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                            June 1, 2020

       Adam Holland
       Chief Financial Officer
       TIVITY HEALTH, INC.
       701 Cool Springs Blvd
       Franklin, TN. 37067

                                                        Re: TIVITY HEALTH, INC.
                                                            Form 10-K for the
year ended December 31, 2019
                                                            Filed on February
27, 2020
                                                            File No. 0000704415

       Dear Mr. Holland:

              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 year ended December 31, 2019

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 37

   1.                                                   In March 2019, you
acquired Nutrisystem, Inc. which resulted in the creation of the
                                                        Nutrition segment. In
less than one year after acquiring this entity, you have recorded
                                                        material goodwill and
intangible asset impairment charges related to this segment in both
                                                        the fourth quarter of
2019 and the first quarter of 2020. This segment represented
                                                        approximately 53% of
your total revenues for the three months ended March 31, 2020.
                                                        We also note that in
May 2020 you announced that the Board has decided to explore
                                                        strategic alternatives
for the Nutrition segment. In light of the above, please provide a
                                                        separate and robust
segment discussion and analysis to help readers better understand your
                                                        results of operations.
Your segment discussion should quantify the impact of each factor
                                                        when multiple factors
contribute to material changes. For example, please quantify the
                                                        extent to which
material changes in sales are due to increases or decreases in prices
 Adam Holland
TIVITY HEALTH, INC.
June 1, 2020
Page 2
         separately from the extent to which material changes are due to
changes in volume.
         Please also provide a discussion of any known trends or uncertainties
that you reasonably
         expect will have a material impact on future operating results. This
could include trends
         related to customer growth or uncertainties related to the
recoverability of recorded assets.
          Please refer to Item 303(a)(3) of Regulation S-K. See also Sections
501.02, 501.07
         and 501.12 of the Financial Reporting Codification as well as Section
III.F.1 of SEC
         Release 33-6835.

4. Revenue Recognition, page 59

2.       Please tell us how you considered the requirements in ASC 606-10-50-13
to 50-15 to
         disclose information about remaining performance obligations or
application of optional
         exemptions. In this regard, we note your disclosure that in your
Health segment there are
         generally no performance obligations that are unsatisfied at the end
of a particular month;
         however, we also note that with the exception of Prime Fitness, your
customer contracts
         generally have initial terms of approximately three years with some
contracts allowing the
         customer to terminate early and/or determine on an annual basis to
which of their
         members they will offer your programs.
       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 Ameen Hamady at 202-551-3891 or in his absence, Nudrat
Salik at
202-551-3692 with any questions.



FirstName LastNameAdam Holland                                 Sincerely,
Comapany NameTIVITY HEALTH, INC.
                                                               Division of
Corporation Finance
June 1, 2020 Page 2                                            Office of Life
Sciences
FirstName LastName