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                             March 12, 2024

       Andrew Brophy
       Principal Financial Officer
       HEALTHCARE SERVICES GROUP INC
       3220 Tillman Drive, Suite 300
       Bensalem, PA 19020

                                                        Re: HEALTHCARE SERVICES
GROUP INC
                                                            Item 2.02 Form 8-K
filed February 14, 2024
                                                            File No. 000-12015

       Dear Andrew Brophy:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comment.

              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
       the 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.

       Item 2.02 Form 8-K filed February 14, 2024

       Exhibit 99.1
       Reconciliations of Non-GAAP Financial Measures, page 6

   1.                                                   We have the following
comments related to certain adjustments made to arrive at your
                                                        non-GAAP adjusted
revenues, adjusted segment revenues, adjusted segment margins,
                                                        adjusted costs of
services provided, adjusted selling, general and administrative expense,
                                                        adjusted net income,
adjusted diluted earnings per share, and EBITDA excluding items
                                                        impacting comparability
("Adjusted EBITDA"):
                                                            We note that client
restructurings include changes to contracts with existing
                                                            customers for which
the Company has either recorded a reduction to revenue or an
                                                            increase to bad
debt expense due to clients entering bankruptcy, receivership, or out-
                                                            of-court workouts.
We further note from disclosures in your Form 10-K that the
                                                            revenue portion of
this adjustment relates to your adjustment to reflect the change in
                                                            estimate for price
concessions based on new facts and circumstances related to a
                                                            client   s
out-of-court restructuring. Such adjustment appears necessary to present your
                                                            revenues in
accordance with GAAP. We also note a portion of this adjustment relates
 Andrew Brophy
HEALTHCARE SERVICES GROUP INC
March 12, 2024
Page 2
              to bad debt expense. In this regard, we note your risk factor
indicating that the
              Company has substantial investment in the creditworthiness and
financial condition
              of its customers as well as your cautionary statement regarding
forward-looking
              statements which addresses this risk and other risks arising from
your providing
              services to the healthcare industry and primarily providers of
long-term care. As
              such, this adjustment appears to relate to normal costs incurred
to operate your
              business. With reference to Questions 100.01 and 100.04 of the
Compliance and
              Disclosure Interpretations (   C&DIs   ) on Non- GAAP Financial
Measures, provide
              your basis for these adjustments or confirm that you will no
longer present them; and
                Your bad debt expense adjustments reflect the difference
between GAAP bad debt
              expense (CECL) and historical write-offs as a percentage of
adjusted revenues. Your
              self-insurance adjustments reflect changes in the accrued
insurance claims liability
              after considering your updated actuarial estimates for projected
incurred losses on
              past claims. Your gain/loss on deferred compensation adjustment,
net represents the
              changes in fair market value of investments held on behalf of the
participating
              employees. Each of these adjustments appear to result in tailored
accounting
              measures and therefore not consistent with Question 100.04 of the
C&DIs. Please
              advise or confirm you will no longer present these adjustments.

       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.

       Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at
202-551-3355 with
any questions.



                                                              Sincerely,
FirstName LastNameAndrew Brophy
                                          Division of Corporation Finance
Comapany NameHEALTHCARE SERVICES GROUP INC
                                          Office of Industrial Applications and
March 12, 2024 Page 2                     Services
FirstName LastName