June 3, 2019

Daniel Cancelmi
Executive Vice President and Chief Financial Officer
Tenet Healthcare Corporation
1445 Ross Avenue, Suite 1400
Dallas, TX 75202

       Re: TENET HEALTHCARE CORP
           10-K filed February 25, 2019
           File No. 001-07293

Dear Mr. Cancelmi:

      We have reviewed your filing and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your
disclosure.

       Please respond to our comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to our comment, we may have additional
comments.

From 10-K for the year ended December 31, 2018

Notes to the consolidated financial statements
Impairment and restructuring charges, and acquisition-related costs
Year ended December 31, 2018, page 112

1.     We note that you recorded impairment charges of $77 million, $402
million, and $54
       million during 2018, 2017, and 2016 respectively. For 2018, the material
adverse trends
       you describe include "reductions in volumes of insured patients, shifts
in payer mix from
       commercial to governmental payers combined with reductions in
reimbursement rates
       from governmental payers, and high levels of uninsured patients." It
appears that these
       factors may apply more broadly as disclosed in your Selected Operating
statistics on page
       42 and also described in your Trends and Strategies section on page 40.
To help us better
       understand your disclosure, tell us whether you expect these trends to
have similar
       impacts on your other hospitals. For any long-lived asset groups
(hospitals) for which you
       have determined that undiscounted cash flows are not substantially in
excess of their
       carrying value and if, in the aggregate or individually, they could
materially impact your
       operating results in the near term, please disclose the following in
future filings:
 Daniel Cancelmi
Tenet Healthcare Corporation
June 3, 2019
Page 2

             the carrying values of the asset groups
             the percentage by which undiscounted cash flows exceed the
carrying values
             their fair values.



        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 Charles Eastman, Senior Staff Accountant at (202)
551-3794 or
Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 if you have any
questions.



FirstName LastNameDaniel Cancelmi                           Sincerely,
Comapany NameTenet Healthcare Corporation
                                                            Division of
Corporation Finance
June 3, 2019 Page 2                                         Office of
Telecommunications
FirstName LastName