November 12, 2024

Jeffrey R. Knudson
Chief Financial Officer
AMN Healthcare Services, Inc.
2999 Olympus Boulevard, Suite 500
Dallas, TX 75019

       Re: AMN Healthcare Services, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2023
           File No. 001-16753
Dear Jeffrey R. Knudson:

        We have reviewed your October 24, 2024 response to our comment letter
and have
the following comments.

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

       After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our October
24, 2024 letter.

Form 10-K for the Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 26

1.     We note your response to prior comment 3 and your belief that changes in
metrics,
       rather than the absolutes of the metrics, are most relevant. To clarify,
our prior
       comment sought quantification of the impact on revenue of factors to
which changes
       are attributed, rather than quantification of the underlying metrics
themselves. As
       an example, you attributed the change in nurse and allied solutions
segment revenue
       to factors including changes in average number of travelers on
assignment, average
       bill rate, and billable hours. These factors pertain to changes in price
and
       volume. Please supplement your disclosure to quantify, in absolute
dollars, the impact
       of factors to which changes are attributed, including changes in price,
volume, and
       acquisitions. Refer to Item 303(b)(2)(iii) of Regulation S-K.
 November 12, 2024
Page 2


(j) Insurance Reserves, page 45

2.     We note your response to prior comment 5. You state you provide
professional
       liability coverage as part of your service offering to clients. You
disclose in note (j)
       Insurance Reserves, that this expense in included in selling, general,
and
       administrative expenses in the statement of comprehensive income. Given
that
       professional liability coverage is part of your service offering to
clients, please explain
       your basis for classifying the expense as SG&A rather than cost of
revenue.
Notes to Consolidated Financial Statements
(k) Revenue Recognition, page 45

3.     We note your response to prior comment 6. You state you record revenue
on a gross
       basis with respect to both (a) direct staffing of locum tenens
physicians, and (b)
       language services business    utilization of contract interpreters. We
assume, based on
       your disclosure on page 2, that both of these categories of revenue are
derived from
       non-employees.

       Please provide us with your analysis of principal versus agent
considerations under
       ASC 606 for of these two categories, or non-employee portions thereof as
applicable.
       In your response, please tell us:

             The specified goods or services (as determined from the end
consumer's
           perspective), including your consideration of the    distinct"
guidance in paragraphs
           25-19 to 25-22 if there are multiple specified goods or services
             The relevant contractual terms (rights and obligations) between
you and both the
           end consumer and the other party involved in providing the specified
goods or
           services (i.e., the supplier)
             Based solely on the definition of control in paragraph 25-25 and
the explanation
           of how control is obtained in paragraph 55-37A, your assessment of
whether and
           how you controlled the specified goods or services before
transferred to the end
           consumer
             If control was not clear based on the above guidance and you
required additional
           evidence to reach a control conclusion:
             o Your assessment of each of the following indicators of control
in paragraph
                55-39 and all other relevant facts and circumstances:
                    Primary responsibility for fulfillment
                    Inventory risk
                    Discretion in pricing
            o   Your assessment of whether and how evidence related to these
indicators of
                control supported that you controlled the specified good or
service before
                transferred to the end consumer

       If there are multiple specified goods or services, provide the
information in the third
 November 12, 2024
Page 3

      and fourth bullets separately for each specified good or service.
Note 1 - Summary of Significant Accounting Policies
(l) Accounts Receivable,, page 46

4.    We note your response to prior comment 7. In regard to the $27 million
increase in
      the provision for credit losses for the year ended December 31, 2022, you
state the
      portion attributed to the macroeconomic outlook is immaterial to your
financial
      statements. As previously requested, please tell us the current status of
your views
      with regard to uncertainty regarding other customers due to the
macroeconomic
      outlook. Please also quantify for us the portion of the provision you
recognized in
      2022 related to the macroeconomic outlook at the time.
       Please contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380
if you
have questions regarding comments on the financial statements and related
matters.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services