                                        admissions excluding
COVID-19 patients" and "Net patient service revenue per adjusted
                                                        admission excluding
COVID-19 patients." Please revise to briefly describe here and
                                                        throughout your filing
how management considers these metrics in evaluating the
                                                        company's business and
financial objectives.
 Martin J. Bonick
FirstName  LastNameMartin
Ardent Health Partners, LLCJ. Bonick
Comapany
June       NameArdent Health Partners, LLC
     14, 2024
June 14,
Page 2 2024 Page 2
FirstName LastName
Prospectus Summary
Overview, page 1

2.       We note your revised disclosure in response to comment 5, including
that "a significant
         portion of our revenue and net income is attributable to JVs." Please
revise your
         disclosure here to quantify the "significant portion" of revenue and
net income attributable
         to your LLCs and VIEs. In addition, please briefly describe the risks
related to you
         owning less than 100% of these operating entities and include a cross
reference to the
         relevant risk factor included elsewhere in your filing. In your risk
factor disclosure, please
         revise to describe the VIEs interests that may differ from the
interests of the Company as a
         whole, which could limit your ability to effectively operate the VIE
and maximize the
         economic benefits from it. Finally, please revise your organizational
chart to disclose, in
         the chart or in narrative disclosure, the percentage interest owned by
your wholly owned
         subsidiaries in your VIEs.
Our platform, page 5

3.       The summary chart on page 5 notes you have 18 JV-operated hospitals.
On page 2 and
         elsewhere in the prospectus you state that nine of your hospitals are
owned and operated
         through LLCs that qualify as VIEs; that through your wholly-owned
subsidiaries, you own
         majority interests in each LLC that owns and operates your hospitals;
and consequently, a
         significant portion of your revenue and net income is attributable to
JVs. Please confirm
         that the number of JV-operated hospitals is larger than the number of
hospitals owned by
         LLCs that qualify as VIEs and, if so, please explain the difference
between the two
         categories. Make conforming changes throughout your filing, including
to your prospectus
         summary.
Corporate Conversion, page 14

4.       We note your revised disclosure in response to prior comment 7,
including that you
         "selected the Corporate Conversion as a transaction structure for
administrative
         efficiency," and to support your "strategic vision to grow." Please
further revise your
         disclosure to clarify the significance of your investors owning common
stock rather than
         interests in a limited liability company, and clarify whether there
are any additional
         incentives, such as tax incentives, to existing investors, principal
equity holders, or other
         related parties related to the Corporate Conversion. Please also
clarify whether there are
         any other material ways in which the structure of the Corporate
Conversion benefits you,
         existing investors, principal equity holders, or other related parties
that may not equally
         benefit public investors. In addition, please clarify the reasons
underlying why you expect
         the intended benefits discussed in your revised disclosure. If the
final structure and details
         of the Corporate Conversion are still being determined, please note
this fact in your
         response letter and consider the need for any additional disclosure
once final details
         are available. In this regard, we note your statement on page 190 that
the treatment of your
         Class C units in connection with the offering will be disclosed in a
future filing.
 Martin J. Bonick
Ardent Health Partners, LLC
June 14, 2024
Page 3
Summary historical financial and operating data, page 20

5.       We note most of the bullets presented to address the limitations of
Adjusted EBTIDA as
         an operating performance measure refer to cash requirements, the
statements of cash
         flows, and other liquidity measures. We further note similar
references in the subsequent
         paragraph, such as "discretionary cash available" and "cash flow from
operations and
         other cash flow data." Please either remove all cash related
references or provide the
         disclosures required by Item 10(e)(1)(i) of Regulation S-K for the
presentation of
         Adjusted EBITDA as a liquidity measure in addition to it being a
performance
         measure. Note that to the extent that you are presenting Adjusted
EBITDA as a liquidity
         measure, it is required to comply with the requirements in Item
10(e)(1)(ii)(A) of
         Regulation S-K.
Non-GAAP Valuation Measure, page 26

