September 13, 2018

Adam Logal
Senior Vice President, Chief Financial Officer, and Treasurer
Opko Health, Inc.
4400 Biscayne Blvd.
Miami, FL 33137

       Re: Opko Health, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed March 1, 2018
           File No. 001-33528

Dear Mr. Logal:

       We have reviewed your August 17, 2018 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to
comments in
our August 3, 2018 letter.

Form 10-K for the Fiscal Year Ended December 31, 2017

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
For the Years Ended December 31, 2017 and December 31, 2016
Revenues, page 61

1.    Please address the following with respect to your response to prior
comment one:
        Regarding the reimbursement decrease in genomics (GeneDx) revenues,
please tell us
         when you first became aware of the changes from payors regarding their
requirements
         under their respective medical policies and where you disclosed the
related expected
         impact on your future results of operations.
 Adam Logal
Opko Health, Inc.
September 13, 2018
Page 2

             Also regarding the overall reimbursement decrease in your genomics
(GeneDx)
             revenues, separately quantify for us the adjustments to estimated
payment amounts
             from third party payors versus the changes from payors'
requirements under their
             medical policies. Tell us why your estimated payment amounts from
third party payors
             changed.
             Regarding the decrease in BioReference revenues, tell us the
reason for the decrease in
             the reason you gave, when you first became aware of this trend,
and where you
             disclosed the related expected impact of this trend.
             Regarding the overpayment from a single payor received in error,
tell us why you
             originally recorded the overpayment as revenue and how such
classification complied
             with your revenue recognition accounting policy. In addition, tell
us why your internal
             controls did not identify the overpayment as such.
2.       We believe the disaggregated information, quantitative and
qualitative, provided in your
         response and the additional information to be provided in response to
the above comment
         is relevant to an investor's understanding of your operations. As
such, please provide us
         proposed disclosure and identify the filing(s) that you intend to
include it in.
       You may contact Sasha Parikh at 202-551-3627 or Kevin Vaughn at
202-551-3494 with
any questions.



FirstName LastNameAdam Logal                                  Sincerely,
Comapany NameOpko Health, Inc.
                                                              Division of
Corporation Finance
September 13, 2018 Page 2                                     Office of
Healthcare & Insurance
FirstName LastName