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                                                           December 7, 2018

Steven E. Voskuil
Senior Vice President and Chief Financial Officer
Avanos Medical, Inc.
5405 Windward Parkway
Suite 100 South
Alpharetta GA 30004

       Re: Avanos Medical, Inc.
           Form 10-K For the Fiscal Year Ended December 31, 2017
           Filed February 27, 2018
           Form 10-Q for the Quarterly Period Ended September 30, 2018
           Filed November 6, 2018
           File No. 001-36440

Dear Mr. Voskuil:

       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 Fiscal Year Ended December 31, 2017

Note 15. Business Segment Information, page 63

1.    We reference your disclosure in Note 2 on page 44 that as a result of the
divesture of the
      S&IP business the Medical Devices business is managed as one operating
segment. The
      objective of requiring disclosures about segments of a public entity is
to provide
      information about the different types of business activities in which a
public entity
      engages and the different economic environments in which it operates. The
footnote does
      not disclose different types of business activities in which the Company
engages, but
      rather includes a measure for the same set of operations that is
presented in the
 Steven E. Voskuil
Avanos Medical, Inc.
December 7, 2018
Page 2
         consolidated financial statements. Please explain to us how the
presentation of a segment
         measure for an entity with one operating segment complies with the
objective of ASC
         280-10-10.
2.       As a related matter, it appears that your presentation of segment
operating profit (loss) is a
         non-GAAP measure. In this regard, please tell us how you considered
the prohibition
         against presenting a non-GAAP financial measure in the footnotes to
the financial
         statements. Refer to Item 10(e)(ii)(C) of Regulation S-K. In future
filings, the disclosures
         required by Item 10(e) of Regulation S-K should also be provided for
the segment
         operating profit (loss) measures provided on page 25 of Management's
Discussion and
         Analysis.
Form 10-Q for the Quarterly Period Ended September 30, 2018

Exhibits 32 (a) and (b), page 39

3.       We note that the 906 certifications in Exhibit 32 incorrectly identify
the Form 10-Q filed
         August 7, 2018. Please file a full amendment to your Form 10-Q to
provide revised 906
         certifications that correctly refer to your Form 10-Q filed November
6, 2018.
       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 Jeanne Bennett, Staff Accountant, at 202-551-3606 or
Brian Cascio,
Accounting Branch Chief, at 202-551-3676 with any questions.



FirstName LastNameSteven E. Voskuil                             Sincerely,
Comapany NameAvanos Medical, Inc.
                                                                Division of
Corporation Finance
December 7, 2018 Page 2                                         Office of
Electronics and Machinery
FirstName LastName
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