August 9, 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. 1 to Registration Statement on Form 10-12B
           Response dated July 31, 2019
           File No. 001-38900

Dear Mr. Walker:

       We have reviewed your July 31, 2019 response to our comment letter and
have the
following comments. In some of our comments, we may ask you to provide us with
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

     After reviewing your response and any amendment you may file in response
to these
comments, we may have additional comments.

Amendment No. 1 to Registration Statement on Form 10-12B

Adjusted EBITDAR, page 132

1.    We note your response to comment 4. We understand that you use combined
      EBITDAR as a valuation measure. As such, please revise to: 1) limit its
disclosure only
      to the most recent period presented; 2) clarify why the measure is useful
as a valuation
      tool; and 3) describe the limitations of the measure.
2.    We note your response to comment 5 and that you will no longer present
      EBITDAR for your Home Health and Hospice segment. However, we believe
that your
      presentation of Adjusted EBITDAR for your Senior Living may violate Rule
100(b) of
      Regulation G because it is measure of segment performance that excludes
      recurring, cash operating expenses necessary to operate your business.
Please revise to
      remove this measure. Refer to Question 100.01 of the Staff's Compliance
and Disclosure
 Daniel H. Walker
Pennant Group, Inc.
August 9, 2019
Page 2
      Interpretations on Non-GAAP Financial Measures.
        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, Staff Accountant at (202) 551-3349 or
Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions
comments on the financial statements and related matters. Please contact Greg
Dundas, Staff
Attorney at (202) 551-3436 or Larry Spirgel, Assistant Director at (202)
551-3815 with any other

FirstName LastNameDaniel H. Walker
                                                           Division of
Corporation Finance
Comapany NamePennant Group, Inc.
                                                           Office of
August 9, 2019 Page 2
cc:       Christian O. Nagler
FirstName LastName