December 31, 2019

Thomas E. Kiraly
Chief Financial Officer
Hanger, Inc.
10910 Domain Drive, Suite 300
Austin, TX 78758

       Re: Hanger, Inc.
           Form 10-K For the Fiscal Year Ended December 31, 2018
           Filed March 14, 2019
           File No. 001-10670

Dear Mr. Kiraly:

       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, 2018

Item 7 - Management's Discussion and Analysis of Financial Condition and
Results of
Operations
Non-GAAP Measures, page 35

1.    We note on page 41 that you present the non-GAAP measures Adjusted gross
revenue and
      Accounts receivable before allowance, which reflect GAAP revenue and
accounts
      receivable excluding implicit price concessions for payor disallowances
and patient non-
      payments. These measures appear to substitute individually tailored
revenue recognition
      and measurement methods for those of GAAP as you are adjusting for
amounts excluded
      from revenue under ASC 606. Please tell us how you considered the
guidance of
      Question 100.04 of the Compliance & Disclosure Interpretations on the use
of Non-GAAP
      Financial Measures and Item 10(e) of Regulation S-K when presenting these
measures.
 Thomas E. Kiraly
FirstName LastNameThomas E. Kiraly
Hanger, Inc.
Comapany31, 2019
December NameHanger, Inc.
Page 2
December 31, 2019 Page 2
FirstName LastName
Note A - Organization and Summary of Significant Accounting Policies
Revenue Recognition
Patient Care Segment, page 76

2.       We note that you recognize revenue for the amounts you expect to
receive net of
         estimated contractual discounts and implicit price concessions. Please
address the
         following:

              Describe how you account for the implicit price concessions and
tell us why you
              present these amounts in the table on page 90 as an allowance to
your accounts
              receivable.
              Tell us how you account for any differences between the
measurement of the
              accounts receivable and the amount of revenue recognized in
accordance with ASC
              606-10-45-4.
              Tell us the factors you considered in determining that patient
non-payment should be
              accounted for as an implicit price concession under ASC
606-10-32-7 and not be
              accounted for in accordance with ASC 310.
              Describe how you reassess and account for the implicit price
concessions at the end
              of each reporting period pursuant to ASC 606-10-32-14.

       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 Eric Atallah at (202) 551-3663 or Kevin Kuhar,
Accounting Branch
Chief, at (202) 551-3662 with any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Life
Sciences