6.       We note your discussion of the limitations of Adjusted EBITDAR appears
to be focused
         on its use as a liquidity measure. Please revise your disclosure to
solely focus on its
         limitations as a valuation measure rather than as a liquidity measure
or an operating
         performance measure.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Overview
Outsourcing of revenue cycle management functions to Ensemble, page 85

7.       We note your statement that the monthly consideration payable to
Ensemble is "based on
         an agreed-upon percentage of the total net cash received by our
entities using Ensemble   s
         services from providing patient services less any refunds of
previously collected revenues
         issued by those entities in such month." Please clarify what
percentage of your total
         revenue is collected via the master service agreement with Ensemble.
Additionally, please
         revise to provide the specific percentage or percentage range of total
net cash received that
         is payable to Ensemble or explain to us why this figure is not
material.
Supplemental non-GAAP performance measure, page 99

8.     We note your response to comment 13 along with the expanded disclosures
you have
       provided. Given that the change in composition of noncontrolling
interest earnings will
       occur in connection with the IPO, any adjustment for noncontrolling
interest earnings
       related to JV partners for Adjusted EBITDA and Adjusted EBITDAR should
be for the
       entire amount recognized for the corresponding period presented. In this
regard, you may
FirstName LastNameMartin J. Bonick
       consider presenting pro forma measures that reflect the impact of the
change in the
Comapany    NameArdent
       composition  of nonHealth Partners,
                            controlling    LLC for the latest year and interim
period. Such
                                        interests
       information
June 14, 2024 Pageshould
                    3      be presented in accordance with Article 11 of
Regulation S-X.
FirstName LastName
 Martin J. Bonick
FirstName  LastNameMartin
Ardent Health Partners, LLCJ. Bonick
Comapany
June       NameArdent Health Partners, LLC
     14, 2024
June 14,
Page 4 2024 Page 4
FirstName LastName
Our Joint Venture Model, page 125

9.       We note your revised disclosure describing the general terms of your
joint ventures on
         page 125, including that "[t]he JV   s profits, losses and cash
distributions are shared
         between us and our partners based upon the respective ownership
interest in the
         JV." Please provide additional detail describing how profits, losses,
and cash distributions
         are shared between you and your partners, including the terms of any
agreements related
         to their allocation.
2. Summary of significant accounting policies
Segment Reporting, page F-27

10.      We note your response to comment 23. Please provide us with the
following additional
         information:

                You state that the President of Hospital Operations (President)
approves all regional
              and facility budgets and forecasts and ensures they are aligned
with the overall
              consolidated budget and forecast. Please tell us whether the
regional and facility
              budgets comprise the entire consolidated budget. If there are
business units,
              departments or other parts of the consolidated budget the
President does not review
              and approve, describe them and tell us who is responsible for
approving them.

                Please explain in further detail how regional and facility
budgets and forecasts are
              aligned with the consolidated budget. In this regard, please tell
us whether, after
              preparing the regional and facility budgets, changes are proposed
to the consolidated
              budget that is then provided to the CEO for review. As part of
your response, please
              describe the President   s involvement in preparing, reviewing,
or approving the
              consolidated budget.

                You state that the President is responsible for the operations
of the Company   s
              regions, as well as driving both organic and inorganic growth
across the regions. The
              President provides direct supervision over each of the Company
s operating regions,
              the regional budgeting, forecasting and related monitoring
processes, and the day-to-
              day operations of the regions, and is responsible for the
continued growth and success
              of the regions across the Company. As such, please provide us
with your analysis of
              whether the President is part of your CODM function. Refer to ASC
280-10-50-5 for
              guidance.
 Martin J. Bonick
FirstName  LastNameMartin
Ardent Health Partners, LLCJ. Bonick
Comapany
June       NameArdent Health Partners, LLC
     14, 2024
June 14,
Page 5 2024 Page 5
FirstName LastName
       Please contact Tracey Houser at 202-551-3736 or Li Xiao at 202-551-4391
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Conlon Danberg at 202-551-4466 or Katherine Bagley at 202-551-2545 with any
other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Industrial
Applications and
                                                          Services
cc:      Samir A. Gandhi, Esq.