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                                                            June 26, 2025

David T. Doherty
Executive Vice President and Chief Financial Officer
Surgery Partners, Inc.
340 Seven Springs Way, Suite 600
Brentwood , Tennessee 37027

       Re: Surgery Partners, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2024
           File No. 001-37576
Dear David T. Doherty:

       We have reviewed your filing and have the following comments.

       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 a
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.

Form 10-K for Fiscal Year Ended December 31, 2024
1. Organization and Summary of Accounting Policies
Revenues, page F-10

1.     We note your disclosures that the transaction price for patient service
revenues is
       based on gross charges net of estimated contractual adjustments and
implicit price
       concessions. We further note your disclosure that contractual allowances
are recorded
       at the time of payment for surgical hospitals and the time of billing
for ASCs. Explain
       what you mean by contractual adjustments versus contractual allowances
and the
       specific reference to the authoritative literature that supports the
timing for
       recognizing contractual allowances.
9. Income Taxes, page F-26

2.     We note that the valuation allowance against deferred tax assets
increased during
       fiscal year 2024 by $134.6 million, of which $115.4 million is disclosed
in the
       effective tax rate reconciliation as a change in federal valuation
allowance, which
       significantly exceeds the amounts recognized during the two previous
fiscal years.
       Please provide a comprehensive explanation here or within MD&A that
provides
       investors with an understanding of the specific facts and circumstances
that led to the
 June 26, 2025
Page 2

       significant increase in the valuation allowance.
14. Segment Reporting, page F-31

3.     Please tell us whether you believe equity in earnings of unconsolidated
affiliates and
       net income attributable to non-controlling interests represent
significant segment
       expenses determined in accordance with ASC 280-10-50-26A. If so, please
provide us
       with an explanation as to why each line item is a significant segment
expense.
       Alternatively, if these amounts are other segment items as addressed in
ASC 280-10-
       50-26B, it appears that these amounts should be aggregated with the
other segment
       expense, net line item into one other segment items line item. Please
correspondingly
       provide a qualitative description of the composition of other segment
items in
       accordance with ASC 280-10-50-26B.
4.     With regards to the Corporate and other unallocated expenses in your
reconciliation of
       Adjusted Surgical Facilities EBITDA to consolidated income before income
taxes,
       please revise this presentation to separately disclose revenue and
expenses from other
       business activities that are not considered reportable segments in an
all other
       category in accordance with ASC 280-10-50-15 and separately identify and
       describe all significant reconciling items in accordance with ASC
280-10-50-31.
        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 Tracey Houser at 202-551-3736 or Nudrat Salik at
202-551-3692 if
you have questions regarding comments on the financial statements and related
matters.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services
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