August 29, 2019

Daniel H. Walker
Chief Executive Officer and President
Pennant Group, Inc.
1675 East Riverside Drive
Suite 150
Eagle, Idaho 83616

       Re: Pennant Group, Inc.
           Amendment No. 2 to Registration Statement on Form 10-12B
           Filed August 19, 2019
           File No. 001-38900

Dear Mr. Walker:

       We have reviewed your filing 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 and any amendment you may file in response
to these
comments, we may have additional comments.

Amendment No. 2 to Registration Statement on Form 10-12B

Adjusted EBITDAR, page 131

1.    Please disclose your rationale for presenting Combined Adjusted EBITDAR
for both the
      most recent interim period and fiscal year, similar to what you told us
in your response to
      comment 1.
2.    We note that in addition to "Segment EBITDAR from Operations," you intend
to present
      "Adjusted Segment EBITDAR from Operations" and that you believe it would
also be
      considered a GAAP measure. Please explain. Additional segment profit or
loss measures
      that are not calculated in accordance with GAAP may be presented outside
of your
      financial statements and footnotes as non-GAAP measures if they comply
with Regulation
      G and Item 10(e) of Regulation S-K. Please consider Question 100.01 of
the Non-GAAP
      Compliance and Disclosure Interpretations, provide us with your proposed
disclosures of
 Daniel H. Walker
Pennant Group, Inc.
August 29, 2019
Page 2
      "Adjusted Segment EBITDAR from Operations," and tell us how you think
these
      measures would comply with the applicable rules.
        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 Claire DeLabar, Senior Staff Accountant, at (202)
551-3349 or Robert
S. Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Gregory Dundas,
Attorney-Adviser, at (202) 551-3436 or Larry Spirgel, Assistant Director, at
(202) 551-3810 with
any other questions.



                                                           Sincerely,
FirstName LastNameDaniel H. Walker
                                                           Division of
Corporation Finance
Comapany NamePennant Group, Inc.
                                                           Office of
Telecommunications
August 29, 2019 Page 2
cc:       Christian O. Nagler
FirstName LastName